I am convinced that removing the present wording of the statute of limitations in BCO 32-20 will lead to other serious problems and unintended consequences.  The proposed amendment will potentially open up members to harassment by the courts; it will allow the shepherding from elders to become lax; it will allow courts to settle for evidence that has been corrupted by time but fits a preconceived narrative; and, ultimately, it will harass and harm untold members of our congregations.

Removing the “Statute of Limitations” from the Book of Church Order (BCO) of the Presbyterian Church in America (PCA) is a serious matter, and I am concerned that last summer’s General Assembly hastily began that process without counting the costs.  If we move forward with the proposed substitute to BCO 32-20, I fear there will be significant unintended consequences.  I write in hopes that Presbyters across the PCA will better appreciate the wisdom of having a statute of limitations and, with Anton Heuss, I hope that the proposed replacement of BCO 32-20 will NOT be approved and that better language will be put forward.
As it stands today, BCO 32-20 begins, “Process, in case of scandal, shall commence within the space of one year after the offense was committed, unless it has recently become flagrant.”  This amounts to what some, including the SJC and an important commentator, have called a “Statute of Limitations” for church discipline,[1] at least for cases of “scandal.”  The new proposal sent to Presbyteries for their advice and consent removes this language altogether and only codifies the right the accused already has to object to indictments and names “degradation of evidence” as one possible ground for objection.[2]
Overture 22, which gave rise to the proposed language, and Howie Donahoe, the esteemed moderator of the 47th GA, raise a number of objections to the current BCO 32-20, but neither account for the significant costs of removing a statute of limitations altogether.  Nevertheless, I share their concern about abuse and other private sins that are not immediately known or discovered.  I wholeheartedly agree with criticisms of the current BCO 32-20 on this point, but this does not warrant overthrowing a statute of limitations altogether when an exception could be built into the BCO that provides a way to bring before the court cases of past abuse.
We need to remember why we have a statute of limitations in the first place, and I posit that there are at least three significant reasons to retain a statute of limitations for church discipline.

To Protect the Accused

A statute of limitations protects every member of the PCA from all kinds of harassment by the courts.  If a court declines to bring charges against a person, it can’t hold the possibility of charges over that person’s head in perpetuity.
Consider another situation.  Suppose a pastor or Session believes a church member is guilty of a particular sin, and, with a clear conscience, the church member does not believe he has committed it.  Or suppose a church member believes he is repentant of a certain sin, but his elders don’t think so.  What happens then?  Often in cases like these, the church member hears continual, frank, and strong counsel about how he needs to own up to his sin or to biblically repent of it.  The shepherds are doing what they believe is right: rebuking strongly from time to time, bearing with the individual over the long haul in a “pastoral” manner, calling him to be faithful to Scripture’s teaching, and seeking to keep the rest of the church pure from the potential defilement of sin.
But the actions of the elders wear down the church member. The elders don’t want to bring charges, so they are “patient.”  They don’t realize how the church member feels like the life is being squeezed out of him.  In these cases, forbearance isn’t the answer.  When the church member and Session legitimately disagree after prayerful dialogue and counsel, the pastoral answer is not to wait it out and hope the church member changes his mind.  The loving and right thing is often for the Session to bring charges.  From the Session’s perspective, he is in conscious sin, and it must be addressed immediately.  From the church member’s perspective, he has the right to have his case heard not just by his Session, but also to have it reviewed by the higher courts of the church.  It is a merciful thing that the church member has his day in court to vindicate himself and to appeal to higher courts for assistance.  We are Presbyterians, and this is Presbyterianism at its best.  This is good for both the Session and the church member because there will be resolution to the disagreement.
A statute of limitations requires Sessions to bring charges sooner rather than later.  It protects the accused from a forbearance in the name of pastoral kindness that ends up being harmful.  Where legitimate disagreement exists, a statute of limitations puts an end to it by requiring action, and it protects the accused from all kinds of potential harassment by the courts of the church.

