Decision Number 977
October 23, 2003
Request From The East Ohio Annual Conference For A Declaratory Decision On The Meaning, Application And Effect Of ¶ 315.6 Of The 2000 Discipline And Whether The Entire Educational Requirements For Election To Probationary Membership And Commissioning Are Set Forth In That Paragraph.
Digest
A local pastor may fulfill the educational requirements for probationary membership and commissioning when they have completed the requirements enumerated in ¶ 315.6 of the 2000 Discipline, and such requirements do not include completion of a bachelor's degree. Thus, a person seeking election to probationary membership and commissioning who is a local pastor must fulfill ¶¶ 315.1, 315.2, and 315.6-14.
Statement of Facts
On June 14, 2003, the East Ohio Annual Conference adopted a motion requesting a declaratory decision from the Judicial Council:
[R]elative to the meaning, application and effect of Paragraph 315.6 of the 2002 [sic] book [sic] of Discipline. Specifically, does that paragraph identify the entire educational requirements for a local pastor seeking to become a probationary member leading to ordination as an elder? Further, is it appropriate for an Annual Conference to also impose the requirements of Paragraph 315.3?
Jurisdiction
The Judicial Council has jurisdiction under ¶ 2610 of the 2000 Discipline.
Analysis and Rationale
Paragraph 315 of the 2000 Discipline addresses the Qualifications for Election to Probationary Membership and Commissioning. In its subparagraphs, the paragraph outlines various requirements for a person to be eligible for election to probationary membership and commissioning. Paragraphs 315.1 and 315.2 address the requirement that the person be a certified candidate for a defined period of years and that the person has served in ministry for a minimum number of years. All persons seeking election to probationary membership and commissioning must comply with these candidacy and service requirements. Paragraphs 315.7-14 also address requirements that are applicable to all persons seeking election to probationary membership or commissioning.
Paragraphs 315.3 and 315.4 outline the undergraduate and graduate educational requirements for a person seeking election to probationary membership and commissioning. Paragraph 315.5 outlines educational requirements with respect to election to probationary membership and commissioning for a person who is pursuing ordination to serve as deacon in full connection as an alternative to the requirements of ¶¶ 315.3 and 315.4 under carefully prescribed parameters. Significantly, ¶ 315.5 expressly provides an alternate route to fulfill the academic requirements (emphasis added) which are outlined in ¶¶ 315.3 and 315.4. The alternate route outlined in ¶ 315.5 expressly requires completion of a bachelors degree.
Here, we are asked to address the meaning, application and effect of ¶ 315.6. Paragraph 315.6 of the 2000 Discipline provides:
Local pastors may fulfill the requirements for probationary membership and commissioning when they have:
a) reached forty years of age;
b) completed the five-year Course of Study for ordained ministry, of which no more than four courses may be taken by correspondence or Internet; and
c) an Advanced Course of Study consisting of thirty-two semester hours of graduate theological study or its equivalent as determined by the General Board of Higher Education and Ministry that shall include the areas of evangelism, and United Methodist history, doctrine, and polity.
Paragraph 315.6 is inartfully worded, creating the ambiguity addressed by the request for declaratory decision. Unlike ¶ 315.5, ¶ 315.6 does not specifically state that it is providing an alternate route to fulfilling academic requirements; however, it is structurally similar to ¶ 315.5 and is clearly intended to provide an alternate route for local pastors who meet its terms. Nothing in the wording of ¶ 315.6 suggests that its purpose is limited to providing an alternate route for satisfaction of academic requirements. Nevertheless, it is plain from the content of ¶ 315 as a whole that a local pastor must comply with the provisions of ¶¶ 315.1, 315.2, and 315.7-14.
Paragraph 315.5, like ¶ 315.6, contains an age requirement before its alternative requirements are applicable. Paragraph 315.5, like ¶ 315.6, contains specific requirements with respect to graduate theological study. However, ¶ 315.6, unlike ¶ 315.5, does not contain an explicit requirement that a local pastor, who has reached forty years of age who is pursuing probationary membership and commissioning, complete a bachelors degree. If the General Conference had intended that local pastors have completed a bachelors degree prior to pursuing election as probationary members and commissioning, it should have explicitly set forth that requirement as it did in ¶ 315.5. It did not do so. The General Conference may not have imposed such a requirement in recognition of the number of alternative means that exist for persons who are local pastors who have reached forty years of age to be prepared educationally for probationary membership and commissioning. The requirements of ¶ 315.6 (b and c) provide substitute educational requirements to the undergraduate and graduate requirements of ¶¶ 315.3 and .4.
Finally, in ¶ 326, the Requirements for Admission to Full Connection and Ordination are set forth. In ¶ 326 (3), the educational requirements for such persons are set forth. Paragraph 326 (3)(c) provides that local pastors seeking admission to full connection and ordination must meet the educational requirements of ¶ 315.6 as an alternative to having received an undergraduate and graduate degree as would otherwise be required by ¶¶ 326(3)(a and b). Paragraph 326 (3)(c) makes no reference to ¶ 315.3.
