Theological diversity: Health or heresy?

Appendix 2: Cases of disciplinary action since 1900

The following cases are those which have come to the authors’ attention in the course of their research in the Anglican and non-conformist traditions within English-speaking countries. The list covers only cases which have received public attention; we have not sought access to private church archives, and there may well be many other cases that we have not been able to discover. We welcome further information on these or other cases.

Charles Augustus Briggs, Presbyterian, USA (1893)

Briggs’ case is typical of the struggles between modern Biblical criticism (favoured by Union Theological Seminary) and traditional views on Biblical inerrancy (the Princeton position). In November of 1890, Briggs was appointed to the Edward Robinson Chair of Biblical Theology at UTS. His inaugural address on 20 Jan 1891 led the Presbytery of New York to charge that three areas of the talk ran counter to the Confession of Faith: in equating the Bible, the Church and Reason; in its rejection of inerrancy; and in proposing a belief in progressive sanctification after death as a biblical and church doctrine.

In October, Briggs was tried on heresy related to the second and third of these points, and was acquitted. The prosecution appealed and the case was remanded to the New York Presbytery, which also acquitted Briggs. The prosecution then appealed to the General Assembly, where Briggs was convicted by a vote of 383 to 116 and suspended. The Assembly also disavowed all responsibility for the faculty of UTS and declined to receive further reports from the seminary until satisfactory relations were re-established.

Briggs was received into the priesthood of the Episcopalian Church in 1899 and continued to teach at Union, focusing particularly on Christian Unity. He died in 1913. Shriver notes: "The heresy trials had done more in two years to spread Briggs’ views on higher criticism than he could have accomplished in a lifetime. Undoubtedly, much of the ecumenical concern that has remained the hallmark of Union Seminary can be traced to his influence."

A C McGiffert, Presbyterian, USA (1900)

McGiffert’s inaugural address at Union Theological Seminary was described as "most excellent Quaker teaching, but...a direct onslaught on the very basis of Reformed and, indeed, of the whole Protestant theology." His 1897 book A History of Christianity in the Apostolic Age aroused much hostility. He worked on the basic assumption that historical change makes all religious teaching relative and there is no continuing ‘essence’ of Christian history. The Assembly strongly disapproved of the book, issued a warning to McGiffert and counselled him to reform his views or peaceably withdraw from the Presbytery. McGiffert refused to do either and the next Assembly referred the matter to the New York Presbytery, which disapproved of specific views but voted against another heresy trial. However, one member then filed formal heresy charges which were again brought to the General Assembly in 1900; McGiffert decided to withdraw ‘to save the Presbyterian Church which he loved dearly, from a great heresy trial." He joined the Congregational Church and was president of Union Theological Seminary from 1917 to 1926.

Hinckley Gilbert Thomas Mitchell, Methodist Episcopal, USA (1901)

Mitchell was investigated in 1895 and 1899 for tendencies towards naturalism and Unitarianism, in the context of the general struggle between traditional teaching and ‘higher criticism’. His 1901 book The World before Abraham opened a further investigation leading to refusal by the Board of Bishops to appoint him to another 5-year term at Boston University. Mitchell requested a trial but this was refused and the Conference passed a vote censuring his teachings. He continued to write and was later appointed to Tufts.

Algernon Sidney Crapsey, Episcopalian, USA (1906)

Crapsey’s troubles began around 1895 regarding his preference for moral and social issues, and church unity, over doctrine. In 1905, as part of a series of lectures on the relationship between the Church and the State, Crapsey made statements which were understood to challenge the doctrines of the virgin birth, the bodily resurrection and the divinity of Jesus. A committee appointed to review his case declined to recommend a trial, but condemned his teaching. Considerable controversy was raised, and the Bishop initiated a presentment in 1906 on two counts of heresy and appointed a court to hear the case. Witnesses called to support the orthodoxy of Crapsey’s views were not allowed to testify, and Crapsey was convicted. On appeal the conviction was upheld. Crapsey resigned and never took another church position. Later in life he described himself as a Pantheistic Humanist.

George B Foster, Southern Baptist, USA (1909)

Foster, an ordained Baptist minister, taught systematic theology and philosophy of religion at the Divinity School of the University of Chicago. The Baptists Ministers’ Conference condemned his 1906 book The Finality of the Christian Religion. On the publication of his 1909 book, The function of religion in man’s struggle for existence, the Minister’s Conference voted on 26 June to expel him. However, he never surrendered his papers of ordination and he continued to teach at the University of Chicago.

