to state action and thus turned on general federal law, it nevertheless delineated the limited role civil courts may constitutionally play in resolving controversies that touch upon religion. See Serbian E. Orthodox Diocese v. Milivojevich, 426 U.S. 696, 710, 96 S.Ct. 2372, 49 L.Ed.2d 151 (1976). 6 . Courts have grounded the doctrine of church autonomy in different aspects of the First Amendment, some looking to the Free Exercise Clause, some to the Establishment Clause, some to both, and others to neither in particular. See Idleman, 75 Ind. LJ. at 223-25; see also Bollard v. Cal. Province of the Soc’y of Jesus, 211 F.3d 1331, 1332 (9th Cir.200), denying reh’g en banc (Wardlaw, J., dissenting) ("Though the concept originate Methodist Church, 894 F.2d 1354, 1356-58 (D.C.Cir.1990) (<HOLDING>); Simpson v. Wells Lamont Coip., 494 F.2d 490,
holding that the free exercise clause prohibits courts from deciding church property disputes by resolving underlying conflicts over the interpretation of particular church doctrines and the importance of those doctrines to the religion holding the application of agediscrimination law in the ministers lawsuit against his church violative of the free exercise clause holding that discrimination based on religion is subjected to strict scrutiny whether a claim arises under the establishment clause the free exercise clause of equal protection clause 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 that possession of marijuana is not protected by the free exercise clause of the first amendment