Decision Number 643


October 24, 1990

Petition From the Eastern Pennsylvania Conference for a Declaratory Decision as to the Constitutionality of Paragraph 453.3(b) of the 1988 Discipline.


Paragraph 453.3(a) and (b) does not violate a pastor's constitutional right to trial under the 1988 Discipline.

Statement of Facts

Reverend J. Westcoat Sandlin requested he be placed on leave of absence by the Eastern Pennsylvania Conference as of May 1, 1986, for purposes of "career revaluation."

In 1987, he applied to the Conference to extend the leave of absence, "to consider returning to the Episcopal Church."

In 1989, he requested that the leave of absence be continued for reasons as stated "to reflect."

In January, 1989, Reverend Sandlin requested that the Conference end his leave of absence status. He was interviewed on February 21, 1989, by the Eastern Pennsylvania Conference Committee on Conference Relations.

The Committee recommended to the Board of Ordained Ministry that his request be denied. The Board, at its meeting of February 27, 1989, agreed with the Committee.

Reverend Sandlin requested a review and reconsideration and a meeting with the full Board of Ordained Ministry, which was granted. He later withdrew his request.

Nevertheless, he did meet with the full Board on May 15, 1989. No action was taken. He requested another extension of leave of absence in January, 1990.

On March 5, 1990, the Board of Ordained Ministry voted to recommend to the Executive Session of the Annual Conference that Reverend Sandlin be placed on Administrative Location under Paragraph 453.3(b) effective July 1, 1990.

Proper notice was sent and received more than sixty days before the opening of the Annual Conference. He was advised of his right to a hearing and on March 21, 1990 requested such a hearing which was scheduled on May 14, 1990.

At the hearing, Reverend Sandlin presented his arguments and the Hearing Committee voted to affirm the Board's recommendation to the Executive Session.

Reverend Sandlin again received notice and was given the opportunity to speak at the Executive Session of the Annual Conference.

The Executive Session voted by an overwhelming majority to place him on Administrative Location.

The Annual Conference then voted to request this Declaratory Decision.

At an oral hearing J. Westcoat Sandlin and E. Lloyd Wilcox appeared. Sandra Forrester Dufresne appeared representing the Eastern Pennsylvania Annual Conference.


The Judicial Council has jurisdiction under ¶ 2615 of the 1988 Discipline. 

Analysis and Rationale

A motion was made at the 204th session of the Eastern Pennsylvania Conference as follows:
I move that the Conference request a declaratory judgement from the Judicial Council on the following question: Does paragraph 453.3(b) of the Discipline (regarding procedure for placing a minister on Administrative Location) violate the right of a United Methodist minister to a trial guaranteed by the Constitution of the United Methodist Church in paragraph 18 of the Discipline as applied to J. Westcoat Sandlin.

The pastor in question has made a request of the Judicial Council as follows:
1. Any and all material regarding John Westcoat Sandlin in the files of:

a. District Superintendent James Corbett of the Lebanon-Reading District.

b. The Board of Ordained Ministry of the Eastern Pennsylvania Conference.

c. The office of the Bishop.

d. Minutes of the Board of Ordained Ministry and the Cabinet.

e. All personnel files maintained under the guidelines of the Council on Finance and Administration adopted November 30, 1989.

This material should include all correspondence, notes and memoranda of telephone conversations with any party. I would specifically request a copy of the statements prepared by Richard Connor of the Board of Ordained Ministry which were read to the Board of Ordained Ministry at its meeting of May 14, 1990 and at the Executive Session of the Annual Conference on June 8, 1990.

This material should also include all correspondence between the Chancellor of the Conference, Mr. Robert Shoemaker, and Sandra Forrester Dufresne, Chairperson of the Board of Ordained Ministry.

The only question before the Judicial Council is the very narrow one presented by the Conference. To grant the request of the pastor would be to expand the scope of the hearing before the Council and is, therefore, denied.

In June, 1990, the Eastern Pennsylvania Conference placed the pastor on Administrative Location in accordance with procedures provided for in  453.3(b) which states:
The Board of Ordained Ministry shall notify the ordained minister, bishop, and district superintendent of the recommendation to administrative location at least sixty (60) days before the opening of the next Annual Conference.

Thereafter, the above cited motion was passed by the Conference. The only issue before the Council is whether  453.3(b) violates  18 of the Discipline concerning the right of a minister to trial, or as stated by the Conference Secretary, "In other words, the question raised is whether 453.3(b) is constitutional." The latter sentence is also an expansion of the motion passed by the Annual Conference.

The case at hand is similar to Judicial Council Decision 485 which involves 449.2 of the 1980 Discipline also concerning administrative location.

Our decision in 485 was:

The provisions for administrative location set forth in subparagraph 449.2 of the Discipline are constitutionally valid. They must be read in relation to subparagraph 449.3 and Par. 2621. So read, they do not deprive a minister who is the subject of an administrative location proceeding of his constitutional right to choose a trial.

A reading of the provisions before us from the 1988 Discipline clearly indicates that the General Conference wished to modify the provisions for Administrative Location. In that modification, it made no provision for giving a minister the right to choose a trial under  18 of the Discipline.

We find that Administrative Location under these articles does not require a complaint. The hearing provided amply protects the pastor's rights to due process. A reading of the Statement of Facts clearly indicates that procedure was followed. Although the minister does not have a right to trial under this procedure 455 of the 1988 Discipline gives the procedure for readmission to the Annual Conference.


Paragraph 453.3(a) and (b) does not violate a pastor's constitutional right to trial under the 1988 Discipline.

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