he dispute's subject matter is purely ecclesiastical. Watson v. Jones, 80 U.S. (13 Wall.) 679, 733, 20 L.Ed. 666 (1871).
[10]  Division One recently addressed the ecclesiastical abstention doctrine again in Rentz v. Werner, No. 62848-8-I, 2010 WL 2252529 (Wash.Ct.App. June 7, 2010). This case does not affect our analysis.
[11]  We recognize Toone and the Church may have possible defenses under the Free Exercise and Establishment Clauses.
[12]  As we already described, Erdman also voluntarily dismissed her negligent infliction of emotional distress claims based on facts not raised in her Form No. 26 grievance.
[13]  "Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof." U.S. Const. amend. I, cl. 1.
[14]  As the Ninth Circuit observed, "The Free Exercise Clause rationale for protecting a church's personnel decisions concerning its ministers is the necessity of allowing the church to choose its representatives using whatever criteria it deems relevant. Bollard, 196 F.3d at 947. Because no protected-choice rationale was present under the circumstances, allowing the plaintiff's claims to proceed did not intrude on church autonomy any more than "allowing parishioners' civil suits against a church for the negligent supervision of ministers who have subjected them to inappropriate sexual behavior." Bollard, 196 F.3d at 947-48.
[15]  In Bollard, the Ninth Circuit also noted that, because the plaintiff sought damages as his sole remedy, there was no danger of a remedy requiring continuing court action that would result in excessive entanglement with religion. 196 F.3d at 950. Here, Erdman also sought injunctive relief based only on the Church's discriminatory employment practices. We caution the trial court that should any of Erdman's claims prevail on remand, such injunctive relief would likely violate the Establishment Clause.
[16]  In its amicus brief, the Presbytery cites Germain v. Pullman Baptist Church, 96 Wash.App. 826, 980 P.2d 809 (1999), contending that a 