New York Supreme Court December 15, 1880 (First Reformed Presbyterian Church v. Bowden)

Macomber, J.

[After stating the facts as above.] —Prior to the passage of the act of 1875, c. 79, the courts of this State took no notice, of the denominational character of religious corporations, and, consequently, could not enforce any ecclesiastical law or rule of church government which did not spring from the corporation itself, but was imposed upon it from without (Petty v. Tooker, 21 N. Y.