of the issue in question. Scott C. Idleman, Tort Liability, Religious Entities, and the Decline of Constitutional Protection, 75 Ind. L.J. 219, 225 (2000). However, there is some disagreement as to the prohibition’s precise legal operation. Id. A few courts conceptualize the general prohibition as a question of justiciability. See, e.g., Najafi v. INS, 104 F.3d 943, 949 (7th Cir.1997) (stating "true belief is not readily justiciable”); Nayak v. MC 33 (4th Cir.1997) (affirming dismissal for lack of subject-matter jurisdiction under First Amendment); Klagsbrun v. Va'ad Harabonim of Greater Monsey, 53 F.Supp.2d 732, 736 (dismissing for lack of subject-matter jurisdiction under Establishment Clause); Young v. N. Ill. Conference of United Methodist Church, 21 F.3d 184, 185-88 (7th Cir.1994) (<HOLDING>). 4 . See Destefano v. Grabrian, 763 P.2d 275,
holding that a title vii plaintiff could not hold coworkers liable in their individual capacities under title vii holding first amendment precluded subjectmatter jurisdiction over title vii suit challenging church hiring procedures holding that standing is component of subjectmatter jurisdiction holding that standing is component of subjectmatter jurisdiction and subjectmatter jurisdiction is essential to courts authority to hear case holding that plaintiffs failure to exhaust available grievance procedures does not bar her title vii claims