Larry Hoop

SJC Announces Verdict in Metro New York Case

The Standing Judicial Commission has published its decision along with concurring and dissenting opinions in a matter referred to it by the 50th General Assembly.

The PCA Standing Judicial Commission has released its decision in Case 2023-13, BCO 40-5 Matter re: Metropolitan New York Presbytery. The case came to the SJC by action of the 50th General Assembly which approved the recommendation of its Committee on Review of Presbytery Records that Metro New York Presbytery be cited to appear before the SJC for failing to redress an unconstitutional proceeding by one of its sessions. The RPR reported to the GA that Metropolitan New York had not redressed one of their sessions for permitting a woman to expound the Scriptures during a Lord’s Day worship service, and for holding services without preaching and serving the Lord’s Supper without a preceding sermon on multiple occasions; nor had Metropolitan New York corrected the church’s pastor who stated his approval of these actions.
The citation was issued by the GA under the provisions of BCO 40-5 which states that when a “credible report” of “an important delinquency or grossly unconstitutional proceedings” of a church court comes to the attention of the next highest court, the lower court should be cited to appear to show what  they had done or failed to do in the matter. The GA, as the next highest court, cited Metropolitan New York to appear before the SJC, their Commission to adjudicate such matters.
In response to the citation, Metropolitan New York appeared before the SJC and produced the minutes of two meetings held subsequent to the citation in which they affirmed that an “exposition of the Word” by a woman shall not take the place of the ordinary sermon in public worship services in the churches within its bounds, that only qualified men should preach to God’s people during public worship services, and that it is permissible for unordained and unlicensed men to occasionally preach but not a woman.
They also adopted this statement: “Though allowing this woman to teach in place of a sermon only happened once, Metropolitan New York Presbytery has informed the church’s Senior Pastor and the Session that this practice is unconstitutional, and they are not to repeat it in the future. The Senior Pastor and Session agreed to submit to the will of the presbytery on this matter.” Metropolitan New York argued they did not err in taking no further action with regard to the allegation that many worship services were held without preaching and that the church in question celebrated the Lord’s Supper without a preceding sermon, having concluded that an exposition of the Word had always taken place though when delivered by a man who was not ordained or licensed, it was referred to as a “message” rather than a “sermon.”
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Missouri Presbytery Reports on Second Hearing Regarding Revoice Conference

As part of MOP’s responsibility “to make clear to the broader Church the errors that were identified in Presbytery’s various investigations” — and the steps it is taking “to fulfill its responsibilities to protect the peace and purity of the broader Church . . . in light of these errors,” … the following documents are posted which report the results of the hearing.

On Tuesday evening, June 14, Missouri Presbytery (MOP) held a second hearing concerning its actions regarding Memorial Presbyterian Church’s involvement with the Revoice conference it hosted in 2018. The hearing was directed by the PCA’s Standing Judicial Commission (SJC) in Case 2020-05.
The Presbytery’s Report
As part of MOP’s responsibility “to make clear to the broader Church the errors that were identified in Presbytery’s various investigations” — and the steps it is taking “to fulfill its responsibilities to protect the peace and purity of the broader Church . . . in light of these errors,” — MOP has asked byFaith, the official communication organ of the PCA, to post the following documents which report the results of the hearing: a cover letter; restating the SJC Amends and the Standard of Review Now Expected of the MOP; and Amended Theological Judgments.
These documents may be accessed here.
Background 
The first Revoice conference, held in July 2018 at Memorial Presbyterian Church in St. Louis, generated controversy in the evangelical community, and especially in the PCA. Ultimately, three matters related to Memorial’s hosting Revoice came before the SJC, the body responsible for handling matters related to judicial process that make their way to the General Assembly (GA):

A complaint filed by Teaching Elder (TE) Ryan Speck contended that MOP should have found a “strong presumption” that TE Greg Johnson, pastor of Memorial, was guilty of four allegations raised against him and should have held an ecclesiastical trial and, if warranted, impose censure (SJC Judicial Case 2020-12).
A second complaint, also filed by TE Speck, charged MOP with error in approving six theological judgments concerning Revoice and Memorial’s involvement with the Conference, as well as a couple of other matters (SJC Judicial Case 2020-05).
Overtures from three presbyteries invoking a “Book of Church Order” (BCO) provisionthat allows any two presbyteries to ask the GA to assume original jurisdiction (the right of a court to hear a case for the first time) when a presbytery refuses to act “in doctrinal cases or cases of public scandal” (BCO 34-1). The three presbyteries alleged that MOP had refused to act by failing to bring TE Johnson to trial.

