Knotts v. Williams
| Decision Date | 07 February 1995 |
| Docket Number | No. 24325,24325 |
| Court | South Carolina Supreme Court |
| Parties | William E. KNOTTS, Eugene E. Bolen, Sr., Tom P. Scott, W.O. Schumpert, Ray Watkins, James L. Boyleston, and Frank Fanning, Individually and Representing all First Baptist Members Voting to Terminate the Pastor, Appellants/Respondents, v. Doug WILLIAMS, Byron Reed, First Baptist Church of Williston Board of Deacons, and Other unnamed Defendants, of whom Doug Williams is Respondents, of whom, Byron Reed, First Baptist Church of Williston Board of Deacons, and Other unnamed Defendants are Respondents/Appellants. . Heard |
Wilburn Brewer, Jr. and Marcus A. Manos, both of Nexsen, Pruet, Jacobs & Pollard, Columbia; and Orin G. Briggs, of Irmo, for appellants/respondents.
S. Jahue Moore and Henry Deneen, both of Kirkland, Wilson, Moore, Allen, Deneen & Taylor, West Columbia, for respondent Williams.
Barry H. Johnson, of Johnson, Johnson, Whittle, Snelgrove & Weeks, Aiken; and Eugene C. Fulton, Jr., Columbia, for respondents/appellants.
This litigation is the product of an intra congregational dispute between two factions at First Baptist Church of Williston. The Plaintiffs, led by William E. Knotts, seek to remove Defendant, Pastor Doug Williams. Defendants want the pastor to remain.
This appeal arises from orders issued by the trial judge in an attempt to bring about an arbitrated settlement of this tragic church division.
This case raises important questions about the propriety and limits of governmental intrusion into the internal affairs of a church.
For the reasons below discussed, we conclude that the dispute presented to the Court by the Plaintiffs is not one the Court should be involved in resolving. Accordingly, we vacate the order of the trial judge and direct that this action be dismissed.
For several years, the membership of the First Baptist Church of Williston (Church) has been divided by a dispute as to whether to retain or terminate the services of its pastor, Reverend Doug Williams (Williams).
At one point in the dispute, Williams negotiated a tentative agreement with the Board of Deacons whereby he would resign in return for a severance package. This proposal required approval by the full congregation. A congregational meeting was held on January 24, 1993 to present the proposed resignation and severance package. At this time the total membership of the church was 423. There were 207 members present. As it developed, 108 members voted not to accept Williams resignation, 92 voted to accept and 7 abstained. As a result, Williams was retained as pastor.
During the balance of 1993, the Church continued to be divided over the issue of its pastor. A regular congregational business meeting was scheduled for 7:00 p.m., Sunday, January 9, 1994. A group of members led by William E. Knotts notified the pastor and the Board of Deacons that they intended to present a motion to terminate the pastor's services at this meeting. The Chairman of the Board of Deacons, Byron Reed (Reed), in cooperation with Williams cancelled this meeting.
Notwithstanding the cancellation, eighty-eight members of the congregation met on the evening of January 9, 1994 at the previously appointed hour and eighty-three voted to remove Williams as pastor. Williams and Reed refused to recognize the vote of this meeting contending the meeting had been properly cancelled and further the required 25 percent quorum was not present. On January 20, 1994, William E. Knotts and other individuals who voted to terminate the pastor (Knotts group) brought this action against Reed, First Baptist Church of Williston Board of Deacons, and other unnamed Defendants (collectively the Reed group) and Williams to enforce the January 9, 1994 vote to terminate Williams. The Knotts group also sought a temporary restraining order enjoining the Reed group and Williams from interfering with the Knotts group in the operation of Church.
On January 27, 1994, after a hearing, the trial judge declined to issue a temporary restraining order but persuaded the parties to this lawsuit to enter into mediation. The parties met for several mediation sessions. Thereafter, the mediator submitted a report to the trial judge in which the parties agreed that the congregation would hold a "no-confidence" vote on the pastor. The parties could not agree on which members were eligible to participate in the vote or on the percentage of no confidence votes required to remove Williams. The parties to this lawsuit agreed the trial judge was to determine the percentage vote necessary under the Church's by-laws for the vote and who would be eligible to vote. No agreement, however, was ever approved by the church membership in this regard.
The Reed group argued the by-laws required a three-fourths vote of the congregation for a "no-confidence" vote, while the Knotts group argued a majority vote is needed. On March 16, 1994, after a hearing, the trial judge held a two-thirds vote is required for a "no-confidence" vote under the Church's by-laws. On March 22, 1994, the Knotts group filed a Rule 59 motion for reconsideration in which they contended that the trial court erred in construing Roberts Rules of Order and the Church By-Laws to require a two-thirds vote to terminate Williams. On March 25, 1994, the trial judge denied the motion and affirmed its prior order.
The Knotts group and the Reed group appealed the March 16, 1994 order of the trial judge.
The Reed group argues this Court is without subject matter jurisdiction to dictate procedures for the Church to follow in terminating its pastor. We agree.
Internal disputes among members of a church present some of the most difficult questions involving the limits of governmental intrusion into the religious affairs of its citizens. Freedom of Religion is among the most fundamental of the guarantees of liberty contained in the Bill of Rights. It is no accident that the very first clause of the First Amendment provides:
Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof ...
U.S. Const. Amend. I. Article I, § 2 of the South Carolina Constitution mirrors the federal constitutional provision.
South Carolina has a long history of concern for the protection of religious freedom. The earliest charter given by Charles II to the Lords Proprietors of Carolina in 1663 contains religious freedom provisions recognizing the need to create a governmental climate of toleration for a variety of religious beliefs and practices.
Although developed somewhat incrementally, the creation of laws supporting a climate of religious freedom in South Carolina in Colonial Times as well as the earliest days of Revolution and of Independence was a product in part of adherence to the sanctity of individual expression and in part of pragmatic economic considerations. To the extent that South Carolina as a colony and as a state...
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