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At its March 3-4 meeting the Standing Judicial Commission (SJC) of the PCA concluded its handling of matters related to Missouri Presbytery’s investigation and adjudication of the 2018 Revoice Conference conducted at Memorial Presbyterian Church in St. Louis, MO. The SJC sustained Missouri Presbytery’s actions on two matters in the complaint, but ruled that the presbytery erred regarding at least three specific judgments related to a third matter in the complaint when the presbytery adjudicated the actions of Memorial Presbyterian Church. 

The SJC also determined that these rulings answer and conclude all matters related to overtures from three presbyteries that had requested the General Assembly assume original jurisdiction to try these matters. 

Issues before the SJC

In July 2018, Revoice held its first conference at Memorial Presbyterian Church in St. Louis, a PCA congregation in Missouri Presbytery (MOP). The conference generated controversy in the evangelical community, and especially in the PCA. Ultimately, three matters related to Memorial’s hosting Revoice came before the PCA’s Standing Judicial Commission (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 to make final determination of his guilt or innocence and, if warranted, impose censure. This complaint became SJC Judicial Case 2020-12.
• A complaint, also filed by TE Speck, charged MOP with error in approving six theological judgments concerning Revoice and Memorial’s involvement with the Conference. The complaint also charged that MOP erred by denying a point of order he had raised, and by refusing to debate and rule on the propriety of gay couples adopting children. This complaint became SJC Judicial Case 2020-05.  
• Overtures from three presbyteries (Central Georgia, Savannah River, and Southeast Alabama) requested that the GA assume original jurisdiction (the right of a court to hear a case for the first time) over MOP’s failure to bring TE Johnson to trial under a Book of Church Order (BCO) provision allowing two presbyteries to request GA to do so when a presbytery refuses to act “in doctrinal cases or cases of public scandal” (BCO 34-1). These presbyteries argued that Johnson should have been brought to trial, and that, therefore, MOP had “refused to act.” This has been identified as SJC 2020-02.

The full SJC held a hearing on 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. The SJC decision may be found here. The following summary is designed to aid someone interested in the case but not well acquainted with PCA judicial procedure.

Case 2020-05: Background

 After the Revoice 18 conference was held at Memorial in July, 2018, the church Session began to receive communications questioning the teachings of the conference and the propriety of Memorial’s hosting it.  On October 10, 2018, TE Johnson and the Memorial Session wrote a letter to MOP requesting, among other things, that Presbytery accept, as a Reference under BCO 41, a request to investigate the allegations leveled against Memorial pertaining to hosting Revoice 2018. BCO 41-1 permits a lower court to ask a higher court to provide advice or take other action on “a matter pending before the lower court.” At its meeting later that month MOP agreed to Memorial’s request. A Committee to Investigate Memorial (CIM) was set up. This Committee established the criteria for the conclusions it would draw from its investigation primarily from two BCO chapters:

• BCO 40, in particular, BCO 40-5: “When any court having appellate jurisdiction shall receive a credible report with respect to the court next below of any important delinquency or grossly unconstitutional proceedings of such court . . . “ The CIM understood that it was tasked to determine whether or not the Memorial Session had committed any important delinquency or grossly unconstitutional proceedings. Where in the BCO could CIM go to determine if hosting Revoice constituted an “important delinquency” or was “grossly unconstitutional”?
• CIM turned to BCO 34, and BCO 34-5 in particular, to answer that question: ”errors ought to be carefully considered, whether they strike at the vitals of religion and are industriously spread or whether they arise from the weakness of the human understanding and are not likely to do much injury. ” 

Thus, CIM addressed this question: In hosting Revoice, did Memorial commit errors that strike at the vitals of religion or were they simply errors resulting from the weakness of human understanding? When the CIM reported to MOP in May, 2019, it proposed 9 Theological Judgments that reflected these criteria. These judgments were adopted by Presbytery. 

