NOTE: Missouri Presbytery (PCA) is the ecclesiastical authority over Pastor Greg Johnson and the elders of Memorial Presbyterian Church. Pastor Johnson and Memorial hosted the first Revoice 18 conference one year ago in St. Louis. The second Revoice (19) will soon be held, once again in St. Louis.

Responding to national pressure from inside and outside their denomination, Missouri Presbytery put together an investigatory committee and just issued their ReportThis is sixth in a series of close readings. For all Warhorn articles on Missouri Presbytery’s Revoice Report, see here. Report text is indented. We pick up where we left off last time.


NOTE: Unless otherwise indicated, all footnotes are from Missouri Presbytery’s Report.

D. Principles of Inquiry and Judgment
We underscore at the outset that we were erected by Presbytery to be a committee not a commission.

Here are the provisions our committee was working under. A letter was received by Missouri Presbytery (MOP) in the early part of October 2018 from Memorial Presbyterian Church and included two requests: one from TE Greg Johnson, who requested of MOP a Book of Church Order (BCO) 31.2 investigation. Here is that section in the BCO:

31.2. It is the duty of all church Sessions and Presbyteries to exercise care over those subject to their authority. They shall with due diligence and great discretion demand from such persons satisfactory explanations concerning reports affecting their Christian character. This duty is more imperative when those who deem themselves aggrieved by injurious reports shall ask an investigation.

If such investigation, however originating, should result in raising a strong presumption of the guilt of the party involved, the court shall institute process, and shall appoint a prosecutor to prepare the indictment and to conduct the case. This prosecutor shall be a member of the court, except that in a case before the Session, he may be any communing member of the same congregation with the accused.1

This last paragraph might make it sound that any finding of guilt, at any level, automatically triggers a movement on Presbytery’s part into a formal trial. We must keep in mind however, that the BCO has been an evolving handbook of rules and processes.

A finding of some level of guilt in a minister does not automatically launch us into a formal trial. Evidence for this is found in a later section (BCO 31.7, which most certainly can be appealed to at the end of a BCO 31.2 process). In 31.7 we see that before instituting a formal trial the Presbytery can send a small team of brothers to reason with the accused man and seek to persuade him to repent. BCO 31.7 reads like this:

31.7. When the prosecution is instituted by the court, the previous steps required by our Lord in the case of personal offenses are not necessary. There are many cases, however, in which it will promote the interests of religion to send a committee to converse in a private manner with the offender, and endeavor to bring him to a sense of his guilt, before instituting actual process.

No arguments here.

1. Principles of Justice and Process in Our PCA Polity
Since the allegations against Memorial Presbyterian Church (Memorial) regarding their decision to host the Revoice 18 conference were based on allegations of serious theological error in the teaching of Revoice, it was incumbent on the committee to assess those allegations against Revoice before assessing the alleged errors of TE Greg Johnson and the Memorial Session in hosting the conference and in doing a poor job of highlighting doctrinal problems with Revoice, both before and after the conference.

The committee began by considering BCO 29 which provides the basic definition of an offense and therefore the basis of any judicial action:

29.1. An offense, the proper object of judicial process, is anything in the doctrines or practice of a Church member professing faith in Christ which is contrary to the Word of God.

Additionally, the following paragraphs in our Book of Church Order, Chapter 34 (especially 34.2, 34.5, and 34.6) regarding process against a minister, were kept central as we investigated the allegations against TE Greg Johnson and as we dealt with the allegations against the Memorial Session sent up to us from them by a BCO 41.1 reference. As the CIM we judged that the core principles of justice enumerated in BCO Chapter 34 ought to govern not only our judicial (judicial in the broad sense of investigating elders under our authority) investigation of TE Johnson, but also the Memorial Session’s role in their decision to host Revoice 18; and that those principles should also govern our assessment of the theological teachings of Revoice, as we found them in the talks of the Revoice 18 speakers and in their writings and teachings in other venues.

Here are the relevant paragraphs of BCO 34 (with key words bolded):

34.2. As no minister ought, on account of his office, to be screened in his sin, or slightly censured, so scandalous charges ought not to be received against him on slight grounds.

