• An Illinois appeals court dismissed a lawsuit brought by a Methodist minister against a Methodist conference for breach of contract and wrongful interference with contractual relations. The minister claimed that despite his “good and satisfactory work” as pastor of a local church, he was assigned by the conference to another church which constituted “a severe demotion in terms of the number of church members, compensation, and opportunity for service.” He further claimed that the conference ordered his transfer without a “consultation” with the churches involved (as required by the Methodist “Book of Discipline”) and therefore amounted to a breach of contract. The conference claimed that the dispute was a purely ecclesiastical matter over which the civil courts had no jurisdiction, and accordingly asked the trial court to dismiss the lawsuit. The trial court agreed with the conference, and the case was appealed to a state appeals court which also agreed with the conference. The appeals court emphasized that the constitutional guaranty of religious freedom “prohibits secular authorities from interfering with internal ecclesiastical workings and discipline of religious bodies.” In dismissing the minister’s lawsuit, the court observed: “[The minister] is asking the court to award damages for breach of contract because of [the] conference’s action of appointing [him] to a different post without providing a consultation—a process wherein the bishop and/or district superintendent of the church organization confer with the pastor and pastor-parish relations committee about the appointment of the particular pastor in question, taking into consideration certain criteria as outlined in the Book of Discipline …. When making appointments, the empowered bishop of the conference is to take into account, among other things, the unique needs of the charge in a particular setting, as well as the gifts and graces of the particular pastor. In other words, the appointment of a pastor is a purely subjective decision to be made by the empowered bishop to advance the purpose of the church organization. Appointment is undoubtedly an ecclesiastical matter to which judicial deference is mandated by the first amendment. Whether or not the conference followed required procedure in appointing [the minister] is not for a civil court to consider, because it would entail scrutinizing the appointment decision-making process and reviewing the subjective criteria used by the church organization in reaching its decision.” The court noted that the appropriate remedy for the minister was “to higher judicial tribunals within the church hierarchy,” and if the minister “has made such appeal and been denied relief, this court must defer to the decision of the church.” It also rejected the minister’s contention that the so-called “neutral principles of law” approach gave the civil courts jurisdiction over this kind of dispute, since the neutral principles approach “has been used primarily for disputes over ownership of church property.” Williams v. Palmer, 532 N.E.2d 1061 (Ill. App. 3rd Dist. 1988).
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