property disputes. Bennison v Sharp, 121 Mich App 705, 712; 329 NW2d 466 (1982). The First Amendment, however, “severely circumscribes the role that civil courts may play in resolving church property disputes” by prohibiting civil courts from resolving church property disputes on the basis of religious doctrine and practice and requiring that courts defer to the resolution of issues of religious doctrine or polity by the highest court of a hierarchical church organization. [Id. at 712-713, quoting Jones v Wolf, 443 US 595, 602; 99 S Ct 3020; 61 L Ed 2d 775 (1979).] The determination of whether a denomination is hierarchical is a factual question. See Calvary Presbyterian Church v Presbytery of Lake Huron of the United Presbyterian Church, 148 Mich App 105, 113; 384 NW2d 92 (1986) (<HOLDING>); Bennison, supra at 718 (holding that “the
holding that the trial court correctly found that the denomination is hierarchical holding that the district court correctly instructed the jury that there had to be a substantial similarity between the indictment and the proof in order to find the defendant guilty holding that where the defendant was in default the district court correctly accepted the fact allegations of the complaint as true holding that the trial court correctly instructed the jury that the defendant had to establish by evidence that outweighed the evidence against him that he lacked the capacity to form specific intent holding that the trial court correctly instructed the jury that the use of physical force to overcome victims resistance was necessary for offense to amount to robbery