How early, Annie? Nicea doesn’t seem to imply papal mandate:
Jon
I don’t know if the issue came up before Zosimus but this is the first that I know of.
Pope Zosimus
When Pope Innocent died in March 417, his successor, Zosimus, made a major change in the Church in Gaul. On March 22, he wrote to the bishops of Gaul, granting extraordinary privileges to Patroclus, bishop of Arles. “It has pleased the Apostolic See,” the pope wrote, that clerics of any rank coming to Rome from Gaul must have litterae formatae, canonical letters of recognition from Patroclus, otherwise they “absolutely cannot be received by us.” The pope added that he had informed all quarters of this order, “so that all regions may realize that what we establish is altogether to be observed,” warning: “if anybody attempts to violate these beneficially established constitutions, let him know that, of his own volition he is separated from our communion.” [PL 20: 642-3]
The next paragraph gave the metropolitan of Arles, “as he has always had,” authority regarding ordinations in three different provinces: the Viennoise, and First and Second Narbonnaise. Whoever dares to give or receive ordination in these provinces without the consent of the bishop of Arles is deposed from the priesthood, Zosimus declared, asserting that he was confirming immemorial privileges held by the Church of Arles since the time of Trophimus, a bishop sent from Rome, from whose mission, attributed to the most distant antiquity, the Catholic faith had spread throughout Gaul. [PL 20: 644-5]
For decades, Arles had been growing in civil importance; it had even become the seat of an imperial prefecture. In the ecclesiastical hierarchy, Arles belonged to the province of Viennoise, whose metropolis was Vienne. The Council of Turin [c. 400] had proposed an arrangement in which each city-- Arles and Vienne-- would share metropolitan rights over the cities closer to its immediate vicinity. Now, thanks to Pope Zosimus, the see of Arles had secured the primacy in Gaul. [Cf. Mansi 3: 861]
In September, the pope disciplined two bishops ordained without the approval of Patroclus. Writing to bishops throughout Africa, Gaul and Spain, Zosimus, citing numerous irregularities, announced that the bishops, Ursus and Tuentius, were illicitly ordained and could not be admitted to communion. [PL 20: 661-5]
When Hilary, bishop of Narbonne, wrote asserting his rights to ordain bishops in First Narbonnaise, the pope replied on September 26, 417. Citing the mission of St. Trophimus, Zosimus declared that the right to ordain bishops in Viennoise and First and Second Narbonnaise belonged to the bishop of Arles. Invoking the authority of the Apostolic See and his own recent “most evident definition,” Pope Zosimus, under pain of excommunication, deprived Hilary of the right of ordaining bishops in First Narbonnaise. [PL 20: 667-8]
Two other metropolitans incurred the pope’s displeasure: Proculus of Marseilles and Simplicius of Vienne. Zosimus wrote to their provinces in late September, outraged that Proculus, in denigration of the Apostolic See, had cited the authority of the Council of Turin and that Simplicius of Vienne had shown similar “impudence” by ordaining bishops in Viennoise. In the name of antiquity, for which the decrees of the Fathers required reverent observance, Pope Zosimus asserted that Proculus and Simplicius had violated the statutes of the Fathers and the reverence due to Trophimus, first metropolitan of Arles sent by the Apostolic See. On September 29, the pope wrote to Patroclus, reaffirming rights that Patroclus enjoyed in Gaul by the authority of the Apostolic See. [PL 20: 665 sq.]
In March 418, Pope Zosimus reaffirmed the extensive authority that Patroclus enjoyed “by pronouncement of the Apostolic See.” The pope also wrote to the clergy and people of Marseilles, entrusting them to the care of Patroclus until they received a new bishop. [PL 20: 673-5]
Meanwhile, answering a consultation from Hesychius, bishop of Salona, who in the pope’s words had called for “a precept of the Apostolic See,” Zosimus reminded him that candidates for orders, whether monks or laymen, must pass through the usual grades and canonical intervals. Surprised that the “statutes of the Apostolic See” had not reached Hesychius, Zosimus directed him to pass on these instructions to the bishops of the neighboring provinces, declaring that whoever ignored “the authority of the Fathers and of the Apostolic See” were subject to severe punishment, and even in danger of losing their rank. [PL 20: 670-73]