through application of the Free Exercise Clause, the Supreme Court has held that the Establishment Clause also protects church autonomy in internal religious matters.”); see generally Douglas Laycock, Towards a General Theory of the Religion Clauses: The Case of Church Labor Relations and the Right to Church Autonomy, 81 Colum. L.Rev. 1373 (1981) (positing that Free Exercise Clause protections against burdens or restrictions on religion more appropriately address church autonomy concerns than the Establishment Clause, which prohibits government sponsorship of religion). Because this case does not raise the question of government-sponsored religion, we ground our analysis in the Free Exercise Clause. 7 . See also Drevlow v. Lutheran Church, Mo. Synod, 991 F.2d 468, 470-71 (8th Cir.1993) (<HOLDING>); Minker v. Baltimore Annual Conference of
holding that defendants sixth amendment right to trial by a jury was not violated by district courts reliance on his prior convictions for purposes of sentencing under the armed career criminal act holding that defendants sixth amendment right to trial by a jury was not violated by district courts reliance on his prior convictions for purposes of sentencing as career offender holding that the prior courts order by its conditional terms allowed subsequent modification by other courts holding ministers claim that the synod violated its bylaws by removing his name from list of eligible ministers not justiciable by secular courts holding that the multiple offender could not expunge all of his convictions by simply removing them from his record one at a time