Taking Exception

At the 2018 General Assembly of the Presbyterian Church in America (PCA), the Committee on Review of Presbytery Records (CRPR) presented its annual report. The Assembly tasks this committee with reviewing the minutes of each of the PCA's Presbyteries. CRPR relays to the Assembly any constitutional irregularities that it believes it has found in those minutes. One alleged irregularity became the occasion of some debate on the floor of this year's Assembly.

A Presbytery had examined and approved a candidate for ordination. In the course of that examination, the candidate declared a difference with Westminster Larger Catechism 109.[1] Having approved the candidate for ordination, the Presbytery subsequently approved a motion that the candidate "not be allowed to teach his exception to LC 109."[2]

CRPR recommended that the Assembly find this action of Presbytery an "exception of substance."[3] A minority of the committee disagreed and argued that Presbytery was within its rights to forbid the ordinand from teaching his exception. After hearing from both the committee and the minority, the Assembly debated the matter. The Assembly ultimately adopted CRPR's recommendation to find the Presbytery's action an "exception of substance."

The Issue

What was properly at issue in this debate? Here it is crucial to define the question. The question is not whether a difference with LC 109 constitutes an acceptable exception in the courts of the PCA. Nor is the question whether it is under any circumstances permissible for an officer to teach an exception to the Westminster Standards. Nor is the question whether the Presbytery, in this particular situation, acted prudentially. The question is whether a Presbytery possesses the power to instruct one of its members or licentiates not to teach a difference that the court has determined an exception. This question is both important and wide-ranging. It touches not only upon the inherent rights of particular church courts, but also upon the relations among the courts of the church. It raises questions of the nature and purpose of confessions, of the relation of officers to the church, and of the liberty of conscience of those who subscribe to the church's standards.

We will argue that Presbytery does possess the power to instruct one of its members or licentiates not to teach a difference that the court has determined an exception. There are four interrelated considerations that will help us to see that Presbytery has such a power.

  1. The Nature and Purpose of Confessional Standards

The first concerns the nature and purpose of confessional standards. The Westminster Standards are, of course, "subject to and subordinate to the Scriptures of the Old and New Testaments, the inerrant Word of God."[4] They "sink below the authority of the Scripture."[5] What, then, are the Westminster Standards, and what purpose do they serve in the PCA? According to the nineteenth century American Presbyterian, Samuel Miller, a creed or confession is "an exhibition, in human language, of those great doctrines which are believed by the framers of it to be taught in the Holy Scriptures; and which are drawn out in regular order, for the purpose of ascertaining how far those who wish to unite in church fellowship are really agreed in the fundamental principles of Christianity."[6] It is "a list of the leading truths which the Bible teaches...which a certain portion of the visible catholic church agree in considering as a formula by means of which they may know and understand one another."[7] Miller highlights two important dimensions of a confession in the life of the church. First, a confession is a statement of the church. It is not the opinion of a private individual or individuals. Neither is it a declaration of a particular assembly of the church's leadership. It is a public and official declaration on the part of the whole church with respect to what she believes the Bible to teach.[8] Second, the purpose of a confession is to maintain and promote unity. Since the church's unity is necessarily founded upon the truth of Scripture, confessions afford invaluable aids to the church to comply with the apostolic command to "maintain the unity of the Spirit in the bond of peace" (Eph 4:3). Creeds and confessions do not merely serve as tools to ascertain the orthodoxy of candidates for office. They promote the church's unity by declaring, up front and in writing, what one may expect to be taught (and not taught) within the church. They mark the boundaries within which those who teach in the church are expected to function.

These considerations help us to understand the ecclesiastical significance of candidates' stated differences to the Westminster Standards. In the judgment of the church, the Westminster Standards summarize the teaching of Scripture. For that reason, "an exception to the Confession, from the point of view of the Church confessing, is an exception to the teaching of Scripture (although obviously not from the point of view of the sincere exceptor)."[9] When a candidate for ordination declares a difference that is subsequently deemed to be an exception, and when this candidate wishes to teach his exception, he is requesting that he be permitted to teach contrary to the church's understanding of the Bible. This is not to say that it is categorically impermissible for an officer to teach an exception to the church's standards. But it is to say that the church has both an interest in and the right to determine whether or not he will be allowed to teach this exception so long as he ministers within her bounds.

