An Illinois state appeals court rejected a minister's claim that his dismissal constituted a breach of contract or intentional infliction of emotional distress.
The minister, who had served as minister of a local Baptist church for over 40 years, had signed an employment agreement of unspecified duration that gave either the minister or the church the right to terminate the employment relationship upon 90 days' written notice. After being discharged by a congregational vote at a church business meeting, the minister sued the church, alleging that (1) the church and three church officers had breached their employment contract by dismissing him against his will, (2) the minister's dismissal was legally void since the business meeting at which the dismissal occurred did not have proper notice, and (3) certain church officers had intentionally inflicted emotional distress upon the minister. A jury ruled in favor of the minister on all three counts, and the church appealed.
The state appeals court held that the evidence in favor of the church defendants was so overwhelming that the trial court had erred in submitting the case to a jury. With respect to the minister's claim of breach of contract, the court observed that the employment contract was of unspecified duration, and "as a matter of law either an employer or an employee may terminate employment based on a yearly salary, without cause, if no employment period is otherwise stated." As to the minister's contention that his dismissal was void since the business meeting at which it occurred lacked adequate notice, the court concluded that adequate notice of the date and purpose of the meeting in fact had been communicated to the minister.
The court, noting that "the church customarily did not follow its own procedures to the letter, but rather used a flexible approach, concluded that "the object of notice is to inform the party notified, and if the information is obtained in any way other than by formal notice, the object of notice is attained." While the minister may not have been duly notified in a formal sense of the agenda of the business meeting, it was nevertheless true that he (and the congregation) knew by other means that his employment would be at issue. This, concluded the court, was sufficient.
Finally, the court rejected the claim of intentional infliction of emotional distress. While not condoning certain activities of church officials (e.g., blocking the minister's access to the pulpit, insisting that he no longer serve communion, and changing the locks on church doors), the court concluded that such behavior simply was not so extreme and outrageous as to constitute the tort of intentional infliction of emotional distress. "Conduct which otherwise amounts to no more than insults or indignities" is not sufficient.
The court's ruling on all three counts is significant, and will provide additional guidance to churches and clergy in similar cases. Owens v. Second Baptist Church, 516 N.E.2d 712 (Ill. App. 1987)
