## Facts

- Temple Church of God in Christ, Inc., a nonprofit church, had long been led by Pastor Samuel Kelsey, who regularly entered significant contracts without specific trustee approval.
- In 1992, because of Kelsey’s ill health, a bishop publicly appointed Frank Morris as co-pastor in the presence of the trustees and congregation, describing Morris as having full authority to run the church; no objection was made.
- Disputes soon arose between Morris and the board of trustees over fiscal responsibility and governance powers.
- In early 1993, Morris orally retained attorney Thomas Ruffin, Jr. to perform legal services on behalf of the church, including drafting bylaws and attempting to resolve the governance conflict.
- Ruffin performed services from January to March 1993 and later billed about $8,000; the church refused payment, asserting only the trustees could authorize contracts and they did not authorize Morris to hire Ruffin.
- Ruffin sued for breach of contract seeking recovery of his fees.

## Issues

1. Whether the evidence, viewed favorably to Ruffin, was sufficient for a reasonable jury to find Morris had implied authority to retain Ruffin for legal services on the church’s behalf, making judgment as a matter of law improper.

## Decision

- The appellate court reversed the trial court’s post-verdict judgment as a matter of law for the church.
- The court held the evidence permitted a reasonable jury to find Morris had implied authority to contract for Ruffin’s services.
- The case was remanded with instructions to reinstate the jury’s verdict in Ruffin’s favor.

## Legal Principles

- Implied authority exists when the principal’s conduct, reasonably interpreted, causes the agent to believe the principal wishes the agent to act, or when the act is incidental to or reasonably necessary to accomplish the agency’s purpose.
- A longstanding course of institutional practice can support a finding that an organization has delegated contractual authority to an officer or leader, notwithstanding formal governance allocations.
- On a Rule 50 motion (judgment as a matter of law), the court must view the evidence and reasonable inferences in the light most favorable to the nonmoving party and may not reweigh evidence or substitute its view for the jury’s if a reasonable jury could find for that party.
- Knowledge of an internal governance dispute does not categorically defeat implied authority where objective manifestations and historical practice could still support the agent’s authority; the dispute is generally for the factfinder to evaluate.

## Conclusion

Because the church’s historical practice of broad pastoral contracting authority and the public, unobjected-to installation of Morris as a pastor with operational authority could support an inference of implied authority, the jury’s verdict for Ruffin had an adequate evidentiary basis and the trial court erred by setting it aside.


Ruffin v. Temple Church of God in Christ, Inc., 749 A.2d 719 (D.C. 2000)