THOMPSON, Associate Judge:

In December 2012, appellant Abune Samuel, identifying himself as the "duly constituted and appointed Archbishop of the Washington DC area diocese of the Ethiopian Orthodox Tewahedo Churches in the Diaspora[,]" filed a Complaint against appellees Nega Lakew and Tesfaye Nega — identified in the Complaint as, respectively, the President of the Board of Directors of Kedus Gabriel Ethiopian Orthodox Tewahedo Church ("Kedus Gabriel") and head of the Kedus Gabriel Parish Administrative Council. The Complaint announced that the case "involves control over real property located at 2601 Evarts Street, NE [the "Evarts Street property"] ... and owned by Kedus Gabriel[.]" The Complaint sought, inter alia, the following injunctive relief: that appellees "be directed to forthwith turn over to Archbishop Abune Samuel any and all property belonging to Kedus Gabriel" and that each appellee "cease and desist from holding himself out in any manner as an administrator or member of the Parish Council of Kedus Gabriel[.]"1 After defendants/appellees Lakew and Nega moved for summary judgment, the trial court (the Honorable Neal Kravitz) dismissed the Complaint, concluding that the court lacked subject matter jurisdiction "to resolve the matter of control of the [Kedus] Gabriel church[.]" In a subsequent order denying appellant's motion to amend the judgment, Judge Kravitz stated that he "remain[ed] of the view ... that the First Amendment does not permit a civil court to determine the religious leader of a religious institution[.]"

Appellant contends that Judge Kravitz had jurisdiction to make a finding that Kedus Gabriel is part of the hierarchical Ethiopian Orthodox Tewahedo Church in the Diaspora and to grant injunctive relief based on deference to the church hierarchy's decision to remove appellees from their positions as Kedus Gabriel administrators. He asks us to remand this matter for the Superior Court to make "a determination of the true form of the organizational structure of Kedus Gabriel[.]"

For the reasons that follow, we affirm the judgment of dismissal.2

I. Background

Political upheaval in Ethiopia in the early 1990s caused a division in the Ethiopian Orthodox Tewahedo Church, the primary religious institution in Ethiopia. The Ethiopian Orthodox Tewahedo Church's original Patriarch, some of its Archbishops, and many other Ethiopians fled to the United States. Some Ethiopians who emigrated to the United States formed Ethiopian Orthodox Tewahedo congregations. Kedus Gabriel, which was incorporated in 1993, is one such congregation. The Patriarch and Archbishops who emigrated to this country formed the Ethiopian Orthodox Tewahedo Church in the Diaspora; its governing body is known as the "Holy Synod."

In 1994, the then-leader of the Ethiopian Orthodox Tewahedo Church in the Diaspora appointed appellant as "priest-in-charge" of Kedus Gabriel. From 1994 until October 2012, appellant's living quarters were provided by Kedus Gabriel. Kedus Gabriel purchased the Evarts Street property on February 17, 2001, and, beginning in July 2001, appellant's living quarters were in the Evarts Street property. Appellant was appointed Archbishop of the Washington Metropolitan area in 2007 by the Patriarch of the Ethiopian Orthodox Tewahedo Church in the Diaspora, Abune Merkorios.

In 2012, a dispute arose between appellant and appellees in their capacity as Kedus Gabriel administrators. We need not describe the background and details of the dispute; it suffices for present purposes to say that a committee appointed by the Holy Synod conducted an ecclesiastical investigation under the leadership of Patriarch Merkorios and determined that appellee Nega and the existing Kedus Gabriel Parish Council members had "no further legal standing and [were] to be replaced under the direction of" appellant. Appellant wrote an October 4, 2012, letter to appellee Nega, describing the committee's decision. The letter recited that the Holy Synod committee had found that appellee Nega and the Parish Council had "broken the laws and traditions of the Church" and had "lost moral standing."3 The letter explained that, in order to "protect the integrity of the Ethiopian Orthodox Tewahedo Religion Church traditions, enforce the ecclesiastical findings, and protect the spiritual well[-]being of parishioners" and to "ensure that only those whom [appellant] deems to be capable of upholding and maintaining the law and traditions of the Church, and who have not been found to violate the laws and traditions of the Church[,] will be able to stand for election to the Church Council[,]"4 appellant had appointed himself Church Administrator (i.e., "the priest who administers the Church"), had removed appellee Nega and all Kedus Gabriel officers from their positions, and had suspended the Kedus Gabriel bylaws. Kedus Gabriel's Board responded by announcing that appellant was terminated, by instructing him to "surrender all keys and properties" of the church and to "leave the premises immediately," and by blocking his access to the Evarts Street property.5