The full SJC heard Judicial Case 2020-12 in March 2021, and rendered its judgment, denying the complaint at its fall meeting the following October. An explanation of that decision may be found here. The SJC reached a final decision about the Case 2020-05 and the three overtures at its spring 2022 meeting on March 3, 2022. In Case 2020-05, the SJC sustained a portion of the complaint (the complete text of the decision may be found here). The SJC answered the overtures from the three presbyteries by reference to its decisions in cases 2020-05 and 2020-12.
The SJC identified three issues raised by the complaint, and sustained one of them: “At its December 7, 2019, called meeting, did Missouri Presbytery (MOP) err in approving six theological judgments (specifically, Judgments # 1-5 and #9) recommended by the Committee to Investigate Memorial?” The SJC answered “yes, ” particularly with regard to theological judgments 2, 3, and 5.
The heart of MOP’s error identified by the SJC was the criteria the presbytery used in adjudicating the allegations presented within the complaint. The SJC determined that MOP improperly applied a standard used in a case against a teaching elder (BCO 34-5) rather than provisions dealing with the responsibilities of church courts (BCO 11-3, 4 and at BCO 13-9(f)). A more comprehensive explanation of the SJC’s rationale for this conclusion as well as its decision as a whole may be found here.
BCO 43-10 says that when a higher court has sustained a complaint (or any part of it) against a lower court, it “has power, in its discretion, to annul the whole or any part of the action of a lower court against which complaint has been made, or to send the matter back to the lower court with instructions for a new hearing.”
In Case 2020-05, the SJC instructed MOP to “hold a new hearing” that would focus on the following matters: “What steps must MOP take to make clear to the broader Church the errors that were identified in Presbytery’s various investigations with regard to some of the teachings at Revoice 18, particularly with regard to Theological Judgments 2, 3, and 5, and what steps must MOP take to fulfill its responsibilities to protect the peace and purity of the broader Church under BCO 11-3, 11-4, and 13-9f in light of those errors?” The SJC encouraged MOP to consider “how specific statements of some speakers at Revoice 18 may have differed from the propositions of the report of the GA’s Ad Interim Committee on Sexuality.” It was this hearing that MOP held on June 14.
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BCO Amendments Related to Homosexuality Now Before PCA Presbyteries

Greco is quick to point out that the proposal applies only to prospective officers, not to all church members. “Officers in the church are to be models of godliness and Christ-likeness,” he says. Though imperfect, “they are not to be identified with their sin.” He believes that the three criteria referred to above “make clear that it is neither being a sinner nor struggling with a sin that disqualifies a man from office. It is identifying with his sin and declaring that the Spirit will never give (indeed, cannot give) victory over his sin.”

Following their approval by the Presbyterian Church in America’s 48th General Assembly, the Book of Church Order (BCO) amendments proposed by Overtures 23 and 37 have been sent the PCA’s 88 presbyteries for their advice and consent. Both proposed amendments deal with homosexuality. Two-thirds of our presbyteries, a total of 59, must approve them before they’re presented to the 49th Assembly for a final vote.
Two Overtures, Three Years in the Making
A lot of history — in the culture and in our church — has brought us to this moment. This is how it goes with controversial issues in the PCA. Sometimes they’re theological — the debate over creation days, for example. Sometimes they’re related to polity — such as the ministry of women in the church. And they can be significant issues in the broader culture, such as racial reconciliation or, as we see today, homosexuality.
Such issues produce debate, prompt disciplinary cases, and spawn overtures to the General Assembly (GA). They can also lead to the creation of study committees to explore the issue, and while the findings of such committees are only advisory, they tend to promote peace in the church around the controversies.
So why this issue, and why now? There are two primary reasons.
The first comes from outside the PCA — the dramatic change in attitudes toward homosexuality in American culture. They’ve occurred quickly — in roughly two decades — and they’ve been pervasive. Sadly, these trends have also been reflected in some Christian churches. Many mainline denominations, for example, now endorse same-sex marriage and the ordination of practicing homosexuals. Though the PCA has faithfully advocated the biblical teaching concerning homosexuality, some have called for the denomination to express its position even more strongly in response to these trends.
The second reason is internal. In July 2018 Revoice, an organization created to support Christians who experience same-sex attraction while upholding the historic Christian teaching about marriage and sexuality, held its first conference at Memorial Presbyterian Church, a PCA congregation in St. Louis. The conference stirred controversy and criticism throughout the evangelical world, and particularly within the PCA.
Over the next several months, Greg Johnson, pastor of Memorial, found himself defending Revoice in a variety of public settings. In the process, he acknowledged his own struggles with same-sex attraction, which intensified the controversy and prompted a series of technical judicial actions:

