And according to the American rule, where the subject-matter of dispute, inquiry, or decision is strictly and purely ecclesiastical in its character, it is a matter over which the civil courts should not exercise any jurisdiction--a matter which concerns theological controversy, church discipline, ecclesiastical government, or the conformity of the members of the church to the standard of morals required of them, the civil court has not and should not have any jurisdiction. If the civil courts were at liberty to inquire into the whole subject of doctrinal theology, usages, and customs, the written laws and fundamental principles would have to be examined into with minuteness and care, for they would be the criteria by which the validity of the ecclesiastical decree would be determined in the civil court. And that would deprive the authorities of the church of their proper right and power to construe their own church laws, and would open the way to the evil of transferring to the civil courts, where the rights to property were concerned, the decision of all ecclesiastical questions.[4] Of all the cases in which this doctrine is applied, no better representative can be found than that of Shannon _v._ Frost,[5] where the principle is ably supported by the learned Chief-Justice of the Court of Appeals of Kentucky, wherein he says: "This court, having no ecclesiastical jurisdiction, cannot revise or question ordinary acts of church discipline. Our only judicial power in the case arises from the conflicting claims of the parties in the church property, and the use of it. We cannot decide who ought to be members of the church, nor whether the excommunicated have been justly or unjustly, regularly or irregularly, cut off from the body of the church." The same principle was laid down in the subsequent case of Gibson _v._ Armstrong,[6] and of Watson _v._ Avery.[7] One of the most careful and well-considered judgments on the subject is that of the Court of Appeals of South Carolina, delivered by Chancellor Johnson in the case of Harmon _v._ Dreher.[8] That case turned upon certain rights in the use of church property claimed by the minister, notwithstanding his expulsion from the synod as one of its members: