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.

TULIP, or the five points of Calvinism, summarizes God’s work of salvation, and it highlights the omnipotent love of God. Christians can rest assured that if they believe, it is because of the work of God, and that work cannot fail because His love cannot fail.

What do tulips, the love of God, and a centuries-old understanding of salvation have in common? They are all reflected in what has come to be known as the five points of Calvinism.
How are these things interconnected? The word tulip forms an acrostic that summarizes a particular understanding of salvation that has at its center the love of God. Let’s see how this works.
Total Depravity
T stands for total depravity, which describes how sin affects human beings. But to understand this, we have to start before sin entered the world. Our triune God from all eternity has existed as Father, Son, and Holy Spirit, equal in power and glory, enjoying a never-beginning and never-ending relationship of holy love. This holy love motivated God’s free decision to create the universe and to create man and woman in His own image to love Him and each other. However, Adam chose to reject our Creator, and, through Adam’s disobedience, humanity fell into sin (Gen. 3; Rom. 5:12–21). Total depravity says that sin has so twisted us that apart from grace, we love other things more than we love God. Our minds, our bodies, our affections, our spirits—every part of us has been affected by sin, and of our own accord, we cannot escape this predicament. God has not stopped loving His creation, however (John 3:16). And in His love, He restrains sin, keeping us from being as bad as we possibly could be. Thus, even those who do not know Christ can do things that are outwardly good. They can be good neighbors, love their children, and so on. However, outside of grace, none of us does these things with the right motivation to love and glorify God.
Unconditional Election
U stands for unconditional election, which is part of God’s solution to our total depravity. The fall into sin, of course, did not surprise God. He knows the end from the beginning and has ordained history as part of the outworking of His plan and purposes for all things (Isa. 46:8–11; Eph. 1:11). The Lord would have been just to keep us in our state of sin and estrangement from Him, but He decided to set His special love on His people, choosing to redeem them and restore to them their status as God’s children. Unconditional electionis God’s loving choice of specific sinners for salvation without respect to any good in them(Rom. 9:1–29). His saving love for us isnot conditioned on our intelligence, our looks, our kindness, our social status, or anything else. He loves His people not because they are less sinfulthan others. Everydescendant of Adam and Eve (except for Christ) is a sinner. Unconditional electionsays that God chooses to save some people and to pass over others. He has a love for some people that He does not have for others. If you are a Christian, it is because in eternity past, long before you were born, God chose to love you with His saving love. He did not choose youbecause you were better than others. He did not choose youbecause He knew you would choose Him if He gave you the chance. He simply chose to love you, and since His love is not conditioned on anything in you, He will never stop loving you.
Limited Atonement
L stands for limited atonement, which describes God’s intent behind the death of Christ in providing salvation. The question is, Did Christ intend to atone for the sins of all people who have ever lived, or did He intend to atone for the sins of the elect only? Another way of putting it: Did God love people generally, without reference at all to them as individuals, and send Christ to die to provide a possibility of salvation?
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Written by Grover E. Gunn |
Monday, November 15, 2021
Paul is also here arguing for an inclusive salvation, a salvation that includes all believers, both Jews and Gentiles. I think that that argument is furthered by the Apostle Paul’s reference to the land promise given to Abraham as a promise that ultimately refers not just to the land of Canaan but to the whole earth.

When God made the covenant of circumcision with Abraham in Genesis 17, God made this promise to Abraham:
“And I will establish My covenant between Me and you and your descendants after you in their generations, for an everlasting covenant, to be God to you and your descendants after you” (Gen 17:7).
This didn’t mean that God was promising that every descendant of Abraham would end up going to heaven. We know that from reading redemptive history, from considering descendants of Abraham such as Ishmael and Esau, descendants of Abraham who were cast out of the covenant community for their disobedience. What this promise meant was that God was establishing a covenant community consisting of Abraham and His descendants, and that this covenant community would be a special and unique place of divine blessings. God gave the pagan nations up to vile passions and over to a debased mind, but God would be the God of Abraham and His descendants. The covenant community would be a special place of spiritual privilege just as surely as the gospel offer is sincere and genuine. This is where the word is preached, where prayers are prayed and where worship is offered to God in spirit and truth. This is also the place where many come to a saving knowledge of Jesus Christ.