  1. The Relation of Officers to the Church

The second consideration comes from the relation of officers to the church. To begin, church office is not a right to which an individual is entitled. It is a privilege that the church grants to those whom it deems qualified. This point is underscored by the Second Preliminary Principle of the PCA's Book of Church Order (BCO):

"In perfect consistency with the above principle [i.e. of the true liberty of individual conscience], every Christian Church, or union or association of particular churches, is entitled to declare the terms of admission into its communion and the qualifications of its ministers and members, as well as the whole system of its internal government which Christ has appointed. In the exercise of this right it may, notwithstanding, err in making the terms of communion either too lax or too narrow; yet even in this case, it does not infringe upon the liberty or the rights of others, but only makes an improper use of its own."

This Preliminary Principle acknowledges that churches may misuse this right, but abusus non tollit usum-that misuse does not nullify the legitimate use of this right. When a man seeks office in the church, he agrees to be examined according to the qualifications set by the church. When the church admits a man into office, the man agrees to hold office on the terms set by the church. A minister or an elder does not function in the capacity of a private individual. He functions as an officeholder in the church. Even as his "commission is from Christ," it is also "through the church." Since "the church's organ, through which she officially performs her witnessing function as a body, is her ministry," the "official testimony [of church officers] is her testimony."[10]

Because officeholders are, in this respect, the church's instruments, when the church admits a man to office, it is a reasonable expectation on the part of the church that an officer of the church would teach the standards of the church. It is, furthermore, a legitimate prerogative of the church to insist that he, so long as he is an officer in her bounds, refrain from teaching a particular doctrine that is contrary to the church's standards.

It is sometimes argued that setting the terms of office in this way violates the liberty of the candidate's conscience. This is a serious concern, not least because Presbyterians have historically stood in the vanguard of those who defend liberty of conscience. Does forbidding a man to teach his exception as a condition of holding office require him to violate his conscience?

The answer to that question is "no." Recall that church office is a privilege and not an entitlement. No individual deserves to hold office in the church. Furthermore, the church is free to set the terms of office how it pleases. Even when she errs here, the Second Preliminary Principle reminds us, the church "does not infringe upon the liberty or the rights of others, but only makes an improper use of her own." If a particular body's terms are not agreeable to the individual, he is not bound to agree to them. No earthly injustice is done to him if, for these reasons, he is not admitted to office. Moreover, he is free to affiliate with some other body whose convictions lie closer to his own. As J. Aspinwall Hodge, commenting on this Second Principle, observed, "This principle is essential to all organizations. Men are at liberty to refuse to be connected with a society, but if they voluntarily enter, they must submit to its terms of admission and to its laws."[11]

  1. The PCA's Constitution

The third consideration concerns the constitutional government of the PCA. The PCA's BCO presently requires all candidates for licensure and ordination to submit their differences to Presbytery. It requires Presbytery to adjudicate those differences in a particular manner. The BCO, however, is silent concerning whether or not a candidate may teach differences determined to be exceptions. On these points of fact, all parties are agreed. But what are we to make of that constitutional silence?

The BCO articulates a nuanced and biblical understanding of the inherent powers of church courts. It notes that "all Church courts are one in nature, constituted of the same elements, possessed inherently of the same kinds of rights and powers, and differing only as the Constitution may provide."[12] Lower courts do not derive their rights and powers from higher courts. They derive them from Christ. It is the Constitution, the previously agreed upon framework of government, that assigns spheres of activity to the graded courts of the church.

Since the constitution of the PCA is silent with respect to exceptions, it is left to Presbyteries, whom the BCO tasks with examining licentiates and ministers, to determine how to handle the exceptions of candidates who come before it. Presbyteries are free to allow men to teach their exceptions, and they are free to forbid men from teaching their exceptions. Unless the Assembly can demonstrate that a Presbytery has violated the constitution in making a particular determination, the Assembly must refrain from interfering with the Presbytery's lawful exercise of its right as a court of the church. In the matter that CRPR presented to this year's General Assembly, no such constitutional violation was proven. The Assembly should have approved the action of Presbytery in question.

