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Presented to the Ninety-first (2025) General Assembly of the Orthodox Presbyterian Church
| General Assembly reports are thoughtful and weighty treatises on important matters but they are not constitutional documents. Only the Confession of Faith and Catechisms, the Form of Government, the Book of Discipline, and the Directory for the Public Worship of God of the Orthodox Presbyterian Church express the church’s official understanding of what the Word of God teaches. |
This report presents to the 91st (2025) General Assembly the results of one year of study, which we hope will be helpful to sessions, churches, and presbyteries in the Orthodox Presbyterian Church, and beyond.
In response to an overture from one of our presbyteries, the 90th General Assembly erected the “Special Committee on Criminal History and Officer Qualifications” (CCHOQ) consisting of three ministers and two ruling elders to “study ways a criminal history affects a repentant man’s ability to serve in ordained office in the church of Christ with specific attention given to crimes of a violent or sexual nature” and “offer recommendations for ways such a potential candidate may be vetted for office and what special accountability might be put into place if such a man is ordained.” The Assembly also adopted the following statement:
In light of the transformative and renewing power of the gospel (e.g., 1 Corinthians 6:9–11, Ephesians 2:1–10, Titus 3:3–7), and in consideration of the biblical examples of Moses, David, and the Apostle Paul, we affirm that those with a criminal past can serve faithfully in ordained office in Christ’s church. However, there are some crimes and some contexts in which ordination should not be pursued, due to the scandalous nature of some sins, and the necessity for ordained officers to be exemplary in character, above reproach, and well thought of even by unbelievers. This decision must ultimately be left to the wisdom of local sessions and/or presbyteries, who ought to ask the Lord of the harvest to provide men fitting to rule His church.
These words remind the committee and readers of the report that this report only offers advice, for the decision on whether to ordain a particular man “must ultimately be left to the wisdom of local sessions and/or presbyteries.” This report is not a binding document, nor does it answer every question on the subject of criminal history in the life of a man being considered for ordained office. The goal of this report is to offer assistance to the churches and presbyteries of the OPC as to what Scripture reveals on this subject and practical issues that may arise.
Serving on the committee are three ministers, Eric R. Hausler (chairman), Robert S. Arendale (secretary), and Andrew J. Miller, and two ruling elders, Michael C. Cloy and Alan W. Montgomery. The committee met in person twice in Naples, FL, and several times via videoconference. The committee met with a variety of individuals, some who had been previously incarcerated, including some church officers, as well as with those who work with former convicts and those who have been impacted by the presence of former convicts in ministry settings.
The most relevant pastoral and theological loci to the question of how a criminal history affects potential ordination are fourfold: First, the doctrine of sin. As the statement above notes, “the scandalous nature of some sins” must be taken into consideration. Second, the doctrine of repentance. What should repentance look like in the life of a candidate for office with a criminal history, particularly when those crimes are of a “violent or sexual nature”? Third, the particular biblical qualifications for office; how do these apply in such cases? Fourth, the report examines how the ordination of men with a criminal history relates to the church’s responsibility to protect the flock.
Finally, the report offers summary observations and makes a recommendation to the 91st General Assembly. There is no minority report.
The Bible’s first explicit mention of sin emphasizes its danger: “sin is crouching at the door” (Gen. 4:7). Sin is personified there, suggesting its link to the serpent who instigated the fall and bruises heels. Thankfully, God had just promised a solution to both the sin and serpent problem, providing a visible illustration of forgiveness through animal sacrifice, covering over guilt by the shedding of blood (Gen. 3:21). Thus, even as we unfold the unsavory nature and dangers of sin below, we remember that Christ, the Snake-Crusher, has destroyed the power of the devil and is able to save “to the uttermost” those who come to him in faith (Heb. 2:14; 7:25).
Sin has far-reaching consequences, even in human lives redeemed by the blood of Christ. The Westminster Confession of Faith (WCF) 6.5 states, “This corruption of nature, during this life, doth remain in those that are regenerated . . . although it be, through Christ, pardoned, and mortified.” While God has been pleased to use many people powerfully after a history of great sin, biblical data suggests that there can also be long-term and ongoing repercussions of sin, even for those who repent. Below we survey the biblical doctrine of sin relevant to the question of the ordination of persons with a criminal history.
God’s Word speaks of some sins in extremely negative terms: for example, “vile abominations” (Ezek. 8:9); “with a high hand” (Num. 15:30); and “an outrageous thing” (Josh. 7:15). Jesus likewise spoke of “the greater sin” in comparison to a lesser sin (Jn. 19:11). WCF 15.4 notes that, “As there is no sin so small, but it deserves damnation; so there is no sin so great, that it can bring damnation upon those who truly repent.” In other words, even what we might consider a “small sin” brings condemnation before God and requires the pardoning grace of Christ, as Westminster Larger Catechism (WLC) 152 also affirms. This affirmation makes clear that by “sin’s aggravations,” we are not speaking in terms of the Roman Catholic Church’s distinction between “mortal” and “venial sins,” mortal sins bringing true guilt and death and venial being lesser, “which only lessens the love of God in our heart, makes us less worthy of God’s help, and weakens our power to resist ‘mortal sin.’”[1] As Robert Shaw puts it, “We admit that a great variety in the degree of guilt attaches to different sins; but we maintain that every sin is worthy of death.”[2]
WCF 15.4’s reference to a “small” sin leads into the assertion of WLC Q&A 150 that some sins are “more heinous in the sight of God than others.” WLC 150 answers, “All transgressions of the law are not equally heinous; but some sins in themselves, and by reason of several aggravations, are more heinous in the sight of God than others.” WLC 151 answers the question, “What are those aggravations that make some sins more heinous than others?” This is explored below in relation to the ordination of men who have committed heinous sins.
The greater the age of the offender, the greater the heinousness of the sin (WLC 151.1). With age should come maturity and understanding. As Bavinck writes, “the guilt of violation is greater or less to the degree the commandment was violated more or less intentionally,” and cites Paul’s appeal to ignorance in 1 Tim. 1:13.[3] Luke 12:47 features this as well: “And that servant who knew his master's will but did not get ready or act according to his will, will receive a severe beating.”
