Pilgrim Rest Missionary Baptist Church v. Wallace, et al.
| Docket Number: | 2002-CA-00070-SCT | |
| Supreme Court: | Opinion Link Opinion Date: 01-23-2003 Opinion Author: Waller, J. Holding: Affirmed |
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| Additional Case Information: |
Topic: Ecclesiastical dispute - Separation of church and state - Enforcement of final judgment - M.R.C.P. 62(a) - Findings of fact - M.R.C.P. 52(a) - Relief granted - M.R.C.P. 54(c) - Ambiguous judgment Judge(s) Concurring: Pittman, C.J., McRae and Smith, P.JJ., Cobb, Diaz, Easley, Carlson and Graves, JJ. Procedural History: Bench Trial Nature of the Case: CIVIL - OTHER |
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| Trial Court: |
Date of Trial Judgment: 01-08-2002 Appealed from: Hinds County Chancery Court Judge: Patricia D. Wise Disposition: The chancellor ordered a determination of voting members of a church and an election to decide whether to terminate the services of its pastor. Case Number: G2001-571 |
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| Party Name: | Attorney Name: | |||
| Appellant: | Pilgrim Rest Missionary Baptist Church by and through Its Board of Deacons |
DOUG DOUGLAS WADE |
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| Appellee: | G. W. Wallace, Elijah Cooper, Lewis Williams, Bobby Wallace and Leonard Wilson | RAMEL LEMAR COTTON |
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| Topic: | Ecclesiastical dispute - Separation of church and state - Enforcement of final judgment - M.R.C.P. 62(a) - Findings of fact - M.R.C.P. 52(a) - Relief granted - M.R.C.P. 54(c) - Ambiguous judgment |
| Summary of the Facts: | Church members of the Pilgrim Rest Missionary Baptist Church voted to remove Reverend W.R. Griffin as pastor because of disputes over the business practices of the Church. Deacon Sylvester Crisler and Reverend Griffin sought injunctive relief in chancery court to enjoin Deacon G.W. Wallace and Trustees Elijah Cooper, Lewis Williams, Bobby Wallace, and Leonard Wilson from doing any act relating to the business affairs of the Church which is against the Church's by-laws. The Board of Trustees responded with a complaint seeking a declaration that the Church membership had the right to relieve Reverend Griffin and a motion for a temporary restraining order to prevent the Board of Deacons and Griffin from spending any Church funds as well as to require them to provide an accounting and reimburse the Church for funds spent. The chancellor granted the Trustees a preliminary injunction freezing the Church's funds and appointed consulting experts to complete an accounting of all funds deposited and to reconcile Church finances. The chancellor ordered a determination of voting members of a church and an election to decide whether to terminate the services of its pastor. The result of the election was 54-0 in favor of removing Reverend Griffin. The Board of Deacons and Griffin appeal. |
| Summary of Opinion Analysis: | Issue 1: Separation of church and state The Board of Deacons and Griffin argue that the chancellor violated the First and Fourteenth Amendments to the U.S. Constitution by becoming involved in an ecclesiastical dispute. Civil courts should not disturb the decisions of the highest ecclesiastical tribunal within a church of hierarchical polity, but must accept such decisions as binding on them. If the church is congregational as are Baptist churches, a civil court retains jurisdiction to determine whether the decision concerning 'who shall preach from the pulpit' was made by the proper church authority. Here, the chancellor merely established a procedure whereby the members of Pilgrim Rest could vote on whether they wanted to retain Reverend Griffin as their pastor and did not overstep her bounds of jurisdiction in ordering an election when doing so was secular in purpose. Issue 2: M.R.C.P. 62(a) The Board of Deacons argues that the chancellor violated M.R.C.P. 62(a) because she held a hearing to enforce her final judgment less than ten days after its entry. In addition to providing no execution shall be issued upon a judgment nor shall proceedings be taken for its enforcement until the expiration of ten days after the later of its entry or the disposition of a motion for new trial, M.R.C.P. 62(a) provides that an interlocutory or final judgment in an action for an injunction shall not be stayed during the period after its entry and until an appeal is taken or during the pendency of an appeal. Therefore, Rule 62(a) excepts injunctions from the automatic stay. Issue 3: M.R.C.P. 52(a) The Board of Deacons argues that the final judgment does not contain anything resembling the required finding of fact or conclusion of law. M.R.C.P. 52(a) provides that in bench trials, the court may, and shall upon the request of any party, find the facts specially and state separately its conclusions of law thereon. This case is not particularly complex, and the facts as stated in the final judgment adequately state the court’s findings of fact. Issue 4: M.R.C.P. 54(c) The Board of Deacons argues that the chancellor violated M.R.C.P. 54(c) by granting relief for which no party prayed. The comment to Rule 54 provides that relief need not be limited in kind or amount by the demand but may include relief not requested in the complaint. All the chancellor did was prescribe a method of election. Issue 5: Ambiguous judgment The Board of Deacons argues that the final judgment was vague, ambiguous, and unclear because it did not set forth a procedure to validate the election. However, the chancellor was certain and quite clear in the regulation of the election. |
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