  1. Past Actions of PCA General Assemblies

The fourth consideration is an historical one. Prior to the matter that came before this year's Assembly, not fewer than three Assemblies upheld the right of Presbytery to forbid a member from teaching his exception. Over a quarter-century ago, a PCA Presbytery forbad a member minister from teaching or preaching a view that Presbytery had deemed an exception. The minister complained against that action and took his complaint to the 1992 General Assembly. That Assembly, through its Standing Judicial Commission, upheld the action of Presbytery.[13] Six years earlier, in 1986, the Assembly upheld the right of Presbytery to restrict its members' teaching of exceptions.[14] The 1990 Assembly reiterated its commitment to this right.[15] This pattern of Assembly actions clearly recognizes the rights of Presbyteries to forbid its members from teaching exceptions.[16]


In summary, Presbytery possesses the power to instruct one of its members or licentiates not to teach a difference that the court has determined an exception. An exception is, in the eyes of the church, a departure from what the church understands the teaching of the Bible to be. In light of that state of affairs, the church has an interest in and a right to determine whether or if exceptions may be taught in its bounds. Officers, furthermore, serve on the terms set by the church. They are instruments of the church as the church bears witness to the truth before the world. For these reasons, the church may require its officers to refrain from teaching their exceptions. When the church does so, it does no violence to the candidate's liberty of conscience. We have also seen that the Constitution of the PCA is silent with respect to the permissibility of the teaching of exceptions. This silence leaves the matter in the hands of Presbyteries, subject, of course, to the provisions of the Constitution. And, finally, we have seen evidence from recent history that PCA Presbyteries have exercised and PCA General Assemblies have upheld the right to forbid its member ministers from teaching their exceptions.

We have avoided addressing both how often Presbyteries should exercise this right and the specific circumstances under which Presbyteries should exercise this right. We have, rather, aspired to show that this right is one that belongs to Presbytery. The Presbyteries of the PCA should remain free to exercise this right within the parameters set by the Bible and the Constitution of the PCA.


Guy Prentiss Waters

Reformed Theological Seminary

Jackson, MS


[1] For the provision in the PCA's Book of Church Order governing the candidate's declaration of his differences with the Westminster Standards and the court's adjudication of any such stated differences, see The Book of Church Order of the Presbyterian Church in America (6th ed.; Lawrenceville, GA: Committee on Discipleship Ministries, 2017), 21-4.f.

[2] Presbyterian Church in America, 46th General Assembly: Commissioner Handbook (2018), p. 1205, citing the minutes of the Presbytery in question.

[3] "Exception...(Preliminary Principle 1)-The resulting prohibition whereby a TE [Teaching Elder] was prevented from teaching his accepted view is contrary to our practice of good faith subscription and the first preliminary principle," Commissioner's Handbook, p. 1204. The term "exception" here refers to the committee's judgment that the Presbytery's action was contrary to the provisions of the PCA's Constitution. A Presbytery uses the same term but in a different way, to refer to its determination that a candidate's stated difference with the Westminster Standards is in fact a difference with those Standards.

[4] "Preface to the Book of Church Order, III. The Constitution Defined," Book of Church Order. Compare Westminster Confession of Faith 1.10.

[5] Francis Turretin, Institutes of Elenctic Theology (3 vols.; Phillipsburg, NJ: P&R, 1992-7), 3:284 (=L.18.30.9).

[6] Samuel Miller, The Utility and Importance of Creeds and Confessions: Addressed Particularly To Candidates For the Ministry (Philadelphia: Presbyterian Board of Publication, 1839), 7.

[7] Miller, Utility and Importance, 8.