The WLC also measures the heinousness of a sin by the person offended. While all sin is first and foremost against God (Ps. 51:4), WLC 151.2 notes it is particularly evil to sin against, for example, “particularly weak brethren.” Even if this is merely taken as a reference to the “weak brethren” of Romans 14, general equity allows us to apply it more broadly to those weaker than ourselves. Sin is aggravated when it is against the vulnerable, as accords with Mark 9:42: “it would be better for him if a great millstone were hung around his neck and he were thrown into the sea.” Along these lines, WLC 151.3 is particularly relevant: sin is more heinous if it is “against the express letter of the law,” and “the light of nature,” which would encompass, for example, murder and rape. Worth noting is that many of these categories overlap: when someone “relapses after repentance,” as in WLC 151.3, in their relapse, they are sinning as a person more knowledgeable (WLC 151.1) than they were the first time they committed the sin. Further, a pattern of crime is usually more egregious than a punctiliar crime, though not always.
Additionally, one crime may “break many commandments,” such as rape, which breaks at least the sixth, seventh, and eighth commandments: harming life, committing adultery, and taking what does not belong to one. This is not to mention the sins that occur in the heart before taking place in action. WLC 151.3 also notes that the heinousness of a sin is increased by the scandal it causes. While our non-Christian neighbors may have a different scale of values than we do, they do share God’s law imprinted on the heart which they cannot truly suppress (Rom. 1:18–21), and the Scriptures call us to a life that even non-Christians can respect (e.g. 1 Tim. 3:7; 1 Thess. 4:12; Titus 2:8; 1 Peter 2:12). WLC 151.4 likewise speaks of a sin being aggravated if it occurs “in the presence of others, who are thereby likely to be provoked or defiled.” Furthermore, as will be mentioned again below, sin is more heinous if it “admits of no reparation,” which applies to cases of violence. Johannes G. Vos comments, “For example, the sin of theft admits reparation; a person who has stolen a sum of money from his neighbor can pay the money back. But the sins of murder and adultery do not admit of reparation; when once the wrong is done to our neighbor, there is no way by which it can be undone.”[4]
The more heinous and aggravated a person’s sin, the more incumbent it is on sessions and presbyteries to ensure that the guilty party is truly repentant. This is not done out of malice or a desire for vengeance, but love for the offender, the church, and Christ’s honor.[5]
The foregoing section shows that when considering the ordination of a man who has committed violent crimes, the nature of the crime may entail deeper scrutiny and caution. Thus, an ordaining body may find that an armed robbery, where violence was threatened but not engaged, is less egregious than a gruesome assault. Both cases are typically less aggravated than murder.
Important for an ordaining body to discern is how the heart of a man has been changed—it is not enough for him simply to have increased his self-control. James 4 roots quarrels, fights, and murder in the heart: “What causes quarrels and what causes fights among you? Is it not this, that your passions are at war within you? You desire and do not have, so you murder. You covet and cannot obtain, so you fight and quarrel” (vv. 1–2a). In other words, ordaining bodies would be wise to uncover the idols of the heart that led to the sin in the first place, and then endeavor to determine how those idols have been mortified. For example, an ordaining body would do well to ask a repentant offender how he has since responded to similar temptations. If a person committed a violent crime, it would be fitting to look for change in terms of present protection of life: according to the WLC (135–6), the sixth commandment calls everyone to “careful study . . . and lawful endeavor” to preserve our own life and that of others. It explains that there are things we do that “tend to the unjust taking away [of] life.” Such things include (but are not limited to) “sinful anger, hatred, envy, desire of revenge; all excessive passions, distracting cares; immoderate use of meat, drink, labor, and recreations; provoking words, oppression, quarreling, striking, wounding . . .” An ordaining body would do well to evaluate how a repentant violent offender now lives out the positive exhortations implicit in the sixth commandment, using WLC 135 as a guide.
Sessions and presbyteries should also take into account the aggravations of a sexual crime. Consonant with WLC 151 on sin’s aggravations, sins that harm a person against their will are more heinous than those where a person consents. For the present study, this is to say that a repentant sex offender who received that label because of statutory rape is not necessarily in the same category as someone who received that label due to child pornography or pedophilia. Of course, statutory rape is what it is precisely because “consent” is undermined by the immaturity of the younger party. Even in cases of statutory rape, the difference in age between the offender and the victim, and the age and maturity of the victim, must be taken into account as it affects the concept of consent: It is more heinous for a 25-year-old to have consensual sexual contact with a 17-year-old than for an 18-year-old to have consensual sexual contact with a 17-year-old. Each of these cases is grievous and should in no way be minimized.
As will be developed below, various states classify sex offenders in the same way. For example, a man at age 19 who had sexual contact once with a 16-year-old might be categorized by the state in the same way as a serial pedophile. A session or presbytery should look into such matters, so they understand the gravity of a person’s former crimes. It may be that the civil authority has classified such offenders differently, and ordaining bodies would be wise to take these considerations into account, and recognize that there may be value in the state’s reasoning. There is a difference between a sexual predator who preyed on multiple persons, or on young children, and someone placed on the sex offender registry who was 18 and had sexual contact with a single 17-year-old.
Similarly, any sexual offense is theft. For example, an adulterer or a rapist is stealing someone (and something) that doesn’t belong to them. Adultery is also made more grievous by the fact that it takes preparation, and multiple steps.[6] Adultery—and its subset, fornication—does not honor another person, but treats them as objects, things used for pleasure. Adultery manipulates what marital intimacy is designed to honor. David’s sin in 2 Sam. 11 illustrates these points and confirms the common biblical observation that sin is like a web, with various side-effects and aggravations. Sessions and presbyteries should consider such factors in evaluating a man’s fitness for office.
Scripture is clear that sin can have long-term earthly repercussions even when its eternal consequences have been remedied in Christ. For example, David’s sins in 2 Samuel 11 are forgiven, but his child still dies (2 Sam. 11:13–4). Moses was unable to enter the earthly Promised Land, though we have no reason to doubt that he entered into the heavenly Promised Land (Heb. 11:24–28; Deut. 3:23–26). Achan may be another example (Josh. 7:19–26). Likewise, adultery can have lasting consequences as it is biblical grounds for divorce (WCF 24.5). There, a punctiliar, one-time event is sufficient to give a party a right to end a marriage. Thus, the heinous sin of violating one’s wedding vows through an affair, while it can be forgiven by God and by the offended spouse, may have lasting earthly consequences. Even in a case where the marriage is continued after adultery, trust takes time to rebuild and protections should be put in place to guard against relapses.
