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REPORT OF THE SPECIAL COMMITTEE TO HELP EQUIP OFFICERS TO PROTECT THE FLOCK

Presented to the Ninetieth (2024) 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.

SYNOPSIS

PREAMBLE

SECTION 1. PROTECTING THE FLOCK AGAINST SEXUAL PREDATION

  1. Biblical and Confessional Considerations
  2. Abuse, Sexual Abuse, and Sexual Predators and their Behavior
  3. Strategies for the Prevention and Creating a Culture of Protection
  4. Ministry to Victims and their Families when Prevention Fails
  5. Ministry to the Perpetrator
  6. Legal and Law Enforcement Cooperation

SECTION 2. STRATEGIES FOR THE PROTECTION OF THE FLOCK AGAINST DOMESTIC VIOLENCE

APPENDIX 1. SAMPLE CHILD PROTECTION POLICY

APPENDIX 2. PREPARING TO BRING A CHARGE IN THE ORTHODOX PRESBYTERIAN CHURCH

APPENDIX 3. CHECKLIST TO PROTECT THE FLOCK

RECOMMENDATIONS

BIBLIOGRAPHY

TABLE OF CITATIONS FROM THE WESTMINSTER STANDARDS


Preamble

The Special Committee to Help Equip Officers to Protect the Flock humbly submits the following report to the 90th General Assembly of the Orthodox Presbyterian Church. Soli Deo Gloria.

In response to an overture from the Presbytery of Ohio, the 88th General Assembly approved the following:

That the Assembly form a special committee of six, consisting of three ministers, two ruling elders, and one deacon, appointed by the Moderator, to the do following:

1. Collect, study, and develop resources to equip officers of the church to protect her members from sexual predators and domestic violence

2. Report to the 89th General Assembly

Subsequently, the Moderator, with input from commissioners from the 88th Assembly, appointed the following individuals:

Ministers: Daniel Patterson (PNYNE), Benjamin Rochester (PSC), and Carl Miller (PSW)

Elders: Thomas Crumplar (Immanuel OPC, Wilmington, DE), James Berry (Reformation OPC, Morgantown, WV)

Deacon: Jim Altensee (Covenant OPC, Vandalia, OH)

Pastor Patterson had to step down from the committee for health reasons. The committee consulted with Pastor John Mallin, an OPC minister and Biblical counselor, as a regular attendee at our meetings following Reverend Patterson’s departure. The committee also consulted with several others, to whom we are greatly indebted for their wisdom.

The committee was continued by the 89th General Assembly in order to complete its work, after giving a brief report to that Assembly.

What follows is the report pursuant to that directive. The aim of this committee is to provide practical guidance to church leaders regarding the protection of the flock against sexual predation and domestic violence. The goal of these documents is to provide church officers an initial resource to become equipped to guard the flock under their care from sexual predators and domestic violence. This committee submits Section 1 regarding the protection of the flock against sexual predators, and Section 2 regarding domestic violence.


SECTION 1. PROTECTING THE FLOCK AGAINST SEXUAL PREDATION

God created sexuality and established the good boundary of marriage for its expression (Gen 2:24). Any sexual expression outside that boundary is sin; fornication, pornography, lust, and homosexuality are such violations. Sexual predation is a heinous variant whereby a perpetrator seeks to prepare, isolate, and assault a victim. Fear, shame and other manipulations are then used to retain the sexual relationship with devastating effect on the victim. It is the sincere desire of the committee that this section will equip parents and churches to protect those under their charge by creating a culture of protection from sexual predation, particularly among the least of the disciples (Matt. 18:6). What follows is a summary of findings; more research and writing can be done in this area.

A. Biblical and Confessional Considerations

We begin with a Biblical account which recorded and denounced the terrible sin of sexual predation. A key account in the Scripture is 2 Samuel 13, which records the rape of Tamar by her half-brother, Amnon. Verse 1 recorded the setting. Amnon “loved” his half sister Tamar. This “love” he felt was obviously sinful sexual desire. The rest of the text confirms it. The account began with an inordinate desire for his sister. Verse 2 described Amnon’s love-sickness for his sister. Obviously he was cherishing the sin instead of mortifying it. Verse 3 reports how Amnon told this to his “shrewd” friend Jonadab. In verse 4–5, Jonadab shrewdly told Amnon how to isolate his half sister. The plot was to act ill and isolate her with him at his bedside. Verses 6–10 described how he did so, and she dutifully came to serve him as nurse while, presumably, he healed. In verse 11 he propositioned her sexually, “Come, lie with me, my sister.” Tamar rejected the advance in verse 12, and then reasoned with him that it would bring terrible shame upon her in verse 13. In verse 14, Amnon forcibly violated her. In verse 15, Amnon told her to leave. She responded that she would have greater shame when she left (v. 16). In verse 17, Amnon villainously called his servants to remove the poor girl. In verse 18, the author noted that she was wearing a virgin’s garment. No doubt this was to show the shame she felt, and how heinous the violation was. Verse 19 described the saddest of scenes for the young woman, “Tamar put ashes on her head and tore her long-sleeved garment which was on her; and she put her hand on her head and went away, crying aloud as she went.” To make matters worse, verse 20 recorded how Absalom (her full brother) told her to remain silent. He plotted revenge, but he kept the matter secret. Verse 21 recorded how David’s anger “burned against” Amnon, but the text recorded no punishment (v. 21).

This text reveals the shame of the violation. How can one not be moved to tears at this terrible sin? It also demonstrates the utter sinfulness of sexual predation. Finally, it exposes the sad reality that David and Absalom failed to protect their daughter and sister or utilize their power as the civil magistrate to bring justice. The careful reader of Scripture will notice both the sinfulness of the event, but also the pattern of behavior that was involved in the perpetration of the sin, not only by the direct perpetrator, but by those who enabled and compounded the sin through commission or omission.

The extra-Biblical term “sexual predator” is now common in popular language. People generally know terms like “groomer” and “pedophile,” and the behaviors they represent. TV crime shows and high-profile court cases have doubtless contributed to this familiar vocabulary. While awareness of the subject can be helpful in preventing sexual predation from happening, the Scriptures give us clear principles regarding God’s perspective on the matter. Specifically, that sexual predation is an especially heinous sin perturbed and aggravated by it being perpetrated against those least capable of self defense. We are also taught that those in authority bear responsibility to protect those under their charge. Those who should have and could have protected the young Tamar failed to do so. Furthermore, they failed to appropriately care for her after the rape.

The Scriptures give us a foundation and pattern of instruction on this subject. There is no excuse to not be at least acquainted with this teaching. The Westminster standards are also a helpful guide for how to understand the phenomena. The WCF 1.6 affirms that Scripture contains places where pertinent teaching is expressly set down (Gen. 39:9), applied from the general principles of the word (Exo. 20:1–17), or can be deduced by good and necessary consequence (2 Sam. 13, Gen. 34) for all matters of faith and life. We do well to study the confessions and catechisms for how to understand, prevent, and respond to sexual predation.

The WLC and WSC sections on the Ten Commandments are especially helpful for this subject. Preventing sexual predation fits in the locus of ethics and leadership. The Lord Jesus taught the disciples to not cause the “least” of the disciples to stumble. He emphasized the gravity of transgressing this ethic with a dramatic word about a long walk off a short pier with a stone necklace (Matthew 18:6). This is gravely serious business.

The WLC interprets the terms “fathers” and “mothers” to refer to all authorities in all divinely instituted spheres of life (WLC Q&A, 125). The Scripture clearly teaches authority and office in the home, church, and society. Usually, sexual predation is perpetrated by superiors against inferiors, or equals against one another. Sexual predators use status and authority for selfish and sinful ends.[1] Sexual predators seek out offices and status to put themselves forward as trustworthy to the wider community.[2] These positions of authority afford reasonable trust to the one holding the office. There are two necessary deductions that must be drawn from this. First, God-instituted authorities, especially church officers, with the responsibility to protect the least of the disciples. Second, premeditating sexual predators seek out positions of authority to gain trust and access to victims.

This reality puts the responsibility upon the officers and parents to have strategies in place to prevent and minister to incidences of sexual abuse. The next section B will define the subject of abuse in general, sexual abuse, and sexual predators and their behavior. Section C will focus on strategies of prevention and creating a culture of protection. Section D will focus on how sessions may minister to the victims and their families. Section E will focus on ministry to the perpetrator. Section F focuses on legal and law enforcement engagement.

B. Abuse, Sexual Abuse, and Sexual Predators and their Behavior

Defining Abuse and Sexual Abuse

Defining abuse is of paramount importance. Common sense definitions would tend to mean what Webster's Dictionary of the English Language (1828) defined as “Verb . . . 1. To use ill; to maltreat; to misuse; to use with bad motives or to wrong purposes; as, to abuse rights or privileges. 2 To violate; to defile by improper sexual intercourse . . . 5.To pervert the meaning of; to misapply; as to abuse words . . . Noun . . . 2. A corrupt practice or custom, as the abuses of government . . . 4. Seduction.” These definitions are old, nonetheless, they fit the wide variety of usage in common parlance. There are contemporary dictionaries with myriad definitions, but we need a definition of terms which accurately accounts for the Biblical concepts described by the English word.

The Association of Certified Biblical Counselors (ACBC) developed a thorough and helpful definition of the term abuse as a summary of Biblical categories.

Abuse is the pattern of sinful, selfish mistreatment of another made in God’s image, whereby moral agency, freedom of conscience informed by God’s Word, and God-given human dignity is violated by harmful acts (physical, sexual, verbal) or schemes to perpetuate oppression and unbiblical control (Exodus 3:9–10; Deuteronomy 26:6–8; Psalm 10; Isaiah 19:20; Isaiah 30:12–13; Isaiah 49:26; Matthew 20:25–28). Acts of abuse are vile practices arising from selfish ambition and bitter jealousy, born from sinful desires in the heart (James 3:16). Physical abuse encompasses actions that harm the body including but not limited to beatings, sexual assault, physical or sexual coercion, sleep deprivation, starvation, or confinement. (ACBC, Committed to Care, Statement on Abuse and Biblical Counseling, section VIII.A)

The committee is thankful for this definition. There are many pithy definitions, or etymological definitions, or psycho-therapeutic definitions which do not necessarily or completely capture what we mean as Biblical Christians. The ubiquitous and varied definitions presented no little difficulty in the committee’s approach to the formation of this document. The committee deemed it best to consider any common uses of the term in light of this statement from the ACBC.

Sexual Predators

We must make a distinction between one who is a sexual sinner in general versus a sexual predator. Instances of sexual sin are distinct from the strategic pattern defined as predation. Sexual predation denotes a specific behavior, pattern, and strategy for gaining access to, victimizing, controlling, and maintaining victims. It is important for sessions to know that sexual predation is not limited only to adults, but predators can also be juveniles (children ages 10–17). Information about sexual predation is fairly easy to find and generally consistent in its presentation. There is no need for special training to understand how wicked it is in the eyes of the Lord. Most of all, the committee commends the reader to search the Scriptures for wisdom from above, especially the account of Amnon and Tamar. This section will define the common behavior patterns of sexual predation. Be aware that younger juveniles can engage in some predatory behaviors because they are mimicking or parroting words or actions that they’ve seen or experienced themselves. Identification of the underlying causes is best worked through with the juvenile’s parents and a trained professional.

Church leaders are also wise to consider the reality that when predatory behavior is demonstrated by an individual, sin, hurt, and dysfunction are often not isolated to just the individual. Consideration of family dynamics, or other factors that may have affected the individual is important for the session and any others who are involved with assessment and care.

Church leaders are wise to be aware of the role that pornography plays in the cycle of sexual predation. Early and frequent exposure to pornography causes great damage to one’s view of human beings, one’s understanding of sex, and one’s formation of sexual desires which are contrary to God’s design. Young, developing brains are particularly susceptible to being shaped by pornography in such a way that lifelong dysfunction may ensue. Patterns may develop such that normal, healthy sexual appetite is unsatisfying and the pursuit of violent and/or pedophilic sexual acts becomes a horrible reality. This damage fuels and lures those exposed to continue in the desire, pleasure, and shame cycles that tempt sinners to predatory behavior.

It is generally considered unwise to allow teen boys to be babysitters as males are more likely to abuse than females. Isolation and unsupervised time with young children can become a terrible playground of sin and destruction for those who would seek the opportunity. Even if parents use cameras in the home for remote supervision, the camera will record incidents but the damage is already done before anyone can respond and intervene. Although it is not always possible, it is best to have two people present while watching children apart from parents.

