Judicial Council Decisions Search
Decision No. 1235
April 19 2013
In Re: Request for a Declaratory Decision from Persons in the Northern Nigeria Annual Conference and the Southern Nigeria Annual Conference as to the Meaning, Effect, and Application of ¶ 405 in the Election Process of the West Africa Central Conference
Digest of Case
The Judicial Council does not have jurisdiction. Only those bodies authorized by the Discipline to make petitions to the Judicial Council may seek declaratory decisions.
Statement of Facts
The West Africa Central Conference met in Sierra Leone, October 4-8, 2012, for its eighth regular quadrennial session. Among the items of business was the election of a Bishop for the Nigeria Episcopal Area. According to the rules of the West Africa Central Conference that were adopted at the seventh quadrennial session in 2008, the term for a bishop was set at twelve years beginning with the 2012 election. In preparation for the Central Conference session and the episcopal election, on June 11, 2012, Bishop Arthur F. Kulah released a letter describing the process that was to be followed for the nomination and election. He designated the date and the site of the meeting as October 3-7, 2012, in Free Town, Sierra Leone. He called special sessions for each of the three annual conferences in the Nigeria Episcopal Area—Northern Nigeria Annual Conference on July 14, Central Nigeria Annual Conference on August 11, and Southern Nigeria Annual Conference on August 13—during which each was to select one nominee as a candidate for election. He stated that a joint session of the three conferences would be convened on September 15-16, so that the three nominees could meet all of the delegates of the three annual conferences. And he stipulated that the persons who would be authorized to participate in the election process were those who were listed as official “delegates” to the 2010 annual conferences. This “identification” process did not occur as scheduled, because the death of Mrs. Kulah—the wife of the Bishop—made it impossible to hold the meetings on the dates that had been announced. Meetings were held, however, on August 18 for the Southern Nigeria Annual Conference, August 25 for the Northern Nigeria Annual Conference, and August 27 for the Central Nigeria Annual Conference. Before the Central Conference Committee on Episcopacy presented its report on the candidates nominated by the Committee, Bishop Arthur F. Kulah of the Nigeria Area summarized the nomination process that had been followed in preparing for the election. The Committee on Episcopacy then reported that twenty candidates had been considered through the nomination process and that three emerged as the nominated candidates. In a total of 1,378 votes in the annual conferences for nomination, the results were that three nominees were ranked as follows: John Wesley Yohanna, 564 votes; Abainatus Akila Hamman, 199 votes; and Daniel Y. Korot, 105 votes. Bishop Julius Trimble, who was assigned by the Council of Bishops to preside at the episcopal election, assumed the chair. The Minutes of the 2012 West Africa Central Conference publish the names of sixty-five clergy and lay delegates and identify them from four Episcopal Areas: Cote d’Ivoire, Liberia, Sierra Leone, and Nigeria. All of these delegates to the West Africa Central Conference received the curricula vitae for the three nominees. The Committee on Episcopacy then submitted these three names for election by secret ballot. Additional nominations from the floor were invited, but none was submitted. The delegates were then instructed to use ballot papers and to place one name on a ballot. The results of the ballot were announced as follows: sixty-five ballots were cast; eight ballots were invalid; fifty-seven ballots were valid; Rev. Korot received 00 votes; Rev. Hamman received 00 votes; Rev. Yohanna received 57 votes. Bishop Trimble announced that, having received 87.6% of the total votes cast, John Wesley Yohanna was elected Bishop. His consecration occurred on October 7, 2012. On October 10, 2012, a meeting of persons from Northern and Southern Nigeria Annual Conferences was convened. Invoking ¶ 603.6 of the 2008 Discipline, the group followed the procedure for choosing a presiding officer when there was no bishop to preside and elected The Rev. Philip Micah Dopah to be the presiding officer. Rev. Dopah announced that the meeting was convened because of the “inconsiderate action” by the West Africa Central Conference “to purportedly elect Rev. Johnwesley [sic] Yohanna as bishop of the Nigeria Area even after we had collectively written series of complaints to Bishop Kulah and Bishop John G. Innis, being the President of WACC.” He stated that a nomination process was not followed in Nigeria, and that “our delegates to WACC who were to go for election in Sierra Leone did not go because it was our collective decision since we sensed that the discipline was about to be circumvented, which it has.” The group, identifying itself as “The House,” adopted a resolution with fourteen enumerated points. In various particulars, the resolution asserts that the election was not done according to procedure of the Constitution, that “Johnwesley [sic] Yohanna” was not duly elected, that no allegiance will be offered to him, that no appointments will be accepted from him, that he will not be recognized “because of his moral bankruptcy,” and that the Northern and Southern Nigeria Annual Conferences “will seek redress for justice at the Judicial Council of the UMC.” One specification, namely item 11 in the resolution, states “that the Church should write both to the Judicial Council and to the West Africa Central Conference College of Bishops to express our displeasure for refusing to listen to our petitions.”
The Judicial Council does not have jurisdiction. Only those bodies authorized by the Discipline to make petitions to the Judicial Council may seek declaratory decisions. Oswald Tweh recused himself and took no part in this decision. Beth Capen and Ruben Reyes were absent. Sandra Lutz, first lay alternate, and Warren Plowden, fifth lay alternate, participated in this decision.