Court Jurisdiction Over Church Disputes

• Key point: The civil courts will not resolve lawsuits brought by dismissed church members challenging the validity of their dismissal.

• The Arkansas Supreme Court ruled that the civil courts have no authority to intervene in internal church disputes, but it upheld a trial court's civil contempt order against a bishop for refusing to acknowledge the trial court's jurisdiction. In 1990, an elder in a local African Methodist Episcopal (AME) church sued a bishop for violating AME bylaws. Specifically, the elder alleged that the bishop was improperly threatening to remove him from his office within the church, and that he was improperly receiving monies. A trial judge asserted jurisdiction over the elder's lawsuit and issued an order prohibiting the bishop from removing the elder from his office and from obtaining any monies from the church. The bishop claimed that this order was improper and refused to acknowledge it. The elder then asked the court to find the bishop to be in contempt of court (for willfully refusing to obey the court's order). The bishop again responded by insisting that the trial court had no jurisdiction over an internal church dispute. The trial court again ruled that it had jurisdiction over this case, and found the bishop in contempt of court. The judge sentenced the bishop to 30 days in prison and fined him $1,000. The bishop failed to challenge this contempt order. Several months later the bishop obtained a new attorney and renewed his challenge to the original court order. Another judge reviewed the case and agreed with the bishop that the trial court had no jurisdiction over the dispute since it involved religious doctrine and practices and also since the elder had failed to pursue remedies available to him within the AME church. The judge also dismissed the bishop's prison sentence and fine since they were based on an order that the trial court had no authority to issue. The elder appealed this decision. The state supreme court ruled that the civil courts lack jurisdiction over internal church disputes: "[T]he general rule is that religious controversies are not a proper subject for inquiry by civil courts, and that ecclesiastical decisions of church tribunals are binding on a civil court …." However, the court upheld the bishop's prison sentence and fine since he had not properly challenged the trial court's order. A dissenting judge pointed out the absurdity of this result: "I question, though, whether we should uphold the contempt sanction against the [bishop], thereby affirming a fine and jail sentence, when the [trial court] lacked jurisdiction over this matter." West v. Belin, 858 S.W.2d 97 (Ark. 1993).

See Also: Removal of Officers, Directors, and Trustees | Judicial Resolution of Church Disputes

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