Further, church leaders must understand the grooming process, the identifying signs and behaviors of sexual predators, and exercise informed intuition. They should know how and when to report to the authorities (each state has different mandatory reporting laws), create a culture of prevention, and institute a vetting process for potential child caregivers as a mechanism for prevention.

The goal of this section is to give church officers a greater awareness of these things, in order to prevent such grave sin from taking place upon the least of the disciples.

Grooming

Sexual predators seduce their victims into sexual acts by gaining trust. Once trust is gained, they gradually and increasingly speak and act in unchaste ways toward their victims. This is also called the grooming process. It is an intentional process of manipulation and seduction. The U.S. Dept. of Justice defines grooming as, “. . . a method used by offenders that involves building trust with a child and the adults around a child in an effort to gain access to and time alone with her/him. In extreme cases, offenders may use threats and physical force to sexually assault or abuse a child. More common, though, are subtle approaches designed to build relationships with families.”[3] Not all victims are children, but this definition accounts for the process of seduction known commonly as grooming.

The fifth commandment applies here. The goal of the predator is to seduce and retain the victim in a sexual relationship. The predator uses authority and trust in order to isolate individuals for these purposes. Superiors have the duty to protect and provide for those they serve according to the revealed will of God. The grooming process violates godly derived authority as it intentionally uses the role of superior in order to sin against the victim

Regarding violation of the seventh commandment, predators will inquire about sexual imaginations or experiences. They may progress intentionally from words to pictures (often using cell phones) to physical contact. WLC 139 includes in violations of the seventh commandment, “all unclean imaginations, thoughts, purposes, and affections; all corrupt or filthy communications, or listening thereunto; wanton looks, impudent or light behavior, immodest apparel.” This section of the WLC, and its appended prooftexts are instructive for church leaders to define the clear violation of God’s Word regarding these sins. Predators may isolate victims and make filthy jokes, ask about immodest thoughts, and eventually make physical contact. They will often use the guise of education or counsel in order to hide their intent. For example, a predator may comment on clothing, physical development, and express how the physical appearance of the victim makes him or her feel.

Another example would be in a counseling situation where an officer asks for exhaustive details of sexual activity or imaginations. There is a difference between confession of sin and “filthy communication and listening thereunto.” Galatians 6:1 instructs caution of temptation for those who seek to restore a sinner. The sexual predator will often seek out isolation of the potential victim under the pretense of counsel with the purpose of unchaste affection.

Further, violating the 5th commandment, predators will use guilt or fear of exposure to retain the victim in the relationship.

In summary, the steps of the grooming process are targeting the victim(s), gaining the victims’ trust (and the trust of the wider church community), securing access to and isolation of the victim, and then controlling and concealing the relationship. The following are some considerations:

A) Targeting the victim: sexual predators choose their victims based on vulnerability. Those vulnerable could be a child who is rarely supervised, or a woman who is in an isolated counseling context, or a man who naïvely trusts, and has a sexually promiscuous past (particularly homosexual acts), or a developmentally disabled child and/or adult. This can occur through electronic communication or in-person contact.
B) Gaining the victim’s trust: sexual predators will attempt to gain the victim’s trust. They may give gifts to the victim, or take special interest in the individual. They might use personal stories or express their own sinful desires in order to draw out the sexual imaginations of victims. The line of unchastity is further crossed when they start asking for details about the sexual desires or inclinations of the victims. They may also divulge personal desires of the same kind, “testing of the waters” before seduction or violation takes place.
A subset of this phenomenon of gaining trust is called “grooming the community.” This process creates the conditions where sexual predation may happen. Obviously, not all trusted persons are sexual predators. That is why positions of trust give cover to the predator. The predator uses the trusted position precisely because it is trusted. The US Dept. of Justice defines grooming of the community, “The offender may assume a caring role, befriend the child or even exploit their position of trust and authority to groom the child and/or the child’s family. These individuals intentionally build relationships with the adults around a child or seek out a child who is less supervised by adults in her/his life. This increases the likelihood that the offender’s time with the child is welcomed and encouraged.”
C) Securing isolation: Sexual predators may secure isolation in one-on-one counseling or transportation to or from events. They will seek trust and authority in the wider community of adults, the intended victims’ family, and the church body. They are often apparently upstanding citizens, teachers, politicians, church members, even officers in churches. They appear in general to be doing normal things. This should not make the reader paranoid, but should make him understand the difficulty of discerning this subject. Clear violations of the Seventh Commandment regarding unchaste and filthy communications are clear sins. They may also be signs of intent. The officer should be wise to distinguish the two.
D) Controlling and Concealing the Relationship: Sexual predators will use physical threats, blackmail, fear of exposure, or lies about the laws of the land to manipulate the victim into remaining in the relationship. Often they will take pictures or request pictures, and then use them for blackmail. Thus, they entrap the victim with fear of public shame. They are master manipulators, so church officers should be informed of these sorts of tactics.

Now we return to the Scripture to see what the Lord says. 2 Samuel 13 recorded the rape of Tamar by Amnon. Consider the unchaste purpose and behavior of Amnon. Verses 1–2 described Amnon as so infatuated with Tamar that he was sick. Verses 3-5 recorded the advice from the “shrewd” (v. 3) Jonadab, who recommended the plot to Amnon. Verse 6 recorded the deception Amnon used to request Tamar as his nurse. He pretended to be sick and requested that she wait on him. In verse 9 Amnon said, “Have everyone go out from me.” In verse 10 he requested Tamar to enter his bedroom. Isolation is a key tactic for sexual predation. Verses 11–13 recorded his attempt at seduction (v.11) and Tamar’s refusal (vv. 12–13). Verse 14 explained how he raped her due to him being stronger than she. The reader can see plainly how Amnon used trust and isolation to secure his victim, and then how he violated when opportunity struck.

Genesis 19:30–38 recorded when the daughters of Lot made him drunk and lay with him in order to conceive children. It could be argued cogently that the goal of the daughters of Lot was to conceive, rather than to find sexual gratification. Evidence for this would be that they had recently witnessed the fire and brimstone of the fall from the sky and destroyed Sodom and Gomorrah and presumed there were no men left on earth (vv. 24–29). Nevertheless, the reader can also deduce their unchaste intent and use of isolation from the events in the account. Isolation and trust played a part in their seduction and sexual actions. Clearly, their actions were a want of conforming to and transgression of the law of God in many ways simultaneously. Verse 30 described the isolation of the three individuals in the Mountains of Zoar. Verses 31–33 recorded the plot devised by the elder daughter. The use of alcohol adds another dimension to this, because it indicates that the intercourse was not consensual (cf. also Genesis 9 regarding Ham’s violation of Noah). This is an example of what the WLC 139 calls, “unclean imaginations, thoughts, purposes, and affections.” It was not merely incest, it also bears the marks of a premeditated act. Though it was a single event for each daughter, and there was no retaining of the sexual relationship afterward, it still illustrates the danger of isolation and evil intent.

Another passage for consideration would be Genesis 39 wherein was recorded the account of Potiphar’s wife attempting to seduce Joseph. These passages are provided as a Biblical basis to consider all of the findings above. Our final standard is the Word of God. Some of the behaviors above can appear to the unequipped onlooker to be normal and explainable. The key reality that determines if someone is a sexual predator is that the predator will cross the line with seductions and then will eventually act. Be aware that predators play a “long game” strategy on communities and victims. Because it is so difficult to discern the intent of another person, many sexual predators are never exposed. Another complicating factor is that most of us have the tendency to think the best of people and dismiss suspicions or allegations against those we like and respect. Having standard policies and procedures as well as objective parties involved when necessary, will help mitigate these natural tendencies.

C. Strategies for the Prevention and Creating a Culture of Protection

The focus of this handbook is to create a culture of protection in the churches. Christian parents, church officers, church employees, and volunteers should all be involved. In order to establish a culture of protection, we begin with strategies for prevention. When we say prevention, it should not be construed to say that the church will be impervious to the possibility of grievous sin. Leaders should also be aware that sexual predators seek out churches, civic organizations, teaching roles, and counseling jobs because these are ways to gain access to pools of potential victims. The goal is not to create paranoia, but to equip the church with Scripture regarding this sad reality. Sessions and diaconates will no doubt have to work out the particulars for themselves. Just state and local laws will also come into play. Undershepherds must exercise a gracious pastoral ministry, church discipline, and the government of the church with courage, discernment, and humility.

Know the Signs

We must begin with identifying signs. The average person is not trained to recognize the signs of sexual predation. The victims of sexual predators are usually the most vulnerable to manipulation. Teaching the vulnerable to detect the signs is not enough. This requires church leaders to be vigilant to protect the flock. Officers in the church should strive to understand how to protect the flock under their care. They should also instruct the congregation on best practices and foster a culture reflective of God’s heart to protect the least among us.

Behaviors that act as signs of grooming behavior include a person who:

  1. seems overly interested in a vulnerable individual or group.
  2. frequently initiates or creates opportunities to be alone with someone.
  3. becomes fixated on a child, woman, or vulnerable man.
  4. gives special privileges to a vulnerable person.
  5. befriends a family and shows more interest in building a relationship with a child than with the adults.
  6. displays favoritism towards one child within a family.
  7. finds opportunities to buy a child gifts.
  8. caters to the interests of the child, or even acts like a child.
  9. displays age and gender preferences. For example, if a man prefers spending time with women or children rather than other adults or other men.[4]

These actions in the abstract may be harmless, or they may be grooming behaviors. It is important for church officers to understand the behaviors and implement a vetting process and policy and procedures to protect those under their care. It is also important for officers, volunteers, and all members to understand in order to avoid giving even the appearance of evil.

Develop Informed Intuition

The officers and volunteers should be informed of the threat of sexual predation within the churches. These signs can be hard to define and identify, because sexual predators are master manipulators. They have already gained the trust of the wider community. Individuals uninformed about these signs may act in inappropriate ways, yet not be sexual predators. There is a distinction between someone telling a crass sexual joke and someone tactically seeking victims by increasingly becoming more intimate with sexual subjects.

Because these are signs that point to possible causes, church officers, parents, and volunteers should be educated in order to exercise informed intuition. Informed intuition is where something seems “off” about a situation. For example, someone may consistently bend the rules which should set off internal alarm bells, as this is done in order to isolate a potential victim. Several of the signs and behaviors mentioned above may also be present. Officers who notice these signs should follow the pattern of personal exhortation outlined in Matthew 18:15–17 and Galatians 6:1 (BD III.5). Members should follow the same pattern if appropriate and/or bring their concerns to the church officers.

If the individual who crossed a line does not repent of the behavior, then a process outlined in a church protection policy should be followed regarding volunteer status. If the man in question holds office, the process should be followed according to Book of Discipline III and 1 Timothy 5:19.

Creating a Culture of Prevention

Church officers and members should become educated about church protective policies, procedures, the relevant ethical categories, and responsibilities of authorities to protect the least of the disciples.

There are several ministries that help churches develop policies and train officers and volunteers regarding how to prevent sexual abuse. Safe Hiring Solutions, Ministry Safe, and Protect My Ministry are all capable resources. It is important to realize that crimes may take place in spite of a protective policy. The policy of a church does not always prevent abuse but minimizes the risk. Churches need to be aware that the policy may become a liability for lawsuits if the policy was ignored or not enforced. Regardless, the point of protective policies is not to protect the church from lawsuit. They are helpful to create a visible and public standard to deter predators and guide safe practices.

Every church should have a child protection policy. A good policy must set forth clear policies and procedures for protecting the flock. Volunteers who have contact with children, those who perform counseling, and church officers should receive training regarding the policy and the subject matter in this report.

The Vetting Process

The vetting process is a mechanism for prevention of sexual predation. A church should develop a protection policy and then use training and adherence as a vetting process. Sexual predators use isolation to accomplish their unchaste purposes. A good policy will put in place safeguards to prevent isolation. If a potential volunteer refuses to go through the vetting process or to adhere to a policy, then the church leadership should remove him or her from consideration for a volunteer position. It is a very bad sign if someone continuously makes exceptions to a policy (especially if that person is defensive and not submissive to the church leadership).

Policies and procedures enforce the ethical and logical boundaries according to the light of nature and general rules of the Word. These act as a vetting process to discriminate against those who may have ill intent. Sessions may consider policies and procedures for pastoral counseling, spaces where men and women may be isolated, child ministry, and ride sharing. The committee also recommends background screenings for all church workers and volunteers that work with children and to clearly define parameters related to child contact (such as vulgar speech, sexual subjects and settings). We also recommend policies and procedures for volunteers and employees on church premises during the week.

