In 1871, the U.S. Supreme Court established the basic guidelines for when and how secular courts are to resolve disputes within religious organizations. Recognizing that some congregations are "strictly congregational or independent" and generally governed by a majority of their members, the court focused primarily on those which are "part of a large and general organization of some religious denomination" with which they are "more or less intimately connected by religious views and ecclesiastical government." Watson v. Jones, 13 Wall (80 US) 679, 726 (1871).