There followed appellant's Complaint for declaratory and injunctive relief. The Complaint alleges that appellees have "refused to step aside," in "total defiance of the Holy Synod[.]" The Complaint further asserts that, "unless enjoined, [appellees] will continue to disobey the directions of the Holy Synod."

II. Applicable Law

The First Amendment provides, in pertinent part, that "Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof[.]" U.S. Const. amend. I. The first of these "religion clauses," the Establishment Clause, "prevents the Government from appointing ministers[.]" Hosanna-Tabor Evangelical Lutheran Church & Sch. v. EEOC, ___ U.S. ___, 132 S.Ct. 694, 702-03, 181 L.Ed.2d 650 (2012). The second, the Free Exercise Clause, "prevents [the government] from interfering with the freedom of religious groups to select their own [ministers]." Id. at 703. The religion clauses "severely circumscribe the role that civil courts may play in the resolution of disputes involving religious organizations." Meshel v. Ohev Sholom Talmud Torah, 869 A.2d 343, 353 (D.C. 2005). This does not mean, of course, "that churches are above the law or that there can never be a civil court review of a church action." Heard v. Johnson, 810 A.2d 871, 879 (D.C.2002). "There are several areas in which civil courts continue to have jurisdiction over church actions." Id. at 880. Courts may, for example, apply "neutral principles of law" to resolve disputes over church property, see, e.g., Jones v. Wolf, 443 U.S. 595, 604, 99 S.Ct. 3020, 61 L.Ed.2d 775 (1979), and "may have jurisdiction over employment disputes where the employee provides a purely secular service for the church." Heard, 810 A.2d at 880. However, civil courts "must be careful not to violate the First Amendment by agreeing to resolve a controversy which, at its heart, concerns religious doctrine and practice." Bible Way, 680 A.2d at 427 (internal quotation marks omitted); see also id. at 429 (noting that a court must not "entangl[e] itself in doctrinal interpretations"); Kedroff v. St. Nicholas Cathedral of Russian Orthodox Church in North America, 344 U.S. 94, 116, 73 S.Ct. 143, 97 L.Ed. 120 (1952) (stating that religious institutions have the "power to decide for themselves, free from state interference, matters of church government as well as those of faith and doctrine"); Meshel, 869 A.2d at 353 ("[T]he Establishment Clause precludes civil courts from resolving disputes involving religious organizations whenever such disputes affect religious doctrine or church polity or administration[.]"). "Any attempt by the civil courts to limit [a] church's choice of its religious representatives would constitute an impermissible burden on the church's First Amendment rights." Pardue v. Center City Consortium Schs. of the Archdiocese of Wash., Inc., 875 A.2d 669, 673 (D.C.2005) (quoting United Methodist Church, Baltimore Annual Conf. v. White, 571 A.2d 790, 794 (D.C.1990)).

