Williams v. Wilson, 349 S.C. 336

Summary

The South Carolina Supreme Court reviewed a dispute concerning governance of The Christian Church of North Myrtle Beach, including the authority to dismiss its preacher and elect trustees. The court held that the church was congregational, that the trustees' dismissal of the preacher was a nullity, and that the congregation had authority to elect trustees. It nevertheless reversed the election ruling because the special congregational meeting was not properly noticed under the church bylaws.

Holdings

1. The church was a congregational church in which the congregation held ultimate authority over church matters. The trustees failed to prove that the church had adopted an alternative form of governance vesting ultimate authority in the trustees.
2. The trustees lacked authority to dismiss Preacher Hall, and their dismissal of him was a nullity.
3. The congregation had authority to elect trustees, but the election was invalid because the special meeting was not noticed in compliance with the church's bylaws.
4. The court's determination that the church was congregational did not infringe the church's freedom of religion because the evidence, including the founders' intent and the bylaws, supported that determination and did not prevent the church from choosing an alternative form of governance.

Questions Presented

1. Whether the church was governed by a congregational form of church government.
2. Whether the court's determination of the church's form of governance infringed the church's constitutional right to freedom of religion.
3. Whether the special congregational meeting at which the congregation reinstated the preacher and elected new trustees was legally noticed and valid.

Disposition

reversed