How have courts interpreted the theory of hierarchy in the context of church property disputes?

The leading American case setting out the theory of hierarchy is Watson v. Jones (1872), 13 Wall. 679, 80 U.S. 679, 20 L.Ed. 666, where the court held that when a religious congregation or ecclesiastical body holding church property is a subordinate body of an organization in which there are superior ecclesiastical tribunals possessing general and ultimate power of control over church matters, the decisions of such tribunals control church property disputes to the exclusion of the civil courts. The hierarchical theory asserts that when a subordinate congregation of a hierarchical church secedes from the church, it has no right [115 Cal.App.3d 612] to retain church property held in its own name. Essentially, the hierarchical theory subordinates civil control of church property to ecclesiastical control of church property. Under this theory the canons and rules of a general church override general principles of legal title in the resolution of church controversies over property.