We recommend officers in the church receive training on how to receive testimony and how to perform preliminary investigations. The main principles are to keep discussions factual and, as much as possible, to corroborate times, dates, locations, recordings, and testimony of what has transpired. Sessions should also stay up to date regarding training and methods of mandatory reporting.

D. Ministry to Victims and their Families when Prevention Fails

The church is ministerial in authority, thus, we administer the good news of Christ and his law. We are to shepherd with sympathetic and pious pleadings for the wayward to repent. This may require pursuing church discipline of the perpetrator, which is a mark and blessing of the church. We also must administer the gospel to those who are hurting that they may know the tender love of Christ as realized through the people of the church. The church should be a shelter for the sufferer and protector of the oppressed.

The committee recommends Mez Mcconnell’s The Creaking on the Stairs as an example of how the gospel transformed the life of a man who was abused as a child. It may be helpful for an officer to consider a first-hand account of one abused and how this perspective may inform your approach to similar situations. A full treatment of the subject of counseling victims of sexual abuse is impossible in a handbook yet, some general guidelines are possible.

1. Beware of the unintended consequences of touch and isolation, as those elements contributed to the grooming process. It is wise to have multiple people (parents or vetted people) in the room with the counselor.

2. Keep preaching the Gospel. Mez McConnell wrote from his own experience:

A miraculous thing happened. Not overnight. But, as the months and years wore on. The more I consider Jesus, the less I consider myself. The more I considered his pain, the more my own pain was put into perspective. Slowly but surely, my emotions began changing. In fact, my feelings caught up to the truth I was believing. I discovered that the secret to my emotional and spiritual healing didn't lie with other people. Nor did it lie within me. The secret to a joyful life had nothing to do with my enemies getting their just desserts. Becoming calm and less angry inside came out of a growing relationship with Jesus. My heart was softening, and my soul was being cleansed of all the dirt and bitterness that had held it captive for so many years. Instead of allowing my demons to camp inside my head and heart, Jesus moved in full-time. Instead of being shaped and formed by my own pain, I began to be shaped and formed by understanding his. I came to understand that true peace and healing can only come about when a soul has been captured by Jesus. And when a life has been fully submitted to his will. I discovered that the answer to all my whys we're tied up in the answer to all his whys. Why did he come to earth? Why did he allow himself to be humiliated? Why put himself through the torture of being rejected by his own creation? Why allow the Jewish leaders to unjustly arrest him? Why allow himself to be scorned by his friends and his neighbors? Why risk the rejection of his earthly family? Why take upon himself the full wrath of God the father? So grand, so immense, I still struggle to comprehend it.[5]

The ministry ought to teach the good news of Christ to the victim, and demonstrate the Spirit’s love and power.

The committee also reminds sessions of our Lord’s warnings, “And whoever receives one such child in My name receives Me; but whoever causes one of these little ones who believe in Me to stumble, it would be better for him to have a heavy millstone hung around his neck, and to be drowned in the depth of the sea.” (Matt. 18:5–6) and “See that you do not despise one of these little ones, for I say to you that their angels in heaven continually see the face of My Father who is in heaven.” (Matt. 18:10). Officers do well to consider how our own behavior towards these little ones contribute to stumbling or despising. We will be held to account and this should make us tremble.

We also remind the reader of the solemn charge of the Apostle Paul, “Do not receive an accusation against an elder except on the basis of two or three witnesses. Those who continue in sin, rebuke in the presence of all, so that the rest also will be fearful of sinning. I solemnly charge you in the presence of God and of Christ Jesus and of His chosen angels, to maintain these principles without bias, doing nothing in a spirit of partiality.” (1 Tim. 5:19–21)

Adjudication of cases of this serious nature must be done for the sake of the reputation of the Lord, Whose name we bear. We are charged by God Himself through Proverbs 31:8–9 by the words of Lemuel’s mother, “Open your mouth for the mute, for the rights of all the unfortunate. Open your mouth, judge righteously, and defend the rights of the afflicted and needy.” Sessions are in a position of authority as superiors over the flock under their care, and thus must take to heart the need to purify and protect the flock. Courage and diligence in duty is of utmost importance regarding these cases. Men must have the will to act, in all gravity and humility.

E. Ministry to the Perpetrator

Though perpetrators have committed heinous sins, as they are men, women, boys, and girls created in the image of God, sessions should consider them as persons that need the ministry of the church. They need the convicting and healing salve of Christ and the Gospel. Yet, with this in mind, wisdom and care is needed regarding how that should be carried out. Here are some important things to be aware of and keep in mind as sessions consider how to best minister to them:

  1. Seek Professional Help. It is unwise for sessions to try to handle all of the needs of ministry to predators (of any age) alone. Doing so could not only open the door to potential risks and liabilities, but blind spots could also blunt progress in healing and cause unintended damage. There are many layers and facets regarding the presenting and underlying issues that sessions aren’t equipped to explore, treat, and bring to resolution. Members of the session may think they know the predator well and can “handle” the situation, but should not approach it alone. Professional counseling and legal consultation should be sought. This being said, it is right and appropriate for sessions to be involved in the treatment process. They play an important role as ministers in the repentance-to-restoration journey.
  2. Struggle in Keeping the 9th Commandment. Sessions should know that those who commit predatory behavior can often be blind to the sin, danger, and concerns regarding their behavior. They may be pridefully self-protective and defensive which presents as frequent lying and diversions. Such self-preserving behavior can also stem from addictive aspects of predation.
  3. Addictive Behavior Awareness. There are addictive qualities in predation that lure the predator to not only take more steps in the behavior patterns discussed earlier in this report, but also to carry out more than one offense. Sessions should be mindful of this and anticipate fluctuations in the healing process which necessitate extraordinary diligence in minimizing exposure to potential victims. They would also be wise to consider the strong temptation predators often face and the real possibility of succumbing to this temptation. The priority should be protecting potential victims at all times.
  4. Safety Plan Caution. Sessions are wise to consider safety plans that comply with their protection policies. However, they should recognize the inherent limitations of such a plan. Viewing a safety plan as sufficient intervention on its own opens the flock to ongoing risk. 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.
  5. View of the Predator. On the one hand, it is important to remember that by the grace and work of the Holy Spirit, a predator may not remain a predator in what they think, say, and do. The Lord’s blood is sufficient for the vilest offender. On the other hand, it is wise to remember that we are all sinners and temptations may not go away, even with the best safety plans and ministry in place. We praise the Lord when sincere healing and change takes place, yet this should be coupled with watchful, waiting, and sober expectations.

F. Legal and Law Enforcement Cooperation

The Lord ordained the civil magistrates. Christians should not hesitate to solicit their involvement when crimes are suspected. Law enforcement will have specific training, investigative skills, and authority that the church does not possess. Church officers should avail themselves, whenever possible, of the assistance of law enforcement personnel in their local communities. Cultivating relationships with these civil servants would be beneficial for both preventive instruction and proper navigation of allegations that arise.

There are several considerations in connection with the legal system which need to be understood. Each state has its own laws about mandatory reporting and statutes of limitations. We will discuss this below.

Reporting and Mandatory Reporting

Reporting incidents of sexual abuse is necessary for the protection of the flock. Policies should reflect the current laws of federal, local, and state governments. This may mean that reporting to the appropriate law enforcement agency is mandatory. One should note, however, that a municipality that does not require reporting after a certain age is not a substitute for godly and Biblical prudence. One may report an incident even if it is not a legal requirement. For further helpful guidelines, see the appendix containing the ACBC Statement on Abuse, specifically the section on “allegations.”

Law enforcement will do their own investigation. The Lord ordained the magistrate for the punishment of evil and preservation of peace. Often cases have been reported where families or churches try to handle serious crimes “in house.” The problem with this approach is that families and churches are neither equipped, nor instructed by God to do so. The civil magistrate is authorized to punish crimes according to just laws; families and churches are not. Volunteers, parents, and church officers are not immune to, or exempt from, God’s ordinance (Rom. 13:1–5).

Sometimes churches or families mistakenly decide to punish a crime themselves “in house.” The problem with dealing with crimes “in house” is that they may not be appropriately dealt with. Further, other sexual predators within a family or church may indeed be seeking cover by protecting others. If a crime has been committed, the Lord has established the magistrate with the sword for the purpose of protecting citizens. Members of the church are subject to civil authorities under the authority of Christ.

An example of this is how David and Absalom responded to Amnon’s rape of Tamar in 2 Samuel 13. King David became angry when he heard about the events (v. 21), but he did not prosecute his son’s crime (vv. 20–21). Absalom (Tamar’s older brother) avenged his sister by murdering Amnon (vv. 28–29). The result was the beginning of the revolt of Absalom against David. These things were written for our instruction (1Cor. 10:11). Therefore, we urge the officer to consider the complexities and inherent biases involved when attempting to adjudicate and prosecute alleged crimes against those we love and respect.

Clergy-Penitent Confidentiality Laws

Clergy-penitent confidentiality refers to the confidentiality between officers of the church and those who confess sin. If a victim of sexual predation indicates such in a counseling session, the officer or volunteer should report it to the proper authorities in the church and civil sphere. Each state has distinct laws regarding clergy-penitent privilege and mandatory reporting. Below are some complicating factors.

One factor of clergy-penitent confidentiality is that sexual predators may confess sins to a pastor or other officer in a counseling situation. Consider the analysis of Richard Hammar in Pastor, Church, & Law, “The clergy-penitent privilege does not prevent clergy from disclosing confidential communications to the police. Rather, it prevents clergy from disclosing the content of privileged communications in court. Clergy who choose to inform the police about information shared with them in confidence are providing no more than a ‘tip.’ The police will need to confirm the information through their own investigation, since the minister will be prevented by privilege from disclosing the information in court.”[6] For a full discussion of clergy-penitent privilege see Hammar, pages 102–134.

It is godly and wise to notify the civil authorities regarding crimes, but local laws of how such notification will be construed by the civil magistrate will vary. It is wrong to assume that clergy-penitent privilege is absolute, especially considering that the legal origin of this privilege is in the Roman Catholic doctrine of the confession as a sacrament. This so-called privilege does not prevent church officers from reporting crimes.

Law enforcement must do their own independent investigation. This may seem like it prevents serious crime from being prosecuted swiftly, but it is the common law of the land and is due process. In cases where families or church officers fail to disclose sexual crimes against the least of the disciples, the civil magistrate may find them liable for crime too. In such cases it shows the ethic of derived authority. Though the church or a family may fail to enforce the will of God, the civil magistrate may fulfill God’s civil will as a duly instituted ordinance.


Section 2. Strategies for the Protection of the Flock against Domestic Violence

“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. I know that after my departure, fierce wolves will come in among you, not sparing the flock.” (Act. 20:28–29)

The family is meant to be a refuge filled with love and peace. This is true of both the biological family and the church as the spiritual family. God is our Father and we are his children. Church members are brothers and sisters of one another, bonded as a bride to Christ, her bridegroom. 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.

As officers of Christ’s church consider how to care for the flock, the best place to begin is to reflect upon God’s heart for the weak and vulnerable. We do not take our cue from the surrounding culture; rather we seek to emulate Christ. Popular cultural paradigms are antagonistic toward authority structures and attempt to flatten all relationships. There is no concern for respecting God’s image or design, either for individuals or institutions. Christ, on the other hand, by his life and words, teaches us something much different. Being eminently powerful, he emptied himself, and, clothed in weakness, poured himself out on behalf of his sheep. In humility, he used his power to heal and protect. He did not erase the God-given institutions and authority of civil government and the family. Rather, he affirmed the primary reason why these institutions exist: to promote justice and ensure that his image bearers are treated with dignity so that they may glorify Him (Psa. 5:11). His under-shepherds in the church are called to do no less. The church has an obligation to do everything in her power to protect the powerless within her fold. God uses the righteous to surround and deliver those who are persecuted (Psa. 142), heal their wounds (Psa. 147), and safeguard justice for the oppressed (Psa. 146).

Regarding domestic violence, the committee considered how to be most helpful within the scope of its mandate and determined to commend two resources for OPC church officers as initial “go-to” resources. There are myriad offerings in this space, both secular and Christian, which have varying degrees of value and utility. The mandate called this committee to collect, recommend, and produce resources for the protection of the flock. The committee determined to put forward materials that would be easily accessible, practical and biblical/confessional. As such, the committee recommends:

Not every officer will, nor necessarily should, agree with everything found in these materials. However, there is much to commend and officers will do well by availing themselves of these writings, both during times of acute need for practical guidance and as a comprehensive introduction to the topic of domestic violence.

What follows is an attempt to curate and direct particular focus on specific areas in these materials that the committee found most helpful.

