Can a Temporary Session Impose a Pastor on a Church Plant?

By Ryan Biese | October 11, 2023

Image Credit: Shutter2U via Adobe Stock


How a church-plant, or “mission church,” (BCO 5-1) transitions to become a “Particular Church” is outlined in BCO 5-9.

Until a “mission church” becomes a particular church, the church plant is usually under the care of a Presbytery by means of one of two temporary arrangements. In the first arrangement, a commission of elders from the Presbytery is appointed to serve as a temporary session (BCO 15-1). In the second arrangement, the “mission church” is erected as a daughter church of another particularized congregation (BCO 5-3b), and the session of that particularized congregation serves as the overseeing session for the mission church.

A mission church is usually served by a “church planter” who is also a member of the commission serving as session (BCO 5-4a). This church planter is called by Presbytery to do the work of ministry organizing the church plant/mission work with the hopes that it will one day be particularized according to the steps outlined in BCO 5-9.

A crucial step toward becoming a particular congregation is the election of a pastor and other  officers.

The election of a Teaching Elder can sometimes be confusing in the case of a mission work. Ordinarily, a church plant already has had a Teaching Elder ministering as a “church planter” among the saints in that congregation for quite some time. In many instances, the members of the church plant will elect that church planter “to be their pastor” (BCO 5-9f), but not always.

If the members of a congregation “choose not to continue the pastoral relationship” with the church planter, they are free to follow the steps of BCO 20 to elect a different pastor in the ordinary manner.

Before the Standing Judicial Commission (SJC) last year, there was a curious case that tested the principles of our Presbyterian polity and challenged the integrity of our Constitution regarding the selection of a pastor by a church plant.

A group of men from a mission work met with the session – including the church planter – overseeing the plant to express their desire that candidates other than the initial church planter be considered for the position of pastor.

It was an undeniable difficult situation. The church planter had labored for years, investing much of his time and energies in the church plant. But now a group of men from several households in the congregation went to the elders and expressed a disagreement with the church planter’s philosophy of ministry and vision for the work.

The Session responded to the men’s concerns by doing three things. First, the Session demanded the men repent of any sin whether of omission or commission against the church planter. Second, the Session demanded the men reaffirm their membership vows. And third, the Session reaffirmed its belief that one of their number should be “offered to the congregation as a candidate to serve as its pastor.”

Eventually the men from the membership of the church plant were investigated, indicted, convicted, and censured by the Session before the Session subsequently resigned and paid out severances of nearly $100,000 of the church plant’s funds to the now-disbanded church staff. I have written more on the particulars of this case here.

The SJC eventually exonerated the church members of the unconstitutional charges and censures imposed on them by the temporary session. In his concurring opinion to the SJC’s decision, RE Jim Eggert offers a number of helpful reminders regarding the selection of a pastor in a mission church:

1. A Congregation picks its own pastor. “No man, however gifted or qualified, may be thrust upon a congregation by a court of the Church without the congregation’s consent.” This means that if a temporary session (BCO 15-1) believes the church planter is the man who should be the pastor of the congregation, it can merely proffer a recommendation, but the members of the mission congregation are free to disagree. RE Eggert observes, “The fact that the appointees of a provisional Session are not even members of the mission churches they govern serves only to accentuate the encroachment on a congregation’s rights if such a provisional Session seeks to exert its preference in selection on members of a congregation” (50GA Handbook p. 2075). This principle is set forth clearly in Preliminary Principle Number 6, which RE Eggart applies in this way: “The inalienable right of church members to either elect or consent to those placed over them applies alike to mission churches as it does to settled congregations” (p. 2076).

2. An Organizing Pastor is not entitled to be called as the Pastor of the Church. An Organizing Pastor (church planter) is called by Presbytery to minister in a church plant, but only the congregation can call a pastor: “In the case of a mission church, the right of selecting a minister at particularization is, in principle, no different than the right prescribed for an established church, except that the appointment of a pulpit committee is entirely optional for the mission congregation” (p. 2077).

3. A Temporary Session has no right to impose its own candidate upon a congregation. In the particular instance described above, despite the vocal opposition of a significant portion of the mission congregation, the temporary session continued to recommend one of their number be set before the congregation to be elected pastor. RE Eggert notes in no uncertain terms: “Session had no lawful authority” to impose its preferences of who should be the first candidate for pastor considered by the Congregation. The Session believed one of their number should be “offered to the congregation as a candidate” (p. 2069), and seven men from the congregation disagreed. But the temporary session was “acting outside of its function and risks encroachment on congregational prerogative” (p. 2078).

4. Members of a mission church have the right to disagree with the members of their temporary session regarding who their pastor will be. The core of the issue addressed by the Eggert concurrence was a disagreement between a temporary session and some of the members of the congregation they were supposed to be serving and shepherding. All church members have a duty to honor their leaders, “to submit to the government and discipline of the Church, and to study her purity and peace.” But this submission does not mean members of a mission congregation must have their consciences bound by the preferences and recommendations of a temporary session comprised of men who are not members of the congregation. When the Session admonished the accused for opposing their recommendation of one of their own number for pastor, “the Session encroached on the exclusive right of these members of the congregation to select their minister, specifically by encroaching on the rights of the Accused to seek to satisfy their own conscience in both selecting and seeking the selection of whomever they deemed suitable, for reasons sufficient to them, to be their pastor” (p. 2078).

Christ has purchased liberty for His people, and the consciences of His people are subject to the Lordship of Christ alone. When a Session attempts to impose its own preferences on the sheep committed to its care, it binds the consciences of Christ’s sheep. This is especially the case in the selection of officers. If a member feels pressured or forced to select a pastor because he or she is threatened with discipline otherwise, this does violence to our Presbyterian system of government and tramples the Crown Rights of Christ our King, the Lord of the Conscience.

Ryan Biese is a PCA Teaching Elder serving as Pastor of First Presbyterian Church (PCA) in Fort Oglethorpe, GA.