III. Analysis

In arguing that Judge Kravitz erred in concluding that the Superior Court lacks jurisdiction to resolve the parties' dispute, appellant relies heavily on Watson v. Jones, 80 U.S. 679, 13 Wall. 679, 20 L.Ed. 666 (1871). In Watson, the Supreme Court prescribed an approach for resolving a dispute involving a church that is "a subordinate member of some general church organization in which there are superior ecclesiastical tribunals with a general and ultimate power of control more or less complete, in some supreme judicatory over the whole membership of that general organization." Id. at 722-23. The Court ruled that, in such cases, "the rule of action which should govern the civil courts... is, that, whenever the questions of discipline, or of faith, or ecclesiastical rule, custom, or law have been decided by the highest of these church judicatories to which the matter has been carried, the legal tribunals must accept such decisions as final, and as binding on them, in their application to the case before them." Id. at 727; see also Meshel, 869 A.2d at 353 ("The Free Exercise Clause requires civil courts to defer to the decisions of the highest tribunals of hierarchical religious organizations on matters of religious doctrine, discipline, faith, and ecclesiastical rule, custom, or law." (citing, inter alia, Watson, 80 U.S. at 727)).6 Appellant contends that the Watson rule applies in this case because this "is a classic case of hierarchical authority and church structure." Appellant asserts that Judge Kravitz had authority to find that Kedus Gabriel is part of the hierarchical Ethiopian Orthodox Tewahedo Church in the Diaspora, to recognize, upon such finding, that the decisions and orders of the Holy Synod and the Patriarch are binding, and to enforce those decisions and orders, which give appellant control over Kedus Gabriel.

As Judge Kravitz noted, however, "the parties disagree over whether the [Kedus] Gabriel church is hierarchical or congregational in structure." And as Justice Brennan recognized in his concurrence in Maryland & Virginia Eldership of Churches of God v. Church of God at Sharpsburg, Inc. (Md. & Va. Churches), "the use of the Watson approach is consonant with the prohibitions of the First Amendment only if the appropriate church governing body can be determined without the resolution of doctrinal questions and without extensive inquiry into religious policy." 396 U.S. 367, 370, 90 S.Ct. 499, 24 L.Ed.2d 582 (1970) (Brennan, J., concurring); see also id. at 369-70, 90 S.Ct. 499 ("[W]here the identity of the governing body or bodies that exercise general authority within a church is a matter of substantial controversy, civil courts are not to make the inquiry into religious law and usage that would be essential to the resolution of the controversy."). In Jones, a Supreme Court majority acknowledged the same principle, explaining that while determining whether a church is hierarchical or congregational will not be difficult in some cases, "in others, the locus of control would be ambiguous, and [a] careful examination of the constitutions of the general and local church, as well as other relevant documents, [would] be necessary to ascertain the form of governance adopted by the members of the religious association." 443 U.S. at 605, 99 S.Ct. 3020 (internal quotation marks omitted). In such cases, the Court held, "the [Watson] rule would appear to require a searching and therefore impermissible inquiry into church polity." Id. (emphasis added, internal quotation marks omitted).

As appellant has framed the issues, this is just such a case, i.e., one in which "the locus of control [is] ambiguous."7 Id. It is not just that the nature of the relationship between the Kedus Gabriel congregation and the Ethiopian Orthodox Tewahedo Church in the Diaspora under the leadership of Patriarch Merkorios is hotly disputed, though that is certainly so. See supra note 5. Even though the parties are in accord in directing our attention to the Kedus Gabriel bylaws,8 determining whether the bylaw that acknowledges the Holy Synod's responsibility for "spiritual and religious matters" gives the Holy Synod authority to remove Kedus Gabriel's elected officers in the circumstances that preceded this litigation would impermissibly entangle the court in "doctrinal interpretation[]." Bible Way, 680 A.2d at 429. The court would have to determine, for example, whether the judgment of the Holy Synod Committee — i.e., that the administrators and officers elected pursuant to the Kedus Gabriel bylaws must be removed because they "lack spirituality[,]" "broke[] the laws and traditions of the Church," "lost moral standing," failed to accord due respect to the "fathers of the Church," "created unnecessary ... arguments," and failed to protect "the spiritual well[-]being of parishioners" — constitutes an exercise of responsibility for "spiritual and religious matters." Answering that question would entail an impermissible inquiry into "church polity," Jones, 443 U.S. at 605, 99 S.Ct. 3020 would involve the court in deciding "ecclesiastical questions," and would require an impermissible inquiry into "religious doctrine and practice." Serbian E. Orthodox Diocese for U.S. & Canada v. Milivojevich, 426 U.S. 696, 709-10, 714, 96 S.Ct. 2372, 49 L.Ed.2d 151 (1976).9 In short, use of the Watson approach in this case would not be "consonant with the prohibitions of the First Amendment[.]" Md. & Va. Churches, 396 U.S. at 370, 90 S.Ct. 499 (Brennan, J., concurring).

