Synod of Bishops of the Russian Orthodox Church Outside of Russia v. Belya

Issue: (1) Whether the First Amendment"s church autonomy doctrine and its "ministerial exception" should be understood as an immunity from judicial interference in internal religious leadership disputes covered by the doctrine, or instead as a mere defense against liability; and (2) whether a minister"s defamation claims against his church arising from internal church disciplinary proceedings are barred by the church autonomy doctrine or may instead proceed under the "neutral principles" approach developed for church property disputes.