In July TE Speck complained against Presbytery’s adoption of these judgments. A Committee was established to review this complaint (we’ll call it CRC1 for reasons that will soon become apparent). At MOP’s meeting in October 2019, CRC1 recommended that MOP partially sustain TE Speck’s complaint and reconsider the 9 Theological Judgments at a called meeting in December. Presbytery approved these recommendations. TE Speck moved that the following question be added to the docket for that meeting: “Did Revoice err by encouraging gay couples and gay individuals to adopt children and, if so, is this a serious error that [MOP] needs publicly to correct and clearly warn against?” The motion was defeated.  

At the December meeting, MOP adopted an amended statement of eight of the nine theological judgments and referred the remaining judgment to an ad hoc study committee. These newly adopted statements included affirmations and criticism of parts of Revoice 18. Presbytery denied a point of order Speck raised concerning materials Presbytery’s Administrative Committee distributed prior to the meeting.

In January 2020 TE Speck filed a complaint against six of the eight theological judgments approved at the December meeting, the denial of his point of order, and MOP’s refusal to debate and rule on gay adoption. At a stated meeting later in January, MOP referred the complaint to a new Complaint Review Committee (CRC2). 

At the July 2020 stated meeting of MOP, CRC2 recommended denial of TE Speck’s complaint, but also recommended revision of two of the theological judgments. Presbytery denied the complaint and adopted one of the recommended revisions (on Spiritual Friendships) but did not approve the other (on Terminology). At the end of July, TE Speck carried his January 2020 complaint to the GA, where it became Case 2020-05.

Case 2020-05: The Decision

In accordance with their normal procedure, the SJC officers assigned the case to a panel made up of three principals and two alternates drawn by lot from the SJC membership. This panel conducted the hearing of the case in September 2021 and in their proposed decision recommended that the complaint be denied. When the full SJC met on March 3, it adopted the following decision. 

The Primary Issue

Three issues raised by the complainant were identified. The SJC sustained the complaint regarding one of them: At its December 7, 2019, Called Meeting, did MOP err in approving six theological judgments (specifically, Judgments # 1-5 and #9) recommended by CIM? Complainant’s specifications of the errors concerned:

MOP Theological Judgment 1 (“Origins of Homoerotic Desire”).

MOP Theological Judgment 2 (“Terminology”).

MOP Theological Judgment 3 (“The Gay Beneath the Gay”)

MOP Theological Judgment 4 (“Gay Identity”).

MOP Theological Judgment 5 (“Spiritual Friendship”).  

MOP Theological Judgment 9 (“Roman Catholic Speakers”).

The SJC ruled that MOP did err in approving Theological Judgments 1-5 and 9, particularly with regard to Judgments 2, 3, and 5, and identified two matters that account for the error: (1) incorrect criteria for review in adjudicating the allegations within the complaint (2) failure to act properly regarding the findings of CIM and CRC 1&2, in applying the incorrect criteria.

Incorrect criteria for review

As indicated above, CIM (and in following their lead, MOP) mixed language from BCO 40 and BCO 34 to evaluate the actions of Memorial regarding Revoice. By doing this, the SJC ruled, MOP limited “any important delinquency or grossly unconstitutional proceedings” to “Heresy and schism . . . [that] strike at the vitals of religion and are industriously spread.”  This was incorrect because it created a criterion for evaluating the actions of a court (BCO 40-5) based on the (demanding) Constitutional standard used when commencing process against a teaching elder (BCO 34-5). The SJC further ruled that CIM and MOP, in adopting this standard, appear to have overlooked Constitutional material that deal specifically with the responsibilities of courts:

• BCO 11-4: “Every court has the right to resolve questions of doctrine and discipline seriously and reasonably proposed, and in general to maintain truth and righteousness, condemning erroneous opinions and practices which tend to the injury of the peace, purity, or progress of the Church.”
• BCO 11-3 says that “disputed matters of doctrine and order arising in the lower courts” may be “referred to the higher courts for decision.” 
• BCO 13-9f. provides the proper criterion for Presbytery as the higher court to make such a decision: if an “opinion” is not only “erroneous” but also “injure[s] the purity or peace of the Church,” then Presbytery may “condemn” that opinion.

