Memorandum Number 1522

Statement of Facts

This matter arose from the decisions of the Board of Ordained Ministry, Conference Relations Committee, Administrative Review Committee, and clergy session of the Western North Carolina Annual Conference to discontinue the provisional membership of Rev. Jason Smith [hereinafter the Appellant] in 2025. The Southeastern Jurisdiction Committee on Appeals [hereinafter SEJCOA] affirmed on November 12, 2025. Within thirty days, the Appellant filed Notice of Appeal with the Judicial Council.

The full text of the SEJCOA decision sent on November 19, 2025, is as follows:

Dear Mr. Smith,

Thank you for your presence before our Committee on Wednesday, November 12, 2025. Having reviewed all the materials and processes leading to the matter at hand, and having discerned the spoken testimony by both parties before us, we adjudicate a denial of your appeal.

We do not believe there to be violations of fair process or errors of church law as to vitiate the decisions of the Administrative Review Committee of the Western North Carolina Annual Conference, and all processes and entities under its purview.

Respectfully submitted,

Rev. Emily Kincaid

Chairperson

Southeastern Jurisdiction Committee on Appeals

Digest

Per Judicial Council Memo 1373, clergypersons are “entitled to an administrative appellate decision expounding the facts and grounds relied upon that allows him [sic] to prepare and bring his [sic] case before the Judicial Council.”

The SEJCOA failed to explain how it reached its decision that it does “not believe there to be violations of fair process or errors of church law as to vitiate the decisions of the Administrative Review Committee of the Western North Carolina Annual Conference, and all processes and entities under its purview” in regard to the Smith appeal. 

The decision of the SEJCOA does not meet the requirements for a decision by a committee on appeals. As the Judicial Council stated in Decision 1373:

Without a well-reasoned appellate opinion that includes the facts, procedural history, legal authorities, and analysis of the case, the Appellant cannot understand the ruling's rationale and adequately prepare his appeal, nor can the Judicial Council properly review and rule on the merits of his case. At a minimum, the SEJCOA must separately address each of the five grounds alleged by Appellant to have violated fair process.

In addition, in its review of this matter before deciding that a remand to the SEJCOA is required, the Judicial Council notes “[a]ppeals shall be heard by the proper appellate body unless it shall appear to the said body that the appellant has forfeited the right to appeal … by withdrawal from the Church …” ¶ 2719.4c. An appeal can also be forfeited for failure to submit a timely appeal.

¶ 2719.4a. Moreover, ¶ 2719.4d provides that “[t]he right to appeal, when once forfeited by neglect or otherwise, cannot be revived by any subsequent appellate body.” On its own motion and in consideration of whether it has jurisdiction in this appeal, the Judicial Council also directs the SEJCOA to determine whether the right of appeal has been forfeited. 

The case is remanded to the SEJCOA for a new ruling within three months from the date of this Memorandum.

Jurisdiction

The Judicial Council has jurisdiction pursuant to The Book of Discipline of the United Methodist Church, 2020/2024 [hereinafter The Discipline], ¶¶ 2719.3 and 2719.4.