Safeguarding Our Unity: RPR’s Citation of a Woman Preaching

By Matt Fender | June 9, 2023

Image Credit: 2ragon via Adobe Stock

Editor’s Note: What follows is a public response to a public criticism of a committee recommendation before the 50th General Assembly of the Presbyterian Church in America (PCA).

The Review of Presbytery Records (RPR) Committee has recommended to the 50th General Assembly of the Presbyterian Church in America (PCA) that Metro New York Presbytery be cited to appear before the Standing Judicial Commission (SJC) for finding that one of its churches and one of its Teaching Elders did nothing wrong when they allowed a woman to preach a sermon during Sunday morning worship. The Assembly should approve this recommendation. To do so is a proper exercise of review and control under our Church’s well-established polity. Presbyteries are not a law unto themselves, and when such a gross breach of the Scriptures and our Constitution occurs, the offending presbytery must be called to account by the General Assembly.

What is Review and Control and How Does it Work?

The polity of the PCA is an inherently federal system. Specific powers are delegated to the several courts of the Church: the session, the presbytery, and the General Assembly. Others are reserved for congregations (e.g. calling a pastor or voting to leave the PCA). This distributed system is reinforced by a system of checks on the power of the various bodies to which power is entrusted. Decisions of lower courts can be brought to higher courts through various methods, including appeals, complaints, and references (see Book of Church Order [BCO] 39).

One very important – but perhaps less well-understood – means of ensuring the courts of the Church abide by the Constitution and the Scriptures is review and control as set forth in BCO 40. Paragraph 40-1 provides as follows:

It is the right and duty of every court above the Session to review, at least once a year, the records of the court next below, and if any lower court fails to present its records for this purpose, the higher court may require them to be produced immediately, or at any time fixed by this higher court.

In practical terms, this means that presbyteries review session minutes, and the General Assembly reviews presbytery minutes. Most (likely all) presbyteries have a standing committee assigned to this task. The PCA General Assembly has its committee for the review of presbytery records (RPR) which is governed by Rules of Assembly Operation (RAO) chapter 16. This particular committee consists of one representative from each presbytery (RAO 8-5).

The designated RPR committee members meet each year prior to the General Assembly. Members are split up into ‘read teams’ with responsibility for the various presbyteries. Members then read the minutes of the presbyteries assigned to their teams, and each team submits a proposed report on its assigned presbyteries. The committee as a whole then meets for two very long days and part of a third to go over the proposed reports, debate various points, offer amendments, and ultimately produce a report to the GA.

If RPR finds discrepancies in presbytery minutes either due to poor record keeping or dubious practice, it has four options. First, it can provide a notation to the presbytery indicating a minor clerical error, as outlined in RAO 16-6(c)(3). No response is required to a notation, and it is communicated only to the presbytery and does not appear in the report to GA. Second, RPR can find an exception of form, as described in RAO 16-6(c)(2). These include violations of the guidelines for keeping minutes, and violations of the rules of order are typically reported under this category. Exceptions of form are also reported only to the presbytery in question, and no response is required.

For more serious violations, RPR can find an exception of substance. To quote from the RAO 16-6(c)(1): “Apparent violations of the Scripture or serious irregularities from the Constitution of the Presbyterian Church in America, actions out of accord with the deliverances of the General Assembly, and matters of impropriety and important delinquencies, and any noncompliance with RAO 16-3.e.5 should be reported under this category.” Exceptions of substance are included in RPR’s report to the GA. They can be debated on the floor of the Assembly when the report comes up, and the findings can be amended. If an exception of substance is approved by the Assembly, the presbytery in-question is required to provide a response to RPR, and the next year’s committee will judge whether the response is adequate.  Sometimes the presbytery in-question and the GA, through RPR, can go back and forth for several years. Relevant to this article is the fourth option: a citation to appear before the Standing Judicial Commission (SJC). This process is described in BCO 40-5. The first paragraph reads as follows:

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.
(emphasis added)

In the case of the General Assembly, RPR recommends the citation and includes that recommendation in its report. If the Assembly approves the recommendation, then the RPR officers appoint a member of RPR to prosecute the matter before the SJC. The matter then becomes an SJC case. The presbytery in-question is expected to appoint representatives to defend the matter, and if the SJC decides the matter for the GA and against the presbytery, the presbytery is subject to censure.

What is the Present Case About?

The RPR recommendation to the 50th GA regarding Metro New York Presbytery is found on page 4114 of the report.  The recommendation itself is as follows:

f. That the 50th General Assembly:

a. Find that the minutes of Metropolitan New York Presbytery (September 20, 2022;  pp. 69–71) constitutes a “credible report” of “an important delinquency or grossly  unconstitutional proceedings” (BCO 40-5) in Presbytery’s delinquency to redress a Session who admitted to unconstitutional proceedings of: (1) permitting a woman to expound the Scriptures during a worship service on the Lord’s Day; (2) holding many worship services without preaching; and (3) serving the Lord’s  Supper at many services without a preceding sermon. Furthermore, Presbytery was delinquent in failing to redress the views of a Teaching Elder who stated his approval of said proceedings.

b. Cite Metropolitan New York Presbytery to appear, per BCO 40-5, before the PCA’s Standing Judicial Commission which the 50th GA constitutes its commission to adjudicate this matter, by representative or in writing, at the SJC’s fall stated meeting, to “show what the lower court has done or failed to do in the case in question,” following the Operating Manual for the SJC, particularly chapter 15; and

c. Direct the CRPR Officers to appoint one or more representatives of the GA and Report (OMSJC 15.2) to present this case to the SJC.