For the foregoing reasons, and primarily because of the explicit inclusion of completion of a bachelors degree in ¶ 315.5 and the explicit omission of completion of such a degree in ¶ 315.6, we hold that a local pastor fulfills the educational requirements for probationary membership and commissioning when they have completed the requirements enumerated in ¶ 315.6, and that such requirements do not include completion of a bachelors degree. Thus, a person seeking election to probationary membership and commissioning who is a local pastor must fulfill ¶¶ 315.1, 315.2, and 315.6-14.
Paragraphs 315.3 and 315.4 outline the undergraduate and graduate educational requirements for a person seeking election to probationary membership and commissioning. Paragraph 315.5 outlines educational requirements with respect to election to probationary membership and commissioning for a person who is pursuing ordination to serve as deacon in full connection as an alternative to the requirements of ¶¶ 315.3 and 315.4 under carefully prescribed parameters. Significantly, ¶ 315.5 expressly provides an alternate route to fulfill the academic requirements (emphasis added) which are outlined in ¶¶ 315.3 and 315.4. The alternate route outlined in ¶ 315.5 expressly requires completion of a bachelors degree.
Here, we are asked to address the meaning, application and effect of ¶ 315.6. Paragraph 315.6 of the 2000 Discipline provides:
Local pastors may fulfill the requirements for probationary membership and commissioning when they have:
a) reached forty years of age;
b) completed the five-year Course of Study for ordained ministry, of which no more than four courses may be taken by correspondence or Internet; and
c) an Advanced Course of Study consisting of thirty-two semester hours of graduate theological study or its equivalent as determined by the General Board of Higher Education and Ministry that shall include the areas of evangelism, and United Methodist history, doctrine, and polity.
Paragraph 315.6 is inartfully worded, creating the ambiguity addressed by the request for declaratory decision. Unlike ¶ 315.5, ¶ 315.6 does not specifically state that it is providing an alternate route to fulfilling academic requirements; however, it is structurally similar to ¶ 315.5 and is clearly intended to provide an alternate route for local pastors who meet its terms. Nothing in the wording of ¶ 315.6 suggests that its purpose is limited to providing an alternate route for satisfaction of academic requirements. Nevertheless, it is plain from the content of ¶ 315 as a whole that a local pastor must comply with the provisions of ¶¶ 315.1, 315.2, and 315.7-14.
Paragraph 315.5, like ¶ 315.6, contains an age requirement before its alternative requirements are applicable. Paragraph 315.5, like ¶ 315.6, contains specific requirements with respect to graduate theological study. However, ¶ 315.6, unlike ¶ 315.5, does not contain an explicit requirement that a local pastor, who has reached forty years of age who is pursuing probationary membership and commissioning, complete a bachelors degree. If the General Conference had intended that local pastors have completed a bachelors degree prior to pursuing election as probationary members and commissioning, it should have explicitly set forth that requirement as it did in ¶ 315.5. It did not do so. The General Conference may not have imposed such a requirement in recognition of the number of alternative means that exist for persons who are local pastors who have reached forty years of age to be prepared educationally for probationary membership and commissioning. The requirements of ¶ 315.6 (b and c) provide substitute educational requirements to the undergraduate and graduate requirements of ¶¶ 315.3 and .4.
Finally, in ¶ 326, the Requirements for Admission to Full Connection and Ordination are set forth. In ¶ 326 (3), the educational requirements for such persons are set forth. Paragraph 326 (3)(c) provides that local pastors seeking admission to full connection and ordination must meet the educational requirements of ¶ 315.6 as an alternative to having received an undergraduate and graduate degree as would otherwise be required by ¶¶ 326(3)(a and b). Paragraph 326 (3)(c) makes no reference to ¶ 315.3.
For the foregoing reasons, and primarily because of the explicit inclusion of completion of a bachelors degree in ¶ 315.5 and the explicit omission of completion of such a degree in ¶ 315.6, we hold that a local pastor fulfills the educational requirements for probationary membership and commissioning when they have completed the requirements enumerated in ¶ 315.6, and that such requirements do not include completion of a bachelors degree. Thus, a person seeking election to probationary membership and commissioning who is a local pastor must fulfill ¶¶ 315.1, 315.2, and 315.6-14.
Decision
A local pastor may fulfill the educational requirements for probationary membership and commissioning when they have completed the requirements enumerated in ¶ 315.6 of the 2000 Discipline, and such requirements do not include completion of a bachelor's degree. Thus, a person seeking election to probationary membership and commissioning who is a local pastor must fulfill ¶¶ 315.1, 315.2, and 315.6-14.
Sally Brown Geis was absent.