39

Epperson v. Myers, 58 So.2d 150, 152 (Fla. 1952). See also Jones v. Wolf, 443 U.S. 595 (1979) (United States Supreme Court suggests that judicial review is permissible if restricted to an analysis based exclusively on “neutral principles” of law devoid of any interpretation of religious doctrine); I. Ellman, Driven From the Tribunal: Judicial Resolution of Internal Church Disputes, 69 CAL. L. REV. 1380 (1981) (arguing that judicial review of internal church disputes should be permitted as long as doctrinal interpretation not required).