To Encourage Diligent Shepherding

If a court is not able to bring a charge on day 366, it is forced to be diligent in shepherding its flock in the first 365 days after a disciplinable offense takes place.  When a court knows that a sin cannot be addressed through process after one year, a statute of limitations actually compels action.  We want to encourage the shepherds of the church to conscientiously care for the hurting and wandering sheep and not to let a sheep walk away from the fold for years before beginning the process of bringing him back.
When someone commits an offence of the sort that often gives rise to formal discipline, it often takes several months for the dust to settle, for the church to understand what happened, and for the offender and the offended parties to appreciate the fallout.  The spiritual realities are not usually immediately clear.  So the statute of limitations ought not be too short to require the court to act before it can shepherd the parties through these early days and gain clarity of the situation.  But it seems that a year has been plenty of time in the PCA to understand what happened, counsel the parties, assess their responses, and determine if formal process is fitting.  These situations are difficult, and courts must be diligent shepherds to adequately care for its members.  A statute of limitations requires them to be engaged intentionally from day one, and that is a good thing.

To Ensure Accurate Evidence

As time goes on, the quality of evidence degrades.  Memories fade.  Witnesses move away, die, or otherwise disappear.  Documentary evidence, whether digital or physical, corrupts or goes missing.  The immediacy of the offence is lost to time, and the accuracy of the remaining testimony decreases in quality.  Overture 22 admits as much.  Of course, there is no certain time where good evidence goes bad, but the principle still stands:  It is better to call upon witnesses and use evidence when it is as fresh as possible so that the accuracy and truthfulness of that testimony is best preserved and conveyed.
Additionally, the further one is from an event, the easier it is to falsify documents or to produce fraudulent testimony.  We minimize the risk of false accusations if we maintain a statute of limitations.
The substitute proposal includes an encouragement to courts to not entertain an indictment if the evidence has been too degraded, but such a question is far too subjective and could easily be answered to accord with the court’s view of the merits of the case.  I question the wisdom of placing this as the only named backstop on the court’s ability to do adjudicate ancient cases.  A bright-line statute of limitations takes this question out the hands of the court in the interests of fairness.
Conclusion
While I deeply appreciate the concern about some alleged offenses that may not be immediately known, I am convinced that removing the present wording of the statute of limitations in BCO 32-20 will lead to other serious problems and unintended consequences.  The proposed amendment will potentially open up members to harassment by the courts; it will allow the shepherding from elders to become lax; it will allow courts to settle for evidence that has been corrupted by time but fits a preconceived narrative; and, ultimately, it will harass and harm untold members of our congregations.
There are better ways to word an amendment to handle the problem of alleged offenses in the church than to remove a reasonable and limited time period altogether, avoiding throwing the proverbial baby out with the bathwater.
I urge Presbyteries to vote against the proposed amendment to BCO 32-20 and then let us find a better solution to the perceived problem.  Concerned members of the PCA can work to make sure a better alternative isn’t too far away.
Jason Piland is a Minister in the Presbyterian Church in America and serves as Associate Pastor of Redeemer (PCA) in Hudson, Ohio.

[1] See, e.g., Grace RPC Session v. Heartland Presbytery, Case No. 93-14, M23GA, 113–121; Morton H. Smith, Commentary on the Book of Church Order of the Presbyterian Church in America, 5th ed. (Greenville: Southern Presbyterian, 2004), 313.
[2] The full text of the proposal is as follows:
The accused or a member of the court may object to the consideration of a charge, for example, if he thinks the passage of time since the alleged offense makes fair adjudication unachievable.  The court should consider factors such as the gravity of the alleged offense as well as what degradations of evidence and memory may have occurred in the intervening period.

Written by Rev. Dr. Andrew W.G. Matthews |
Tuesday, March 29, 2022
It is time for Presbyterian ministers, along with elders, to affirm their ordination vows by using the right and biblical administration of baptism. As for me I am done with dunking, and I will boldly proclaim that “baptism is rightly administered with pouring, or sprinkling water upon the person.”