That was such a wonderful promise that God made to Abraham, the promise the God would be Abraham’s God and also the God of Abraham’s descendants. We believe that this promise remains true today under the new covenant. The Philippian jailor asked Paul and Silas what he had to do to be saved, and they answered, “Believe on the Lord Jesus Christ, and you will be saved, you and your household.” That is another way of expressing the promise that God made to Abraham, the promise that God would be Abraham’s God and the God of Abraham’s descendants.
Yet there are obviously differences between the way God administered His covenant with Abraham and the way God administers the new covenant with us today. The covenant that God made with Abraham involved the circumcision of the male children born into the covenant community. We don’t use circumcision as a religious initiation sacrament today. We use baptism with water, and we don’t limit its application to boys. God promised the land of Canaan to Abraham and Abraham’s descendants. We as Christians in American don’t claim any property rights in the Middle East.
Many argue that if that is the case, then we have no right to claim the promise that God will be the God of believers and their children. If we don’t circumcise our children and if we don’t claim ownership of any real estate in Canaan, then the promise, “I will be your God and the God of your descendants,” does not apply to us either. They say that it was a package deal, and that if any of it was set aside, then all of it was set aside. They say that our children who have not yet professed faith are not in any way a part of God’s covenant community.
How do we answer that argument? What is our relationship to the covenants that we find in the Old Testament? I would argue that our relationship with the Old Testament is not an all or nothing proposition. I would argue that the choice is not between total change and no change. I would argue that you shouldn’t throw the baby out with the bath water, and I would also argue that you shouldn’t think that you have to keep the bath water in order to keep the baby. These are not the only choices. There are other options, other possibilities.
Let me share with you my understanding. There was a crucial event in history that marked the transition of God’s covenant people from covenant childhood to covenant adulthood. That crucial event was the saving work of Jesus Christ in history. And the saving work of Jesus Christ in history culminated in His pouring out His Holy Spirit upon His people in new covenant fullness on the Pentecost of Acts chapter two. Before that event, the covenants had a form and administration that were appropriate for the people of God in their covenant childhood. After that event, the covenants have a form and administration that are appropriate for the people of God in their covenant adulthood. There was a transition from one to the other recorded for us in the book of Acts. We find in the New Testament the guidance that we need to understand the differences in the childhood administration and the adulthood administration of God’s covenants. Christians today are directly under an administration of the covenant of grace called the new covenant, and the new covenant is a continuation of the Abrahamic covenant in a form suited for the covenant adulthood of this age of the Holy Spirit.
Here is what the Apostle Paul had to say in Romans 4:13:
For the promise that he would be the heir of the world was not to Abraham or to his seed through the law, but through the righteousness of faith.
What I believe that the Apostle Paul is doing here is taking a promise that God gave to Abraham in terms of old covenant childhood and then applying it in the Apostle Paul’s time in terms of new covenant maturity. In the book of Genesis, every time that God promised to give something to Abraham or to Abraham’s seed, that which was promised was the land of Canaan (Genesis 12:7; 13:15; 15:18; 24:7). The same is true of every such promise that God gave to Isaac and to Isaac’s seed (Genesis 26:3-4) and every such promise that God gave to Jacob and to Jacob’s seed (Genesis 28:4,13; 35:12; 48:4). These promises always referred to the Old Testament land promise. Also, in Romans 4:13, the Apostle Paul was referring to a promise that was given not through law but through the righteousness of faith. This would point especially to Abraham’s encounter with God regarding which we are told that Abraham believed in the LORD, and the LORD accounted it to Abraham for righteousness. And look at what God promised Abraham in that very encounter found in Genesis chapter 15:
“I am the LORD, who brought you out of Ur of the Chaldeans, to give you this land to inherit it” (v. 7)
“To your descendants I have given this land, from the river of Egypt to the great river, the River Euphrates …” (v. 18)
Now the promise that God gave to Abraham and to Abraham’s seed through the righteousness of Abraham’s faith was a promise to inherit the land of Canaan. And the Apostle Paul referred to this promise as a promise to inherit the world. Now why did the Apostle Paul change the language here? I believe that he did so because he was interpreting the land promise of the Abrahamic covenant in terms of the new covenant and the age of spiritual maturity.
