Ruffin v. Temple Church of God in Christ, Inc.

749 A.2d 719 (2000)

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Ruffin v. Temple Church of God in Christ, Inc.

District of Columbia Court of Appeals
749 A.2d 719 (2000)

Facts

Temple Church of God in Christ, Inc. (Temple) (defendant) had one pastor, founding Pastor Samuel Kelsey, for around 70 years, from 1923 to 1992. Because Pastor Kelsey was ailing, in 1992, Frank Morris was appointed as copastor in front of the board, the congregation, and attorney Thomas Ruffin (plaintiff) and was given full authorization to operate the church. Temple considered its pastors to be chief executive officers who were authorized to lead the church as they deemed appropriate. Not long after Morris’s appointment, he and the board clashed over fiscal issues. Morris then entered into a contract with attorney Ruffin to help resolve the conflict, draft new bylaws, and so forth. However, when Ruffin submitted an invoice for his legal fees in the amount of $8,000, Temple did not pay the bill, asserting that only the board had authority to enter into contracts and that the board had not authorized nor given the appearance of authorizing Pastor Morris to enter into a contract with Ruffin. Yet Pastor Kelsey had entered into significant contracts over the course of 70 years without board approval. Ruffin filed suit for payment for his services. The case went to trial, and the jury was instructed that if Ruffin or Pastor Morris reasonably thought Pastor Morris had the authority to make a contract on Temple’s behalf, then Temple would be liable. The jury’s verdict was in Ruffin’s favor. However, Temple filed a motion for judgment as a matter of law, which the trial judge granted because he felt that the conflict between the board and Pastor Morris, of which Ruffin was aware, meant that no reasonable jury would determine that Pastor Morris had implied authority. Implied authority existed if an agent’s action was incidental to conduct the agent was authorized to take and could be inferred based on the circumstances. Ruffin appealed.

Rule of Law

Issue

Holding and Reasoning (Steadman, J.)

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