By Rev. Dr. Luan-Vu “Lui” Tran, Ph.D.
I. Episcopal Accountability as Sacred Trust
Complaints against bishops occupy one of the most sensitive areas of United Methodist law. Bishops are not merely institutional executives. They are ordained elders consecrated to the episcopal office and entrusted with the general superintendency of the Church. Their ministry flows from the gospel, from the Church’s theology of ordination, and from the responsibilities assigned to the episcopal office in the Book of Discipline 2020/2024 (“Discipline”).
The Discipline states that episcopal leadership “shares with all other ordained persons in the sacred trust of their ordination,” and that when a bishop violates this trust or is unable to fulfill appropriate responsibilities, continuation in episcopal office is subject to review, with the primary purpose of just resolution, justice, reconciliation, and healing. Discipline, ¶ 413.1.
This means that bishop accountability is neither optional nor merely political. It is part of the Church’s covenantal legal order. The same Discipline that protects the episcopal office also provides procedures for review, complaint, fair process, administrative action, judicial complaint, trial, appeal, and healing. The governing provisions begin with Discipline, ¶¶ 412–413, but they must be read together with the constitutional provisions on episcopal supervision and the judiciary, the fair-process provisions in Discipline, ¶¶ 362 and 2701, the judicial complaint provisions in Discipline, ¶¶ 2702–2707, trial and appeal provisions in Discipline, ¶¶ 2711–2717, and administrative review provisions such as Discipline, ¶¶ 422 and 540.
The January 2026 Errata/Addendum is also essential. It directs that, throughout the nonconstitutional portions of the Discipline, “central conference” should be replaced with “regional conference,” except in the Constitution and in specified references involving the Standing Committee on Regional Conference Matters Outside the United States. Therefore, this article uses “regional conference” where the printed 2020/2024 Discipline may still say “central conference,” unless the constitutional context requires otherwise.
II. Evaluation Under ¶ 412 and Complaint Under ¶ 413
The first distinction is between episcopal evaluation and episcopal complaint. Discipline, ¶ 412 governs review and evaluation of bishops. In its review of the work, character, and official administration of bishops, the jurisdictional or regional conference committee on episcopacy must establish and implement processes that provide, at least once each quadrennium, a full and formal evaluation of each active bishop. That evaluation includes self-evaluation, assessment by episcopal peers, and comment from persons affected by the bishop’s superintendency, such as cabinets, lay leaders, and directors of agencies served. Discipline, ¶ 412.
This evaluation process is supervisory, formative, and corrective. It is not itself a complaint process. The College of Bishops must consult and cooperate with the committee on episcopacy to schedule and facilitate evaluations and to address issues that arise. Where issues need to be addressed, the committee on episcopacy must ensure that the respective College of Bishops is informed and receives quarterly reports showing that the bishop is appropriately addressing the identified concerns. Discipline, ¶ 412.
A complaint under Discipline, ¶ 413 is different. A complaint is the formal disciplinary mechanism for addressing allegations concerning a bishop’s effectiveness, competence, misconduct, unsatisfactory performance of ministerial duties, or one or more chargeable offenses listed in Discipline, ¶ 2702. Discipline, ¶ 413.2. An evaluation may identify concerns, but it cannot be used to remove a bishop, impose discipline, adjudicate guilt, or bypass the procedures required for complaints. That distinction is required by the principle of legality, which the Judicial Council has grounded in JCD 96, JCD 1341, and JCD 1366.
III. Definition and Filing of a Complaint Against a Bishop
Discipline, ¶ 413.2 provides that any complaint concerning a bishop’s effectiveness, competence, or one or more offenses listed in Discipline, ¶ 2702 shall be submitted to the president of the College of Bishops in that jurisdictional or regional conference. If the complaint concerns the president, it is submitted to the secretary of the College of Bishops. Discipline, ¶ 413.2.
