Fourteen members of Mississippi Boulevard Christian Church, Inc. (MBCC) filed a complaint in the Chancery Court of Shelby County seeking an injunction against the church leadership to prevent the renewal of the pastor's contract and to stop the use of church funds that they opposed. The case was settled through a settlement agreement, which the court incorporated into its dismissal order. Subsequently, the members petitioned the court to hold the church leadership in contempt for violating the settlement terms. The chancellor found the leadership in both civil and criminal contempt, imposing fines and jail time. The church leadership appealed, and upon review, the Court of Appeals determined that the chancery court lacked subject matter jurisdiction from the outset, rendering the contempt order void. Consequently, the appellate court reversed the chancellor's ruling and dismissed the case entirely. The factual background reveals that Dr. Frank Thomas was the Senior Pastor of MBCC under a contract that allowed for indefinite service subject to review every three years, with provisions for salary and bonuses, as well as a financial partnership with an organization aimed at supporting his ministry.
In September 2002, Church Leadership initiated negotiations to renew Dr. Thomas' contract, leading to the approval of a new contract effective January 1, 2003. Members filed a lawsuit aiming to prevent Church Leadership from entering into any contract with Dr. Thomas without congregational approval, asserting their rights under the church's constitution and bylaws. They claimed the lawsuit involved property rights, thus granting the court jurisdiction. The Members argued that under Dr. Thomas, the church's financial status deteriorated from a debt-free position with reserves over $2.6 million, leading to reduced tithes and reliance on reserves. They contended that bonuses paid to Dr. Thomas lacked proper justification based on performance goals. Additionally, they highlighted a lack of accounting for $90,000 contributed to a partnership initiative called Hope for Life. The Members sought an injunction to prevent new contracts without their vote, demand accountability for the funds, and verify the legitimacy of bonuses. In response, Church Leadership arranged a special election on December 15, 2002, allowing the congregation to vote on Dr. Thomas' retention and proposed constitutional amendments regarding the annual review process. The congregation ultimately voted to retain Dr. Thomas and against annual reviews. Dissatisfied with the election outcome, the Members submitted an amended complaint for injunctive relief and derivative action.
The amended complaint reiterated the injunctive relief sought in the original complaint, highlighting that the Members' property rights were not addressed in the election. It also included a derivative claim against Dr. Thomas and the Church Leadership for misappropriating church funds. On the same day, the Members filed a contempt petition, alleging violations of a prior court order that prohibited harassment and retaliation. The Church Leadership responded, asserting that the court lacked subject matter jurisdiction due to the ecclesiastical nature of the claims.
During a hearing on the contempt petition, the parties negotiated a settlement, which was finalized on August 1, 2003, leading to a dismissal of the case with prejudice. However, some Members were later excommunicated, and they filed additional contempt petitions for violations of the settlement agreement, settling all but one. The chancellor found Dr. Thomas and the Church Leadership in civil and criminal contempt on August 13, 2004, imposing sanctions despite the Appellants' claims of lack of jurisdiction.
The Appellants appealed, primarily contesting the contempt ruling, while the Appellees questioned the court's failure to restore their membership rights. The court identified the central issue as the initial subject matter jurisdiction and concluded that the chancery court lacked jurisdiction, leading to a reversal of the contempt ruling and a complete dismissal of the case. The chancellor had claimed authority based on the breach of contract aspect, but this was ultimately found to be unfounded.
Appellants contend that entering the settlement agreement did not waive their First Amendment rights and argue that the chancery court lacked subject matter jurisdiction over the contempt petition, as it required the chancellor to address ecclesiastical matters. In contrast, the Members assert that incorporating the settlement agreement into the court's dismissal order transformed it into a court order, making any subsequent violations grounds for a contempt petition. The term ‘contempt of court’ encompasses various actions, and historically, courts possessed broad powers to address contempt, leading to legislative regulation of such powers. Current statutes limit courts’ contempt authority to specific cases, including willful disobedience of court orders. For the court to find the Appellants in contempt, it must establish a violation of a specific court order. It is crucial that contempt cannot be imposed without a clear violation of an order from a court with proper jurisdiction. Settlements are viewed as contracts, and their enforceability is governed by contract law, emphasizing that resolution through agreements is encouraged to prevent protracted litigation.