In summary, by incorrectly setting the bar for being concerned about what happened when Memorial hosted Revoice so high (delinquency only exists if “the vitals of religion” are attacked), proper criteria – a “lower level” of error that injured the purity and peace of the church – was not properly addressed. 

Failure to act on the findings

In an investigation, the criteria for review determine what you are looking for. When a committee is looking only for heresy, schism, or matters that strike the vitals of religion, you would expect its report would reflect finding or not finding those things.

But the SJC observed that the reports of the CIM and the CRC, as well as the Theological Judgments MOP adopted at their recommendation, reflect serious concerns about matters that should have been addressed – yet the Committees did not recommend action the Presbytery should take in response, nor did the Presbytery take action. The SJC noted this was particularly the case in material related to Theological Judgments 2, 3, and 5. The SJC Decision provides just over four pages of examples and commentary about this. The following paragraph provides a helpful summary of their conclusion:

Although MOP registered concern with respect to the teachings of Revoice 18 in view in Theological Judgments 2, 3, and 5, it declined to take further action than it did. MOP unnecessarily restrained itself by the incorrect criteria for review that it opted to follow in evaluating the teachings of Revoice 18. Consequently, it did not take adequate action with respect to the errors that it had identified (Theological Judgments 3, 5), and with respect to teachings that it identified as “confusing to some and potentially unwise” (Theological Judgment 2) …. 

The Other Issues

The SJC denied the complaint on the other two issues:

• Did the MOP err when it acted to deny TE Speck’s point of order regarding the Administrative Committee’s handling of the December 7, 2019 meeting? The SJC answered “no”, arguing: (1) the question concerned a violation of MOP’s Standing Rules, not the PCA Constitution, and MOP itself is the proper authority for interpreting its rules; (2) the BCO does not address the point TE Speck made regarding materials the Administrative Committee distributed prior to the meeting; and (3) while the Presbytery Clerk did err in part of his characterization of the materials in question,  it was harmless as to the outcome of the vote at the meeting.
• Did the MOP err when it acted to refuse to debate and rule on the propriety of gay couples adopting children, as TE Speck suggests was advanced at Revoice 18? Again, the SJC answered “no.” The Commission noted that the CIM discovered that Revoice 18 had not advocated gay adoption, though one guest invited by one of the speakers had made an off-hand remark in the course of a particular conversation that could have been construed as such. The Commission expressed sympathy with TE Speck’s desire for MOP to address the issue raised by this comment, but as this was not a position advocated by Revoice 18, it was not a proper subject of a theological determination about that conference. 

Case 2020-05: What is Missouri Presbytery to Do Now?

In SJC parlance, this is the “Amends.” BCO 43-10 says that, after hearing a complaint carried from a lower court, “The higher court 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 this case, the SJC has instructed MOP to “hold a new hearing.” This hearing is to focus only 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?”  In undertaking this review, 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.

2020-02: Decision Regarding the Overtures Requesting the SJC Assume Original Jurisdiction

The SJC answered these Overtures by reference to its Decisions in Cases 2020-05 and 2020-12 (the official text of this answer may be found here). This means that the overtures from Central Georgia, Savannah River, and Southeast Alabama Presbyteries, requesting that the General Assembly (GA) itself try these matters that were before MOP, have now been adjudicated by the SJC (acting for the GA). According to our Book of Church Order such matters would only have come to the General Assembly if at least a third of the SJC believed that its judgments were in error. However, in this case the rulings of the SJC were nearly unanimous. 

This concludes the matters that have been before the SJC related to Revoice 18 involving TE Greg Johnson, the Session of Memorial Presbyterian Church, and Missouri Presbytery.