Not trampling on religious territory?

Interesting post in The Patry Copyright Blog: Copyright and Religion. William Patry writes regarding Merkos L'Inyonei Chinuch, Inc. v. Otsar Sifrei Lubavitch dispute about the Suddur:

"There also was a challenge to the court's authority to hear the dispute, since a religious court (bet din) had made a determination, but binding on only one of the parties. The court noted that both parties were corporations, and that the federal judiciary could apply netural secular law (the Copyright Act) to resolve the dispute, thereby not trampling on religious territory."

For the court to rule in a dispute about the ARI�s siddur is "not trampling on religious territory". Yet MA Appellate Court refused to rule on the authority of corporate bylaws in Marc Oster vs. New England Hebrew Academy because "the only parties who are qualified to determine whether the leadership of a religious organization is acting in the best interests of that organization are the leaders themselves, not the courts."

Nu, nu...