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A UMNS file photo by Mike DuBose In 2004, the Rev. Benjamin Boni (right) — later elected a bishop — and the Rev. R. Randy Day announce the Protestant Methodist Church of Cote d'Ivoire is joining the denomination.

By Neill Caldwell*

CINCINNATI (UMNS)  — The top court of the United Methodist Church has ruled that the 2004 General Conference was within its authority to limit the United Methodist Church of Cote d'Ivoire (Ivory Coast) to two General Conference delegates.

Meeting Oct. 25-28, the Judicial Council made it clear that the action by the 2004 General Conference "was not a final act of admission" of the Methodist Church of Cote d'Ivoire into the United Methodist Church. "By its terms, the legislation contemplated that further action would be taken by the 2008 General Conference," the council said in its ruling.

But the Judicial Council said that action by the 2004 General Conference "has led the church into a veritable no-man's land where the questions are many and the answers are few," and would require additional legislative work in 2008 to complete the admission process.

The 2008 General Conference will meet April 23-May 2 in Fort Worth, Texas.

The ruling cites Paragraph 502 of the Book of Discipline as authority for a General Conference to provide for the composition and allocation of its delegates.

Conference deviated

The council also scolded the 2004 General Conference, saying its action "deviated" from the Discipline. "The General Conference cannot function effectively as a committee of the whole," the ruling said.

On the final morning of the 2004 General Conference, delegates considered a recommendation from the Commission on Central Conference Affairs proposing the addition of Cote d'Ivoire to the West Africa Central Conference. The committee's recommendation was a referral so that the West Africa Central Conference, the Commission on Central Conference Affairs and the church's Board of Global Ministries could work together on the entry of Cote d'Ivoire into the denomination.

Instead a substitute motion was offered from the floor that included four separate actions. Those included a measure "that Cote d'Ivoire be added to the West Africa Central Conference and the West Africa Central Conference is authorized to elect a bishop to serve as episcopal leader in a new Cote d'Ivoire Episcopal Area."

"The Cote d'Ivoire Episcopal Area is responsible to set up and fully fund its own episcopal fund during the 2005-2008 quadrennium with no funding from either GCFA (General Council on Finance and Administration) or the Episcopal Fund of the United Methodist Church," the substitute motion said.

"Further, the annual conference within the Cote d'Ivoire Episcopal Area shall be represented at the 2008 General Conference with two delegates (one lay and one clergy).

"Finally, the Commission on Central Conference Affairs, in consultation with the Council of Bishops and the Connectional Table, shall bring enabling legislation to the 2008 General Conference to include the Cote d'Ivoire Episcopal Area in the Episcopal Fund of the United Methodist Church."

This substitute motion passed.

Not a full member

Both the 2004 and 2000 Disciplines set out the procedures by which churches may join the United Methodist Church, the Judicial Council said.

"The original resolutions contemplated following the provisions of Paragraph 537 of the 2000 Discipline. The substitute motion offered referred to Paragraph 535.3 of the 2000 Discipline. The aftermath of the harried discussion and precipitous action on the substitute motion has led many to believe that the Church of Cote d'Ivoire has joined the United Methodist Church under the provisions of Paragraph 575. Such a process has not been achieved. In fact, none of the processes that lead to church affiliation were perfected by the General Conference action. ...

"The substitute (motion) adopted anticipates that the 2008 General Conference will consider further legislative action to include Cote d'Ivoire into the Episcopal Fund," the council's ruling continues. "The remaining formalities of affiliation or admission should be completed by the agencies to whom the responsibility is assigned in time for presentation to and perfection by the 2008 General Conference. Once the process of joining the United Methodist Church is fully achieved, Cote d'Ivoire would have the right to full representation in its delegations to the 2012 and succeeding General Conference sessions."

Dissenting opinion

In a signed dissent, four council members — Rodolfo Beltran, Rev. Dennis Blackwell, the Rev. Keith Boyette and Dr. James Holsinger — said they believed that the action of 2004 General Conference was unconstitutional. "The General Conference, and now this Judicial Council, has acted in a way which substantially disenfranchises what statistically is the largest annual conference in the United Methodist Church. And applying the logic of our colleagues, it creates a situation where other annual conferences can likewise be denied proportionate representation so long as they are provided with the minimal representation of one lay and one clergy delegate. This is a dangerous precedent and one which reflects poorly upon the global nature of our church. 

"Four of the seven members of the Judicial Council present and voting (at) our fall 2006 session have voted to hold the action of the 2004 General Conference in allocating two clergy delegates to the Cote d'Ivoire Episcopal Area unconstitutional. Paragraph 2608 of the 2004 Discipline requires that '(a)n affirmative vote of at least six members of the council shall be necessary to declare any act of the General Conference unconstitutional.'

"Following the conclusion of the 2004 General Conference, the West Africa Central Conference elected Rev. Benjamin Boni to the episcopacy of the United Methodist Church, as it was authorized to do by the action of the 2004 General Conference and by Paragraph 543.2 of the 2004 Discipline. The West Africa Central Conference then assigned Bishop Boni to the Cote d'Ivoire Episcopal Area, composed of the Cote d'Ivoire Annual Conference, as it was authorized to do by the action of the 2004 General Conference and by Paragraphs 543.5 and 543.8 of the 2004 Discipline.

"As a result of the action by the 2004 General Conference and the subsequent meeting of the West Africa Central Conference, the Cote d'Ivoire Annual Conference came into existence and was immediately entitled to all of the rights and privileges of any annual conference in The United Methodist Church," the dissent said.

Oral arguments

In oral arguments for the case, Sam Dixon of the United Methodist Board of Global Ministries told council members that the Methodist Church of Cote d'Ivoire is a strong church with a long history that is "ready to fully participate in United Methodist activities around the world." Cote d'Ivoire "should be brought into our family with open arms," he said.

Dixon said the latest survey numbers sent to the General Council on Finance and Administration by the Board of Global Ministries tallied 579,000 members in the Methodist Church of Cote d'Ivoire, but only 123 ordained clergy and around 500 local pastors. Three districts there are involved in a civil war, making an accurate count difficult, Dixon said.

Jim Allen, GCFA general counsel, said no one is really sure how many members and pastors Cote d'Ivoire has and that more research is needed.

Greg Stover of the Commission on Christian Unity and Interreligious Concerns said that while getting accurate information from central conferences is often a challenge, that fact should not prevent representation. Central conferences are regional units of the church in Africa, Asia and Europe.

Judicial Council members Mary A. Daffin and Shamwange P. Kyungu were absent from the meeting.

*Caldwell covers the Judicial Council for United Methodist News Service and is editor of the Virginia Advocate of the Virginia Annual Conference in Richmond.

News media contact: Tim Tanton, Nashville, Tenn., (615) 742-5470 or newsdesk@umcom.org.

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Resources

Judicial Council Decisions

Decision No. 1032

Rules of Practice and Procedure