Judicial Council Decisions Search
Decision No. 823
April 24 1998
In Re: Review of Decision of Law by Bishop Marion Edwards in the North Carolina Annual Conference on the Authority of the North Carolina Annual Conference to Require a Master of Divinity Degree for Membership in Full Connection and Elder's Orders.
Digest of Case
The ruling of Bishop Marion M. Edwards is not affirmed. The policy in the North Carolina Annual Conference requiring all candidates for full connection, including local pastors, to have a Master of Divinity degree, unconstitutionally negates General Conference legislation which gives local pastors an alternate educational route to full connection.
Statement of Facts
On June 11, 1997, during a regular business session of the North Carolina Annual Conference, a full-time local pastor in the North Carolina Annual Conference, submitted a written question of law to Bishop Marion M. Edwards. The question posed was: "Can an annual conference establish the Master of Divinity degree (or its equivalent) as the minimum requirement for admission into full connection, to the exclusion of equivalent educational requirements as determined by the General Board of Higher Education and Ministry, such as the Course of Study School for ordained ministry? Can the annual conference exclude the local pastor track as an avenue for admission to the North Carolina annual conference, as it has in past years?" The North Carolina Annual Conference has been operating under the following policy since 1975: Elder in Full Connection - Only those persons who have completed the M. Div. degree (or its equivalent) in seminary shall be elected to full membership (1975). Attention is called to the course requirements contained in Par. 326(3)c of The 1996 Book of Discipline. Candidates must complete the Methodist courses PRIOR to the interview: 1. United Methodist Polity; 2. United Methodist Theology and Doctrine; 3. A History of Methodism. Under this policy, a local pastor without a seminary degree could become an associate member of the Annual Conference, but could not become a member in full connection. The bishop ruled that the North Carolina policy as delineated above was constitutionally valid under the 1996 Discipline. Jurisdiction The Judicial Council has jurisdiction under ¶ 2613 of the 1996 Discipline. Analysis and Rationale The General Conference, under Article 15 of the Constitution, has full legislative power over all matters distinctively connectional. The authority of the Annual Conference, as the basic body of the Church, under Article 31 of the Constitution, includes the right to vote on all matters relating to the character and conference relations of its ministerial members, and on the ordination of ministers and such other rights as have not been delegated to the General Conference under the Constitution. Clearly, however, in exercising its rights, an Annual Conference cannot take an action which negates General Conference legislation. The North Carolina Annual Conference's policy of requiring the minimum of a Master of Divinity degree in order to become in full connection with the Annual Conference, eliminates an educational path to full connection which is given in the 1996 Discipline as an option for local pastors. (¶¶ 315.6 and 326(3)b [second clause]) These alternate educational routes allow for viable ordination options for clergy worldwide, regardless of their geographical location. The North Carolina Annual Conference policy, by adding standards to the minimum requirements for ordination and full connection, negates General Conference legislation and is therefore unconstitutional.
The ruling of Bishop Marion M. Edwards is not affirmed. The policy in the North Carolina Annual Conference requiring all candidates for full connection, including local pastors, to have a Master of Divinity degree, unconstitutionally negates General Conference legislation which gives local pastors an alternate educational route to full connection. Concurring Opinion While agreeing with our colleagues we urge caution regarding the authority of the Annual Conference in expanding the requirement for ordination and conference membership. The Constitution in ¶ 15 grants to the General Conference "full legislative power over all matters distinctively connectional." Qualifications for admission to the ministry is a matter distinctively connectional. In Judicial Council Decision 313 the council stated: The power to establish standards, conditions and qualifications for admission to the ministry is a matter of distinct connectional importance and is initially placed by the Constitution in the General Conference. This constitutional authority must be honored. An Annual Conference cannot establish requirements in conflict with the standards, conditions and qualifications established by the General Conference. In cases where the General Conference clearly states that standards, conditions and qualifications are minimal, the Annual Conference may under ¶ 31 of the Constitution expand these requirements but these requirements cannot conflict or eliminate the standards of the Discipline. Judicial Council Decision 318 stated that: An Annual Conference may not add to or subtract from the basic ministerial obligations established by act of the General Conference. Judicial Council Decision 440 allowed an expansion of a very narrow question wherein General Conference passed legislation which clearly indicated a minimum requirement by use of the word "at least" and "one full Annual Conference year." Because standards related to ordination and conference membership are distinctively connectional, Annual Conferences must exercise great caution in establishing requirements beyond those stated in the Discipline. Susan T. Henry-Crowe Wesley Bailey C. Rex Bevins Evelynn S. Caterson John G.Corry Zan Holmes, Jr. Tom Matheny Theodore H. Walter