In the 1968 case of Presbyterian Church in the United States et al. v. Mary Elizabeth Blue Hull Memorial Presbyterian Church et al., two local Georgia churches sought to separate from their parent organization, The Presbyterian Church in the U.S., due to theological differences. They claimed ownership over church property and assets under a state law that allowed such separation if it was found that the parent church had "substantially abandoned" its original doctrines or practices. However, this brought up First Amendment issues as it required civil courts to interpret religious doctrine and practice - something they are constitutionally prohibited from doing. The Supreme Court ruled in favor of the national church, stating that civil courts cannot determine matters of religious belief or practice when deciding disputes over church property. Instead, they must defer to an established governing body within a hierarchical religious organization (in this case, The Presbyterian Church). This decision reinforced principles of freedom of religion by limiting government interference into internal affairs and doctrinal disputes within religious organizations.

In the dissenting opinion for the case of Presbyterian Church in the United States v. Mary Elizabeth Blue Hull Memorial Presbyterian Church, Justice Harlan disagreed with the majority's decision to prohibit civil courts from deciding church property disputes based on doctrinal issues. He argued that this ruling violated principles of federalism by interfering with states' rights to regulate their own internal affairs, including matters related to religious organizations and property disputes within them. Furthermore, he contended that it was possible for civil courts to resolve such conflicts without delving into theological controversies or violating First Amendment protections against government involvement in religion. Instead of adopting a blanket rule barring all ecclesiastical cases from secular courtrooms, Justice Harlan suggested that each dispute should be evaluated individually based on its specific circumstances and merits.