Stories of exiled bishops abound in late antique sources. How to explain this, considering that late antique elites faced increasingly harsh forms of punishment? This paper argues that Constantine's precedent established a pattern for Christian rulers of Late Antiquity in their dealings with bishops. The first Christian emperor respected the methods of dispute settlement already in place among Christian communities and used councils of bishops to resolve Christian conflicts. But because Christian institutions did not possess the means to enforce their decisions, the role of the Christian ruler became crucial in enforcing the decisions of assemblies of bishops. In order to enforce those decisions, Constantine used exile as the typical form of punishment for bishops condemned by councils, which established a second important precedent after the use of councils. The use of exile was especially well-suited to the new status of bishops in the Christian Roman Empire as well as in the "successor kingdoms" because it followed both Roman and Christian traditions. Constantine's interventions in ecclesiastical controversies show that he was extremely concerned with religious unity within his realm but that he was not ready to use coercion to impose unity at all costs. Instead, the emperor established a precedent among Christian rulers by his use of exile as the best form of non-violent civil sanction to implement conciliar decisions. As this paper will intend to show, the pattern set by Constantine was readily adopted by his late antique successors, both Roman and "Barbarian."