A complaint against a bishop is defined as “a written statement claiming misconduct, unsatisfactory performance of ministerial duties, or one or more of the offenses listed in ¶ 2702.” Discipline, ¶ 413.2. This wording should be cited carefully. The clergy complaint provision in Discipline, ¶ 363.2 refers to a “written and signed statement,” but Discipline, ¶ 413.2, governing bishops, refers to a “written statement.” Practically, the complaint must contain enough information to allow fair notice, identify the alleged misconduct or performance concern, and allow the proper supervisory process to begin. But citation to bishop complaints should not silently import wording from Discipline, ¶ 363.2 that is not in Discipline, ¶ 413.2.
The chargeable offenses listed in Discipline, ¶ 2702.1 include immorality; crime; disobedience to the order and discipline of The United Methodist Church; dissemination of doctrines contrary to the established standards of doctrine of The United Methodist Church; relationships or behavior that undermines the ministry of another pastor; child abuse; sexual abuse; sexual misconduct; harassment; racial or gender discrimination; fiscal malfeasance; and domestic violence. Discipline, ¶ 2702.1.
IV. Initial Processing and the Supervisory Response
After a complaint is received, the president and secretary of the College of Bishops, or the proper substitutes if the complaint concerns one of them, must consult within ten days with the chair of the jurisdictional or regional conference committee on episcopacy. The chair then appoints one professing member and one clergy member from the committee to participate in the supervisory response. These persons must not be from the same episcopal area, must not be from the episcopal area from which the bishop under complaint was elected or to which the bishop has been assigned, and must not be of the same gender. Discipline, ¶ 413.3.
These structural safeguards are important. They reflect the Judicial Council’s due-process concern that persons and bodies involved in complaint processes must not collapse multiple roles in a way that destroys impartiality. JCD 1366 states that impartiality and independence of decision-making bodies are hallmarks of due process. JCD 689 states that separation of authority and decision-making is integral to United Methodist constitutional law.
The supervisory response itself is pastoral and administrative. It is directed toward just resolution and is not part of any judicial process. Discipline, ¶ 413.3b. It should be carried out confidentially and should be completed within 120 days. Discipline, ¶ 413.3b. A first extension of 120 days is permitted if the supervising bishop and the two appointed committee members determine that an extension will be productive. Discipline, ¶ 413.3b. A second 120-day extension requires the mutual written consent of the supervising bishop, the appointed committee members, the complainant, and the bishop under complaint. Discipline, ¶ 413.3b.
The supervisory response may include persons with qualifications and experience in assessment, intervention, or healing. Others may also be consulted. Discipline, ¶ 413.3b. The process is designed to seek truth, repair harm, protect the Church, and resolve matters justly where possible without prematurely converting every concern into a judicial proceeding.
V. Temporary Suspension During the Supervisory Response
Discipline, ¶ 413.3a authorizes temporary suspension of a bishop during the complaint process when appropriate to protect the well-being of the complainant, the Church, and/or the bishop. The College of Bishops, in consultation with the jurisdictional or regional conference committee on episcopacy, may suspend the bishop from all episcopal responsibilities for a period not to exceed sixty days. Salary, housing, and benefits continue during the suspension. Discipline, ¶ 413.3a.
This suspension is protective, not punitive. It is not a finding of guilt, not removal from office, and not a substitute for the administrative or judicial process. Because the Discipline sets a specific sixty-day limit, the principle of legality requires the Church to observe that limit. JCD 1156 warns that deviations from disciplinary process are themselves violations of the Discipline.
VI. Just Resolution
The supervisory response may include a process seeking just resolution. In such a process, the parties may be assisted by a trained, impartial third-party facilitator or mediator in reaching an agreement satisfactory to all parties. Discipline, ¶ 413.3c. The appropriate persons, including the president of the College of Bishops or the secretary if the complaint concerns the president, should enter into a written agreement outlining the process, including confidentiality. Discipline, ¶ 413.3c.
