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Carden v. La Grone, 169 S.E.2d 168, 172 (Ga. 1969) (“a court of equity will not interfere with the internal management of a religious society where property rights are not involved”); Third Missionary Baptist Church v. Garrett, 158 N.W.2d 771, 776 (Iowa 1968) (“It is a general rule recognized here and in foreign jurisdictions that ordinarily the courts have no jurisdiction over, and no concern with, purely ecclesiastical questions and controversies, including membership in a church organization, but they do have jurisdiction as to civil, contract, and property rights which are involved in or arise from a church controversy.”); Mitchell v. Albanian Orthodox Diocese, 244 N.E.2d 276, 278--79 (Mass. 1969) (“[C]ourts do not interfere in a controversy that is exclusively or primarily of an ecclesiastical nature. Where civil or property rights or the construction of legal instruments are involved, however, the courts have been less reluctant to interfere.”); Fast v. Smyth, 527 S.W.2d 673, 676 (Mo. 1975) (“[T]he determination of who are qualified members of a church is an ecclesiastical matter. There is, however, a well recognized exception to this general rule in this state. Civil courts will review ecclesiastical matters where necessary to protect the property, contracts, or civil rights of members.”).