34.3. If anyone knows a minister to be guilty of a private offense, he should warn him in private. But if the offense be persisted in, or become public, he should bring the case to the attention of some other minister of the Presbytery.

34.5. Heresy and schism may be of such a nature as to warrant deposition; but 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.

34.6. If the Presbytery find on trial that the matter complained of amounts to no more than such acts of infirmity as may be amended, so that little or nothing remains to hinder the minister’s usefulness, it shall take all prudent measures to remove the scandal.

It is true that 34.6 envisions a trial, but we understood the basic principles enunciated in that paragraph to be relevant to all doctrine-related investigations of ministers or courts of the church (whether a 31.2, a 41.1, or a 40.5 investigation) especially in light of BCO 31.7 which encourages a court to consider visiting a minister in private before judicial process is begun.

Note carefully the texts Missouri Presbytery highlights in bold. Each of these texts telegraphs to readers the arguments they will be making later in their Report.

So, for instance, from the texts in bold above, we learn Missouri Presbytery’s Committee is going to claim Memorial Presbyterian Church’s Session and Pastor Greg Johnson are guilty of “errors,” but that those errors do not “strike at the vitals of religion” and are not being “industriously spread.”

Rather, those errors “arise from the weakness of human understanding and are not likely to do much injury.”

Relevant also to this situation are the stipulations in BCO 40.5. Here is the BCO text in full:

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 first step shall be to cite the court alleged to have offended to appear before the court having appellate jurisdiction, or its commission, by representative or in writing, at a specified time and place, and to show what the lower court has done or failed to do in the case in question.

The court thus issuing the citation may reverse or redress the proceedings of the court below in other than judicial cases; or it may censure the delinquent court; or it may remit the whole matter to the delinquent court with an injunction to take it up and dispose of it in a constitutional manner; or it may stay all further proceedings in the case; as circumstances may require.

Again, Missouri Presbytery’s Committee uses bold typeface to telegraph to readers that the reports of error are not “credible”; but even if credible, they are not “any important delinquency or grossly unconstitutional.”

In the first paragraph above we find spelled out the right and responsibility of a higher court in requiring from a lower court an accounting when there are credible reports made against that lower court, alleging that they are guilty of some delinquency—but not just any delinquency: the reports must have evidence which is credible that the said delinquency is an important delinquency; and/or the report must have the same kind of credible evidence that an unconstitutional proceeding is not merely unconstitutional but grossly unconstitutional.2

It is our judgment that this language in BCO 40.5 ought to be interpreted more broadly than the language of BCO 34.5, as 40.5 seems to have in view not simply doctrinal teaching of ministers that may be erroneous or divisive (which seems to be the focus of BCO 34.5) but any and all “constitutional” breaches that a lower court may have committed. This could include such “important” negligence as failing to examine a man’s theological views before ordaining him, or failing to give a minister the opportunity to speak in defense of his actions or views at a trial after charges were found in order, etc.

It could also include such “important” negligence as Missouri Presbytery committed in not themselves bringing charges against Memorial Presbyterian Church and Pastor Johnson, but only adjudicating the matter when Memorial and Pastor Johnson forced them to do so.

The upshot is that when it comes to assessing doctrinal teaching done by or sanctioned by (explicitly or implicitly) a lower church court, BCO 40.5 constrains Presbytery to ask the questions, “By what criteria should we judge whether there has been a delinquency at all, and if so, whether it was an ‘important’ delinquency? And were there any ‘unconstitutional’ proceedings,and if there were, by what criteria do we judge whether they were ‘grossly’ unconstitutional or not?”

Yes yes, we know this will be your conclusion, so stop talking about it and do your dirty work already.

We believe that when reports and allegations of misconduct are about doctrine, the BCO implicitly allows us to interpret the general terms of 40.5 (important delinquency and grossly unconstitutional proceedings) in the light of the more specific terms of 34.5 where the possibility of false or schismatic teaching seems to be primarily in view. In 34.5 we are called upon to distinguish between “errors” which strike at the vitals of religion and are industriously spread or, on the other hand, “errors” that arise from the weakness of the human understanding and are not likely to do much injury. In other words, at least with regard to doctrinal allegations, we are not left without a criterion for whether a court is guilty of committing an important delinquency or engaging in grossly unconstitutional proceedings. The criterion is that the teaching in question must not only be judged to be doctrinal “error,” but also error of such a serious nature as to strike at the vitals of religion.