The January 2026 Errata/Addendum strengthens the just-resolution language in Discipline, ¶ 413.3c by clarifying that the complainant shall be a party to the resolution process, that every effort shall be made to have the complainant agree before the resolution takes effect, and that just resolutions shall state all identified harms and how they shall be addressed by the Church and other parties to the complaint. This aligns bishop complaints with the broader just-resolution theology of Discipline, ¶ 363.
Just resolution is not a shortcut around accountability. It is a disciplined process for repair, truth-telling, accountability, and healing. The written statement of resolution should identify the terms and conditions of the resolution and specify what, if anything, may be disclosed to third parties. Discipline, ¶ 413.3c. If resolution is achieved, the written statement is given to the person in charge of that stage of the process for further action consistent with the agreement. Discipline, ¶ 413.3c.
VII. Outcomes After Supervisory Response
If the supervisory response resolves the matter, the bishop in charge of the supervisory response and the two appointed committee members must monitor fulfillment of the terms of the resolution. They must prepare a report for the full committee on episcopacy and the College of Bishops concerning the outcome of the supervisory process and ensure distribution of the report. Discipline, ¶ 413.3d(1).
If the supervisory response does not resolve the matter, the president or secretary of the College of Bishops may dismiss the complaint with the consent of the College of Bishops and the committee on episcopacy, refer the matter to the committee on episcopacy as an administrative complaint under Discipline, ¶ 413.3e, or refer the matter to counsel for the Church under Discipline, ¶ 2704.1 to prepare a complaint for the committee on investigation. Discipline, ¶ 413.3d(1).
The January 2026 Errata/Addendum clarifies the dismissal language by providing that dismissal is appropriate where the complaint has no basis in law or fact, that reasons must be given in writing, that copies must be placed in the bishop’s file, and that the reasons must be shared with the complainant. This correction matters because dismissal is not merely private disposal of a complaint; it is a formal disposition requiring written reasons and appropriate notice.
VIII. Council of Bishops Intervention
Discipline, ¶ 413.3d creates a second level of accountability when the ordinary College of Bishops process does not move forward. If, within 180 days after receipt of the complaint, the supervisory response has not resolved the matter and the president or secretary of the College of Bishops has not referred the matter as either an administrative or judicial complaint, then the matter moves to the Council of Bishops. The Council of Bishops must develop processes and procedures consistent with the fair-process provisions of the Discipline for adjudicating the complaint, and those procedures must be publicly available when approved. Discipline, ¶ 413.3d(2).
The Council of Bishops may also remove a complaint from the College of Bishops to the Council of Bishops by a two-thirds vote at any time after a complaint is filed, including after a just resolution. Discipline, ¶ 413.3d(4). When a complaint is removed to the Council of Bishops, bishops who have served on committees pertaining to adjudication of the complaint may not participate in subsequent steps in that complaint process. Discipline, ¶ 413.3d(5).
The January 2026 Errata/Addendum corrects the cross-reference in Discipline, ¶ 413.3d(6). The printed text refers to “¶ 413.3.d (v),” but the corrected reference is Discipline, ¶ 413.3d(5). This confirms that active and retired bishops may serve on committees adjudicating complaints against another bishop only subject to the recusal rule in Discipline, ¶ 413.3d(5).
JCD 1484 is the key Judicial Council decision on this portion of Discipline, ¶ 413. The Judicial Council upheld the constitutionality of Discipline, ¶ 413.3d(2) and Discipline, ¶ 413.3d(4), confirming the validity of the Council of Bishops’ role when a matter has not been resolved or referred within 180 days and its authority to remove a complaint from a College of Bishops by two-thirds vote.
IX. Administrative Complaints Against Bishops
A bishop complaint may proceed administratively when it concerns effectiveness, competence, unwillingness or inability to perform episcopal duties, or other matters that do not require judicial processing as chargeable offenses. Discipline, ¶ 413.3e. In that case, the president and secretary of the College of Bishops, or proper substitutes, refer the complaint to the jurisdictional or regional conference committee on episcopacy. Discipline, ¶ 413.3e.
