The case of Shepard et al. v. Barkley, Moderator of the General Assembly and Chairman of the Executive Commission of the General Assembly of The Presbyterian Church in The United States Of America, et al., 1917 revolved around a dispute within a religious organization over property rights. A faction within the church sought to secede from its parent body due to disagreements on doctrinal issues and claimed ownership over certain properties that were held by local churches but had been dedicated for use by the larger denomination. The Supreme Court ruled against this faction (Shepard et al.), stating that civil courts should not interfere with internal disputes within religious organizations unless there is clear evidence that an established legal right has been violated or if it's necessary to prevent trespassing or disturbance of peace. In such cases, courts must defer to decisions made by recognized authorities within these organizations as long as they are acting within their jurisdictional limits.

The dissenting opinion in the Shepard et al. v. Barkley case argued that the court should not have intervened in a matter of church governance, as it was outside its jurisdiction and expertise. The justice believed that religious organizations should be free to manage their internal affairs without interference from secular courts, including decisions about property distribution following a schism within the church. They contended that by ruling on this issue, the court had overstepped its bounds and violated principles of separation between church and state. Furthermore, they disagreed with majority's interpretation of Presbyterian Church law regarding property rights after a split within congregation; instead arguing for deference to ecclesiastical authorities' interpretations of their own rules.