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In the seminal case outlining the contours of permissible civil liability against religious organizations, the Missouri Supreme Court in Gibson v. Brewer made clear that civil courts must not be in the business of analyzing or interpreting religious doctrine and administration. Any such “excessive entanglement” between church and state has the effect of inhibiting religion, which of course would violate the First Amendment. For this reason, Missouri courts are precluded from reviewing questions of hiring, ordaining, and retention of clergy in religious organizations ...