Terminology

It is not the purpose of the committee to offer an authoritative definition of abuse. What proceeds are definitions as used by the resources discussed above.

1) DASA uses the Biblical verb “to oppress” (‘anah) as a synonym for abuse and cites several examples: Sarai dealing “harshly” with Hagar (Gen. 16:6), Laban invoking God as a witness lest Jacob should “oppress my daughters,” (Gen. 31:50), and God’s command to Israel not to “mistreat any widow or fatherless child,” (Exod. 22:22). To oppress is to “afflict by mistreatment.” This is mistreatment that wounds another person physically, emotionally, psychologically, and spiritually (DASA, p. 2306–2307). The word describes a pattern of coercive, controlling, and punishing behaviors (p. 2462). In domestic abuse, power, authority and strength are selfishly used to tear down another person in the family rather than to build up (p. 2343). Footnote #50 found on page 2343 is a pithy reference from Dr. Nathanael Brooks of Reformed Theological Seminary, Charlotte, North Carolina, to consider the Biblical value of words that aren’t explicitly found in the Bible, but capture the teaching of the Bible. “The Trinity” is an example of such terminology. Using words like “abuse” can help distinguish between the general fray of two sinners relating to each other and a specifically sinful exploitative pattern of oppression by one person over another.

2) WHH defines domestic abuse as a pattern in which a “person in a position of greater influence uses his personal capacities to diminish the personal capacities of those under his influence in order to control them” (WHH, p. 39). Specifically, the “abusive person uses his personal capacities to force other people to deliver on his personal desires” (p. 40). This does violence against the image of God in the person abused and is described by the relational dynamic as “me over you” (p. 70-71).

WHH distinguishes two different attitudes, a “me over you” attitude and a “me before you” attitude. WHH specifies that the generally selfish posture of putting oneself before others is sinful, but not necessarily abusive. “Abuse” goes further; it is sin characterized by the use of personal capacity to diminish the capacities of another for the purpose of control (p. 69). An analogous example in nature is the difference between a competitor such as a squirrel who is competing for seed resources with a blue jay and a predator such as a red-tailed hawk that seeks to eat the squirrel for dinner. A parasite, by analogy, is another example of the distinction in that botfly larvae will burrow under a squirrel’s skin, slowly destroying the squirrel by feeding on the nutritious blood. Both the predator and the parasite are using the victim for their own gain. Abuse can be both obvious, as in the case of the predator and more maliciously subtle, as in the case of a parasite (p. 70–71)

WHH illustrates their distinction between what is meant by abuse and what is not by providing, by example, how a church leader might confront a husband who has been abusing his wife (p. 117):

You’re probably wondering why I’m this alarmed about your wife’s concerns. I’m about to use a word you may not like and may never have considered, so I want to be clear what I mean and what I don’t mean. The word is “abuse.”
What I don’t mean by “abuse” is anything your wife doesn’t like about the way you treat her. No one should use the word “abuse” as a generic catch-all for anything mean or unpleasant. If that’s how we used it, then almost anything could be described as abuse.
Instead, I’m trying to see abuse from God’s eyes. In other words, what does He consider abusive? Let me share some things I’ve learned about abuse, so that you understand why I’m concerned . . .

3) The Association of Certified Biblical Counselors, (hereafter, ACBC) Statement on Abuse and Biblical Counseling section VIII put the problem this way, “. . . Christian and secular definitions of abuse are ever broadening, resulting in confusion and making it possible to label nearly every sinful act as abuse . . . .” They address the problem as follows:

Whereas, a definition of abuse utilizing biblical principles, concepts, and language is therefore necessary to help the church appropriately consider the nature, causes, and impacts of abuse, in order to engage the abused and abuser with hope-filled solutions; therefore:
We Affirm that abuse is the pattern of sinful, selfish mistreatment of another made in God’s image, whereby moral agency, freedom of conscience informed by God’s Word, and God-given human dignity is violated by harmful acts (physical, sexual, verbal) or schemes to perpetuate oppression and unbiblical control.(3) Using biblical terms and concepts including oppress, violate, defile, humiliate, deceive, weaken, scheme, bring low, self-interest, selfish ambition, and others to replace ambiguous psychological terms provides a biblical roadmap and solution for counsel. Using these biblical terms and concepts better depict the sinful depravity of abuse against the dignity and personal capacities of those created in God’s image. Expressions of abuse seek self-interest in the misuse and defilement of another person. Culpability before the Lord is not dependent upon awareness or intentionality of the abusive behavior. Acts of abuse can be sorted into three broad categories: inflicting physical and sexual harm, speaking reviling and corrupting words, and scheming to isolate from certain relationships and to restrict economic resources.(4) We affirm victims of abuse experience symptoms from these acts of abuse in a multitude of ways including emotional, spiritual, and physical distress that may compound over time, yet abuse is best identified by intentional sinful acts against another for the purpose of harm and control.” (Section VIII.A https://abuse.biblicalcounseling.com, accessed 02/09/2024).

We cite only a portion of the documents. We commend the reader to their entirety.

Biblical and Confessional Considerations

The heart of the matter is God’s heart for his people. In the Word, as summarized in the standards, God makes himself known as a jealous husband and a loving father to his people. Our Lord is an affectionate and loving Husband of his bride, the church. Further, the Chief Shepherd has ordained officers of the church to guard and protect the object of his great affection, the flock. Scripture abounds with references to his care and deliverance of the oppressed. Exodus 2:4 reads, “So God heard their groaning; and God remembered his covenant with Abraham, Isaac, and Jacob.” Not only was the Lord jealous for the redemption of Israel, but his love was tenderly disposed toward their plight, “He heard their groaning.” Arguably, the greatest and clearest theme of God’s posture towards his people throughout history is that of deliverer. The Exodus of beleaguered Israel from Egyptian oppressors stands as a key historical revelation of God’s passionate concern towards his people; a concern which resounds throughout Scripture and culminates in the Gospel of Christ’s deliverance. This is a deliverance from sin, which is spiritual, but also a deliverance from the sinful oppressor which is spiritual and physical. Man is body and soul. God delivers the whole man through the God-Man, Jesus Christ, Who was raised body and soul that those who are united to him may be likewise raised. When violence is done to the body, violence is done to the soul (Exo. 6:9). When violence is done to the soul, violence is done to the body (Psa. 32:3). And, violence is an offense against God as man is made in his image (Gen. 9:6).

We can draw an analogy from the abuse of civil magistrates (e.g., the ancient Egyptians) to the abuse of other superiors. Parents, church officers, sessions, presbyteries, general assemblies can and do err, but this does not negate them as God’s ordinance. The abuse of authority is a departure, not in degree, but in quality. The quality which makes the authority abusive is that it departs from the Word of God. Rulers are derived authorities duly appointed under God. They do not have independent authority. They are not absolute. They must reinforce the will of God by the manner and authority circumscribed by the Word of God. The defining factor in abuse of authority is a leader selfishly and unlawfully forcing his will by means of his vocation or status. Rulers like the Egyptians seek autonomy from God, when they treat their subjects as serving themselves as their chief end. They replace God’s glory and joyful communion as man’s chief end. When they make their own word out to be law, they replace God as the lawgiver. When they coerce to get their way beyond lawful means, they make their authority absolute and sovereign, but there is only one Absolute and Sovereign Being to Whom all honor is due. All superiors are subject to God’s Word as derived authorities.

WHH helpfully argues that Scripture provides, by way of narrative accounts, the authoritative perspectives that should shape our own as we consider our current situations (p. 37). These perspectives are essentially codified in the doctrines of the church. The committee emphatically agrees with WHH’s statement, “. . . these Biblical themes offer the only ultimately true perspective of domestic violence, since they alone give us insight into God’s ultimate perspective” (p. 38). WHH further emphasizes the practical implications of proper theology when ministering within the circumstances of domestic violence, “A theology of suffering is essential for a church leader, but a theology of suffering without considering God’s view of, and response to, violence and oppression can lead to reckless care and harmful counsel” (p. 42).

WHH lists 6 biblical themes as a lens by which to view domestic abuse (p. 38–39):

  1. The image of God, displayed in our capacity both to perceive the world as persons and to influence one another as persons.
  2. Sin, which disorders this design, warping both the ability to perceive the world rightly and to relate to others righteously.
  3. Love, which is God’s design purpose for human relationships. It is the building up of another person at cost to self, which is the precise opposite of abuse.
  4. Oppression, which is not generic suffering, but a unique form of suffering involving the intentional sin of those with greater capacity against those with less.
  5. Marriage, which is God’s arrangement for a man and a woman to live out an exclusive form of love in which a husband leads in sacrificing his interests for his wife, who follows him in freedom.
  6. The Church, the Spirit-indwelled people of God who seek to be a community that honors what is true and good and thwarts what is false and evil.

Much of chapter 2 in WHH is an exploration of these themes in approaching domestic violence from a Biblical framework.

Although much aligned, WHH is not written specifically from our reformed Presbyterian tradition. For a perspective that explores domestic violence specifically from the standpoint of our standards, DASA Section One (p. 2308–2342) should be consulted. Officers of the OPC will find a treatment of the Westminster Larger Catechism (WLC) concerning abuse through the exposition of the Ten Commandments, which officers of the OPC are bound by oath to teach and obey. For quick reference, readers are referred to Chart A in the preamble of this report.

DASA makes use of WLC 151 (regarding aggravations that make sins more heinous) as the theological basis for understanding abuse (p. 2309–2313). Reflecting on this portion of our standards, DASA states:

The WLC and supporting Scripture show that the sins of those in authority are more heinous, causing more damage and deserving of greater punishment because of the position of authority. The confession supports the existence of a differential of power in certain relationships. In each of the instances mentioned, summarized as leadership status, age, and knowledge of the faith, we find accompanying power over another. Power can be misused in order to control, oppress, and harm others. When the misuse of power occurs, it may be considered an abuse of authority.

The existence of “power differentials” is supported in the confession (e.g., cf. chapter 23.3) and catechisms as a Biblical concept. WLC 151 makes clear the ethical obligation of those with greater power towards those under their authority. This obligation comes with great responsibility to use power in a godly manner, not to exploit others for selfish gain. This is especially so with those who are much weaker and more vulnerable and therefore, at risk of extreme harm given their status (such as orphans and widows).

Other examples of the vulnerable may include those with disabilities, the elderly, wives who are physically weaker than their husbands, and laypersons in relation to church officers, to name a few.

WLC 151 notes that many of these relationships are fixed with “vows, [and] covenants” which when transgressed compounds the offense. WLC 151 further elaborates, “If done . . . frequently, [or] with . . . continuance” that a sinful pattern of behavior is more heinous.

By specifying “Relapsing after repentance,” WLC 151 addresses a significant feature of ministering to those in an abusive relationship. Judging whether or not repentance is genuine is critically important. Confession and seeking forgiveness are necessary but not sufficient. In an appropriate desire to reconcile a relationship and pursue unity, an officer may prematurely advise an abused person to return to the abuser after “apologies” were made. This can place the abused in an unsafe situation where violence may continue to be perpetrated. Fruit, in keeping with repentance, must be demonstrated before any counsel of reunification in many situations where the risk of ongoing harm is likely. For example, Saul repeatedly apologized to David, and yet David never returned with him. WLC 151 makes clear that greater care should be given to protect those under authority. This should be the guiding priority. DASA Attachments 9 and 10 (p. 2484–2491) offer a helpful guide on Biblical forgiveness and repentance respectively. Due to the reality of ongoing susceptibility to danger in cases of domestic violence, it is important for the officers to discern the fruit of repentance.

It is worth noting at this point a practical consideration of Matthew 18:15–17 in relation to superiors and inferiors. Often, when an inferior is sinned against by a superior, well-meaning counselors will use Matthew 18:15–17 to implore the inferior to first seek an audience with the superior regarding the matter.

