Amendment limits on secular court jurisdiction over religious disputes even though a church “entity” was not a party to the litigation. See, e.g., Downs v. Roman Catholic Archbishop of Baltimore, 111 Md.App. 616, 683 A.2d 808 (Md.1996); Marshall v. Munro, 845 P.2d 424 (Alaska 1993); Gipson v. Brown, 295 Ark. 371, 749 S.W.2d 297 (1988); Heard v. Johnson, 810 A.2d 871 (D.C.App.2002); Vukovich v. Radulovich, 235 Cal.App.3d 281, 286 Cal.Rptr. 547 (Cal.App.1991); Galich v. Catholic Bishop of Chicago, 75 Ill.App.3d 538, 31 Ill.Dec. 370, 394 N.E.2d 572 (1979). As to the alleged pleading difference, none exists. Plaintiffs incorporated the subject letter into their pleadings, and the letter was clearly signed by Defendants in their role as pastors of the Church. See Heard, 810 A.2d at 878 (<HOLDING>). Second, Plaintiffs argue Gaydos is
holding that members of a church congregation lacked sufficient interest to support intervention in an action by the church itself challenging the designation of the church as a landmark holding even though trustees of church were sued in individual capacities facts clearly demonstrated that the individuals named in the complaint were named precisely because they were trustees of the church and were being sued as trustees not as individuals holding that tolling does not apply to additional defendants who were not named in the class action holding that after a class is certified the controversy may exist  between a named defendant and a member of the class represented by the named plaintiff even though the claim of the named plaintiff has become moot holding that courts can adjudicate property disputes as well as exercise jurisdiction over the narrow issue of whether bylaws of the church were properly adopted