This means that the commission of some crimes, particularly of a violent or sexual nature, may be forgiven by God but continue to have lasting earthly consequences, including not being able to serve in church office. It must be emphasized, however, that this in no way infringes on the offender’s holding of the “general office” of believer, though churches are wise to put policies and practices in place to monitor any attenders who are on a sex offender registry. Form of Government (FG) III.1 describes the general office of believer: “All believers are endued with the Spirit and called of Christ to join in the worship, edification, and witness of the church which grows as the body of Christ fitly framed and knit together through that which every joint supplies, according to the working in due measure of each part.” Likewise, FG XXX.1 reminds us that, “Every Christian has the freedom and obligation to exercise the general office of the believer not only individually but also in fellowship with other members of the body of Christ” (cf. WCF 26). Alan Strange comments,
Insofar as office denotes duty (Lat. officium, duty), all believers might be said to have a general office in that they have a duty to serve the Lord Christ in his church. All believers have vocations and are to pursue the whole of their lives as unto the Lord (Eph. 6:5–8). As well, all believers have their place of service within the body (1 Cor. 12:12 ff.), often referred to as the “general office of believers.”[7]
Though repentant persons with a criminal background may exercise special office under particular circumstances, they can nevertheless always rejoice in being part of God’s “royal priesthood” (1 Pet. 2:9), “proclaiming the excellencies of him who called [them] out of darkness into his marvelous light.” After writing of the general office of believers, Guy Prentiss Waters adds of Eph. 4:7,
Christ apportions certain gifts to certain believers. There is no ground for jealousy in the church concerning spiritual gifts. If Christ has given me a certain gift, or has withheld a certain gift from me, then I know the following three things: (1) I do not deserve a single gift. By definition, a gift is ‘given.’ If I do not have a particular gift, I have no cause for complaint. If I have a particular gift, I have every reason to be humbled and to be thankful (see Rom. 12:3–6). (2) Christ is Head and King of his church, and not I. He is the one who decides which persons will receive which gifts. (3) Christ has assured me that I and my fellow believers will benefit from my brother’s spiritual gift.[8]
These are fitting reminders for anyone who receives a “not yet” or “no” from the church regarding special office.
Sessions considering ordaining a man to elder or deacon and presbyteries considering ordaining a man as a pastor should keep the deceitfulness of sin in mind. Caution must be taken not only because a repentant felon might be deceiving them, but also because he might not even be able to see his own sinful propensities clearly himself. Several Scripture passages indicate this: “Who can discern his errors? Declare me innocent from hidden faults” (Ps. 19:12); “The heart is deceitful above all things, and desperately sick; who can understand it?” (Jer. 17:9). We can deceive ourselves when it comes to sin (1 John 1:8), and perceive the speck in another’s eye while missing the log in our own (Luke 6:41–42). Sin can remain hidden for a long time: “The sins of some men are conspicuous, going before them to judgment, but the sins of others appear later. So also good works are conspicuous, and even those that are not cannot remain hidden” (1 Tim. 5:24–25). Thus an ordaining body must exercise great caution and patience when considering a man for office. A criminal history requires a prolonged period of testing post-incarceration, showing much fruit of resisting temptation; one question that credentialing bodies would do well to ask is how a man has more recently responded to similar temptations and situations as the ones that previously led to incarceration. Given man’s ability to self-deception, a repentant person with a criminal history should welcome the probing questions of godly friends: “Faithful are the wounds of a friend” (Prov. 27:6), and “Iron sharpens iron, and one man sharpens another” (Prov. 27:17). The realities of justification by faith alone and perseverance of the saints give a believer freedom to be open about their struggles.
When considering individuals that have a criminal history for ordained office, it is important that the term “criminal history” be defined. Criminal history information, as one US state (Pennsylvania) defines it, in part is, “Information collected by criminal justice agencies concerning individuals, and arising from the initiation of a criminal proceeding . . .”[9] Generally, these are offenses which are graded from less serious to more serious on an increasing scale and are identified as misdemeanors, felonies, and criminal homicide. Since criminal history is maintained by the civil government, it is worthwhile to consider how the civil authorities view both acts of a violent or sexual nature and those offenders.
God has established kingdoms and governments. He has ordained them “to be under Him, and over the people, for His own glory and the public good” (WCF 23.1). In a subsequent section of the same chapter, the Confession states, “It is the duty of people to pray for magistrates, to honor their persons, to pay them tribute or other dues, to obey their lawful commands, and to be subject to their authority, for conscience’ sake.” When those “lawful commands” are broken, the civil government determines the severity of the disobedience.
The gradation of criminal offenses of a violent or sexual nature varies from state to state. For example, upon reviewing the Crimes Code of Pennsylvania, crimes of this nature are generally graded as felonies. Aggravating circumstances are considered more heinous and invoke a higher grading of the offense. Such aggravations include, but are not limited to, crimes against minors, crimes against the mentally incompetent, or crimes where a superior/inferior relationship exists between the offender and the victim. When determining the grade of the offense, the civil government also considers the number of prior convictions and the offender’s criminal history.
In addition to the grading of criminal offenses, when considering sexual offenders, Pennsylvania categorizes specific sexual-related offenses in three tiers, with tier one offenses being the lowest and tier three offenses being the highest. All those offenders convicted of a sexual offense are required to be placed on a registry, and upon fulfilling their incarceration/punishment, to verify the registry information on a regular basis. The regularity of that verification and the length of time they are required to be on the registry is determined by the tier in which they are placed. The offender’s registration information is also placed on the National Sex Offender Registry (https://www.nsopw.gov).
Civil authorities have determined that offenses of a violent nature are heinous, against the public good, and deserve commensurate punishment. In addition to the appropriate punishment, those same authorities have determined that those criminal acts of a sexual nature are even more egregious and require additional requirements to maintain the public good, even after the offender has fulfilled their initial punishment.
It is noteworthy for the present topic that the civil authority’s gradation of offenses is consonant with the Scripture’s teaching regarding the degrees of heinousness, as discussed above. The civil authorities have determined that all crimes are not equal; some are more heinous than others. Civil authorities handle crimes (sins) of a violent nature with the most severe degree of punishment, even capital punishment. Though these crimes can incur the severest punishments, civil authorities recognize these too, have several aggravations that determine the degree of punishment. Such aggravations would include forethought or premeditation, committed while perpetrating a violent crime, done recklessly or with gross negligence, to name a few.