The committee on episcopacy may recommend involuntary retirement under Discipline, ¶ 408.3, disability leave under Discipline, ¶ 410.4, remedial measures, other appropriate action, or dismissal of the complaint. Discipline, ¶ 413.3e. If the committee determines that the matter is serious enough and appears to involve one or more chargeable offenses under Discipline, ¶ 2702, the committee may refer the matter back to the president and secretary of the College of Bishops for referral as a judicial complaint to the committee on investigation. Discipline, ¶ 413.3e.
Administrative complaint processing is governed by fair process. Discipline, ¶ 413.3e expressly incorporates the fair-process protections of Discipline, ¶ 362.2. Those protections include written notice, sufficient detail to allow response, opportunity to be heard, access to records relied upon, prohibition of substantive ex parte communications, and the right to be accompanied by a clergyperson in full connection. Discipline, ¶ 362.2. These protections are not procedural ornaments. They are enforceable requirements of church law.
Administrative review is also relevant. Discipline, ¶ 540 establishes the jurisdictional administrative review committee, which reviews procedures in administrative processes involving bishops. Discipline, ¶ 422 also provides procedures for Council of Bishops action in certain involuntary leave or retirement matters. The January 2026 Errata/Addendum corrects several Discipline, ¶ 422 provisions, including that the Council of Bishops “may affirm or reverse” the committee’s decision and that the respondent has the right to be accompanied by a clergyperson “in full connection.”
X. Judicial Complaints Against Bishops
A judicial complaint against a bishop is appropriate when the allegation involves one or more chargeable offenses under Discipline, ¶ 2702.1. The judicial pathway begins through Discipline, ¶ 2704.1. A complaint against a bishop alleging a chargeable offense is submitted to the president and secretary of the College of Bishops. The president provides a copy to the respondent bishop, notifies active bishops of the existence and nature of the complaint, and refers the matter to an elder in full connection within the same jurisdictional or regional conference to serve as counsel for the Church. Discipline, ¶ 2704.1.
Counsel for the Church represents the interests of the Church and the claims of the complainant. Counsel for the Church prepares and signs the judicial complaint and forwards it to the jurisdictional or regional conference committee on investigation. Discipline, ¶ 2704.1; Discipline, ¶ 2705. The judicial complaint must contain the charges and specifications with sufficient clarity to give notice and allow response. Discipline, ¶ 2705.
The committee on investigation does not determine guilt or innocence. Its task is to determine whether reasonable grounds exist to support charges and specifications. Discipline, ¶ 2706. In a case involving a bishop, the committee on investigation functions as the screening body that decides whether the matter should proceed to trial. Discipline, ¶ 2706. Five votes are required to certify a charge and specification. Discipline, ¶ 2706.
Trial is governed by the judicial process provisions of the Discipline. Discipline, ¶ 2707 states that no judicial complaint should be tried until every reasonable effort has been made to resolve the matter justly. Discipline, ¶ 2712 governs the trial of a bishop. Discipline, ¶ 2711 sets the trial procedures, and Discipline, ¶ 2711.2 provides that the burden of proof is clear and convincing evidence.
Appeals are governed by Discipline, ¶¶ 2715–2717. A bishop convicted at trial has the right to appeal under the procedures for appeals. Discipline, ¶ 2717. Appeals are generally limited to the record and to questions of whether the weight of the evidence sustains the charge and whether errors of Church law vitiate the verdict or penalty. Discipline, ¶ 2716.7.
XI. Fair Process and the Rights of All Parties
Fair process protects the respondent bishop, the complainant, and the Church. Discipline, ¶ 2701 governs fair process in judicial proceedings. It protects the right to be heard, the right to notice with sufficient detail to prepare a response, the right to be present, the right to assistance of counsel as provided by the Discipline, access to records relied upon, protection against double jeopardy, and prohibition of substantive ex parte communications. Discipline, ¶ 2701.
