The case of Jones et al. v. Wolf et al., 1978, revolved around a property dispute between two factions within a local Presbyterian church in Georgia following its split over theological differences. The Supreme Court was tasked with determining which faction had the right to retain control over the church's property. In their decision, they upheld that civil courts could intervene in such disputes but must take a "neutral principles of law" approach to avoid excessive entanglement in religious doctrine or practice - meaning they should rely on secular legal rules and objective methods for resolving property disputes rather than delving into ecclesiastical matters or interpreting religious doctrine. The court ruled that the faction loyal to the parent denomination (Presbyterian Church U.S.) retained control of the disputed property because it held an implied trust clause favoring them.

In the dissenting opinion for Jones et al. v. Wolf et al., Justice William Rehnquist argued that the majority's decision to apply neutral principles of law in church property disputes was a departure from previous precedent and an intrusion into religious freedom. He contended that this approach could lead to government interference in religious matters, violating the First Amendment’s guarantee of free exercise of religion and prohibition on establishment of religion. Instead, he advocated for adherence to the "principle of government", which defers decisions about internal church governance and control over property to hierarchical ecclesiastical authorities within each denomination or faith group, thus respecting their autonomy and minimizing state intervention in religious affairs.