Throughout the Scriptures, mention is made of caring for widows and orphans (Ex. 22:22, Deut. 10:18, Deut. 14:29, Deut. 24:17, Ps. 68:5, Ps. 146:9, Is. 10:2, Zech. 7:10, etc.). Even among those who are incarcerated there is a recognition of the heinous nature of crimes committed against the weaker citizens of society. During an interview with a former inmate who was incarcerated for over 20 years, he recounted that inmates looked down upon other inmates who had victimized a woman or a child. When corrections personnel interviewed for this report were asked whether they would consider a sex offender for a church office, without hesitation the response was, “Absolutely not.”
From both the Word of God and the laws of a civil society, violent crimes and crimes of a sexual nature are both heinous. For the public good and protection of her citizens, the God-ordained civil government clearly distinguishes between violent crimes and crimes of a sexual nature in both the way the offenders are handled during the time of their incarceration and in the way they are handled post-incarceration and post-probation. This reality cannot be overlooked, nor understated: crimes of a sexual nature receive additional civil oversight and monitoring of the offender, in some cases, for the duration of their earthly life.
God’s Word is clear: God can change people. “Therefore, if anyone is in Christ, he is a new creation. The old has passed away; behold, the new has come” (2 Cor. 5:17). It is also true that not everyone should be an officer in the church. While God used many men powerfully after a history of evil deeds (King David, John Newton, etc.), there may be not only biblical qualifications that exclude a man from office, but the wisdom consideration: it may not be wise for a session or presbytery to ordain a man to office, given the nature of the offense and the real-life consequences of sin. While guilt can be taken away in Christ, often consequences of sin remain, as examined above. The commission of sins serious enough to warrant criminal charges and civil incarceration have lasting earthly consequences.
Though repentance will be treated further below, note that repentance entails an acknowledgement that one’s sins have forfeited any blessings in this life and even life itself: our guilt makes each of us “justly liable to all punishments in this world, and that which is to come” (WLC 27; also 28 and 152). The attitude of true repentance renounces any demands: “Father, I have sinned against heaven and before you. I am no longer worthy to be called your son” (Luke 15:21). The tax collector beat his breast and stood far off because of his sense of sinfulness (Luke 18:13). A redeemed servant’s heart does not insist on any supposed “right” to the trust of ordination, but is led as a captive in Christ’s triumphal procession, ever submitting to him: “not my will, but thy will be done” (2 Cor. 2:14; Matt. 26:42). Christ is the head of the church, who gives different roles to each of us according to his will. In a way specialized to each person’s own gifts and circumstances, each disciple must reckon with the words of the Savior: “If anyone would come after me, let him deny himself and take up his cross and follow me” (Matt. 16:24).
As we are all prone to self-pity and pride, it might be a temptation for a repentant offender to decry the extra precautions that sessions and presbyteries must take in considering their ordination. Such a person should recognize that they are different from others because of their past; they may feel the burden of having to prove themselves, but their past public sin has made them different in a sense—for example, they have a higher bar to gain the trust of others. But they can look at this as an opportunity to show the transformative work of Christ. God’s grace is sufficient in every test (2 Cor. 12:9).
God’s Word lifts up the importance, beauty, and glory of God-wrought repentance. Westminster Shorter Catechism (WSC) Q&A 87 defines repentance unto life as “a saving grace, whereby a sinner, out of a true sense of his sin, and apprehension of the mercy of God in Christ, doth, with grief and hatred of his sin, turn from it unto God, with full purpose of, and endeavor after, new obedience.” Similarly, John Calvin described repentance as “that by which the sinner, though grievously downcast in himself, yet looks up and sees in Christ the cure of his wound, the solace of his terror; the haven of rest from his misery,” and noted that “repentance consists of two parts—viz. the mortification of the flesh, and the quickening of the Spirit.”[10] God is said to rejoice over the repentance of sinners, and invites others to do the same (e.g., Luke 15). Our study presumes the stated repentance of a man with a criminal history, and this repentance should be appreciated. God has done a wonderful thing. However, because the church does not have God’s ability to perceive the heart with certainty, we must keep watch for fruits in keeping with repentance, that “adorn the doctrine of God our Savior” (Titus 2:10).
The egregious nature of sexual sin creates an odor of shame that can linger for many years even after true repentance is made, and can therefore give the appearance that the man is not above reproach (the meaning of which we will examine further below). Therefore, the aroma of repentance should be unmistakable before considering a man above reproach (1 Timothy 3:2 and Titus 1:6–7).
The Scriptures speak of this aroma of true repentance in Luke 7:36–39 when a notoriously sinful woman washed Jesus’s feet with her tears and dried them with her hair during a banquet in the home of a Pharisee. Uninvited to the banquet, this woman anointed Jesus' feet with the expensive ointment that permeated the room with a pleasant odor of repentance. In a real sense she was casting her sins on Jesus, as she most likely purchased the expensive perfume with money she received from her actions that made her notorious. Although Luke does not identify what these sins are, it is possible the sins were sexual in nature. Jesus, inhaling the aroma of the woman’s true repentance, forgave her sins. Most assuredly she went back into the city with her guilt and shame removed by God. However, the citizens of the city would need evidence of true repentance to see her new life as other than notoriously sinful.
So, how do the Scriptures help the church recognize the unmistakable evidence of the aroma of true repentance in order to determine if a man is above reproach to hold office? In the sections below, we address some of the ways the church should look for evidence of such repentance in a candidate for ordination.
The aroma of true repentance is evidenced by the splendor of holiness (spiritual attractiveness) which is garnered through spiritual maturity over time. WCF 16.2 explains how the fruits and evidence of a true and lively faith adorn the profession of the gospel:
These good works, done in obedience to God’s commandments, are the fruits and evidences of a true and lively faith: and by them believers manifest their thankfulness, strengthen their assurance, edify their brethren, adorn the profession of the gospel, stop the mouths of the adversaries, and glorify God, whose workmanship they are, created in Christ Jesus thereunto, that, having their fruit unto holiness, they may have the end, eternal life.
James 2:18 and 22 remind Christians that their works manifest their faith in Christ. A true profession of faith bears fruit. This profession will be known outside of the church, as 1 Peter 2:12 commands to “Keep your conduct among the Gentiles (pagans) honorable, so that when they speak against you as evildoers, they may see your good deeds and glorify God on the day of visitation.”