The land promise had an application consistent with the age of the old covenant, the age of covenant childhood. God promised the land of Canaan to Abraham, Isaac and Jacob, and their seed. About four centuries after Abraham, the descendants of Abraham, Isaac and Jacob conquered the land of Canaan under the leadership of Joshua. Later King David subdued all the enemies within the land, and King Solomon had peace on every side around him. Thus, King Solomon was able to say,
 “Blessed be the LORD, who has given rest to His people Israel, according to all that He promised. There has not failed one word of all His good promise, which He promised through His servant Moses” (1 King 8:56).
In this way, God fulfilled His land promise in its old covenant application and form.
Yet God’s promises, fulfilled in their original form, are often harbingers of even greater things to come. They are like seeds that germinate and break through the shell of their original form into fulfillments that surpass original expectations. There were some indications of greater fulfillments in the land promise as it was originally given to Abraham. God repeatedly told Abraham that both he and his seed would be a blessing to all the families of the earth and to all the nations of the earth. Yet I think that the Apostle Paul had additional reasons for believing that the promise of the land of Canaan ultimately referred to a promise of the entire world as the inheritance of God’s covenant people.
I think that the Apostle Paul could see such reasons by looking back before the time of Abraham to the time of Adam and Eve in the garden of Eden. God blessed Adam and Eve and said to them,
“Be fruitful and multiply; fill the earth and subdue it; have dominion over the fish of the sea, over the birds of the air, and over every living thing that moves on the earth” (Genesis 1:28).
God gave Adam and Eve dominion over all the earth, and yet God initially entrusted them with only a small but choice piece of real estate, a garden within the land of Eden. God told Adam to guard that garden, to protect it from any invasion of evil, and to cultivate that garden, to make it even more fruitful and productive. I believe that if Adam had kept covenant with God through obedience, that he would have been able to expand the garden and to fill it with his offspring until the garden reached to the very ends of the earth. Yet Adam did not guard the garden when Satan invaded it through his agent the serpent. Adam fell into sin, became an outlaw along with Satan and forfeited his dominion over the earth.
Let’s now go forward to the time of Noah. The earth had become dominated by perversion and violence, and those who still worshiped God had dwindled down to the family of Noah. In judgment, God cleansed the earth with a universal flood. Out of all humanity, only Noah and his family were delivered from that judgment through the safety of the ark, the ark being a picture of Jesus Christ as Savior. In the flood, we have the imagery of a new creation. As originally created, the earth was a chaotic watery abyss that was hostile to life. It was without form, without the order necessary to sustain life, and therefore it was void of life. During the flood, the earth again became without form and void, and no life dependent upon breathe could survive except for those safe in the ark. Then God began His work of a new creation. In the original creation, God began His work by sending His Spirit to hover over the watery abyss like a bird. In the new creation after the flood in the days of Noah, God sent His wind to pass over the earth, and the waters resided. The Hebrew word for “wind” is the same as  Hebrew word for “Spirit.” In the original creation, the Spirit had hovered over the watery abyss like a bird. In the new creation in the days of Noah, Noah sent out a dove to confirm that life had returned to the earth. The symbolism of the dove was confirmed when the Spirit of God descended upon Jesus like a dove at the time of His baptism with water.
After this world had been cleansed by a watery judgment and then restored as a place that sustained life, there was another fall into sin in the rebellion at the tower of Babel. God then used the judgment of confused languages to create the nations. God allowed the nations to go their own ways and gave them over to their sinful rebellion. God, however, also chose one man to be the father of a nation that would be God’s special treasure, a holy nation of priests. That man was Abraham. God promised Abraham and Abraham’s descendants a small but choice piece of real estate that was located at the crossroads of three continents: Africa, Asia and Europe. God promised Abraham and his seed a place that could become a spiritual oasis in the midst of a spiritually hostile world. It was in a sense and to a degree a new garden of Eden. And since God promised that Abraham and his seed would be a blessing to all the nations, we shouldn’t be surprised that this land promise would one day expand to encompass the whole world.