Fair process also protects the Church. The Church has the right to be heard before final action and the right to have complaints processed through lawful procedures rather than rumor, political pressure, or informal punishment. Discipline, ¶ 2701.
JCD 1366 provides the clearest modern statement of the constitutional dimension of fair process. It states that impartiality and independence of decision-making bodies are hallmarks of due process. It also holds that fair process is denied when complainants are among those tasked with reviewing and making the final decision. This principle is especially important in bishop complaint matters because episcopal accountability can involve overlapping relationships among bishops, committees on episcopacy, cabinets, and conference leaders.
JCD 1156 is also important. It warns that deviations from disciplinary process are violations of the Discipline. In bishop complaint matters, leaders may not invent alternative processes because they seem more efficient, more pastoral, or more institutionally convenient. The proper question is always: what does the Discipline require, and which body has authority to act?
XII. Legality, Separation of Powers, and Institutional Roles
The principle of legality means that the Church is governed by law. JCD 96 declares that the Discipline is the Church’s book of law. JCD 1341 and JCD 1366 develop this principle by stating that all persons and bodies are equally bound by Church law and that no individual or entity may violate, ignore, or negate the Discipline.
This principle applies directly to complaints against bishops. A College of Bishops, Council of Bishops, committee on episcopacy, counsel for the Church, committee on investigation, trial court, committee on appeals, or Judicial Council may act only within the authority assigned to it by the Discipline. No body may absorb the work of another.
The separation-of-powers principle reinforces this. JCD 689 states that separation of authority and decision-making is integral to United Methodist constitutional law. JCD 1312 states that no single entity has authority for all ecclesial matters. In bishop complaints, this means that supervisory officials may conduct a supervisory response, but they may not adjudicate guilt. Committees on episcopacy may handle administrative complaints, but they may not conduct a judicial trial. Committees on investigation determine whether reasonable grounds exist, but they do not determine guilt. Trial courts decide guilt and penalty. Appellate bodies review according to their limited authority. The Judicial Council decides questions within its constitutional and disciplinary jurisdiction.
JCD 1275 remains useful background because it addressed earlier ambiguity in Discipline, ¶ 413 concerning dismissal and referral authority. The current text of Discipline, ¶ 413 is more detailed, but the principle remains: the proper body must make the proper decision at the proper stage of the process.
XIII. Confidentiality, Care, and Healing
Bishop complaints affect more than the bishop and complainant. They may affect episcopal areas, cabinets, conference staff, clergy, laity, victims, families, and the wider Church. Discipline, ¶ 413.5 requires each jurisdiction to develop a protocol for caring for lay, clergy, and staff persons determined to be affected by the processing of a complaint. Discipline, ¶ 413.5.
Healing is also part of the judicial process. Discipline, ¶ 2701 requires bishops and cabinets, in consultation with the presiding officer of the pending body, to provide a process for healing when a judicial matter causes significant disruption in a congregation, annual conference, or other ministry context. Discipline, ¶ 2701. Although Discipline, ¶ 2701 governs judicial proceedings, the same pastoral logic should inform administrative and supervisory responses. Accountability is not only about whether misconduct occurred. It is also about repairing harm, restoring trust where possible, and protecting the Church’s witness.
Confidentiality is important, but confidentiality is not secrecy. Confidentiality protects sensitive information, complainants, respondents, victims, witnesses, and the integrity of the process. It may not be used to conceal required notice, deny access to records relied upon, suppress written reasons, or hide process defects.
XIV. Immunity for Participants
Discipline, ¶ 413.6 provides immunity from prosecution for persons participating in the bishop complaint process, including the College of Bishops, the supervisory response team, the jurisdictional or regional conference committee on episcopacy, witnesses, advocates, and others participating in the process. Discipline, ¶ 413.6. This immunity applies to complaints arising from their role in the process unless they commit a chargeable offense in conscious and knowing bad faith. Discipline, ¶ 413.6.