Evidence of spiritually attractive good works that testifies to a true and lively faith and enhances an officer’s ecclesiastical authority is outlined by the Apostle Paul in 1 Timothy 3. He is to be a husband of one wife, temperate, sober-minded, of good behavior, hospitable, able to teach, not given to wine, not violent, not greedy for money, but gentle, not quarrelsome and not covetous (1 Tim. 3:2–3). Sexual sins involve egregious violence, extreme behavior that is far from being gentle as they are nested in deep sexual covetousness. Likewise, the aroma of repentance is evident in honoring and submitting to authority, especially someone who is being considered as an officer of the church. In this way, a man shows his temperateness, sober-mindedness, and gentleness. A body considering the ordination of a man with a violent criminal history should go above and beyond to interview a potential ordinand’s friends and family to ensure, as much as they are able, that he exhibits gentleness today.
WCF 16.3 provides help to understanding spiritual maturity over time:
Their ability to do good works is not at all of themselves, but wholly from the Spirit of Christ. And that they may be enabled thereunto, beside the graces they have already received, there is required an actual influence of the same Holy Spirit, to work in them to will, and to do, of his good pleasure: yet are they not hereupon to grow negligent, as if they were not bound to perform any duty unless upon a special motion of the Spirit; but they ought to be diligent in stirring up the grace of God that is in them.
The Confession, utilizing Phil. 2:12–13,[11] speaks of working out one’s salvation and God’s working in a person in terms of duration of time when it uses the word diligence. Diligence can be defined as careful and persistent work. For men to be qualified for office they must present a body of work. Any man who has been criminally convicted of sexual sin must have more time to demonstrate to the church and to the world the grace of God that is in them because of the egregious effects of sin on all relationships both inside and outside the church.
Reformed theology insists that a person’s actions are only one aspect—albeit a critical aspect—of sin. We sin against God daily in “thought, word, and deed” (Westminster Shorter Catechism [WCF] 82 and WCF 33.1). Our actions reveal our hearts (e.g., Matt. 7:16; Prov. 4:23; Matt. 15:19; Luke 6:45). Likewise, the Reformed confessions on good works reflect this holistic picture where the heart matters. Heidelberg Catechism 91 and WCF 16.7 note that an action must be motivated by true faith (cf. Heb. 11:6), conform to the standard of God’s law, and be done for God’s glory (1 Cor. 10:31). In other words, sessions and presbyteries looking for the mortification of sin in a candidate should not only consider their abstaining from heinous sinful deeds, but also seek evidence of changed desires. Although we cannot read minds, one’s actions do give an indication of progress. “Let the thief no longer steal, but rather let him labor, doing honest work with his own hands, so that he may have something to share with anyone in need” (Eph. 4:28). Here a repentant thief shows the fruit of repentance by doing the opposite of taking from others: sharing. Such is a reflection of a generous heart.
Another way of saying this is that we are called to be a certain “sort of people” (2 Pet. 3:11). This means that true and lasting heart change should be sought not only in terms of abstinence from criminal behaviors, but positively in terms of the presence of corresponding virtues or character traits (cf. Gal. 5:16-26; Eph. 4:22–24). Does a man with a history of violent behavior now show forth the utmost gentleness? Can he be said to be a person of gentleness?
Personal moral agency spans both the civil and the ecclesiastical domains. Both require justice. Both require accountability, restitution, and amends. However, the church seeks a justice of true repentance in Christ. The world seeks a justice of conformity to the law. Geerhardus Vos reminds the church that the justice it seeks is different from the justice of the world:
Ecclesiastical and civil dealings with sins do not exclude each other but run parallel. That someone has borne his civil punishment and so is once again right with the civil authority does not vindicate him before the church. It can also occur that in one way or another civil law does not condemn him while there are still reasons to deal with him ecclesiastically. The church need not conform to the opinions of worldly justice. It has its own administration of justice, and is itself responsible to God.[12]
Vos reminds church officers to uphold the good order and peace of the church because God’s justice is a matter of the heart. Distinguishing between true repentance and its counterfeit with respect to sexual sins is helped by understanding Biblical accountability, restitution, and amends. 2 Corinthians 7:10 is a sound starting point for officers and congregations to determine if a sexual offender is living godly sorrow or worldly sorrow: “For godly grief produces a repentance that leads to salvation without regret, whereas worldly grief produces death.” Those who demonstrate godly sorrow will submit to accountability, restitution, and amends without reservation.
Realizing the potential notorious effects of their sin on the sheep, accountability without reservation should be evidenced by any person with a criminal background involving sexual sin. They must humbly submit to the will of the session without objection and accept the requirement for total disclosure of their sin to the session as an expression of trust and transparency to those overseeing their spiritual welfare and for the protection of the sheep. This baseline accountability for known sexual offenders should be required for membership in the church before any discussion of being considered as a church officer. Men being considered as an officer of the church must embrace ecclesiastical and civil accountability as a means of communicating public godly sorrow as a “creature naked and exposed to the eyes of him to whom we must give account” (Hebrews 4:13).[13]
God’s Word enjoins restitution without reservation, as evidenced by the offender seeking to restore what was taken from its original estate and adding a fifth, Lev. 6:1–5, Luke 19:1–10. Restitution for sexual sin is difficult as the person offended normally does not want any form of communication or contact, even through third parties. The spiritual and physical harm by the sinful joining of flesh creates a shame that is spiritually damaging to the soul that can never be restored to its original innocence. This is one reason why sexual sin is so egregious. Nevertheless, the sexual offender must be able to communicate to his session the desire to make restitution although it realistically might not be met. The sexual offender also must communicate with the session what the civil courts have required of him for terms of restitution and if he has completed these terms.
Given the goodness of repentance and the glory it gives to God, a repentant offender should be willing to be open with others about his history. Given the grievousness of some offenses, prudence in speaking of such matters is required. However, repentance without reservation is evidenced by the news of repentance being at least as widespread as public knowledge of the sin.
Likewise, Matthew 5:23–24 speaks of the importance of reconciliation, where possible: “So if you are offering your gift at the altar and there remember that your brother has something against you, leave your gift there before the altar and go. First be reconciled to your brother, and then come and offer your gift.” This shows the importance of being restored to someone against whom a repentant person has sinned. One intent of amends is to make a relationship right in a way that will make sense to the person who was sinned against. This is not always possible given the nature of some offenses because of “no-contact” orders.
So, amends without reservation is evidenced by the sexual offender desiring to make things right and to live peaceably with those they have sinned against. But the sexual offender also understands that his amends must be received with respect to Romans 12:16–18, “if possible” by the person sinned against. However, even if it is not practically or legally possible to make amends, the sexual offender must be able to communicate to his session the desire to make restitution.