The dipping of the person into the water is not necessary; but baptism is rightly administered by pouring, or sprinkling water upon the person.—Westminster Confession of Faith, Ch. 28:3
I’m done with dunking. I will never again perform an immersion baptism for a Christian, but will henceforth be true to the biblical and confessional standards of my Presbyterian faith. To say this is the final step on my long sacramental journey from being a credo-baptist to being fully Reformed. I myself experienced an immersion baptism in a charismatic Methodist church a year after my conversion and spent the first decade of my Christian life in churches that only did immersion baptism.
As a Presbyterian minister, I once borrowed the baptismal facilities of a Baptist church in order to immerse a family of teenagers who attended my church. In my last Presbyterian parish in the country, I was willing to accommodate the preferences of Baptists in my church and go down to the local lake to immerse their believing children. I’m done with that now.
The Baptist belief is that immersion (the total submerging of the person underwater) and emersion (the coming up out of the water) is necessary in order to have a true baptism. Presbyterians hold an immersion baptism is valid before God when it meets the essential criteria of water applied by a minister in the name of the Father, Son, and Holy Spirit, but that it is unnecessary. The correct administration of baptism actually is “by pouring, or sprinkling water upon the person.” For me, to practice immersion baptism is to replace a superior mode with an inferior one and to endorse error.
The Baptist contention that the only valid mode of baptism is by immersion rests upon three flawed lines of argumentation: the meaning of the word “baptism” itself, New Testament accounts of baptisms, and the imagery of death, burial, and resurrection.
First, Baptists hold that the Greek word baptizo, “to baptise,” exclusively means “to dip” or “to immerse,” thus all baptisms must be by immersion. As with most words, baptizo has a range of senses, one of which is “to dip.” Baptists argue that “to dip” is the core meaning of the word which controls every use. I will spare you an exhaustive exposition on semantic theory, etymology, and every example of baptizo in the Bible and ancient literature and simply state, in contradiction, that baptizo primarily conveys the senses of wash, cleanse, or unite which can take place through dipping, pouring, sprinkling, or wiping.
The main point is to apply water to something or someone to cleanse it. The Baptist might say then that only bathing or immersion truly conveys the cleansing of a person, and that sprinkling or pouring water over the head does not cleanse the body. Really? In that case, we should get rid of all our bathroom showers and commit to taking baths every day. Using showers, faucets, basins and towels, as well as bathing in rivers and lakes, has been used to wash bodies for millennia. Jesus seemed quite satisfied with a few wet teardrops and some long hair when his feet were cleansed (Luke 7:44).
Secondly, the supposed New Testament accounts of immersion baptism in the Gospels and Acts are examples of the use of sloppy eisegesis. When Jesus came “up from the water” (Matt. 3:16) or “up out of the water” (Mark 1:10) he was not necessarily emerging from beneath the water but walking out of the water or up from the river bed. The same action is enacted with Philip and the Ethiopian eunuch who saw water and stop the chariot. The text says “they both went down into the water” and then “they came out of the water.” (Acts 8:38-39). Did Philip perform a tandem baptism by both going beneath the water?  Obviously not, they both walked down into the pool of water and then both walked out.
In both the cases of Jesus and the eunuch they could have stood or kneeled in the water while water was poured over them. It is supposed that John the Baptist chose the desert of Aenon near Salim because the “much water” or “plentiful water” provided deep water for immersion (John 3:23). A better reading is that these many springs of waters were where people gathered to retrieve water—and were usually quite shallow—but the springs also served John’s purpose for baptizing.
Other baptisms in the book of Acts were more likely accomplished by applying water than by immersing people. The three thousand at the feast of Pentecost could have been baptised using the lavers of water used in Old Testament ceremonial cleaning. Paul and Cornelius and his Gentile guests were baptised inside houses where it was uncommon to have a deep bathtub.
Within the house of Cornelius the question, “Can anyone withhold water for baptising these people?” (Acts 10:47) implies that water would be brought to the new converts. Lydia’s baptism does allow for an immersion baptism in a river (Acts 16:13-15), but the Philippian jailor was present in his house, not the river when he and all his household heard the word of God and were baptised (Acts 16:32-33). The New Testament Christian baptisms simply do not prove a case for exclusive, immersion-only baptism, but instead, demonstrate the probability of a pouring or sprinkling mode.
Thirdly, and most importantly within the Baptist perspective, the act of baptism supposedly depicts the imagery of the death, burial, and resurrection of Jesus. The go-to verse for Baptists to prove that baptism is essentially an immersion and emersion act is Romans 6:3, “We were buried therefore with him by baptism into death, in order that, just as Christ was raised from the dead by the glory of the Father, we too might walk in newness of life.” When the convert goes down into the water his old man dies with the crucified Christ, but then he rises up out of the water as a new man with the resurrected Christ.
Read More