However, Matthew 18:15-17 has in mind equals as evidenced by the use of the word “brother” in “if your brother sins against you.” Much damage can be done by requiring a person in an abusive relationship to confront the abuser in this manner. Dr. Alan Strange speaks to this in his commentary on the Book of Discipline of the Orthodox Presbyterian Church, Chapter 3.I (Ordained Servant: https://www.opc.org/os.html?article_id=1006):

Matthew 18 does not have in view inferiors going to superiors with alleged offenses. Such can perhaps be done in cases in which the superior is truly humble and will give a fair hearing to the inferior and even repent. Often, however, the very behavior that an inferior would be offended by involves an alleged misuse of authority and power on the part of the superior. If a superior is alleged to be abusing his office as a superior, it is unreasonable and irrational to insist that the inferior must approach him under the rubric of Matthew 18, as if they were the equals implied in the text (“if your brother sins against you”).
If the superior can be easily entreated by the inferior, then that is a happy, though perhaps unusual, situation, and Matthew 18 may be quite possible. However, if the superior is offended by being challenged by the inferior, as is often the case even when things are at the level of simple forgiveness—in which parties, whether superior or inferior, acknowledge sin and seek forgiveness and restoration—it is usually the case that an inferior is quite vulnerable and in no position to “go to the superior under the rubric of Matthew 18.” Even if the superior claims to be reasonable and approachable, he may not be, and the judgment of others about whether he can truly be easily entreated in the given case should or would need to be brought into view and the superior not simply be left to be judge in his own case.
All this is to say that Matthew 18 is not customarily in play in the case of a superior offended by an inferior: to insist that it is misguidedly puts them on the same level; at the same time, when an inferior alleges offense by a superior, especially of a serious nature (abuse of various sorts come to mind), the judgment of the church should usually be brought in as the first step (which should refer violations of the law to civil authorities), rather than the session wrongheadedly requiring a member alleging pastoral or other special officer malfeasance to “go to the pastor (or elder/deacon) and work it out with him in terms of Matthew 18.”
That is not the proper use of Matthew 18—to require inferiors claiming injury to go to superiors with whom there is no proper sense of a level playing field. Matthew 18, if carefully thought through, just as it is not required in cases of public sin, is also not required when a superior, especially in the discharge of his office, is thought by an inferior to have offended. An allegation of such to the local elders should be sufficient for them to seek to address the matter, involving the presbytery if and as necessary. Matthew 18 has too often been as heavy-handedly abused as was Job at the hands of his well-meaning but ultimately misguided friends.

Having established WLC 151 as a foundational catechism text for the theology of abuse, DASA explores the catechism’s treatment of the fifth (p. 2313–2321), sixth (p. 2321–2329), seventh (p. 2330–2337) and ninth (p. 2337–2342) commandments on the topic.

Some Practical Application of these Principles

The reality of violence could make one on one confrontation a volatile and dangerous situation. Sessions should take care to listen, be concerned, and to investigate the matter. Sessions should exercise caution for the safety of the accuser. Sessions should also consider that the matter may fall under the lawful jurisdiction of the civil authority. Also, there is the possibility that further violence could take place. It should be remembered, “A gentle answer turns away wrath, but a harsh word stirs up anger” (Prov. 15:1). Be very cautious that in your legitimate concern and possible indignation, you do not unwisely pour gasoline on a fire and put yourself or others at risk of harm.

Ask permission to meet with the accuser in person (considering safety concerns). Ask questions as to what happened, when and where. Stay tender, but ask clear questions so that you may ascertain the facts. Keep in mind that the accuser may be in a fragile state, nervous, inarticulate, and confused. They may contradict themselves and may be unclear or uncertain regarding the facts. This is not unusual for someone who has repeatedly been subject to oppressive behavior. Often, it would be pastoral and loving to invite the accuser to meet in a setting that she or he is comfortable with and to encourage the presence of a trusted friend or family member for support. Recognize the significant fear, shame, and difficulty one may experience as they consider meeting with a group of officers and the pain of telling their story.

Do not insist that the accuser meet with the accused initially, rather ensure the safety of the accuser. In some cases it may be necessary to help the accuser find temporary lodging with family, friends, or a shelter. It may also be helpful to encourage professional counseling with the help of the session. The deacons can be of service in these areas.

It may be appropriate to inform the civil authorities. If the accuser expresses that desire, it is good to assist in doing so. You may also notice marks on the skin indicative of violence or the use of clothes, make-up, or sunglasses to cover marks. If the accuser desires to go home and do nothing about the situation, respect this desire and be available to help as needed. Remember that the victim knows the dynamics better than you do and understands the consequences of escalating concerns.

The ecclesiastical judicatory may also need to begin an investigation for a charge, so careful notes should be taken and one should familiarize oneself with the judicial process. It is always wise to keep an ongoing record of all interactions and reports and to reach out for help if needed. Resources from WHH’s appendices are of use here. See also Appendix 2. Preparing to Bring a Charge in the Orthodox Presbyterian Church.

Once safety is established and with the permission of the accuser, it is appropriate to proceed further by having at least two officers meet with the accused. Be objective and non-prejudicial. Attempt to learn the facts, hear their perspective, and note their behavior. Be prepared for a spectrum of responses including defensiveness, anger, dismissiveness, humor, crying, graciousness, and openness. The officers’ job is not to act as judge to settle the case, but rather it is to wisely ascertain, as best one can, the nature of the situation including the dynamics involved. Understand that this will likely be the first in a series of meetings. It may be obvious in the first meeting that the accuser demonstrates behavior consistent with the profile of an abuser and/or sincerely acknowledges the wrong they have caused. More likely than not, it will take time for a pattern to develop and reveal itself.

Reconciliation between accused and accuser is a worthy goal which should be pursued. However, it should not be pursued prematurely, putting the accuser at risk of harm. If it is determined that there exist patterns of abuse, the focus should be on the abuser’s change of heart and subsequent change of behavior. Much of the informal discipline of gospel ministry can perhaps (with prayer) lead to reconciliation in full. Pastoral care, with all the appropriate firmness and tenderness, should be adapted to the situation. Professional individual counseling, mediated meetings with the abused, and specific guardrails all may be necessary elements required by the session in order to set the stage for reconciliation. The session must also be prepared for a lack of repentance or impatience with the process such that reconciliation is not likely. Formal judicial process according to the Book of Discipline exists to restore the sinner and preserve the name of Christ and may be necessary in such cases. Follow the Book of Discipline with parallel pastoral care to all parties involved. See Appendix 2 on sessions taking the lead on Preparing to Bring a Charge in the Orthodox Presbyterian Church as judicatory.

The Fifth Commandment

WLC 129 and WLC 130 address the ethical responsibilities that superiors have towards inferiors. God blesses superiors with power and authority that they may use this power and authority to bless others. Noteworthy is the phrase “protecting, and providing for them all things necessary for soul and body.” Superiors are to protect and nurture both the body and the soul of inferiors. This charge reflects both the spiritual/physical obligation and potential spiritual/physical harm intrinsic to the relationship. Church officers in particular are to “discountenance” sin and to “reprove and chastise” those who sin. The culture of congregations should be such that all clearly understand that abuse of authority is ungodly, will not be countenanced, and that victims of abuse will be respected and well-cared for. Development of policies and procedures, as well as education on domestic violence are certainly in keeping with faithful obedience to the fifth commandment. DASA emphasizes the “repeated persistent pattern of sin over a prolonged period” as necessary to constitute abuse, rather than singular instances of sin. (Officers are cautioned not to neglect single incidents of violence which may not constitute abuse in this sense.) Furthermore, counseling an abused person to return to the hands of the abuser, such as a woman to return to her unrepentant husband, would be wrong as this would constitute a “careless exposing, or leaving” her to wrong.

The Sixth Commandment

WLC 135 and WLC 136 explore the duties required and sins forbidden in regards to the preservation and protection of life. The catechism obligates one to protect one’s own life in addition to others. Careful consideration must be given by officers to a “just defense thereof against violence” perpetrated against those under their care. An attempt to reconcile two parties, if pursued too quickly and without due diligence that ensures demonstrable fruit of repentance, may place a victim in harm’s way. “Forbearance, readiness to be reconciled, patient bearing and forgiving of injuries” must be measured by the duty to preserve life and “comfort and succor the distressed.” “Requiting good for evil” will require that repentance is genuine, and restitution may be required as a necessary prerequisite to reconciliation.

The catechism clearly delineates elements that tend to destroy life to include: “sinful anger, hatred, envy, desire of revenge . . . provoking words, oppression, quarreling, striking, wounding”. This list is a powerful testament to the Biblical teaching that the sin of murder begins in the heart, includes our words, and is violence against body and soul. Non-physical forms of abuse are frequently dismissed as they are harder to prove. A black eye or a broken bone is clear evidence. Diagnosing the wounds of one repeatedly denigrated, compulsively controlled, and persistently threatened is much more difficult. This takes time, requires patience, and could benefit from a knowledge of patterns typical of a relationship characterized by these sins.

The Seventh Commandment

WLC 139 defines what constitutes adultery. “Rape” is the categorical term used in the Westminster Standards that includes all types of sexual abuse, which is broader than the specific legal category we think of today. The rape of Tamar by her brother Amnon in 2 Samuel is the scriptural reference the Divines used to teach this prohibition. Instructively, the narrative describes many elements typical of a sexually abusive relationship such as grooming, stalking, the use of force, etc. Lack of consent is a key element that differentiates rape from other types of sexual sin (Deut. 22:22–29).

“Unjust divorce, or desertion.” It is here that many will likely find a source of disagreement in the DASA report as it deals with the hotly debated yet critical question of what constitutes an unjust divorce and desertion. Attachment 11 Divorce and Domestic Abuse (p. 2492–2501) is an additional foray into this matter. The PCA previously produced a study report on divorce (1992 Report of the Ad Interim Committee on Divorce and Remarriage [PCA]) and this report is used to inform the discussion and argumentation in this part of DASA. The present committee believes this issue is beyond the scope of its mandate. However, the committee does believe that the following statement is biblically defensible and OPC sessions should agree: “When physical abuse is occurring in a marriage, the church must deal with a situation which, as the Puritans saw, is contrary to God’s purpose for marriage. A temporary separation may be necessary for safety, which the church may need to facilitate, and the abusing partner should be disciplined, with helpful counsel but eventually to the point of excommunication if there is not repentance in deed as well as in word.” (DASA, 2335)

The Ninth Commandment

WLC 144 and WLC 145 address items “that relate to the investigations of abuse allegations, the response of the church to abuse, proper repentance of an abuser, and the issue of false reports.” Scripture abounds with the command to judge righteously and do so without prejudice. This is commanded in order that the “preserving and promoting of truth” and the “good name of our neighbor, as well as our own” is maintained. Ecclesiastically, this is the duty and responsibility of church courts.

DASA advises that the best way to engage in a competent and unprejudiced investigation is to make use of a skilled third party. This may not always be necessary but should always be considered. It may be necessary to involve law enforcement with the consent of the accused.

Regardless, church judicial process should be conducted with reverent diligence so that “concealing the truth, undue silence in a just cause, and holding our peace when iniquity calleth for either a reproof from ourselves, or complaint to others” would not be found in our churches. Those who abuse conceal their abuse through silence and darkness that they may continue and not be held accountable. A proper investigation will shine the necessary light of truth, thereby ensuring justice and protection for the abused as well as provide a deterrent to future abusers. Such an investigation should also protect one’s good name so as to not countenance, “raising false rumors” and “receiving and countenancing evil reports”.

Statistics suggest that false reports of physical and sexual abuse are rare (between 2% to 10% - Lisak, D., Gardinier, L., Nicksa, S. C., & Cote, A. M. (2010). False allegations of sexual assault: An analysis of ten years of reported cases. Violence Against Women, 16(12), 1318–1334). This is consistent with the direction given to Israel in Deuteronomy 22:25–27 that a woman who is alone with a man during a sexual assault should be given the benefit of the doubt. Regardless, it is worth noting the importance of ensuring the physical safety of one who is claiming abuse prior to an investigation into the claims. As mentioned previously, prioritizing physical safety should be of utmost concern, and sessions and deacons should do everything within their power to do so.


APPENDIX 1. SAMPLE CHILD PROTECTION POLICY

Generic Orthodox Church is committed to providing a safe and secure environment for those participating in our ministry activities with children and youth. We also seek to minimize any vulnerability to unwarranted accusations of improper behavior that our organization, volunteers, and employees may experience as they fulfill their ministerial duties. To fulfill these commitments as fully as possible, the Session has adopted the following procedures to be used, without exception, when selecting ministry volunteers and new employees.

Volunteer Screening Procedures

1. Prior to consideration, all candidates seeking a volunteer position that involves working with children or youth will complete and return a Children’s/Youth Work Application.

2. The Session, or designee, will carefully review the application, ensuring that the candidate is an appropriate match for the ministry position. The Clerk of the Session will store all application materials— the application form, background checks, reference check, notes from interviews, etc.—in a locked file cabinet or other secure location.

3. If the individual appears to be an appropriate candidate for the ministry position, the Session, or designee, will check at least two references to confirm the information that the candidate provided on the ministry application. The Session will also conduct a criminal background check through a state law enforcement agency or other provider of such services. The background check includes a minimum of the following levels of screening:

4. 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.

Employee Screening Procedures

1. The same procedures required for volunteer workers also apply to all potential employees, regardless of the ministry position for which they are being considered.

2. When indicated by our reference and/or background checks, employment candidates who pose a threat to others, or have a prior history of physical or sexual abuse directed against another person, will be removed immediately from consideration for employment within our organization.

Waiting Period

All volunteer candidates must be members of Generic Presbyterian Church for six months or more before they will be considered for any ministry position involving contact with children or youth.

Note: At the discretion and direction of the Session this requirement may be waived in the event of member transfers, etc.

Supervision

1. At least two adults must be present at every function or program involving children or youth. This includes each classroom, vehicle, or other enclosed area. One or more of these adults must be 21 years of age or older. For large groups, the number of adult supervisors must be increased in accordance with state student/teacher ratio requirements.

2. Two or more adults must be assigned to monitor children and youth activities in areas outside the location of a ministry service or event that is in progress. The adults assigned must have been previously approved through our ministry screening process

3. Workers should arrive at least ten minutes before a scheduled activity. They must remain at their assigned post until an authorized person has picked up all people in their care. No children or youth should be released to find their parents or wait unattended for transportation.

Counseling

1. When workers meet with youth for spiritual/emotional counseling, we encourage team counseling by two screened adults. If only one screened individual conducts the counseling session, it should be conducted in view of another screened worker through a window or an open door.

2. All counseling sessions should be limited to three occasions for no more than 30 minutes at a time. If more counseling is required, a professional counselor should be recommended

3. Written permission from parents/guardians must be obtained prior to counseling minors.

Work Restrictions

1. For children age six or older, at least one adult female should take girls to the restroom, and one adult male should take boys to the restroom. The adult should check to make sure the facility is safe and then wait outside the restroom for the children. The presence of a second adult escort is also recommended.

2. Children age five or younger (boys and girls) should be assisted as needed in the restroom by an adult female.

3. Never touch a person’s private areas except when necessary, as in the case of changing a diaper.

4. Workers should avoid the appearance of impropriety—such as sitting older children on their lap, kissing, or embracing others, etc.

5. Workers are to release children in their care only to parents, guardians, or persons specifically authorized to pick up the child.

Discipline

1. Workers are never to spank, hit, grab, shake, or otherwise physically discipline anyone. Physical restraint should only be used in a situation where it is reasonably necessary to prevent an individual from physically harming himself or another individual.

2. Disciplinary problems should be reported to a parent or guardian and Session if necessary.

Injury or Illness

1. Persons who are ill (with a fever, or a communicable disease that can be transmitted by cough or by touch) will not be permitted to participate in any ministry activity.

2. A suitable worker—one who has been previously approved through our ministry screening process—must be used to take the place of a worker who is ill.

3. Participants should be returned to their parent or guardian as soon as illness is discovered. If immediate return is not possible, then the person who is ill should be isolated in a manner that allows an adult worker to monitor the participant until he/she can be returned to a parent or guardian.

4. Take reasonable steps to avoid contact with blood, saliva, or other bodily fluids.

5. Church leaders who become aware of an injury to a worker or participant will take steps to ensure that proper medical attention is given to the injured person and provide for continued monitoring of the remaining activity participants.

6. Persons who have received an injury that is obviously minor should be given first aid as needed at the time of injury. The individual’s parents or guardians should be notified of the injury when they pick up the injured person.

7. Any injury that may require medical treatment beyond simple first aid should be given immediate attention. The parents or guardians of the injured person should be notified immediately along with church leadership. If warranted by the injury, emergency medical personnel should be called.

Record Keeping

1. All ministry functions involving children and youth, shall maintain an attendance list for every function. Record the date of the function, along with the names of all participants, ministry coordinators, and supervisors.

2. Ministry workers should prepare a written Notice of Injury report whenever an injury occurs during a ministry function. Promptly forward the incident report to the ministry coordinator or supervisor.

Notice of Injury, Abuse, or Molestation

1. Volunteer or paid ministry workers who become aware of any injury, abuse, or molestation occurring within any ministry activity must immediately inform the session. A Notice of Injury form must be completed for the incident.

2. Church leaders who become aware of possible abuse or molestation of a participant must ensure that the participant’s parent or guardian is immediately informed that possible abuse or molestation has occurred. If there is any doubt as to whether or not to report an incident or accusation to the civil authorities, the session will also ensure that an attorney is immediately contacted to provide a written opinion as to whether the organization should report to law enforcement authorities. The written opinion should be obtained within 24 hours after leadership first becomes aware of the situation. The attorney’s advice should be acted upon immediately, including reporting the incident to the authorities. An attorney also should be contacted immediately if leadership or the activity monitor becomes aware of possible abuse or molestation of a participant by a parent or guardian.

3. The session must promptly notify our ministry’s insurance carrier (general or professional liability insurance) upon notice of abuse or molestation.

Violation of Policy or Procedures

1. Ministry workers must promptly notify church leadership when they or others violate the procedures mandated by this policy.

2. Church leaders who become aware of a violation of the procedures set by this policy are required to take all necessary steps to ensure future compliance with them. In the process of ensuring compliance with this policy, it may become necessary to remove workers from their positions.

Internal Investigation

1. This ministry organization considers any allegation of abuse or molestation a serious matter. Each situation will be fully investigated by church leadership, always with the assistance of legal counsel and civil authorities.

2. Employees who are the subject of an investigation will be removed from their position, with pay, pending completion of the investigation. Employees who admit to the abuse or molestation will be terminated consistent with the established employment practices of Generic Presbyterian Church.

3. Volunteer subjects of any investigation will be removed from their positions pending completion of the investigation.

4. This ministry will permanently remove any employees or volunteers from their ministerial duties within the organization if they are found guilty of abuse or molestation. Whenever termination of employment is a factor, we also will consult with legal counsel.

Dealing with Law Enforcement and News Media

1. All leaders, employees, and volunteers of Generic Presbyterian Church will cooperate fully with law enforcement or governmental agencies investigating allegations of injury, abuse, or molestation.

2. The leadership of Generic Presbyterian Church will seek legal counsel as soon as possible after we receive notice of possible abuse or molestation within the organization. Advice from legal counsel will be the basis for our response to the allegations.

3. One individual—a member of the Session or our attorney—will be the designated spokesperson to handle all inquiries from the news media. Our spokesperson will be the only person to convey information concerning the situation, doing so in a prudent manner to avoid compromising an ongoing investigation and to maintain the privacy of the individuals involved.

Annual Review

1. Each year, we will conduct a review meeting. At that time, the procedures mandated by this policy will be reviewed with all volunteers, employees and the leadership of the organization.

2. Paid ministry employees and all volunteers working in any capacity with children or youth will complete a brief renewal application annually.

3. Should the renewal application indicate that any employees or volunteers have become unsuitable for working with children or youth they will be removed immediately from their current position. They will not be considered for positions involving work with other similar groups.

Revision of Policy and Procedures

The leadership of this ministry, with the assistance of legal counsel, will regularly review this policy and the procedures established within it. If necessary, the policies and procedures will be modified in accordance with the bylaws of the organization. When changes are made, ministry leaders will communicate them to all employees and volunteers affected by the policy changes.


APPENDIX 2. PREPARING TO BRING A CHARGE IN THE ORTHODOX PRESBYTERIAN CHURCH

As an appendix to the Report of the Committee for the Protection of the Flock, it seems good to include a guide to help people who believe they have been victims of abuse, or those who wish to help such a person, navigate through the process of writing a charge against the alleged abuser.

It is often claimed that the process of writing a charge (not to mention conducting a preliminary investigation and a trial) is exceedingly difficult, confusing, and time-consuming. Indeed, even for experienced officers of the church the task of writing a charge in such a way that it passes the test of a preliminary investigation can be daunting. The fact is, though, that most officers in the church do not regularly have to consult the Book of Discipline. We tend to do so only when the need arises.

The following is meant to be a step-by-step guide for the writing of a charge. It would still be good to have an experienced officer or church member help in the writing process and to give advice during the course of a preliminary investigation and the ensuing trial.

Preliminary Matters

There are a few questions that need to be answered before a charge is written. First, “Can I bring a charge?” The answer is found in the Book of Discipline III, 1 (page 98 in the 2020 edition of the Book of Church Order). If you are an injured party (a victim of abuse in this case) the answer is “yes.” If you know of a victim, but are not yourself a victim, you can also bring a charge. If you are a member of a judicatory (a session or a presbytery) the judicatory itself can bring a charge. Another question is this: “Does the one who brings a charge need to be a member of the Orthodox Presbyterian Church?” It seems clear that the writers of the Book of Discipline intended the provisions of the book to be used by members and officers of the Orthodox Presbyterian Church. Non-OPC people are not under the jurisdiction of the church. Therefore, the answer to the above question is, “yes, the author of a charge needs to be a member of the OPC.” However, the victim may not necessarily be a member. In such a case, a judicatory, if warranted, may formally bring a charge. In the case of a minor child who has been victimized by a member of the OPC, but that child is not a member, a member of the OPC would still be the person who brings the charge to the appropriate judicatory.

Before proceeding to the next question, we should consider the advantage of having a judicatory bring the charge. The Session or Presbytery should be notified as soon as possible after the alleged abuse has taken place. These are the bodies that exercise oversight over the members, elders, deacons and ministers of the church. Once the alleged abuse has been brought to the attention of the appropriate judicatory, that judicatory has a responsibility to take the matter seriously and follow up with an investigation into the allegation. Thus, the judicatory is already at this point involved in the matter and, if warranted, would be the best entity to bring a charge against an alleged abuser. We cannot stress this point enough. The judicatory is the ecclesiastical entity that is best suited to investigate a claim of abuse, to offer some protection and support to the person who may have been abused, and to take the lead in any formal judicial actions that result from the accusation and investigation.

However, suppose a person has decided to bring a charge against an alleged abuser by himself or herself. Perhaps, also, that person finds that it is too difficult a process to follow once they have started. He submits a charge that does not fit the proper form. According to Book of Discipline III, 7, b it is the responsibility of the judicatory to put the charge in a proper form. Book of Discipline III, 7, c provides for the person bringing a charge to ask the judicatory to take the responsibility for “prosecuting” the charge. In this case, “prosecuting” should be understood in a general sense to mean “to move forward”.

A second question is: “Do I have to follow the pattern of Matthew 18:15–20 before I can present a charge?” The basis of an answer to this question is found in Book of Discipline III, 4–5.

The only scenario in which following the procedure of Matthew 18:15–20 is mandatory is when the alleged sin is of a private (known only to one or a few people), personal (the person bringing the charge has suffered injury) nature among equals (reference the commentary on the Book of Discipline 3.5 by Alan Strange).

In cases of domestic violence and sexual abuse we are dealing with matters that are criminal and, in the case of abuse of minors, must be referred to civil authorities. Abuse is a sin of violence against the person. It is the immediate concern of a Session to protect that person. If such is the case, the matter is no longer private. Therefore, Matthew 18 would not apply. An alleged abuser should never be able to hide behind Matthew 18 when there is sufficient evidence to proceed with discipline. This also highlights the advantage of having a judicatory bring the charge, as was discussed earlier.

The fact that a criminal act which is heinous and may involve physical violence, sexual molestation, along with emotional control or manipulation, is alleged ought to caution us against a wooden approach to Matthew 18. Certainly, it would be wrong and even dangerous to send a minor child to confront an adult alleged to have committed a violent or perverse act against the person of that child.

Consider the following scenario: a child returns from a youth activity at church. During the course of getting the child ready for bed, a parent notices marks on the body of the child. The child, when asked about the marks, says that Mr. _________ touched him there and hurt him. The parents notify the pastor or an elder and ask to talk to the Session about the incident. Already, at this point, we are beyond a “private offense” and the invocation of Matthew 18 is moot. Similar scenarios may be imagined in which events unfold in such a way that the application of Matthew 18 is difficult, if not impossible.

According to Book of Discipline III, 2, a charge must be filed with a judicatory no more than two years after the alleged offense took place “unless it appears that unavoidable impediments have prevented an earlier filing of the charge.” It should be noted that this so-called “statute of limitations” is not absolute. Moreover, a judicatory should consider the difficulty in bringing a charge of abuse. It is not unusual for years to pass before abuse becomes known or understood. People should be encouraged to report abuse to the judicatory quickly, but sometimes that is simply not possible.

The next question to consider is: “Is there a specific form that I need to use to write a charge?” The answer is “yes.” Page 169 in the current edition of the Book of Church Order has a suggested form for a charge. It is as follows:

CHARGE AND SPECIFICATIONS

_____________ [here insert the title of the trial judicatory] of The Orthodox Presbyterian Church charges ____________ with __________ [here name the alleged offense]: __________ [here give references to applicable portions of the Word of God, and, where pertinent, to relevant provisions of the constitution]. Specifications: That on or about __________ the said ________ did ________ [here set forth briefly the place and circumstances of the alleged offense]. Witnesses and/or Documents: ___________ [here set forth the names of witnesses and/or the titles of documents to be produced in support of the charge and specifications].

_______________ [Moderator]

_______________ [Clerk]

Date: ___________

This form follows the instructions given for the proper form of a charge found in Book of Discipline III, 3 (page 98). While the form above seems short, it will become much longer when the Scripture references, constitutional references, specifications, witnesses and documents are all listed.

One more point before we move on to filling in the necessary information in a charge. According to Book of Discipline III, 1, a charge can only be brought against an elder in the church (ruling or teaching elder) by two or more people. Again, note the advantage to having a judicatory bring the charge since that would involve more than one person.

Writing the Charge

The first blank to be filled in is the name(s) of those who are bringing the charge. If a judicatory is bringing the charge (which is how the suggested form on page 169 is worded), the blank would be filled in with the name of the judicatory. For instance: “The Session of _____ OPC” or “Presbytery of ____ of the OPC”. If the charge is brought by a person(s), the name of the person(s) would be put in the space.

The next blank should be filled with the name of the person who is being accused of the abuse.

Immediately following the name of the accused comes the offense or sin with which the person is being accused. Sin is defined according to the objective standard of God’s law, therefore, the sin named here must be linked to at least one of the commandments of God. Generally, abuse involves the abuse of authority. The commandment that teaches us about the lines of authority that God has established is the fifth commandment (Exodus 20:12 “Honor your father and your mother, that your days may be long in the land that the LORD your God is giving you.). Abuse also may involve violent acts. In that case, the sixth commandment would be applicable (Exodus 20:13, “You shall not murder”). Abuse may also involve sexual sins which are covered under the seventh commandment (Exodus 20:14 “You shall not commit adultery.”) Abusers are often master-manipulators. Their efforts to manipulate their victims and also manipulate those who attempt to confront them may involve deception and outright lies. The ninth commandment applies in this case (Exodus 20:16 “You shall not bear false witness against your neighbor.).

These are the commandments commonly broken in cases of abuse. Depending on other factors, other commandments might be cited.

Now, the particular act which is alleged in the charge should be named in the context of the relevant commandment. Thus, for instance, this entry might read: “Breaking the sixth commandment by repeatedly striking his wife.” Or, “Breaking the seventh commandment by engaging in sexual activity with a child.” Notice that only one sin is mentioned in each of these examples even though a person may be guilty of several sins by the same act. That is because, according to Book of Discipline III, 3, (c), only one alleged offense can be listed in each charge. If more than one sin is alleged, then a second, or third charge should be written.

Next, there ought to be a list of relevant Scripture passages. This list need only include enough Scripture to define the act as sinful. Thus, in the case of domestic violence, there might be a list of citations as follows:

  1. Exodus 20:13 You shall not murder (also Deuteronomy 5:17)
  2. Matthew 5:21–22 “You have heard that it was said to those of old, ‘You shall not murder; and whoever murders will be liable to judgment.’ (22) But I say to you that everyone who is angry with his brother will be liable to judgment; whoever insults his brother will be liable to the council; and whoever says, ‘You fool!’ will be liable to the hell of fire.”
  3. Ephesians 5:28–30 In the same way husbands should love their wives as their own bodies. He who loves his wife loves himself. (29) For no one ever hated his own flesh, but nourishes and cherishes it, just as Christ does the church, (30) because we are members of his body.

More Scripture could be added, however, the above is sufficient. Closely following the citation of Scripture is the citation of relevant passages from the secondary standards of the church. The Bible is the primary standard, the Confession of Faith, Shorter and Larger Catechisms are the secondary standards. Why is it good to add these references? The secondary standards function, among other ways, as our agreed-upon interpretation and systematization of the statements of the Bible. Thus, if we look at the Larger Catechism we see that the Ten Commandments are interpreted according to certain principles (Q. 99. What rules are to be observed for the right understanding of the ten commandments?). The OPC, in adopting these standards, has committed itself to hold to these interpretations of the commandments. Thus, citations from the secondary standards illustrate the proper understanding of the passages of Scripture that were cited in the previous section.

In the case of the sixth commandment, it would be proper to cite the following from the Larger Catechism:

Q. 135. What are the duties required in the sixth commandment? A. The duties required in the sixth commandment are all careful studies, and lawful endeavors, to preserve the life of ourselves and others by resisting all thoughts and purposes, subduing all passions, and avoiding all occasions, temptations, and practices, which tend to the unjust taking away the life of any; by just defence thereof against violence, patient bearing of the hand of God, quietness of mind, cheerfulness of spirit; a sober use of meat, drink, physic, sleep, labour, and recreations; by charitable thoughts, love, compassion, meekness, gentleness, kindness; peaceable, mild and courteous speeches and behaviour; forbearance, readiness to be reconciled, patient bearing and forgiving of injuries, and requiting good for evil; comforting and succouring the distressed and protecting and defending the innocent.
Q. 136. What are the sins forbidden in the sixth commandment? A. The sins forbidden in the sixth commandment are, all taking away the life of ourselves, or of others, except in case of public justice, lawful war, or necessary defence; the neglecting or withdrawing the lawful and necessary means of preservation of life; 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, and whatsoever else tends to the destruction of the life of any.

Again, more could be added to this list, but even these two citations from the secondary standards are sufficient to establish that the commandment, when properly interpreted, forbids the physical abuse involved in domestic violence, and, moreover, the accused abuser has failed to keep the duties required in the commandment. Similar questions and answers from the Larger Catechism on the fifth, seventh and ninth commandments should be cited when those commandments are applicable to the alleged offense.

Specifications and Evidence

In the form for a Charge and Specifications above, the next entry is “Specifications”. What is a specification? It is a specific instance of the alleged offense. For example: A person may be charged with breaking the sixth commandment by physically assaulting his wife. A specification supporting that charge would be “On February 2, 2023, Mr. _______ violently attacked his wife causing several bruises.” If this has happened several times, then each of those instances would be a specification supporting the charge.

Each specification needs to be supported by evidence. The evidence may come in the form of the verbal testimony of the victim who, during the trial, would be called upon as a witness to testify. There might also be verbal testimony from people who became aware of the physical abuse. A person who met Mrs. ______ at a grocery store and noticed defensive bruises on her arms may have asked her about those bruises.

That person could also be called as a witness. A session member could testify about conversations that he may have had with the victim or even the abuser.

Evidence may also come in the form of documents that are submitted with the specifications. These documents may be letters, photographs or recordings. They should be listed along with the witnesses after each specification.

Acts of abuse, violent and sexual, often happen in secret. It is important for a victim, or, in the case of children, the parents of the child, to gather and preserve evidence as soon as possible after the event. If there are injuries, take pictures and send those pictures to a third party with an explanation. A medical report given to an injured person during an emergency room or doctor visit can become documentary evidence in a trial, but it must be preserved. An adult victim should tell someone else about the abuse. This requires courage, but it may be a key element in stopping the abuse and holding the abuser to account in both the criminal and ecclesiastical proceedings that may follow.

Notifying a third party or sending photographs to a third party with an explanation of the photograph also helps the judicatory when it is conducting a preliminary investigation. The testimony of witnesses must be relevant to the specification and the documentary evidence must be shown to be authentic, relevant and admissible.

When the charge has been written according to the form that we have been following, it is then sent to the clerk of the appropriate judicatory. In the case of a minister who has been accused, the judicatory would be the presbytery of which he is a member. In the case of members, including ruling elders and deacons, the judicatory would be the session of the congregation. The clerk will log the date that he received the charge and place it on the docket for the next meeting of the judicatory. At that time, the judicatory will consider the charge and determine if it should be sent for a preliminary investigation. The preliminary investigation will determine whether or not the charge should be approved by the judicatory and a trial date set.


APPENDIX 3. CHECKLIST TO PROTECT THE FLOCK

This checklist is designed to help sessions improve their preparedness to protect their flocks.

A. Childhood Sexual Abuse

Does your Church have a formal written Childhood Sexual Abuse Policy?

Yes_____ No_____

Does your Church require annual training of all staff and all volunteers who work with children?

Yes_____ No_____

Does your Church have an insurance policy that covers the Church, its Employers and Officers form Childhood Sexual Abuse Lawsuits?

Yes_____ No_____

Are your Employee and Officers aware of your State’s reporting requirements?

Yes_____ No_____

In the past 20 years, has an Employee or Officer been put on notice of an alleged incident of Childhood Sexual Abuse involving the Church?

Yes_____ No_____

If yes, state the circumstances, location, and time ____________________________

(a) On Church premises, while a Church event was occurring ______

(b) On Church premises, but after hours __________________

(c) Not on Church premises but during a Church event ______

Who was the alleged perpetrator? ___________________

(a) Church officer _____

(b) Church employee ___

(c) Adult Church member

(d) Child under 18 ______

(e) Other______ check and describe ______________

Was the abuse reported to the Local Authorities?

Yes_____ No_____

If no, why not? _____________________________________

What was the result of the charge, including a lawsuit or prosecution and Church discipline? Was there repentance from the perpetrator? What Pastoral care and Church support was given to the victim and his/her family? _____________________

How public was the abuse claim? Was the congregation informed? ____________________________________________

What changes, if any, were made after the incident or claim?

Is there anything else you would like to comment on or describe?

B. Domestic Violence

Does your Church have a policy on Domestic Violence?

Yes_____ No_____

If it has a policy, has this been communicated to its members?

Yes_____ No_____

In the past 20 years, have the Officers or Employees of the Church been made aware of Domestic Violence involving one or more of its members?

Yes_____ No_____

If yes, was the matter brought to the attention of the Local Authorities? If so, by whom and how? ________________________________________________

If yes, was the Session involved in Pastoral Care and/or Church Discipline? If so, briefly describe it and the result _________________________________

What was the final result? _______________________________

What changes, if any, were made by the Session as a result of the incident and its involvement? _____________________________________


RECOMMENDATIONS

1. That the 90th GA communicate this report to the churches for study and edification.

2. That the 90th GA dissolve the committee.


BIBLIOGRAPHY

Daniel, Pollack. “Understanding Sexual Grooming in Child Abuse Cases.” www.americanbar.org, November 1, 2015.

Edgington, David. The Abusive Wife: Ministering to the Contentious Woman. Pheonix, AZ: Compassionate Counselors, n.d.

Gouge, William. Building a Godly Home, Volume 1: A Holy Vision for Family Life. Grand Rapids, MI: Reformation Heritage Books, 2013.

Hammar, Richard R. Pastor, Church & Law. Matthews, NC: Christian Ministy Resources, 2000.

Kellemen, Robert W. Sexual Abuse: Beauty for Ashes (Gospel for Real Life). Phillipsburg, NJ: P&R Publishing, 2013.

McConnell, Mez. The Creaking on the Stairs: Finding Faith in God Through Childhood Abuse (Biography). Revised. Christian Focus, 2019.

Needham, Robert, and Debi Pryde. What To Do When You are Abused by Your Husband: A Biblical Perspective. 4th ed. San Bernardino, CA, 2023.

Newheiser, Jim. Help! Someone I Love Has Been Abused (Life-Line Mini-Book). Wapwallopen, PA: Shepherd Press, 2014.

Perina, Kaja. “When Female Predators Assault Men.” www.psychologytoday.com, October 19, 2019. Psychology Today.

Perkins, William. The Works of William Perkins. Edited by Stephen J. Yuille. Vol. 10. Grand Rapids, MI: Reformation Heritage Books, 2014. Notice particularly his section on correction of wives. Perkins demonstrated that the Scriptures does not support physical correction of wives. Therefore, deducing from the lesser to the greater, husbands should not strike their wives in anger.

Pierre, Jeremy, and Greg Wilson. When home hurts: A guide for responding wisely to domestic abuse in your church. Christian Focus, 2021.

Strickland, Darby A. Domestic Abuse: Recognize, Respond, Rescue. Phillipsburg, NJ: P&R Publishing, 2018.

Strickland, Darby A. Is it Abuse?: A Biblical Guide to Identifying Domestic Abuse and Helping Victims. P&R Publishing, 2020.