Unquestionably, one of the most significant and relevant realms of biblical content for the possible ordination of men with a criminal history are the biblical texts related to officer qualifications. Our mandate assumes the repentance of the individuals in question, and asks how a criminal history affects a person’s ability to be ordained and to serve in office. Therefore, we are assuming that various qualifications not related to that criminal history have been satisfied. The three texts that seem to us most relevant are 1 Tim. 3:1–7; Acts 20:28; and 1 Tim. 5:22. Below is a brief exegesis of the relevant texts followed by several observations.
1 Timothy 3:1–7 (ESV) reads:
The saying is trustworthy: If anyone aspires to the office of overseer, he desires a noble task. Therefore an overseer must be above reproach, the husband of one wife, sober-minded, self-controlled, respectable, hospitable, able to teach, not a drunkard, not violent but gentle, not quarrelsome, not a lover of money. He must manage his own household well, with all dignity keeping his children submissive, for if someone does not know how to manage his own household, how will he care for God's church? He must not be a recent convert, or he may become puffed up with conceit and fall into the condemnation of the devil. Moreover, he must be well thought of by outsiders, so that he may not fall into disgrace, into a snare of the devil.
Most relevant to the matter at hand are two phrases in this text, the first being “above reproach” in 1 Tim. 3:2, and the second being “he must be well thought of by outsiders” in 1 Tim. 3:7.
The calling to ecclesiastical office is a high calling and a noble desire, therefore certain qualifications are necessary. In one Greek sentence comprising fifty-seven words (vv. 2–6), Paul enumerates several character traits that are to mark the overseer of the congregation of God’s people. Seven positive traits are mentioned in v. 2, the first of which, “above reproach,” merits brief consideration. The term translated “above reproach (ESV)” is only used in two other places in the New Testament, both of which are in 1 Timothy (5:7; 6:14).[14] The term indicates a general blamelessness in all areas of life. As Barcley states, “[irreproachable] is a general term, which encompasses the moral and interpersonal qualities that follow. In all areas of life, an overseer must be a person of character and integrity, having a blameless reputation with others.”[15] Mounce adds, “It cannot mean that an overseer must be free from any sin, internal or visible, but the emphasis here is on the type of external personal reputation that would be a credit to the church.”[16] Gordon Fee notes that what is specifically in view is irreproachable ‘observable’ conduct[17]. The shepherd of God’s flock is to be a man of integrity marked by a general blamelessness. He is to be one the people in the pew look to follow and to emulate. The considerations throughout this report have shown the difficulty of considering a man “above reproach” who has a criminal history of heinous sexual sin, even after he has shown various fruits of repentance.
Paul’s seven positive character traits in v. 2 are followed by four disqualifiers in v. 3. Following a statement regarding reputable household management in vv. 4–5; Paul cautions against ordaining recent converts in v. 6. While vv. 1–6 highlights the ‘view’ of the candidate for office from within the covenant community, in v. 7 Paul speaks to the importance of the ‘view’ of the man from outside the covenant community. He writes, “Moreover, he must be well thought of by outsiders, so that he may not fall into disgrace, into a snare of the devil” (v. 7). The inclusion of this requirement speaks to the public reputation of the church. Christians are called to holiness and to adorn the gospel of God. They are called to bear witness to Christ in their conduct before “outsiders.” (cf. 1 Cor. 5:12–13).[18]
Furthermore, 1 Tim. 3:7 alerts us to an additional danger to elders that may be exacerbated by having a criminal history: “Moreover, he must be well thought of by outsiders, so that he may not fall into disgrace, into a snare of the devil.” Knight comments, “A man without a good testimony from outsiders could ‘lose his head’ or ‘senses’ when he fell into reproach and thereby be ensnared to obey the evil one and disobey God.”[19]
Acts 6:3 includes a similar concern: in the selection of the first deacons, the instruction was to “pick out from among you seven men of good repute, full of the Spirit and of wisdom, whom we will appoint to this duty.” The reality of the public perception of the church, particularly how candidates for office are ‘perceived’ by outsiders, raises several questions that ought to be considered by an ordaining body. What is the public perception of a man with a criminal history? What is the public perception of a man with a criminal history that is violent or sexual in nature? Is such a public perception warranted? Again it should be emphasized for purposes of this report: though a man may be repentant and may be walking with the Lord, even for some period of time, his poor reputation before outsiders may persist. Robert Yarbrough comments, “Public perception may well furnish input that someone like Timothy at Ephesus needs to heed in leadership selection.”[20] At a minimum, Paul is calling the church to consider the public reputation of a candidate, whether such a reputation is warranted or not.
In Acts 20:17–35, Paul delivers his farewell address to the elders of the church at Ephesus. After recounting various aspects of his personal ministry, he charges the elders: “Pay careful attention to yourselves and to all the flock, in which the Holy Spirit has made you overseers, to care for the church of God, which he obtained with his own blood” (v. 28). The relevant portion to be considered for this report is Paul’s charge to the elders to “pay careful attention to . . . all the flock.” While this verse stands as the theological center of Paul’s speech, one specific matter needs addressing for this report, namely the comprehensiveness of the elders' care for souls in the local church. The elders are tasked with caring for the whole church. To ask a clarifying question: in this text is each elder specifically tasked with the care for each member of the congregation? It seems to push the bounds of reasonableness to press this verse to such a conclusion. Often in our congregations, for example, elders will be given charge to care for a certain segment of the congregation, perhaps segmented geographically. However, the committee is persuaded that any elder must at a minimum be available to care for each individual soul of the local congregation. Thus, an officer candidate may be functionally disqualified from office if he is not permitted to be in the proximity of a certain demographic due to the specific nature of his crime. To give one example, a repentant pedophile who is walking with the Lord may be prohibited from being within a given proximity of children. Such a prohibition may disqualify one from fulfilling the calling of Acts 20:28 to care for “all the flock.” By good and necessary consequence, this applies to deacons as well. It should be added that a person with a history of sexual abuse would normally be hindered from ministering effectively to a victim of such abuse, further limiting care for “all the flock.”