One of the most important and striking characteristics of Hoste was his prayer life—and related to that, his true humility before God and in his ministry. Hoste never sought fame or power. Instead, he was determined that his name and reputation would be subsumed under the desire to see Jesus get all the honor for everything. Hoste “lived to be forgotten” because he chose to be “hidden with Christ in God” (Col. 3:3).

Dixon Edward Hoste (1861–1946) was a British missionary who served in China for over 40 years. Although he succeeded James Hudson Taylor as the general director of the China Inland Mission (CIM), much less has been written and recorded of his life and ministry than of Taylor’s.
This is not, however, because Hoste lacked achievements and contributions to the mission in China. He was instrumental to CIM’s development not only in terms of organization and mission mobilization but also in the indigenous principles that encouraged Chinese churches to self-grow and rely less on Western missionaries, as well as in dealing with the difficult Boxer Rebellion aftermath with grace and “the power of gentleness,” as former CT editor in chief David Neff put it.
One of the most important and striking characteristics of Hoste was his prayer life—and related to that, his true humility before God and in his ministry. Hoste never sought fame or power. Instead, he was determined that his name and reputation would be subsumed under the desire to see Jesus get all the honor for everything. Hoste “lived to be forgotten” because he chose to be “hidden with Christ in God” (Col. 3:3).
Talking to God
Dixon E. Hoste was born on July 23, 1861, four years before CIM’s founding. Both his father and his grandfather were military men. When Dixon was 17, he entered the Royal Military Academy. At 18, he received his commission as a lieutenant to serve in the Royal Artillery.
Three years later, in 1882, Dixon’s elder brother, William, invited him to attend a special meeting in Brighton where the speaker was the American evangelist D. L. Moody. Phyllis Thompson, author of D. E. Hoste: A Prince with God (the primary biographical source in this article), described the scene. When Moody prayed, Thompson wrote, Dixon felt that he “talked as though God was there, as though he knew him, as a man talks to a friend. He talked as though God could be depended upon to do his work in men’s hearts, right then and there.” Hoste was converted at the meeting. Moody’s prayer left a deep impression on him that shaped his own prayer life over the next 40 years.
It did not take long before Hoste came across Hudson Taylor’s little bookChina: Its Spiritual Need and Claims. Hoste was captured by Taylor’s call for missionaries to serve “four hundred millions of souls, ‘having no hope, and without God’” in China. Hoste wrote to the London office of the CIM in 1883 and offered himself to be a candidate.

However, the reference letter from the vicar of Sandown, Isle of Wight, W. T. Storrs, was not totally encouraging. On Hoste’s application form (in the OMF International archive) Storrs praised Hoste’s Christian character, calling him “a straightforward fellow, with much love and faith.” But he also characterized Hoste as naturally shy, a little impulsive, not able to teach well, not very enterprising, and not “naturally fitted” for missionary work—with a disclaimer of “but I may be mistaken.”

Though the clergyman’s assessment wasn’t very hopeful, Thompson writes, members of the London Council took note of the spiritual stature of this quiet young man. He was clearly humble and sincere and even in his youth demonstrated balanced judgment and foresight.
Read More
Related Posts: