4

For example, a New York court ruled in 1985 that the “implied trust” doctrine may be used to the extent that it “involves no interpretation of religious doctrine.” It observed that “if the original precepts of a church were known, uncontested and unambiguous, then those precepts could form the basis of a doctrinal trust to which claimants to that church's property must be faithful.” Park Slope Jewish Center v. Stern, 491 N.Y.S.2d 958 (N.Y. App. 1985).