The objection might be raised that families troubled by a repentant officer’s former sexual offenses could simply find another church. This is problematic for several reasons. For one, sending away families with children who cannot be cared for by a repentant registered sex offender shifts the burden of the elders to be obedient to Paul’s charge to care for “all the flock” to the individual to find another congregation where he/the family can be properly shepherded. Paul’s teaching strongly suggests that all the elders must be able to care for “all the flock.” If an officer has to tell a family, for example, “legally I’m not permitted to care for you,” it translates into, “therefore you need to find another church.” Further, such practice results in a segmented church that violates the catholic nature of the church. The church is one, not divided into special interest branches. Our congregations are Christian churches, not divided up into a church for former criminals and a church without former criminals. As Charles Hodge points out, “You cannot possibly make your notion of a Church narrower than your notion of a Christian.”[21]
In 1 Timothy 5:22, Paul instructs Timothy regarding the ordination of men to special office. He writes, “Do not be hasty in the laying on of hands, nor take part in the sins of others; keep yourself pure.” The reference to “the laying on of hands,” specifically as used in the Pastoral Epistles, brings into view a man’s ordination to office in the local church (cf. 1 Tim. 4:14; 2 Tim. 1:6). Paul cautions against “hastiness” in the ordination of men to leadership in the church. Neither the immediate text nor the surrounding context address the specific reason why one might be hastily placed in office.[22] Paul does state, however, that the overly hasty placing of one in special office may cause Timothy (or the ordaining body) to “take part in the sins” of the unqualified individual. Thus, not only could there be negative consequences on the flock in ordaining unqualified men to office, but also such an act could cloud the integrity of Timothy’s (or the ordaining body’s) leadership in the eyes of the congregation or of the surrounding culture.[23] While there are many specific details in this text not stated, the fundamental point to note as concerns this report is the clear call to wisdom and patience with respect to the ordination of men to special office.
A man’s desire to serve in ordained office is a good thing (1 Cor. 12:31; 1 Cor. 14:1; 1 Tim. 3:1). These offices are precious and significant; as Calvin writes, “This is a great and excellent thing, for men to be set over the Church, that they may represent the person of the Son of God.”[24] The preciousness and spiritual importance of ordained ministry is also why there is great importance in ordaining only qualified men. Every man considering ordained office should do so with a sense of trepidation and unworthiness: “Who is sufficient for these things?” (2 Cor. 2:16). No man comes to office without sin, and every man must come in reliance on the grace of God.
The three texts examined above (1 Tim. 3:1–7; Acts 20:28; and 1 Tim. 5:22) suggest three key considerations for ordaining bodies to consider: First, the public reputation of Christ’s church. The church has a public reputation; and as much as she is able, she should strive to uphold her reputation before the watching world. To not ordain someone to special office out of concern for the church’s public reputation in no way undermines the gospel of free grace and the glorious forgiveness of sins through the finished work of Christ that should be preached from our pulpits. Second, the duty of officers to care for the whole flock, and their ability to do so. Elders (and deacons) should have the capacity to care for each soul on the membership rolls. To not have the ability to do so would disqualify someone from special office. Third, the importance of taking time in the process of testing a man for office. Indeed, while there are times when we must act quickly in boldness and courage, often hastiness leads to foolishness. The church must take heed to Paul’s injunction not to be hasty in ordaining men to special office. When in doubt, we should err on the side of patience over hastiness.
In considering the ordination of a man with a criminal history, an ordaining body would be wise to consider its duty to protect the flock entrusted to their care and learn about how they may best undertake this important task. The 90th OPC General Assembly received a report to which we now refer readers, the Report of the Special Committee to Help Equip Officers to Protect the Flock (https://opc.org/GA/protect.html). That report notes,
Great care must be taken to ensure that every member is loved well and protected from those who would seek to devour. Scripture warns us that the enemy seeks to destroy (1 Pet. 5:8), and there will be wolves in our midst (Matt. 7:15). Officers of the church are duty-bound to guard the welfare of God’s children from such as these. This holds especially true for those who are least among us, a type represented by the child, orphan, and widow.
Particularly pertinent is the statement from that report that “Sexual predators seek out offices and status to put themselves forward as trustworthy to the wider community.” Additionally, under “safety plan,” that report notes that “How best to proceed with a confessed perpetrator who expresses remorse and a willingness to repent must be approached with much caution and counsel. Further, sessions would be wise to have a proactive, consistent safety plan review process, to maintain the effectiveness of the plan.”[25] Applying these cautions for the present purposes, any body considering ordaining a man with a history of a sexual crime should consider the necessity of safety plans and how the man’s ordination will affect the implementation of said safety plans. In Appendix 1 of that report, a sample child protection policy includes the following: “When indicated by our reference and/or background checks, or at the discretion of the Session, volunteer candidates who pose a threat to others, or have a prior history of physical or sexual abuse directed against another person, will be immediately removed from consideration for ministry positions within our organization.” This would in itself eliminate from consideration most of the persons we are contemplating in this report.
Our sessions and presbyters are not investigators trained in reading body language, but they can do due diligence, such as reading a man’s arrest report and court documents to ensure they match what the man himself reports. An ordaining body should read documentation related to a man’s former criminal charges and interview the man related to those events and his time incarcerated. Court documents do not always tell the whole story, but will begin a conversation.
Likewise, the Report of the Special Committee to Help Equip Officers to Protect the Flock notes that abuse or “oppression” can occur through the misuse of authority, and the WLC leads us to see this as one of sin’s aggravations. If such was part of the person’s criminal history, it is reasonable to take extra care before putting them in a position of authority again.
Church leaders should also take into account the terrible prevalence of sexual abuse in our society. 1 in 4 women and 1 in 6 men in America have been sexually abused before the age of eighteen.[26] How will victims of various crimes receive ministry from officers with a particular criminal history? How can the church communicate these appropriately to visitors? These questions highlight the difficulty facing those who would ordain men with a criminal history to office. These practical considerations lead to further wisdom questions: even when it might be “permissible” to ordain such a man to office, is it “beneficial” (1 Cor. 10:23; 6:12)? Typically, schools will not allow a person to volunteer as a helper unless they have passed a background check, and will not allow a person with a past sexual crime to volunteer. When the church considers the ordination of such a man, it should ask if it is wise to spurn this common grace wisdom.
Our study has led us to the conclusion that a man with a history of sexual crime faces an even higher bar for ordination than a violent offender (of a non-sexual nature). The cumulative factors of the biblical and spiritual qualifications (e.g., “above reproach,” and “avoid any appearance of evil”), wisdom considerations, as well as the practical problems of accountability and transparency, lead this committee to the conclusion that, with very rare exceptions, such a bar is practically insurmountable and would preclude such a man from ordination to office. As the 90th General Assembly concluded in the creation of this special committee, “there are some crimes and some contexts in which ordination should not be pursued.”
