Rentz v. Werner

156 Wash. App. 423
CourtCourt of Appeals of Washington
DecidedJune 7, 2010
DocketNo. 62848-8-I
StatusPublished
Cited by5 cases

This text of 156 Wash. App. 423 (Rentz v. Werner) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rentz v. Werner, 156 Wash. App. 423 (Wash. Ct. App. 2010).

Opinion

Dwyer, C.J.

¶1 Where the subject matter of a church-related dispute concerns the church’s ecclesiastical affairs, the First Amendment requires a civil court to abstain from adjudicating the dispute. The claims herein at issue con[426]*426cern the power of a church minister and the church’s membership policies, all issues that are recognized as being at the core of a religious organization’s ecclesiastical affairs. Accordingly, we affirm the trial court’s summary judgment order of dismissal.

I

¶2 This case arises out of a dispute between former members of the Aquarian Foundation, a spiritualist church headquartered in Seattle, Washington, with branches in several other locales, and the church’s current minister concerning the church’s internal governance and membership policies. The church was founded in 1955 by Keith Milton Rhinehart. In 1966, the church filed articles of incorporation with Washington’s secretary of state1 and adopted bylaws governing its internal affairs. The underlying dispute in this case concerns the interpretation of these governing documents as they relate to the minister’s power and authority in church affairs. Thomas Rentz and other former church members2 contend that Jann Werner, the current minister and president, abused her official powers by wrongfully expelling them and other individuals from the church.

¶3 Together, the church’s articles of incorporation and its bylaws set forth the purpose of the church as being an organization dedicated to religious study and public worship. The governing documents indicate that the church was formed to conduct classes on the “phenomenon of spirit return” and to conduct “seances” and “spirit communions.” The bylaws provide that “THE GOLDEN RULE — in the true spirit of Matthew 22:37-39, must be [the church [427]*427ministry’s] standard in thought, word, feeling and action in all things relating to Church and [the ministry’s] activities therein.”

¶4 The church’s governing documents also establish the church’s organizational structure. It consists of five parts: (1) the church membership, (2) the board of directors, (3) three officers, (4) the position of minister or ecclesiastical head, and (5) various “workers” responsible for conducting some of the church’s religious activities.

¶5 With respect to the qualification for, and terms of, membership, the governing documents generally provide that membership in the church “shall be open to [all persons] who desire to study the phenomenon of spirit return, subscribing to the teachings thereof.” To become a member of the church, individuals must complete an application form requiring them to profess their belief in certain doctrinal teachings of the church. In addition, applicants are required to affirm that they will adhere to, and not attempt to change, church dogma established by Rhinehart. They must “solemnly swear” that they will “support the existing traditions, policies, and teachings of the church as established and evolved by its founder,” Rhinehart. Applicants must promise never to “attempt... to alter or change the sacred teachings, policies or traditions” of the church “except that which is endorsed by” Rhinehart. Furthermore, applicants must acknowledge that, upon Rhinehart’s “retirement or transition or cryonization, the teachings and policies as evolved by him or through him shall forever rule the church.” The bylaws provide that “[o]nly members of this Church shall elect the Board of Directors ... or vote on other matters which may arise or may offer such suggestions to the Board of Directors as may in their judgment seem advisable for the good of the Church.”

¶6 The governing documents provide that a five-member board of directors shall manage the church’s “secular affairs.” Pursuant to the bylaws, at the church’s biennial meeting, the church membership shall elect fellow members to two-year terms on the board “upon recommendation [428]*428of the ecclesiastical head” or minister. In addition, the bylaws provide that

[t]he Minister, Dr. Keith Milton Rhinehart, shall be the permanent President of the Board as long as he may live, unless he voluntarily resigns, and may exercise a vote only in case of a tie. In the event the Minister elects to serve as a permanent member of the Board and not as President, then the Board shall elect a President to serve in accordance with these By-Laws with full voting powers.

Further, the board is responsible for setting the minister’s salary, approving contractual undertakings between the church and external parties, and amending the bylaws.

¶7 The church’s three officers include a president, secretary, and treasurer. According to the bylaws, each officer is to be elected by the church membership to a two-year term at the church’s biennial meeting. The president’s duties consist of “presiding] over all meetings of the Board [of Directors] and all meetings of the Membership.” The secretary is responsible for keeping “an accurate record and minutes of all business meetings” and for chairing a committee responsible for maintaining the church’s membership rolls. The treasurer is responsible for keeping the church’s financial records and arranging for an annual audit. Although the treasurer is not required to be a member of the board of directors, both the president and the secretary are required by the bylaws to sit on the board.

¶8 The church’s governing documents specify that the church’s minister shall manage its “ecclesiastical affairs.” The bylaws do not set forth a procedure for the selection of the minister. However, the articles of incorporation provide the following:

The ecclesiastical affairs of this Church shall be managed by its Minister, Keith Milton Rhinehart, so long as he is living or until his voluntary resignation, or by such other person as he may appoint or designate; provided, however, that should he become unable, or unwilling upon voluntary resignation, to so appoint or delegate, then in that event, the Board of Directors [429]*429shall appoint a successor Minister to manage the ecclesiastical affairs of the Church or a temporary Minister to manage the ecclesiastical affairs of the Church until Keith Milton Rhinehart has become capable of resuming his duties.

According to the bylaws, the minister shall have the power to control the “character and method” of the church’s services and all its spiritual work and to select and appoint all church committees and “helpers” in the church’s ecclesiastical work.

¶9 The bylaws provide that those “helpers” whom the minister may select include “ministers,” “spiritual healers and practitioners,” “teachers,” and “mediators.” Individuals may be eligible for ordination to those positions “upon action by the Board,” after passing an examination as to their “moral, intellectual and educational fitness.” Further, the bylaws specify that the “examiner shall be the ecclesiastical head of the Church.”

¶10 From the date that he founded the church in 1955 until his death in 1999, Rhinehart served as the Aquarian Foundation’s sole minister and president. The parties agree that Rhinehart exerted uncontested control over the church during his tenure. However, they disagree as to why Rhinehart was able to do so. Rentz maintains that Rhinehart was able to exercise complete control over the church without facing dissent from among the membership because he was charismatic and persuasive.

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Cite This Page — Counsel Stack

Bluebook (online)
156 Wash. App. 423, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rentz-v-werner-washctapp-2010.