James Henry George Chapple, Presbyterian minister, New Zealand (1910)

In 1907 there was an attempt to remove James Henry George Chapple (1865-1947) from his Timaru (NZ) church. The vote was 200 for him and 8 against. In 1910 proceedings were brought against Chapple in the Timaru Presbytery for having, amongst other things, preached in the Unitarian church at Auckland as a candidate. Chapple resigned and started a Unitarian church in Timaru. He stayed until July 1915, then spent two years in California, and returned to Christchurch in 1917 to start Unitarian meetings there.

Frank Staff, Southern Baptist, USA (1911)

Staff was a professor at New Orleans Baptist Theological Seminary. He was investigated in 1956 and charged with undue emphasis on the human elements in the New Testament, alleging that the Trinity was unbiblical, viewing the atonement as ‘transactional’, holding that God’s wrath was the consequence of sin rather than a response to sin, and holding a ‘too psychological’ explanation of demons. Stagg was called before the Trustees to respond, and then acquitted. He stayed at NOBTS until 1964, then went to Southern Baptist Seminary and remained there until his retirement in 1982.

John Dietrich, Reformed Church, USA (1911)

John Dietrich was minister of St. Mark’s Memorial Church in Pittsburgh. His ministry appears to have been controversial in several ways. The Allegheny Classis investigated his teaching and determined that Dietrich did not believe in the infallibility of the Bible, nor in the virgin birth and deity of Jesus, nor in the traditional understanding of the atonement. A trial was set for July 10, 1911; Dietrich refused to defend himself and was "defrocked", in spite of the continuous support of his board of trustees and many of the members at St. Mark's. After his last Sunday as minister, St. Mark's was closed and the next service was not held until a year later. Dietrich became a Unitarian minister and gradually moved from a position of liberal theistic Unitarianism to religious non-theistic humanism.

Bishop William Montgomery Brown, Episopalian, USA (1924-25)

Brown was tried for heresy in 1924-25, largely because of his outspoken support for Communism.

Dr Ernest Davey, Presbyterian, Ireland (1927)

Dr Davey was Principal and Professor at Presbyterian College, Belfast (now called Union College). He was tried for heresy in 1927, primarily on issues related to modern Biblical criticism. Although he was acquitted, the trial had a deeply discouraging effect on him, virtually ending his activity as an author.

J Gresham Machen, Presbyterian, USA (1932)

Machen was expelled from the PCUSA for his opposition (sic!) to modernism. In his 1923 book Christianity and Liberalism he stated that liberalism/ modernism was not a perversion of Christianity but a completely different religion, because it was not based on the narration of a historical event. In 1932 he published an attack on the report "Rethinking Missions’, which had advocated tolerance and acceptance of other religions; he set up an independent mission board in opposition to the General Assembly. The New Brunswick Presbytery then pressed charges against Machen for violation of ordination vows, rebellious defiance, and disobeying the lawful authority of the Church. They refused to hear substantive justifications of Machen’s position and focused only on the question of obedience. He was found guilty and suspended. Machen formed the Orthodox Presbyterian Church but died of pneumonia in 1937.

Mercer University, Baptist, USA (1939)

In 1939, 13 University students filed charges against 4 professors, focusing on issues of modern biblical criticism and evolution. Resignations (under pressure) due to doctrinal irregularity had already occurred in 1894, 1905, 1906 and 1924. A 10-hour trial was held wherein the faculty were accused of denying the existence of demons, the blood atonement of Christ, conversion from sin, the second coming of Christ, the resurrection of the body, hell, the Genesis account of creation, and the molding of Eve from the rib of Adam; and of saying that the Bible contained contradictions. The trustee investigative committee however refused to condemn them and simply issued a caution; the majority of students also supported the professors.

The Louisville 13, Southern Baptist, USA (1958)

In 1958 13 faculty members were forced to resign from Southern Seminary for unorthodoxy.

Theodore R Clark, Southern Baptist, USA (1960)

Clark taught at New Orleans Baptist Theological Seminary; he was dismissed in 1960 primarily as a result of the publication of his book Saved by His Life (Macmillan, 1959), a meditation on salvation. The trustees did not make clear the nature of their complaint but said that "His recently published book is one of several instances in which the board had been confronted with questions as to limitations in the area of communication with students and hearers as well as content of lecture materials." The process appears to have been obscure; it is not clear that the Board ever met with Clark or that the faculty were aware that an investigation was underway. The Dean, J Hardee Kennedy, had written an approving review of Clark’s book and does not appear to have participated in the dismissal. Clark took an appointment at Pan American College in Edinburg, Texas.