The ordination of repentant men with a history of sexual or violent crime should be rare. The PCA’s Book of Church Order puts it well:
A minister under indefinite suspension from his office or deposed for scandalous conduct shall not be restored, even on the deepest sorrow for his sin, until he shall exhibit for a considerable time such an eminently exemplary, humble and edifying life and testimony as shall heal the wound made by his scandal. A deposed minister shall in no case be restored until it shall appear that the general sentiment of the Church is strongly in his favor, and demands his restoration; and then only by the court inflicting the censure, or with that court’s consent. (34-8)
We believe the same principles apply here: when contemplating such an ordination, it is critical for the man to “exhibit for a considerable time such an eminently exemplary, humble, and edifying life and testimony as shall heal the wound made by his scandal.” Furthermore, it would be wise for any sessions or presbyteries contemplating such an ordination to consider the sentiment of the broader church—that the broader church “is strongly in his favor, and demands his restoration.”
In those cases where a brother desires office, which is a noble task (1 Tim. 3:1), but a session or presbytery determines it would not be wise to ordain him, the session or presbytery would be wise to “reaffirm [their] love for him” lest “he may be overwhelmed by excessive sorrow” (2 Cor. 2:8; cf. Eph. 6:4). As we have shown above, there is great joy in holding the general office of believer, and God’s grace is sufficient for all hardships, including the disappointment of not obtaining a special office one desires.
[1] Johannes G. Vos, The Westminster Larger Catechism: A Commentary ed. G. I. Williamson (P&R Publishing, 2002), 410. Cf. Berkhof, Systematic Theology, 252.
[2] Robert Shaw, The Reformed Faith: An Exposition of the Westminster Confession of Faith (Christian Focus, 2008; orig. 1845), 214–5.
[3] Bavinck, Reformed Dogmatics, 3.150. Bavinck has a helpful summary (3.151): “And just as sins differ in degree and extent depending on whether they were committed out of ignorance and weakness or intentionally out of wickedness, so they also differ in terms of the object against which they are directed. Sins committed against the first table of the law are more grave than those against the second (Matt. 22:37–38). Or they differ in terms of the subject who commits them: the more richly gifted a person is, the more the guilt of his or her sin increases (Matt. 11:21; Luke 12:47–48; John 9:41; 15:22, 24). Or they differ in terms of the circumstances under which they are committed: the person who steals because he is poor is less guilty than the person who steals out of avarice (Prov. 6:30; Isa. 26:10). Or they differ in terms of the degree to which people give in to sin: those who commit adultery in thought and word are culpable but increase their judgment when they proceed to complete the sin by action (cf. Matt. 5:28).”
[4] J.G. Vos, The Westminster Larger Catechism, 420.
[5] See Bavinck, Reformed Dogmatics, 3.161, 166, on how punishment or discipline must accord to the crime.
[6] See Thomas Watson, The Ten Commandments (Carlisle: Banner of Truth, 1995, orig. 1692), 155.
[7] Alan D. Strange, “Do the Minister and the Elder Hold the Same Office?” Ordained Servant, Dec. 2013.
[8] Guy Prentiss Waters, How Jesus Runs the Church (P&R, 2011), 83.
[9] Statutes of Pennsylvania, Title 18, Crimes and Offenses, Part III, Miscellaneous Provisions, Chapter 91, Criminal History Record Information, §9102.
[10] John Calvin, Institutes, 3.3.
[11] Philippians 2:12–13: “Therefore, my beloved, as you have always obeyed, so now, not only as in my presence but much more in my absence, work out your own salvation with fear and trembling, for it is God who works in you, both to will and to work for his good pleasure.”
[12] Geerhardus Vos, Reformed Dogmatics Vol 5, ed. Richard B. Gaffin Jr. (Bellingham: Lexham, 2016), 50.
[13] One case study of the implementation of a safety plan for a person with a criminal history can be found in Alfred Poirier, The Peacemaking Pastor: A Biblical Guide to Resolving Church Conflict (Grand Rapids: Baker Books, 2006), 285-298.
[14] 1 Tim. 3:10 uses a similar term for deacons; that term is also used in Titus 1:6–7. In Titus 1:6, “above reproach” or “blameless” serves as a heading that is explained by what follows. See William D. Mounce, Pastoral Epistles WBC 46 (Thomas Nelson, 2000), 388.
[15] William Bayless Barcley, A Study Commentary on 1 and 2 Timothy (Webster, New York: Evangelical Press, 2005), 102.
[16] Mounce, Pastoral Epistles, 170.
[17] Gordon D. Fee, 1 and 2 Timothy, Titus (Peabody, MA: Hendrickson Publishers, 1984), 80.
[18] It is important to note that Paul has a category of “outsider,” that is, there are those inside and those outside the covenant community (see Col. 4:5; 1 Thess. 4:12).
[19] George W. Knight III, The Pastoral Epistles NIGTC (Grand Rapids: William B. Eerdmans Publishing Co., 1992), 166.
[20] Robert W. Yarbrough, The Letters to Timothy and Titus (Pillar; Grand Rapids: Eerdmans, 2018), 203.
[21] Charles Hodge, Discussions in Church Polity (Princeton Review, Charles Scribner’s Sons, 1878, Repr. 1835-1837), 45.
[22] In 1 Timothy 3:6 Paul warns against ordaining recent converts, lest the recent convert be tempted to “become puffed up with conceit and fall into the condemnation of the devil.”
[23] Yarbrough, 1 Timothy, 297.
[24] John Calvin, Commentary, on John 3:29. Quoted in Charles Bridges, The Christian Ministry (Carlisle: Banner of Truth, 2018), 5–6.
[25] Alfred Poirier provides an instructive case study in the implementation of a safety plan in The Peacemaking Pastor: A Biblical Guide to Resolving Church Conflict (Grand Rapids: Baker Books, 2006), 285–298.
[26] See S. R. Dube, R. F. Anda, C. L. Whitfield, D. W. Brown, V. J. Felitti, M. Dong, and W. H. Giles, “Long-Term Consequences of Childhood Sexual Abuse by Gender of Victim,” American Journal of Preventative Medicine 28 (2005), 430–38.
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