civil courts are to do no more than determine the highest ecclesiastical tribunal with jurisdiction over the dispute, ascertain the decision of the tribunal, and defer to its resolution of the dispute.”37 In an important decision at the end of the nineteenth century, in Order of St. Benedict v. Steinhauser, the U.S. Supreme Court awarded a monk’s assets to the Order over against the claims of the executor of the monk’s estates because of the voluntary association of the monk within the Order and