Ralph Elliott, Southern Baptist, USA (1962)

Elliott was dismissed from Midwestern Baptist Theological Seminary over conflict about contemporary biblical criticism. He was tried twice: in 1960 after publishing The Message of Genesis: A theological interpretation, he was examined by the board of trustees who supported him, 14 to 7. At the next Southern Baptist Convention, elections at the convention changed the balance of trustees at Midwestern. The new board met for a second trial; they agreed with Elliott on 9 out of 10 points, but they failed to agree on republication of the book – the trustees didn’t want to take responsibility for banning it, and Elliott refused to ‘volunteer’ not to seek its republication. The board then dismissed him by a vote of 22 to 7. Elliott moved to the American Baptist church and continued his career.

Revd Walter Gill, Methodist minister, England (1962-64)

Rev. Walter Gill was expelled from the Methodist ministry for heresy in 1964. In 1962, Gill was charged with denying the virgin birth, the resurrection and the divinity of Christ. The Methodist Committee of Doctrinal Appeal dropped the first charge and accepted Gill's response to the second charge. They rejected his view of the divinity of Christ and formally reprimanded him. When Gill persisted, they expelled him from the ministry in 1964. He later wrote a book, Truth to Tell, published by Lindsey Press. In 1970, he applied for re-instatement as a local preacher, but his application was rejected by the Ministerial Session of the General Purposes Committee.

John Hick, Presbyterian, USA (1962, 1980s)

Hick has twice been the subject of heresy proceedings.

a. In 1961 or 1962, when he was teaching at Princeton Theological Seminary, he sought, as a Presbyterian minister, to join the local Presbytery of New Brunswick. He was asked whether he took exception to anything in the Westminster Confession of 1647 and answered that several points were open to question; for example, he was agnostic on the historical truth of the Virgin Birth and did not regard it as an essential item of Christian faith. Because of this, some of the local ministers appealed against his reception into the Presbytery. Their appeal was sustained by the Synod. A year later, a counter-appeal was sustained by the Judicial Committee of the General Assembly, and Hick became a member of the Presbytery.

b. In the mid-1980s, when teaching at the Claremont Graduate School in California, Hick sought to join the local Presbytery of San Gabriel. His application was strongly opposed by certain local ministers. After long discussion, the relevant committee told him that his application would be extremely divisive and invited him to withdraw it, which he did.

James Pike, Episopalian, USA (1961, 1965, 1966)

Pike was dean of the Cathedral of St John the Divine in New York, then became Bishop of California. Pike was close to and much influenced by John Robinson and Tillich. He rejected dogmatic interpretations of the Virgin Birth and the Incarnation, questioned the basis of theological concepts such as Original Sin and the Trinity, and challenged the infallibility of scripture. His critics charged him with heresy in 1961, 1965 and 1966. The first time, Pike defended his views as orthodox, and counterattacked that racial segregation was a worse heresy than anything he had written. The second time he was accused of both unorthodox views and of plans to ordain women; he defended himself and was cleared by the House of Bishops, but the Bishops ruled that women could not be ordained.

In 1966 charges were again raised; in an attempt to avoid a trial, a committee was appointed which produced a report declaring Pike’s teaching irresponsible, "cheap vulgarizations of great expressions of faith." The report was accepted, 103 to 36; Pike then demanded a formal trial, claiming that the Bishops had refused to address the theological issues. Again attempting to avoid a trial, the House of Bishops created a Committee on Theological Freedom which included Pike along with prominent theologians such as John AT Robinson; Pike agreed to withdraw demands for a trial if the Committee’s report was accepted, which it was. The church then made formal moves to allow more room for doctrinal diversity and to make heresy charges much harder to bring.

Robert Briggs, William Strickland and Harold Oliver, Southern Baptist, USA (1964)

Briggs, Strickland and Oliver taught at Southeastern Baptist Theological Seminary. In 1960 an investigation was begun into their teaching, alleging "the application of radical Existentialism and so-called Bultmanianism." Over the next three years an extended struggle regarding the academic freedom of the faculty versus adherence to the Abstract of Principles which all faculty members had signed on appointment; no formal charge of heretical teaching was ever made. In 1964 Briggs resigned; shortly thereafter he took a post at Vanderbilt University, and then moved on to the Interdenominational Theological Center in Atlanta. Oliver resigned and went to Boston University; Strickland resigned in 1966 to go to Appalachian State University.

