Horne v. Andrews

Resolution of a pastor's claims regarding published statements about his failure to follow church discipline, failure to participate in a stewardship campaign and improper use of a church cell phone would require a prohibited inquiry into church doctrine and policy.

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Danny Horne, the pastor of the Ariel Bowen Methodist Church, sued Leonard Andrews, a church official, who allegedly libeled and slandered Horne. Andrews moved for summary judgment, which the trial court granted. In its order, the trial court concluded that it lacked jurisdiction to address the claims. Specifically, the trial court found that it could not address the issue without delving into issues of church governance, “which is prohibited by the Free Exercise Clause of the United States Constitution.” Horne appeals, asserting that the trial court: 1 erred in finding it lacked jurisdiction, 2 applied an incorrect standard of review; and 3 erred in finding that Andrews’ statements were privileged. Horne’s allegations of error lack merit, and we affirm. The record reveals that Horne served as the Senior Pastor of the Ariel Bowen United Methodist Church. In 1999, Andrews became the chairman of the “Pastor Parish Relations Committee.” According to Andrews, his duties included ensuring that the pastor and the congregation were working together for the benefit of the church and “advising Reverend Horne of the membership concerns of” the church.

Apparently, the members of the committee had concerns regarding Horne’s leadership of the church. In February 2001, Andrews, along with four other members of the committee, drafted a document outlining their collective concerns, which they provided to Reverend Martha Forrest, the district superintendent of the North Georgia Conference. The document accused Horne of, among other things: 1 “refusing to follow the United Methodist Discipline”; 2 failing to visit members who were ill or otherwise unable to attend church; 3 failing to participate in the church’s stewardship campaign; 4 failing to meet or communicate with other church leaders; 5 failing to raise funds for the church; and 6 inappropriate behavior. Andrews also wrote a letter to Reverend Forrest and Bishop Lindsey, which stated that “Horne had arrived at church just in time for service.”

Horne v. Andrews

Resolution of a pastor's claims regarding published statements about his failure to follow church discipline, failure to participate in a stewardship campaign and improper use of a church cell phone would require a prohibited inquiry into church doctrine and policy.

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