At the request of the Memorial session, Missouri Presbytery created a committee to investigate allegations raised against Johnson and Memorial for hosting Revoice.
In May 2019, the committee presented its findings; while concluding that the Memorial session had failed to exercise due diligence in its handling of the conference, no charges were filed against Johnson or the session.
In January 2020, two presbyteries invoked the provisions of BCO 34-1 that allow a presbytery to ask the General Assembly’s Standing Judicial Commission (SJC) to assume original jurisdiction when a presbytery fails to act on a matter of theological error. The presbyteries alleged that Missouri’s failure to charge Johnson constituted such a failure.
In the same timeframe, two presbyteries and two sessions outside Missouri presbytery requested that Missouri initiate a disciplinary investigation of Johnson under BCO 31-2. The presbytery established a committee to conduct such an investigation in October 2019. It found no strong presumption of guilt and in July 2020 the presbytery exonerated Johnson.
This led a third presbytery to ask the SJC to assume original jurisdiction in Johnson’s case.
But before the SJC could act on these requests, an elder in Missouri Presbytery filed a formal complaint against the presbytery for exonerating Johnson. The complaint was denied by Missouri and then taken to the SJC, which ruled that the complaint should be considered before the requests for original jurisdiction. That complaint is currently being decided.

The PCA Reacts With 11 Overtures
All this — external and internal factors combined — led to a flurry of 11 overtures sent to the 2019 General Assembly.

One asked the Assembly to commend a study paper on sexual orientation produced by the Reformed Presbyterian Church of North America (RPCNA) and make it available to the denomination.
Two offered their own statements on homosexuality.
Two others asked the Assembly to re-affirm previous statements.
Two presbyteries overtured the Assembly to commend the Nashville Statement, produced by the Council on Biblical Manhood and Womanhood, and make it available to the denomination.
Four presbyteries asked the Assembly to appoint a study committee to address the issue.

Ultimately, the Assembly commended the Nashville Statement and the RPCNA’s study paper. It also approved the appointment of a study committee; GA Moderator Howard Donahoe appointed the Ad-Interim Committee on Human Sexuality (AIC) which posted its report in May 2020, prior to the Assembly that was postponed because of COVID-19.
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For a complete statement of Fred Greco’s arguments in favor of Overtures 23 and 37, click here.
For a complete statement of Kyle Keating’s argument against the Overtures, click here.

[The Aquila Report Editor’s Note: Here are the proposed amendments to the PCA’s Book of Church Order as approved by the PCA General Assembly and sent to the presbyteries for their votes]:
BCO 16-4. Officers in the Presbyterian Church in America must be above reproach in their walk and Christlike in their character. Those who profess an identity (such as, but not limited to, “gay Christian,” “same sex attracted Christian,” “homosexual Christian,” or like terms) that undermines or contradicts their identity as new creations in Christ, either (1) by denying the sinfulness of fallen desires (such as, but not limited to, same sex attraction), or (2) by denying the reality and hope of progressive sanctification, or (3) by failing to pursue Spirit-empowered victory over their sinful temptations, inclinations, and actions are not qualified for ordained office.
BCO 21-4 e. In the examination of the candidate’s personal character, the presbytery shall give specific attention to potentially notorious concerns, such as but not limited to relational sins, sexual immorality (including homosexuality, child sexual abuse, fornication, and pornography), addictions, abusive behavior, racism, and financial mismanagement. Careful attention must be given to his practical struggle against sinful actions, as well as to persistent sinful desires. The candidate must give clear testimony of reliance upon his union with Christ and the benefits thereof by the Holy Spirit, depending on this work of grace to make progress over sin (Psalm 103:2-5, Romans 8:29) and to bear fruit (Psalm 1:3; Gal. 5:22-23). While imperfection will remain, he must not be known by reputation or self-profession according to his remaining sinfulness, but rather by the work of the Holy Spirit in Christ Jesus (1 Cor. 6:9-11). In order to maintain discretion and protect the honor of the pastoral office, Presbyteries are encouraged to appoint a committee to conduct detailed examinations of these matters and to give prayerful support to candidates.
BCO 24-1. In the examination of each nominee’s personal character, the Session shall give specific attention to potentially notorious concerns, such as but not limited to relational sins, sexual immorality (including homosexuality, child sexual abuse, fornication, and pornography), addictions, abusive behavior, racism, and financial mismanagement. Careful attention must be given to his practical struggle against sinful actions, as well as to persistent sinful desires. Each nominee must give clear testimony of reliance upon his union with Christ and the benefits thereof by the Holy Spirit, depending upon this work of grace to make progress over sin (Psalm 103:2-5; Romans 8:29) and to bear fruit (Psalm 1:3; Gal. 5:22-23). While imperfection will remain, he must not be known by reputation or self-profession according to his remaining sinfulness, but rather by the work of the Holy Spirit in Christ Jesus (1 Cor. 6:9-11). In order to maintain discretion and protect the honor of church office, Sessions are encouraged to appoint a committee to conduct detailed examinations into these matters and to give prayerful support to nominees.

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