Yes yes, we get you. Get to the point, please.

What this means in practical terms is that in order for us to judge the Memorial elders and pastor to be guilty of an important delinquency and/or a grossly unconstitutional proceeding in allowing the outside group, Revoice, to use its facilities for its conference, we have to judge them to have been guilty of permitting and then leaving unchallenged certain doctrinal “errors” taught by Revoice. But we also have to conclude that these doctrinal errors of Revoice were not simply errors, but errors so serious that they strike at the vitals of religion (in faith or morals) AND as well, are industriously spread.


Or to say it differently

Please don’t.

we approached our assessment of the Revoice teaching and Memorial’s actions in hosting the Revoice conference, with the view that we might find some of the teachings of Revoice to be errors that are industriously spread—since Revoice continues to exist and to teach its views—and that are errors so serious that they do strike at the vitals of religion; or that we might find some of the teaching to contain errors, but of a kind that do not strike at the vitals of religion AND are not likely to do much injury since they are the result, principally, of the weakness of human understanding, and are acts of infirmity that may be amended. Or, we realized, we might find errors of both species—or even some that are “mixed” (e.g., errors that are likely to be “industriously spread,” if Revoice continues to teach them but nevertheless are judged not to be errors that strike at the vitals of religion).


These two species of error set out in BCO 34.5 we regard as pivotal.

No kidding.

We appreciate the exhortation of the BCO that even upon finding what we consider to be genuine doctrinal error, a court should then take great care to carefully consider these errors and separate them out, if need be, into those that are more serious for strik[ing] at the vitals of religion (i.e, those errors that deny or fatally undermine key doctrines of the faith and morals of the Word of God) and those that are less serious for being able to be understood as acts of infirmity resulting from the weakness of human understanding. We take the phrase, “the weakness of human understanding” not simply to refer to a failure to understand a doctrine accurately enough to teach/preach it well, with all the clarity and care it deserves, but more comprehensively, so as to include also any fault in discerning what doctrinal truths, or boundaries, or caveats, or applications a given situation calls for, given its context. Hence, there are errors in doctrinal teaching that are still errors, but are best judged to be the result of carelessness, immaturity, benign neglect, imprudence, ignorance, superficiality, onesidedness, etc.

“Carelessness, immaturity, benign neglect, imprudence, ignorance, superficiality, onesidedness, etc.”

We could add credulity, naivete, artlessness, callowness, childishness, gullibility, ingenuousness, etc.

Thus, in our process we considered BCO chapters 29, 34, and 40 in determining whether either Revoice or Memorial committed errors that strike at the vitals of religion or simply errors resulting from the weakness of human understanding. Both our judicial and theological judgments as well as our recommendations are informed by these considerations of our polity.

Okay, we got it. Let’s move on.


This is sixth in a series of close readings. For all Warhorn articles on Missouri Presbytery’s Revoice Report, see here. The series will continue.

Thankful for this content? Let others know:

1Words bolded within the text of the BCO below are our emphases, calling attention to them for their particular relevance to the situation before us.
2 It is true that the criteria for judgment in BCO 40-5 are different than those set out in BCO 34.5. In BCO 40.5 we read that if a “report” alleging wrongdoing in a lower court—meaning, presumably, a report that is not just empty and unsubstantiated gossip but rather an allegation that comes to the higher court with some evidence that is arguably credible—then the higher court shall take such and such steps with regard to the court under its jurisdiction. In 40.5 the wrongdoing alleged against the lower court is not referred to as the “error” in two kinds set out in BCO 34.5, but instead the wrongdoing in 40.5 is referred to as any important delinquency or grossly unconstitutional proceedings. [This paragraph should be moved to a footnote at the end of the previous paragraph]

Tags: , , ,