The Kedroff case involved a New York statute that proposed giving the property of the St. Nicholas Cathedral of the Russian Orthodox Church to a group of members who had broken from the Church and alleged that its leadership had betrayed the faith and adopted incorrect doctrine.
The Supreme Court declared the statute unconstitutional. The Court held that the State must defer to a religion’s determination of articles of faith—the existing church and not the challengers, in this case: “There are occasions when civil courts must draw lines between the responsibilities of church and state for the disposition or use of property. Even in those cases when the property right follows as an incident from decisions of the church custom or law on ecclesiastical issues, the church rule controls. This under our Constitution necessarily follows in order that there may be free exercise of religion.”
It was in Kedroff that the Supreme Court expressly recognized the constitutional primacy of the Watson principle [see Watson v. Jones]. In speaking of Watson, the Court opined: “The opinion radiates … spirit of freedom for religious organizations, an independence from secular control or manipulation, in short, power to decide for themselves, free from state interference, matters of church government as well as those of faith and doctrine.”