An extensive rationale is included in the RPR report that makes the case for this citation and includes lengthy quotation from the Metro New York Presbytery minutes. Significantly, this is not a situation where there is a tangential mention in the minutes that requires more information. If that were the case, an exception of substance would be the appropriate action. Here, rather, the Presbytery conducted an investigation, and the Church in-question made elaborate response, answering written interrogatories as to what went on. No additional information is required, and all an exception of substance would do is delay the matter. Here is the rationale from the RPR report:

Rationale: There are two major reasons for citing the Presbytery to appear before the SJC to redress the delinquency of the Presbytery. Pages 69-71 of Presbytery Minutes contain the following language:

As requested by the Presbytery, the Shepherding Team followed up with [church name omitted] in response to concerns raised from outside the Presbytery about a recent female guest speaker at their church.

[Church name omitted] reports that they invited [a female minister of another denomination] to speak in their worship service on Sunday, October 31, 2021. Her remarks were presented as a Bible study, not as a sermon. Before the invitation to the Lord’s Table, an authoritative word of exhortation was given by the Senior Pastor, setting the sacrament in the context of the Word.

[Church name omitted] reports that a mistake was made in posting Dr. [name omitted]’s talk on their church website. Because of website presets, when the talk was initially posted it was inadvertently identified as a sermon. This error was quickly rectified, and the recording is now identified as a Bible study.

TE [name omitted] stated that while he believes that what happened was within biblical bounds, he does apologize for the confusion caused and will strive to operate with more wisdom as a session and church.

The first reason the presbytery should be cited to appear before the SJC deals with the egregiousness of the issue. The cultural zeitgeist of egalitarianism continues to exert pressure on the church, and it is vitally important for the purity and peace of the church that we honor and implement the Biblical prohibition on women teaching (1 Tim 2:12).

The second reason reflects the reality that the Presbytery fully investigated this incident, discovered a number of grossly unconstitutional proceedings, and took no action to redress the situation after the investigation.

During the investigation, the following grossly unconstitutional proceedings were reported and recorded in the minutes:

● A woman read and expounded the Scriptures in a “Bible study” (listed in the bulletin as a “message”; pp. 69, 70) during a Lord’s Day worship service, contrary to BCO 4-4, 8-5; WCF 21.5; WLC 156, 158.

● While the church attempted to distinguish the “Bible study” from a “sermon,” the church also acknowledged that they celebrated the Lord’s Supper after the “Bible study,” which was preceded by “an authoritative word of exhortation was given by the Senior Pastor, setting the sacrament in the context of the Word” (pp. 69–70). This is contrary to the constitutional requirement that the Lord’s Supper should follow a sermon (BCO 58-4).

● Furthermore, the church admitted that the church has “had many services without a ‘sermon’ by an ordained minister. We have had many different people speak during the service at various times: seminary students, visiting missionaries…, etc….Our practice, since we celebrate Communion weekly, is that one of our pastors always ‘adds’ an additional word of biblical exposition just before we come to the Lord’s Table” (p. 70). In addition to the issue named above, requiring a sermon to precede the celebration of the Lord’s Supper, this general neglect of preaching is contrary to the constitutional requirements for worship services, as reflected in BCO 4-4; WCF 21.5; WLC 35, 108.

After these facts were ascertained during the investigation, the Presbytery found “no further reason to pursue this matter” (p. 71). In this finding, they became delinquent in failing to redress grossly unconstitutional proceedings from a church in the Presbytery and the views of the Teaching Elder who stated his approval of said proceedings.

Ultimately, Presbytery’s failure to take remedial action on this matter should be referred to the SJC (2023 RPR Report pp. 4114-4115 [emphasis in original indicating material quoted from Metro New York Presbytery minutes]).

Note that RPR also recommends citing the Presbytery for failing to redress the administration of the Lord’s Supper without an accompanying sermon, and for holding worship services without a sermon. These additional gross violations of the PCA’s Constitution stem from the offending Church’s attempts to circumvent the scriptural limitations on eligibility to preach. It is also worth mentioning that at the time of the RPR meeting, the “Bible study” was still posted on the church’s website and described as a sermon.


If allowing a woman to preach during a Sunday morning worship service is not an “important delinquency or grossly unconstitutional proceeding,” then I am at a loss for what is. While I hope the obvious result here – that the GA should approve the RPR recommendation to cite Metro New York Presbytery – is self-evident, I fear there may be an attempt on the floor to amend the Report and strike this recommendation or change it to an exception of substance. Any such effort should be rejected. The PCA is not a loose federation of churches. We are united by our Constitution and our commitment to the Scriptures. The actions complained of here egregiously violate both, and the matter must be redressed.

Matt Fender is a PCA Ruling Elder serving on the session of All Saints Presbyterian Church in Richmond, VA.

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