Committed to Care: Statement on Abuse and Biblical Counseling https://abuse.biblicalcounseling.com. “Framework & Guidelines.” www.biblicalcounseling.com. Association of Biblical Certified Biblical Counselors, 2023

https://www.nsopw.gov. “Get Answers about Sexual Abuse and Associated Risks: Common Questions.” https://www.nsopw.gov. US Dept. Of Justice, n.d. Accessed October 26, 2023.

www.Americanbar.org. “Understanding Sexual Grooming.” www.Americanbar.org. American Bar Association, n.d. Accessed October 2, 2022.

www.rainn.org. “Victims of Sexual Violence.” www.rainn.org, n.d. Accessed October 26, 2023.


TABLE OF CITATIONS FROM THE ORTHODOX PRESBYTERIAN CHURCH STANDARDS

Standard

Chapter

Details

Comment

Westminster Confession of Faith (WCF)

Chapter 1: Of the Holy Scripture

The Holy Scriptures are given by inspiration of God to be the rule of faith and life, that we may be moved and induced by the testimony of the church to a high and reverent esteem of the Holy Scripture, having it written on our hearts.

We are to have the Word written on our hearts; yet with sexual predation and domestic violence the heart is captive to sin until transformed by the Holy Spirit.

Chapter 4: Of Creation

After God had made all other creatures, he created man, male and female after his own image; having the law of God written in their hearts, and power to fulfill it: and yet under a possibility of transgressing, being left to the liberty of their own will.

Sexual predation and domestic violence are acts of sin against God’s image in our brothers and sisters.

Chapter 6: Of the Fall of Man, of Sin, and of the Punishment Thereof

Every sin, both original and actual, being a transgression of the righteous law of God, and contrary thereunto, doth, in its own nature, bring guilt upon the sinner, whereby he is bound over to the wrath of God, and curse of the law, and so made subject to death, with all miseries spiritual, temporal, and eternal.

Sexual predation and domestic violence are acts of sin and brings guilt upon the sinner; spiritual and temporal miseries in the present becoming eternal without a regenerated heart

Chapter 17: Of the Perseverance of the Saints

Nevertheless, they may, through the temptations of Satan and of the world, the prevalency of corruption remaining in them, and the neglect of the means of their preservation, fall into grievous sins; and, for a time, continue therein: whereby they incur God’s displeasure, and grieve his Holy Spirit, come to be deprived of some measure of their graces and comforts, have their hearts hardened, and their consciences wounded; hurt and scandalize others, and bring temporal judgments upon themselves.

The sin of sexual predation and domestic violence may be perpetrated by one whom God has effectually called; and while that call will persevere by the free and unchangeable love of God the Father, the efficacy of the merit and intercession of Jesus Christ, the abiding of the Spirit, and of the seed of God within them; yet devastating, grievous loss and pain may result.

Chapter 24: Of Marriage and Divorce

Marriage was ordained for the mutual help of husband and wife, for the increase of mankind with legitimate issue, and of the church with an holy seed; and for preventing of uncleanness.

Marriage is a creation ordinance patterned on the union of Adam and Eve; a holy institution before God and man. Domestic violence in marriage violates that holy union and grieves God's heart.

Westminster Larger Catechism (WLC)

Question 129

What is required of superiors towards their inferiors?

It is required of superiors, according to that power they receive from God, and that relation wherein they stand, to love, pray for, and bless their inferiors; to instruct, counsel and admonish them; countenancing, commending, and rewarding such as do well; and discountenancing, reproving, and chastising such as do ill; protecting, and providing for them all things necessary for soul and body: and, by grave, wise, holy, and exemplary carriage, to procure glory to God, honor to themselves, and so to preserve that authority which God hath put upon them.

Question 130

What are the sins of superiors?

The sins of superiors are, besides the neglect of the duties required of them, an inordinate seeking of themselves, their own glory, ease, profit, or pleasure; commanding things unlawful, or not in the power of inferiors to perform; counseling, encouraging, or favoring them in that which is evil; dissuading, discouraging, or discountenancing them in that which is good; correcting them unduly; careless exposing, or leaving them to wrong, temptation, and danger; provoking them to wrath; or in any way dishonoring themselves, or lessening their authority, by an unjust, indiscreet, rigorous, or remiss behavior.

Question 135

What duties are required in the 6th commandment?

The duties required in the sixth commandment are, all careful studies, and lawful endeavours, to preserve the life of ourselves and others by resisting all thoughts and purposes, subduing all passions, and avoiding all occasions, temptations, and practices, which tend to the unjust taking away the life of any; by just defence thereof against violence, patient bearing of the hand of God, quietness of mind, cheerfulness of spirit; a sober use of meat, drink, physic, sleep, labor, and recreation; by charitable thoughts, love, compassion, meekness, gentleness, kindness; peaceable, mild, and courteous speeches and behavior: forbearance, readiness to be reconciled, patient bearing and forgiving of injuries, and requiting good for evil; comforting and succoring the distressed, and protecting and defending the innocent.

Question 136

What are the sins forbidden in the 6th commandment?

The sins forbidden in the sixth commandment are, all taking away the life of ourselves, or of others, except in case of public justice, lawful war, or necessary defence; the neglecting or withdrawing the lawful and necessary means of preservation of life; 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, and whatsoever else tends to the destruction of the life of any.

Question 139

What are the sins forbidden in the 7th commandment?

The sins forbidden in the seventh commandment, besides the neglect of the duties required, are, adultery, fornication, rape, incest, sodomy, and all unnatural lusts; all unclean imaginations, thoughts, purposes, and affections; all corrupt or filthy communications, or listening thereunto; wanton looks; impudent or light behavior; immodest apparel; prohibiting of lawful, and dispensing with unlawful marriages; allowing, tolerating, keeping of stews, and resorting to them; entangling vows of single life; undue delay of marriage; having more wives or husbands than one at the same time; unjust divorce or desertion; idleness, gluttony, drunkenness, unchaste company; lascivious songs, books, pictures, dancing, stage plays; all other provocations to, or acts of uncleanness, either in ourselves or others.

Question 142

What are the sins forbidden in the 8th commandment?

The sins forbidden in the eighth commandment, besides the neglect of the duties required, are, theft, robbery, man-stealing, and receiving any thing that is stolen; fraudulent dealing; false weights and measures; removing landmarks; injustice and unfaithfulness in contracts between man and man, or in matters of trust; oppression; extortion; usury; bribery; vexatious lawsuits; unjust inclosures and depopulations; engrossing commodities to enhance the price, unlawful callings, and all other unjust or sinful ways of taking or withholding from our neighbor what belongs to him, or of enriching ourselves; covetousness; inordinate prizing and affecting worldly goods; distrustful and distracting cares and studies in getting, keeping, and using them; envying at the prosperity of others; as likewise idleness, prodigality, wasteful gaming; and all others ways whereby we do unduly prejudice our own outward estate, and defrauding ourselves of the due use and comfort of that estate which God hath given us.

Question 144

What duties are required in the ninth commandment?

The duties required in the ninth commandment are, the preserving and promoting of truth between man and man, and the good name of our neighbor, as well as our own: appearing and standing for the truth; and from the heart, sincerely, freely, clearly, and fully, speaking the truth, and only the truth, in matters of judgment and justice, and in all other things whatsoever; a charitable esteem of our neighbors; loving, desiring, and rejoicing in their good name; sorrowing for, and covering of their infirmities; freely acknowledging of their gifts and graces, defending their innocency; a ready receiving of good report, and unwillingness to admit of an evil report, concerning them; discouraging tale-bearers, flatterers, and slanderers; love and care of our own good name, and defending it when need requireth; keeping of lawful promises; study and practising of whatsoever things are true, honest, lovely, and of good report.

Question 145

What are the sins forbidden in the ninth commandment?

The sins forbidden in the ninth commandment are, all prejudicing the truth, and the good name of our neighbors, as well as our own, especially in public judicature; giving false evidence; suborning false witnesses; wittingly appearing and pleading for an evil cause; out-facing and overbearing the truth; passing unjust sentence; calling evil good, and good evil; rewarding the wicked according to the work of the righteous, and the righteous according to the work of the wicked; forgery; concealing the truth; undue silence in a just cause, and holding our peace when iniquity calleth for either a reproof from ourselves, or complaint to others; speaking the truth unseasonably, or maliciously to a wrong end, or perverting it to a wrong meaning, or in doubtful and equivocal expressions, to the prejudice of truth or justice; speaking untruth, lying, slandering, backbiting, detracting, tale-bearing, whispering, scoffing, reviling, rash, harsh, and partial censuring; misconstructing intentions, words, and actions; flattering, vain-glorious boasting, thinking or speaking too highly or too meanly of ourselves or others; denying the gifts and graces of God; aggravating smaller faults; hiding, excusing, or extenuating of sins, when called to a free confession; unnecessary discovering of infirmities; raising false rumours, receiving and countenancing evil reports, and stopping our ears against just defence; evil suspicion; envying or grieving at the deserved credit of any, endeavouring or desiring to impair it, rejoicing in their disgrace and infamy; scornful contempt; fond admiration; breach of lawful promises; neglecting such things as are of good report; and practicing or not avoiding ourselves, or not hindering what we can in others, such things as procure an ill name.

Question 151

What are those aggravations that make some sins more heinous than others?

1. From the persons offending: if they be of riper age, greater experience or grace, eminent for profession, gifts, place, office, guides to others, and whose example is likely to be followed by others.

2. From the parties offended: if immediately against God, his attributes, and worship; against Christ, and his grace; the Holy Spirit, his witness, and workings; against superiors, men of eminency, and such as we stand especially related and engaged unto; against any of the saints, particularly weak brethren, the souls of them or any other, and the common good of all or many.

3. From the nature and quality of the offence: if it be against the express letter of the law, break many commandments, contain in it many sins: if not only conceived in the heart, but break forth in words and actions, scandalize others, and admit of no reparation: if against means, mercies, judgments, light of nature, conviction of conscience, public or private admonition, censures of the church, civil punishments; and our prayers, purposes, promises, vows, covenants, and engagements to God or men: if done deliberately, willfully, presumptuously, impudently, boastingly, maliciously, frequently, obstinately, with delight, continuance, or relapsing after repentance.

4. From circumstances of time and place: if on the Lord’s day, or other times of divine worship; or immediately before or after these, or other helps to prevent or remedy such miscarriages: if in public, or in the presence of others, who are thereby likely to be provoked or defiled.

Book of Discipline

Chapter 1: The Nature and Purposes of Discipline

Ecclesiastical, administrative and judicial disciplines are defined in the context that all members under the care of the church are subject to such disciplines

Additional comment not necessary

Chapter 2: Jurisdiction

Jurisdiction over an individual belongs to the judicatory of the body of which the individual is a member

Additional comment not necessary

Chapter 3: Steps in the Institution of Judicial Process

Steps 1 to 8 applied as appropriate, the offense alleged in the charge should be serious enough to warrant a trial

Step 2: it is not uncommon for there to be many years of abusive conduct before a victim realizes and reports the hurt; such history may be essential then to exposing a heart that the Spirit can transform through repentance from sin.

Step 5: careful situational discernment is vital to ensure the safety of victims in a domestic violence situation.

Chapter 4: The Trial of Judicial Cases

Rules for the judiciary, clerk, accused, witnesses, evidence and trial proceedings

Additional comment not necessary

Chapter 5: Cases without Full Process

When a person comes before a judicatory as his own accuser

Additional comment not necessary

Chapter 6: Censure and Restoration

Judicial discipline described within five possible degrees of censure: admonition, rebuke, suspension, deposition, and excommunication

Additional comment not necessary

Chapter 7: Appeals

The removal of the case to an appellate judicatory by the filing of a petition asking that the final judgment of a lower judicatory be reversed or modified

Additional comment not necessary

Chapter 8: Dissents and Protests

Any member of a judicatory may file a written protest stating his reasons for objecting to an action or judgment of the judicatory

Additional comment not necessary

Chapter 9: Complaints

A complaint is a written representation, other than an appeal or a protest, charging a judicatory with delinquency or error

Additional comment not necessary

Endnotes

[1]“Framework & Guidelines,” www.biblicalcounseling.com (Association of Certified Biblical Counselors, 2023), https://abuse.biblicalcounseling.com.

[2]“Understanding Sexual Grooming,” www.Americanbar.org (American Bar Association, n.d.), accessed October 2, 2022.

[3]“Get Answers about Sexual Abuse and Associated Risks: Common Questions,” https://www.nsopw.gov (US Dept. Of Justice, n.d.), accessed October 26, 2023.

[4] “Understanding Sexual Grooming in Child Abuse Cases.” www.americanbar.org, November 1, 2015.

[5]Mez McConnell, The Creaking on the Stairs: Finding Faith in God Through Childhood Abuse (Biography), Revised (Christian Focus, 2019), 174.

[6]Hammar, Pastor, 133.

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