A consent judgment reflects the agreement of the parties rather than a court's reasoned decision, as established in Harbour and Van Donselaar. While a signed settlement agreement is enforceable like a contract, it does not become a court judgment until approved by the trial judge. Courts retain the inherent power to enforce settlement agreements, as noted in multiple cases.
Subject matter jurisdiction is crucial for a court to render valid judgments, and cannot be waived or conferred by party consent. The appellate court must assess jurisdiction whether or not it was raised on appeal, per Tenn. R. App. P. 13(b). The lack of subject matter jurisdiction can be identified at any point in the proceedings by either party or the court itself. This principle applies universally across court levels, as stated in various cases.
The excerpt also references the First Amendment, highlighting its applicability to the states through the Fourteenth Amendment, emphasizing the constitutional implications of jurisdictional issues.
Tennessee courts maintain a longstanding principle that civil courts lack jurisdiction over internal ecclesiastical matters of churches, as established in cases such as Ausley v. Shaw and Lewis v. Partee. The First Amendment and Article I, Section 3 of the Tennessee Constitution limit civil court involvement in religious disputes. Civil courts are restricted to adjudicating civil and property rights, having no ecclesiastical jurisdiction, as noted in Nance v. Busby. However, civil courts may engage in ecclesiastical matters if they are incidental to property rights, as seen in various case law, including Edmondson v. Church of God and Church of God in Christ, Inc. v. Middle City Church of God in Christ. When courts do intervene in ecclesiastical disputes, they must do so using neutral legal principles and only as necessary to resolve civil or property issues.
In the case at hand, church members sought to prevent leadership from finalizing a new employment contract with Dr. Thomas until a congregation vote could occur regarding his retention as Senior Pastor. The church leadership agreed to facilitate a special election, but the chancellor took over the process by drafting ballots, notifying the congregation, and appointing a special master to oversee the election, including the presence of sheriff's deputies. The selection and termination of clergy are typically ecclesiastical matters outside civil court purview, as reinforced by precedent in Mason v. Winstead, which addressed similar church governance issues.
The pastor's use of "objectionable language" led to discord within the church, prompting six trustees to file a complaint in chancery court for an injunction to prevent the pastor from conducting church services. The chancellor ordered a congregational vote on the pastor's retention, which resulted in a unanimous dismissal. The supreme court determined that the chancellor's actions exceeded the court's jurisdiction, as the removal of a pastor is an ecclesiastical matter reserved for church tribunals, not civil courts. The court found that the chancery court lacked subject matter jurisdiction over the members' complaint, which attempted to assert jurisdiction by framing the issue as involving property rights related to church funds. However, the court referenced a precedent indicating that church members have no property rights in their contributions, thus affirming that the mere claim of property rights does not grant civil courts jurisdiction over religious disputes. The absence of subject matter jurisdiction rendered the chancery court’s orders void, as any judgment made without jurisdiction is a nullity. The court emphasized that it is the responsibility of courts to assess their own jurisdiction, and in this case, the only proper action would have been to dismiss the suit.
Disobedience of a court order that is void or issued without jurisdiction does not constitute contempt. Conversely, disobedience of an erroneous order issued by a court with proper jurisdiction does constitute contempt. An injunction order must be followed unless it is void on its face due to the issuing judge's lack of jurisdiction, regardless of its correctness, until it is properly challenged or dissolved. The chancery court's finding of contempt was erroneous because the underlying order was deemed void. Consequently, if the trial court lacked subject matter jurisdiction, the case must be dismissed. The court reversed the contempt ruling, dismissed the case entirely, and found the issue of reinstatement to the membership rolls moot. Costs of the appeal are to be borne by the Appellees, Melvin Foster and others, and execution may follow if necessary. An earlier order concerning a stay pending appeal was vacated, and the bonds previously posted were released.