[8] See also John Murray, "Tradition: Romish and Protestant," in Collected Writings of John Murray (4 vols.; Edinburgh: Banner of Truth, 1982), 4:272, as cited at David F. Coffin, Jr. "The Justification of Confessions and the Logic of Confessional Subscription," in ed. Peter A. Lillback, The Practical Calvinist: An Introduction to the Presbyterian & Reformed Heritage (Fearn: Christian Focus, 2002), 341.

[9] Coffin, "Justification," 340.

[10] Robert L. Dabney, "Broad Churchism," in Discussions: Evangelical and Theological, Volume 2 (1891; repr. Edinburgh: Banner of Truth, 1967), 453, 454. Dabney continues, "The church, then, must bear an official witness, which is the act of the body, and not merely of the individual agents. Hence it must follow that the body, and also each ruling part thereof, is responsible to God for the tolerated official acts of each member. If I, then, a ruler in this body, lend to an officer or member of it any portion of my official weight or countenance to aid him in proclaiming religious error, contradicting in any point more or less essential that code of redeeming truth which Christ has committed to us, I am, to that extent, recreant to my obligations-unfaithful to my Master. I am prostituting power with which he has clothed me for the edification and guardianship of his redeemed sheep," 454.

[11] J. Aspinwall Hodge, What Is Presbyterian Law As Defined By Church Courts? (7th ed.; Philadelphia: Presbyterian Board of Publication and Sabbath Work, 1894), 24.

[12] Book of Church Order 11-3. Compare here Thomas E. Peck, "That in matters of original jurisdiction every court has, prior to any constitutional distribution of power, all the power that any court has. The presbytery does not derive its powers from the session, nor the synod from the presbytery, nor the general assembly from synods or presbyteries in an ascending scale, nor the synod from the general assembly in a descending scale, etc. But as every court is a presbytery composed of presbyters of two classes, it is clothed with all the powers of government...The sphere of the several courts, therefore, in matters of original jurisdiction is not determined by the places they occupy in the scale, but by the definitions of the constitution," Notes On Ecclesiology (Richmond: Presbyterian Committee of Publication, 1892), 196.

[13] TE Hooper vs. James River Presbytery, cited at Morton H. Smith, The Subscription Debate: Studies in Presbyterian Polity (Greenville, SC: Greenville Presbyterian Theological Seminary, n.d.), 13-15. The decision reads, in part, "Presbyteries may exercise such power over the preaching and teaching of its members short of a determination that the forbidden teaching is heresy, without necessarily binding the consciences of the men under its care. JRP has not determined, in this case, that the complainant's preaching or teaching is heretical. We must defer to presbytery, therefore, as the court most able to determine what may be harmful to the spiritual welfare of the churches under its care." The decision further noted, "we do not find any evidence in this case that JRP, by limiting the preaching and teaching of the complainant in the areas here in issue, has violated Chapter XX of the Confession of Faith or the Scripture cited in the complaint....," cited at ibid.

[14] "When a man is ordained with the allowance of exceptions to his full acceptance of the PCA standards, he thereby obtains (1) approval of his suitability to function within the ordained office, and (2) liberty to believe and live in some way not fully in accord with some portion of those standards. This allowance of exceptions, however, does not warrant his teaching or preaching of that matter so as to disturb the peace and purity of the church. The court of jurisdiction must determine in each situation whether such unwarranted actions have occurred," M14GA, pp. 125, 126, cited at Smith, The Subscription Debate, 14.

[15] "Presbyteries do have jurisdiction over TEs and have the authority to restrict a minister from preaching views which the presbytery is convinced may be harmful to the spiritual welfare of the churches under its care (BCO 13-9 and 34-5). If a member of a church is convinced that the presbytery under whose jurisdiction he is has erred, judicial process is provided for in BCO 43," M18GA, p. 205, citied at ibid.

[16] Recognizing, of course, that Assembly deliverances do not carry constitutional authority, and that Assembly judicial decisions are "applicable only to similar cases," Thomas E. Peck, "The Action of the Assembly of 1879 on Worldly Amusements, or The Powers of Our Several Church Courts" in ed. Thomas C. Johnson, Miscellanies of Rev. Thomas E. Peck (3 vols.; Richmond: Presbyterian Committee of Publication, 1895-7), 2:345.