Nor is this a dispute about ownership of property that could perhaps have been resolved using neutral principles.10 To be sure, the second sentence of the Complaint asserts that this matter is about "control over real property[.]" However, as this court has previously explained, "`in determining whether the adjudication of an action would require a civil court to stray impermissibly into ecclesiastical matters, we look not at the label placed on the action but at the actual issues the court has been asked to decide.'" Prioleau, 49 A.3d at 816 (bracket omitted) (quoting Meshel, 869 A.2d at 356)11; see also Heard, 810 A.2d at 885 (looking behind the label "defamation" to the actual issues the court had been asked to decide). Here, notwithstanding the second sentence of the Complaint, appellant was not actually asking the trial court to resolve a dispute about property. He did not ask the court to decide whether the local church, Kedus Gabriel, or, instead, the Ethiopian Orthodox Tewahedo Church in the Diaspora owns the Evarts Street property.12 Quite the contrary, the Complaint states in two places that the Evarts Street church property is "owned by Kedus Gabriel" and additionally asks for a transfer to appellant of "all property belonging to Kedus Gabriel" (emphasis added). Thus, this is not a matter that Judge Kravitz might have resolved by, for example, enforcing a provision of the "corporate charter or the constitution of the general church ... [specifying] ... that the [local] church property is held in trust for the general church[.]" Jones, 443 U.S. at 607-08, 99 S.Ct. 3020. To the extent that appellant asserted a right to control of church property, he did so not on the basis of neutral principles of law but rather based on arguments that could not be resolved without requiring the court to resolve theological issues that a secular court could not properly resolve.

This also is not a case in which Judge Kravitz could have applied neutral principles of law to resolve a dispute about whether the leaders and members of the Kedus Gabriel Parish Council and Board had been duly elected in accordance with church bylaws.13 In asserting that appellees have no "claim to legitimacy[,]" appellant does not purport to enforce the Kedus Gabriel bylaws; rather, he claims to have suspended the bylaws and asserts that appellees must be required to "step aside" because of the Holy Synod's decree that they have lost "moral standing." "[T]he conformity of the members of the church to the standard of morals required of them" is a matter "strictly and purely ecclesiastical in its character," "over which the civil courts exercise no jurisdiction[.]" Watson, 80 U.S. at 733.

Notwithstanding the (bare) allegation in the Complaint that appellee Nega and the members of the Parish Administrative Council have failed to "call[] elections to the council as required by the Kedus Gabriel By-Laws,"14 the record makes clear that this is really a dispute about whether appellant is entitled to "control over the local church" as its "complete administrator[,]" and whether appellees should be enjoined from holding themselves out as Kedus Gabriel's administrators. Given that the Complaint uses the term "Parish church administrator" to mean "the priest who administers the Church" or "a clergyman who is ... a priest in charge,"15 we understand the dispute to be about which individuals are entitled to serve as the clergy of Kedus Gabriel.

As the Supreme Court explained in Hosanna-Tabor, and as appellees stressed in their motion for summary judgment,

132 S.Ct. at 706. Informed by both parties' summary judgment papers that the dispute here at bottom is about which clergy have the right to control Kedus Gabriel, Judge Kravitz properly denied relief, on the ground that "the First Amendment does not permit a civil court to determine the religious leader of a religious institution[.]"16 Accordingly, the judgment of the Superior Court dismissing the Complaint is

Affirmed.