Decision Number 252
Ruling of Bishop James W. Henley in the Florida Annual Conference Concerning the Right of the Annual Conference to Determine the Maximum Amount Which a Local Church May Allow Its Pastor or Pastors as Reimbursement for Travel Expenses.
An Annual Conference is without disciplinary authority to place a limit upon the Quarterly Conferences of its local churches in their determination of amounts to be allowed their pastors as reimbursement for travel expenses.
Statement of Facts
From the Journal of the Florida Annual Conference and other certified documents it appears that the conference at its session in 1959 (Journal, page 100) adopted an action determining a "maximum sum of $600 as a fair limit for the pastor's travel and expense fund." At the Quarterly Conference of St. Luke's Methodist Church in St. Petersburg, Florida, held March 16, 1966, a resolution was presented by its Commission on Stewardship and Finance as follows:
"1. The Commission on Stewardship and Finance, after consultation with the Committee on Pastoral Relations, moves herewith that the Quarterly Conference of St. Luke's Church establish a Fund of $1,000 for the Senior Pastor, and of $500 for the Associate Pastor, from which our ministers shall be reimbursed their actual recorded travel expenses in connection with their duties."
The presiding District Superintendent, C. Eugene West, ruled the resolution out of order because it violated the rule of the Annual Conference referred to above. Whereupon the Quarterly Conference voted to appeal the decision of the District Superintendent to the presiding bishop of the Annual Conference as provided in the 1964 Discipline, Paragraph 362.14.
This action was certified to the Annual Conference and the Judicial Council in a "Certification of Appeal" as follows:
"This certifies that the above Resolution was properly presented and ruled out of order by the District Superintendent in compliance with the action of the Florida Annual Conference ('59 Journal, p. 100) fixing an arbitrary limit of $600 for travel allowances.
"The Quarterly Conference thereupon by unanimous vote appealed the ruling of the Superintendent to the Presiding Bishop for an episcopal ruling on Paragraph 148 which vests the power and directs the Quarterly Conference 'to fix the salary and other remuneration of the pastor, or pastors' so that St. Luke's Church could pay the actual, validated travel expenses of its pastor even though in excess of the limit fixed by the Annual Conference."
Signed by C. Eugene West, District Superintendent Ellen Smith, Recording Steward, and Albert Dale Hagler, Pastor
In response to this appeal Bishop Henley reported his decision to the Annual Conference as follows:
"Paragraph 148 of the Discipline provides that the Quarterly Conference 'shall fix the salary and other remuneration of the pastor or pastors.' In the Judicial Council Ruling #213 is an amplification of this Disciplinary paragraph which states: 'The Judicial Council holds that under the legislation cited above the authority to fix the salary and other compensation of the pastor rests solely with the Quarterly Conference.'
"A 1947 Ruling by Bishop William C. Martin and upheld by the Judicial Council states that 'an allowance for travel expenses to pastors is not to be regarded as supplementary compensation tending to defeat proportional payment . . . provided always that such item represents an actual expense for the purpose stated and is not a cover-up for additional salary paid to the pastor.' The implications inherent in this ruling are that travel expenses (which may be allowed by the Quarterly Conference in whole or in part) are not compensation but in fact reimbursement for the expenses entailed in the minister's pursuance of his pastoral duties.
"It is therefore to be concluded that the legislation of the Florida Annual Conference of 1959 setting a 'maximum' sum of $600 as a limit for the pastor's travel and expense is in conflict with the Discipline and is therefore illegal."
The Judicial Council has jurisdiction in this matter under Paragraph 909 of the 1964 Discipline.
Analysis and Rationale
Paragraph 145.2 of the 1964 Discipline provides that the Committee on Pastoral Relations of a Quarterly Conference shall "consult with the pastor about adequate provision for his salary, housing, and travel and other expenses and recommend to the Commission or Commissions on Stewardship and Finance and the Official Board or Boards the amounts agreed upon."
Paragraph 215.2 of the 1964 Discipline requires the Official Board of the local church to "recommend to the Quarterly Conference at the session next preceding the Annual Conference the salary and expenses of the pastor, and of the associate pastor or pastors, if any."
Paragraph 148, referred to in Bishop Henley's ruling and by the Judicial Council in its Decision No. 213, provides that the Quarterly Conference "shall fix the salary and other remuneration of the pastor or pastors." By reference to the above quoted provisions of the Discipline, it seems evident that the broad term, "other remuneration," is intended to include reimbursement for travel expenses of pastor or pastors.
In Decision No. 213 we held that "the authority to fix the salary and other compensation of the pastor rests solely with the Quarterly Conference."
In the same decision the Judicial Council pointed out that "the Annual Conference has disciplinary authority to make its own procedural rules but in doing so may not invade the authority granted to other bodies by the Constitution or by the legislation of the General Conference."
We hold that the action of the Florida Annual Conference fixing a "maximum sum of $600 as a fair limit for the pastor's travel and expense fund" is such an invasion of the powers and authority of the Quarterly Conference granted to it by the General Conference.
It is the decision of the Judicial Council that an Annual Conference is without disciplinary authority to place a limit upon the amount which may be allowed by a Quarterly Conference as reimbursement for travel expense for its pastor or pastors.
The ruling of Bishop James W. Henley in this case is hereby affirmed.