Lloyd Geering, Presbyterian Minister, New Zealand (1967)

Geering was tried for doctrinal error and disturbing the peace of the church by the Presbyterian Church of New Zealand in 1967. The trial was televised in New Zealand, but the Assembly judged that no doctrinal error had been proved, dismissed the charges and declared the case closed. The Church later published a 112-page booklet about the trial. Geering has since become a well-published theologian, and was awarded the New Zealand Order of Merit in 2001; in 1988 he was honoured as a Companion of the British Empire. He is Emeritus Professor of Religious Studies at Victoria University, Wellington, New Zealand, a founding member of SoF NZ and a Fellow of the Westar Institute Jesus Seminar.

Ray Billington, Methodist minister, England (1971)

Billington was charged with teaching false doctrine following the publication of his book The Christian Outsider, specifically because he stated that God did not exist, that Jesus was not the Son of God, and that there was no life after death. The complaint was researched and the Committee of Doctrinal Appeal submitted a report to the 1971 Methodist Conference, which dismissed Mr Billington in June of that year. Billington's most recent book is Religion without God (Routledge, 2001).

John Tietjen, Missouri Synod Lutheran, USA (1973-77)

Tietjen was President of Concordia Seminary. He favoured a more moderate, ecumenical approach to religion, but became entangled in struggles by the Missouri Synod President to control the teaching at Concordia. In 1973 the Convention declared the faculty heretical (e.g. for denying the historicity of Adam and Eve); in 1974 the Board suspended Tietjen as President, whereupon the students and faculty declared a moratorium, then created the Seminex (seminary in exile). The board terminated them. In 1977 Tietjen was formally expelled from the clergy; in fact he had already joined the American Evangelical Lutherans.

Walter Kenyon, Presbyterian ordinand, USA (1974)

Kenyon was barred from ordination by the United Presbyterian Church in 1974 because of his stance against the ordination of women. Kenyon believed that an inerrant view of the Bible required subordination of women. At his final interview with the Committee on Candidates and Credentials, he was asked if he would ordain women; Kenyon made clear that he would not block women and would work with women elders and ministers, but would not participate in their ordination service. The Committee did not recommend him for ordination. The Presbytery, however, authorized his ordination by a vote of 144 to 133. A case was then filed stating that the Presbytery had violated Presbyterian constitutional law. The Synod’s Permanent Judicial Commission upheld the complaint, stating that Kenyon was ‘in irreconcilable conflict with Presbyterian polity, government and discipline." The Presbytery appealed to the General Assembly Permanent Judicial Commission, which agreed with the Synod PJC, stating that a candidate for ordination must endorse Presbyterian polity, i.e. as a matter of government. The case is unusual in that it focused on Kenyon’s actions (he was free to think as he liked, but not free to refuse to ordain women) and in its focus on the actions of the Presbytery rather than of Kenyon himself.

Dale Moody, Southern Baptist, USA (1984)

Moody taught at Southern Baptist Seminary. He aroused controversy as to whether he supported the Baptist principle of ‘perseverance of the saints’ (drawn from Hebrews 6:4-6). He was accused in 1961 of teaching that it was possible for a person ‘once saved to be lost’ but was acquitted. In 1979, Moody proposed revision of the Abstract of Principles on this point; the University then said it did not wish to inhibit faculty freedom but would not extend his teaching contract past normal retirement age unless his teaching on this point was more traditional. Moody argued that his reading of the principle was in line with the original Biblical texts and the argument continued for roughly 3 years. In 1983, Moody gave a talk on the topic "Can a saved person ever be lost?"; whereupon the Arkansas Baptist State Convention asked the university to terminate him. The University employed him until 1984 but refused to give him a further contract.

Southeastern Baptist Theological Seminary, USA, (1985-94)

The SBTS was initially investigated for allowing teaching contrary to Biblical inerrancy. In 1987 the Trustees announced a hiring policy that would include only orthodox inerrantists; whereupon the President resigned. Since then, the school has declined; the Southern Association of Colleges and Schools has declared it deficient, AAUP has censured it, multiple resignations were submitted in 1991 and the school has been placed on probation (i.e. just short of loss of accreditation). Between 1985 and 1994, 27 of the 34 faculty and 13 of the 16 administrators resigned.

