Minister Sues Denomination Over Broken Promise

He claimed a bishop had promised to appoint him to a particular church.

Church Law and Tax 1994-03-01 Recent Developments

Clergy – Removal

Key point: The civil courts cannot resolve disputes over the appointment or removal of ministers if those disputes cannot be resolved without inquiring into doctrine and polity.

The Arkansas Supreme Court dismissed a lawsuit brought by a minister claiming that a denominational official broke a promise to appoint him to a particular church. A minister of the African Methodist Episcopal Church (A.M.E. Church) filed a lawsuit claiming that his bishop failed to honor a promise to appoint him to a particular church. The minister claimed that when other ministers became aware that the bishop was going to appoint him as pastor of the church, they contacted the bishop and persuaded him not to follow through on his promise. The minister sued the other ministers for interfering with a contract, and the bishop for breaking his promise. A trial court ruled in favor of the minister, and awarded him $75,000. The case was appealed, and an appeals court reversed the trial court’s decision. The appeals court acknowledged that one commits interference with a contract relationship when the following four conditions are satisfied: (1) the existence of a valid contractual relationship or business expectancy; (2) knowledge of the contract or business expectancy on the part of the interfering party; (3) intentional interference causing a breach of the contract or expectancy; and (4) damage to the party whose contract or expectancy has been disrupted. The appeals court dismissed the interference with contract claim since the minister did not bring it in a county with proper venue. The court then addressed the remaining question of whether or not the minister could sue the bishop for breaking his promise. The court began its analysis by noting that “it is not unconstitutional for civil courts to resolve legal disputes involving a church or minister so long as the court is not required to interpret church doctrine to render a decision.” The minister claimed that he was asking a civil court to render a decision on the merits of his case without consulting A.M.E. doctrine or polity. The court concluded that a court could not resolve the minister’s claim against the bishop without consulting church doctrine:

It is true that the United States Supreme Court has said that if a dispute involving a church can be resolved without addressing ecclesiastical questions, the first amendment does not prohibit consideration by the civil courts. However, whenever a civil court must resort to the interpretation of church doctrine or polity, the Supreme Court has held that the civil court exercises its jurisdiction in violation of the first amendment ….

It is impossible to decide the [claim against the bishop] without inquiring in to A.M.E. Church doctrine and polity and drawing conclusions as to what those doctrines provide. In order to [prevail the minister] must prove reasonable reliance on the alleged promise of [the bishop] to appoint him to the pastorship of [the church]. This necessarily requires inquiry into A.M.E. Church doctrine and polity to determine whether it is reasonable to rely on the promise of an A.M.E. Church bishop that he is going to appoint one to a specific pastorship. This requires the court to determine whether church doctrine gives bishops authority to promise appointments. Such an inquiry is impermissible under the first amendment. Therefore … the claim is dismissed. Belin v. West, 864 S.W.2d 838 (Ark. 1993).

See Also:

This content is designed to provide accurate and authoritative information in regard to the subject matter covered. It is sold with the understanding that the publisher is not engaged in rendering legal, accounting, or other professional service. If legal advice or other expert assistance is required, the services of a competent professional person should be sought. "From a Declaration of Principles jointly adopted by a Committee of the American Bar Association and a Committee of Publishers and Associations." Due to the nature of the U.S. legal system, laws and regulations constantly change. The editors encourage readers to carefully search the site for all content related to the topic of interest and consult qualified local counsel to verify the status of specific statutes, laws, regulations, and precedential court holdings.

ajax-loader-largecaret-downcloseHamburger Menuicon_amazonApple PodcastsBio Iconicon_cards_grid_caretChild Abuse Reporting Laws by State IconChurchSalary Iconicon_facebookGoogle Podcastsicon_instagramLegal Library IconLegal Library Iconicon_linkedinLock IconMegaphone IconOnline Learning IconPodcast IconRecent Legal Developments IconRecommended Reading IconRSS IconSubmiticon_select-arrowSpotify IconAlaska State MapAlabama State MapArkansas State MapArizona State MapCalifornia State MapColorado State MapConnecticut State MapWashington DC State MapDelaware State MapFederal MapFlorida State MapGeorgia State MapHawaii State MapIowa State MapIdaho State MapIllinois State MapIndiana State MapKansas State MapKentucky State MapLouisiana State MapMassachusetts State MapMaryland State MapMaine State MapMichigan State MapMinnesota State MapMissouri State MapMississippi State MapMontana State MapMulti State MapNorth Carolina State MapNorth Dakota State MapNebraska State MapNew Hampshire State MapNew Jersey State MapNew Mexico IconNevada State MapNew York State MapOhio State MapOklahoma State MapOregon State MapPennsylvania State MapRhode Island State MapSouth Carolina State MapSouth Dakota State MapTennessee State MapTexas State MapUtah State MapVirginia State MapVermont State MapWashington State MapWisconsin State MapWest Virginia State MapWyoming State IconShopping Cart IconTax Calendar Iconicon_twitteryoutubepauseplay
caret-downclosefacebook-squarehamburgerinstagram-squarelinkedin-squarepauseplaytwitter-square