The burden is on the person alleging bad faith, and the proof must be clear and convincing. Discipline, ¶ 413.6. The provision also extends immunity to civil court proceedings to the extent permitted by civil law. Discipline, ¶ 413.6.
The purpose of immunity is not to excuse misconduct. It is to protect persons who participate in disciplinary processes from retaliatory complaints merely because they fulfilled an assigned role. At the same time, the bad-faith exception preserves accountability for persons who knowingly abuse the process.
XV. Human-Sexuality Moratorium Under ¶2701.6
Discipline, ¶ 2701.6 contains a moratorium affecting certain judicial proceedings related to homosexuality, same-gender weddings or unions, certification, licensing, commissioning, ordination, or consecration of persons in same-gender relationships, funding or support of gay caucuses or advocacy groups, or conduct previously described in the 2016 Discipline as incompatible with Christian teaching. Discipline, ¶ 2701.6.
This provision must be considered in any complaint against a bishop if the alleged judicial offense is based in whole or in part on conduct covered by Discipline, ¶ 2701.6. The 2024 General Conference substantially changed prior disciplinary language on human sexuality, but Discipline, ¶ 2701.6 remains part of the 2020/2024 Discipline unless amended, repealed, or authoritatively interpreted.
XVI. Practical Process Map
A complaint against a bishop generally follows this sequence:
- A written complaint is submitted to the president of the College of Bishops, or to the secretary if the complaint concerns the president. Discipline, ¶ 413.2.
- The president and secretary, or proper substitutes, consult within ten days with the chair of the jurisdictional or regional conference committee on episcopacy. Discipline, ¶ 413.3.
- The chair appoints one professing member and one clergy member from the committee on episcopacy, subject to the area and gender safeguards of Discipline, ¶ 413.3.
- The supervisory response begins. It is pastoral and administrative, directed toward just resolution, confidential, and not part of the judicial process. Discipline, ¶ 413.3b.
- The College of Bishops may suspend the bishop from episcopal responsibilities for up to sixty days when necessary to protect the complainant, the Church, and/or the bishop, with salary, housing, and benefits continuing. Discipline, ¶ 413.3a.
- The supervisory response may include just resolution with a trained, impartial facilitator or mediator. Discipline, ¶ 413.3c.
- If the matter is resolved, the supervising bishop and appointed committee members monitor fulfillment and report to the full committee on episcopacy and the College of Bishops. Discipline, ¶ 413.3d(1).
- If unresolved, the matter may be dismissed with proper consent and written reasons, referred as an administrative complaint, or referred to counsel for the Church for preparation of a judicial complaint. Discipline, ¶ 413.3d(1).
- If the matter is not resolved or referred within 180 days, it moves to the Council of Bishops for fair-process adjudication under publicly available procedures. Discipline, ¶ 413.3d(2).
- The Council of Bishops may remove a complaint from the College of Bishops by a two-thirds vote. Discipline, ¶ 413.3d(4).
XVII. Conclusion
Complaints against bishops test the Church’s commitment to lawful accountability. The episcopal office is a sacred trust, but sacred trust does not mean immunity from review. At the same time, accountability must not become punishment by rumor, institutional pressure, factional politics, or procedural shortcuts.
Discipline, ¶¶ 412 and 413 create a layered system. Discipline, ¶ 412 provides regular evaluation and review of episcopal leadership. Discipline, ¶ 413 provides the complaint process when concerns involve effectiveness, competence, misconduct, unsatisfactory performance of ministerial duties, or chargeable offenses. Administrative complaints proceed through the committee on episcopacy with fair-process protections. Judicial complaints proceed through counsel for the Church, the committee on investigation, trial, and appeal.
The controlling principles are legality, fair process, separation of powers, just resolution, and healing. These principles do not weaken accountability. They make accountability lawful, credible, and faithful to the Church’s covenantal life.