Dr Peter S Cameron, Presbyterian minister, Australia (1992)

On the 2nd March 1992, the Rev. Dr Peter Cameron, Principal of St Andrew’s College at the University of Sidney, preached a sermon at a Dorcas Society Rally in the Ashfield Presbyterian Church entitled "The Place of Women in the Church". As well as supporting the principle that women should be ordained to the ministry, it argued that the Bible had to be understood within the context of the times in which they were written. Cameron was tried and convicted for heresy. He appealed, but resigned before the appeal could be heard. He has subsequently published three books: Heretic (Doubleday 1994), Necessary Heresies (New South Wales University Press, 1993) and Fundamentalism and Freedom (Doubleday, 1995).

Paul Simmons, Southern Baptist, USA (1992)

Simmons was Professor of Christian ethics at Southern Baptist Seminary. He was attacked not for theological beliefs but for ethical positions, particularly in the areas of abortion, elective death and homosexuality. In 1987 the Trustees reviewed Simmons’ positions and asked that he ‘moderate his public involvement’ in the debate on abortion. In 1989 he was accused of saying that Jesus was sexually active but this was proved false. Pressure to remove Simmons for his position on abortion continued and in 1992 the President attempted to offer him a financial package to leave, which Simmons refused. Following a further controversy about a film used by Simmons in a lecture, the Trustees proposed sanctions which Simmons was unwilling to accept, and he resigned.

Molly Marshall, Southern Baptist, USA (1994)

Marshall resigned from Southern Baptist Theological Seminary in 1994. A heresy trial was in the offing at the time of her resignation; the Seminary statement at the time of her resignation says that her views were ‘significantly outside the parameters of the Abstract of Principles’ although it did not offer any specifics. Marshall then went to Central Baptist Theological Seminary (American Baptist, not Southern).

Anthony Freeman, Anglican priest, England (1994)

Freeman, a member of Sea of Faith, was sacked by the Bishop of Chichester following the publication of his book God in Us: the case for Christian Humanism. He is currently the editor of the Journal for Consciousness Studies.

Walter Righter, Episcopalian, USA (1996)

In the fall of 1990, Barry Stopfel was ordained a deacon in the Diocese of Newark. Stopfel is gay and, at the time of his ordination, was living "in a sexual partnership" with another man. The assistant bishop of Newark, the Rt. Revd Walter Righter, then faced a church court over his decision to ordain the gay man. On May 15, 1996, an Episcopal Church court dismissed charges against Righter. The Court held that neither the doctrine nor the discipline of the Church currently prohibit the ordination of a non-celibate homosexual person living in a committed relationship.

C. Joseph Sprague, Methodist, USA (1998-2003)

Bishop Joseph Sprague, who directs the United Methodists' Northern Illinois Conference, has been the target of ongoing complaints since 1998, and was accused of heresy in June 2000 and again in early 2003. The charges were dismissed by Bishop Bruce R. Ough, President of the North Central Jurisdiction College of Bishops. The supervisory committee which reviewed the charges against Sprague has proposed a public dialogue, facilitated by a third party, in order to explore the implications of Sprague's statements.

Don Stroud, Presbyterian, USA (2001)

Rev Don Stroud, a minister in the Presbyterian Church in Baltimore, Maryland, was accused of heresy in September 2001 because he is openly gay.

David Moyer, Episcopal, USA (2002)

The Rev David Moyer, President of Forward in Faith of North America, has been deposed by his bishop for refusing episcopal visits and for generally violating canonical discipline. Although canonical discipline is cited as the immediate cause for this affair, the underlying cause is doctrinal; Moyer objects to the ordination of women and to his bishop's liberal position on this and other issues.

Andrew Furlong, Dean of Clonmacnoise, Ireland (2002)

In 2001 Furlong published on his church website a number of articles challenging traditional doctrine, including statements that Jesus was not the Son of God. His bishop directed him to take three months to reflect on his beliefs; having not changed his beliefs in that period, Furlong was invited to resign, which he declined to do. He was then due to appear before an ecclesiastical court on charges of heresy, but resigned on the day before his trial. Furlong has recently published an account of this episode in Tried for Heresy: A 21st Century Journey of Faith (John Hunt, 2003).

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