1

See generally W. TORPEY, JUDICIAL DOCTRINES OF RELIGIOUS RIGHTS IN AMERICA (1948) (while this text is obsolete in most particulars, it presents a principled analysis that is of continuing utility); Bernard, Churches, Members and the Role of the Courts: Toward a Contractual Analysis, 51 NOTRE DAME LAWYER 545 (1976) (provides useful suggestions regarding judicial involvement in church membership determinations); Ellman, Driven from the Tribunal: Judicial Resolution of Internal Church Disputes, 69 CALIF. L. REV. 1380 (1981) (contending that churches must engage in limited involvement in internal church disputes, ideally through construction of doctrinally--neutral internal church “contractual” documents).