809 N.W.2d 117
Iowa Ct. App.2011Background
- Faith Evangelical Methodist Church sought affiliation with EMC in 2002; Faith attempted withdrawal in 2010; EMC sought to compel conciliation/arbitration; district court granted arbitration and ordered Faith to schedule an annual conference; issue centered on whether there is a valid arbitration contract and whether the dispute is non-doctrinal; Discipline contains the arbitration clause in paragraph 701; court held contract exists and dispute is non-doctrinal, but ordered conference scheduling was improper.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Validity of arbitration agreement | Faith asserts no written contract under Iowa law. | EMC argues Discipline is a contract offering arbitration. | Contract exists; parties bound to Discipline. |
| Scope of arbitration (non-doctrinal vs doctrinal) | Dispute is doctrinal (doctrine-focused). | Dispute is non-doctrinal (property/withdrawal). | Dispute falls within non-doctrinal arbitration per Discipline. |
| Court’s ordering of annual conference | Equity allows enforcement of Discipline procedures. | District court acted within arbitration framework. | Affirm arbitration but reverse scheduling of annual conference. |
Key Cases Cited
- Bullis v. Bear, Stearns & Co., Inc., 553 N.W.2d 599 (Iowa 1996) (arbitration requires meeting contract elements; threshold question is arbitratability)
- Postville Cmty. Sch. Dist. v. Billmeyer, 548 N.W.2d 558 (Iowa 1996) (threshold to arbitrate; merits not considered beyond contract language)
- Lewis Cent. Educ. Ass'n v. Lewis Cent. Cmty. Sch. Dist., 559 N.W.2d 19 (Iowa 1997) (arbitration scope and contract interpretation; two-part gateway tests)
- Margeson v. Artis, 776 N.W.2d 652 (Iowa 2009) (contract elements and consideration in arbitration agreements)
- Anderson v. Douglas & Lomason Co., 540 N.W.2d 277 (Iowa 1995) (mutual assent required for contract formation; arbitration predicates)