By looking back in time before Abraham, we see the parallel of the land of promise given to Abraham with the garden of Eden given to Adam. Then by looking forward in time after Abraham, we find confirmation that the land promised to Abraham was indeed a token and pledge of something bigger and better. The land promise was a promise that would eventually expand to encompass the whole earth. Listen to a prophecy made about the then coming Messiah, the Messiah who would be the ultimate Seed of Abraham. And as you listen to these words, remember that the River, a reference to the Euphrates River, was the northern boundary of the land promised to Abraham.
He shall have dominion also from sea to sea, and from the River to the ends of the earth (Psalm 72:8).
Also consider the prophecy found in Zechariah 9:10, the verse immediately following the prophecy that the Messiah would enter Jerusalem one day riding on a donkey, a prophecy fulfilled by the triumphal entry of Jesus into Jerusalem at the beginning of His passion week.
His dominion shall be “from sea to sea, and from the River to the ends of the earth” (Zechaiah 9:10).
The Messiah will have dominion from sea to sea, perhaps a reference to the promised land between the Mediterranean Sea to the west and the Dead Sea and the Sea of Galilee to the east. That is not surprising, but the Messiah will also have dominion from the Euphrates River, the northern boundary of the land promised to Abraham, to the very ends of the earth. The land promise under the Messiah expands to include the whole earth.
We see this fulfilled when the resurrected Jesus receives the nations as His inheritance and is given all authority in heaven and on earth. We see this fulfilled when Jesus commands His disciples to disciple the nations. We further see this fulfilled in the age to come when the people of God as the seed of Abraham inherit for eternity the new heavens and the new earth.
“For as the new heavens and the new earth which I will make shall remain before Me,” says the LORD, “So shall your descendants and your name remain” Isaiah 66:22).
What this all points to is what the Apostle Paul took for granted. Paul simply stated without any argumentation that the promise which God made to Abraham or to Abraham’s seed was a promise that he would be the heir of the world. Paul is here arguing for a salvation that is both exclusive and inclusive. It is exclusive in that it excludes all boasting. Verse 13 continues that argument in that the land promise was given through the righteousness of faith and not through law. One of the times when God gave the land promise to Abraham was His appearance to Abraham in Genesis chapter 15 and the verse that Paul repeatedly quotes:
And [Abraham] believed in the LORD, and [the LORD] accounted it to him for righteousness (Genesis 15:6).
Here was see what Paul called the righteousness of faith and a justification that excludes all boasting. It was a gift of grace, grace being God’s undeserved favor. Abraham believed in a promise of God whose ultimate fulfillment was dependent upon Jesus and His saving work. God then reckoned that faith to Abraham as Abraham’s righteousness because Jesus was the ultimate object of that faith. God reckoned or accounted the righteousness of Jesus as Abraham’s legal record. That is a salvation that excludes all boasting.
Paul is also here arguing for an inclusive salvation, a salvation that includes all believers, both Jews and Gentiles. I think that that argument is furthered by the Apostle Paul’s reference to the land promise given to Abraham as a promise that ultimately refers not just to the land of Canaan but to the whole earth.
You will hear many people today claiming that the land promise given to Abraham does not today belong to Christians in any sense but instead finds its fulfillment in the modern nation of Israel founded in 1948. I would encourage you to listen instead to what the Apostle Paul has to say about the land promise in Romans 4. Also, if the land promise belongs to us today in a new covenant form, then so does the promise that God made to Abraham that He would be the God of both Abraham and His descendants. Let us take full advantage of that promise by worshipping with our children with the people of God on the Lord’s Day, by praying for our children and by living out a life of faith before our children. Remember what the Apostle Paul said about Timothy in his last letter. He said that he was filled with joy when he remembered the genuine faith that was in Timothy and which first dwelt in Timothy’s grandmother and mother (2 Timothy 1:4-5). May God grant us such joy regarding our own children as well.
Dr. Grover Gunn is a Minister in the Presbyterian Church in America and is pastor of MacDonald PCA in Collins, MS.