• Key point: The dismissal of a minister by a denominational agency generally will not be reviewed by the civil courts, even if the agency allegedly did not comply fully with its own bylaws or other internal rules and procedures in dismissing the minister.
The Iowa Supreme Court dismissed a lawsuit brought by a former minister who claimed that a denominational agency violated his legal rights when it dismissed him. The executive committee of each local “conferenceof the Seventh—Day Adventist Church has authority over churches within the conference. This authority includes the right to hire ministers for local churches. In 1985, the executive committee of the Iowa—Missouri Conference hired a minister (the “plaintiff”) who later served in a number of pastoral positions within the conference. In 1990, the executive committee voted to terminate the plaintiff’s employment. This decision was made without providing the plaintiff with any counseling, and the plaintiff was given no opportunity to correct any problems associated with his ministry. The plaintiff unsuccessfully challenged his dismissal within the church. He later filed a lawsuit in civil court, challenging his dismissal on the following grounds: (1) breach of contract; (2) negligence; (3) defamation; (4) intentional infliction of severe emotional distress; (5) fraud; and (6) economic duress. The conference claimed that the first amendment guaranty of religious freedom prevented the civil courts from interfering with a church’s employment decisions concerning its ministers. A trial court agreed with the conference, and dismissed the case. The plaintiff appealed, claiming that the first amendment does not prevent civil courts from reviewing the purely “secular” aspects of clergy dismissals. He insisted that this was such a case. In support of his position, the plaintiff relied on a “working policy” adopted by the conference, which provides:
The effectiveness of all employees is to be reviewed periodically. Where employees are found to be ineffective, counsel shall be given them and if necessary they should be given other lines of work or be advised to seek employment outside of the denomination.
The plaintiff claimed that the conference violated this policy, since he was never provided counseling at the time of his dismissal and he was not given any opportunity to correct any perceived problems with his ministry.
The Iowa Supreme Court affirmed the trial court’s dismissal of the case. It observed, quoting in part from the decisions of other courts:
The [constitutional guaranty of religious freedom] prohibits courts from interfering with ecclesiastical decision making …. Consistent with this prohibition, Iowa courts have traditionally refrained from interfering in purely ecclesiastical matters. However, we have not been confronted with a claim that a church has failed to follow its policies in terminating a minister.
We believe [the plaintiff’s] effectiveness as a minister was the essence of his termination …. [A] church’s relationship with its ministers implicates internal church discipline, faith, and organization, all of which are governed by ecclesiastical rule, custom and law. The minister is the chief instrument by which the church seeks to fulfill its purpose. Matters touching this relationship must necessarily be recognized as of prime ecclesiastical concern.
We agree with those courts that have determined that the first amendment requires secular tribunals to refuse to interfere with a church’s relationship with its ministers. Accordingly, we decline to review any aspect of the executive committee’s decision to terminate [the plaintiff’s] employment as a [minister].
Similarly, the United States Supreme Court observed in a landmark case:
Nor do we see that justice would be likely to be promoted by submitting those decisions to review in the ordinary judicial tribunals. Each of these large influential bodies … has a body of constitutional and ecclesiastical law of its own, to be found in their written organic laws, their books of discipline, in their collections of precedents, in their usage and customs, which to each constitute a system of ecclesiastical law and religious faith that tasks the ablest minds to become familiar with. It is not to be supposed that the judges of the civil courts can be as competent in the ecclesiastical law and religious faith of all these bodies as the ablest men in each are in reference to their own. It would therefore be an appeal from the more learned tribunal in the law which should decide the case, to one which is less so.
The decisions of ecclesiastical courts, like every other judicial tribunal, are final, as they are the best judges of what constitutes an offense against the word of God and the discipline of the church. Any other than those courts must be incompetent judges of matters of faith, discipline, and doctrine; and civil courts, if they should be so unwise as to attempt to supervise their judgments on matters which come within their jurisdiction would only involve themselves in a sea of uncertainty and doubt which would do anything but improve either religion or good morals. Watson v. Jones, 80 U.S. (13 Wall.) 679 (1872).
These cases illustrate a conclusion reached by the vast majority of courts that have addressed the question—the civil courts will not second—guess the decisions of religious organizations concerning the status, selection, or discipline of ministers. This is so even if the religious organization allegedly fails to follow its own internal rules. Pierce v. Iowa—Missouri Conference of Seventh—Day Adventists, 534 N.W.2d 425 (Iowa 1995). [ Termination, Judicial Resolution of Church Disputes]
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