Official Response to the Presentment

Official Response to the Presentment

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THE PROTESTANT EPISCOPAL CHURCH
IN THE UNITED STATES OF AMERICA

             IN THE COURT FOR THE TRIAL OF A BISHOP

________________________________________________
                                        }
JAMES M. STANTON, BISHOP OF DALLAS,     }
et al.,                                 }
                PRESENTERS,             }
                                        }
v.                                      }
                                        }
THE RT. REV. WALTER C. RIGHTER,         }
                                        }
                RESPONDENT.             } 
________________________________________________} 

     
_______________________________________________________________________

     BRIEF OF RESPONDENT IN SUPPORT OF ANSWER TO PRESENTMENT
_______________________________________________________________________


                                        Respectfully submitted,

                                        MICHAEL F. REHILL
Of Counsel and                          Chancellor, Diocese of Newark
On the Brief:
                                        Counsel for Respondent
WILLIAM C. BULLITT                      The Rt. Rev. Walter C. Righter
Chancellor, Diocese of Pennsylvania     Retired Bishop of Iowa
                                        
JOHN K. CANNON
Chancellor, Diocese of Michigan

PAUL E. COONEY                          
Chancellor, Diocese of Washington

RICHARD J. HOSKINS
Chancellor, Diocese of Chicago

Dated: May 10, 1995                                    
                        TABLE OF CONTENTS
                                                              PAGE

INTRODUCTORY STATEMENT  ........................................ 1

SUMMARY OF THE ARGUMENT  ........................................2

PRIOR PROCEEDINGS  ..............................................3

THE PRESENTMENT  ................................................3

THE ANSWER TO THE PRESENTMENT  ..................................8

ARGUMENT

I.   WHETHER IT IS "IMPERMISSIBLE" TO ORDAIN A 
     NON-CELIBATE HOMOSEXUAL PERSON IS NOT A 
     QUESTION OF DOCTRINE .......................................9

     A.   DOCTRINE CONCERNS FUNDAMENTAL MATTERS OF 
          THE SUBSTANCE OF THE CATHOLIC FAITH .................. 9
     
          1.   THE DOCTRINE OF THE EPISCOPAL CHURCH IS
               FOUND IN HOLY SCRIPTURE, THE APOSTLES'
               AND NICENE CREEDS, AND THE BOOK OF
               COMMON PRAYER ...................................10

          2.   THE DOCTRINE OF THE EPISCOPAL CHURCH IS 
               NOT THE SAME THING AS ITS MORAL AND
               SOCIAL TEACHING .................................13

          3.   THE DOCTRINE OF THE EPISCOPAL CHURCH IS NOT
               ESTABLISHED BY RESOLUTIONS OF GENERAL
               CONVENTION OR THE HOUSE OF BISHOPS ..........14
     
     B.   QUALIFICATIONS FOR ORDINATION ARE PART OF 
          THE DISCIPLINE OF THE CHURCH ..............................16

II.  TO ACCEPT THE ARGUMENT OF THE PRESENTMENT WOULD
     BE TO HOLD THAT ALL THOSE BISHOPS WHO SIGNED THE
     STATEMENT OF CONSCIENCE IN RESPONSE TO THE 1979
     GENERAL CONVENTION RESOLUTION, ALL THOSE BISHOPS
     WHO VOTED AGAINST THE 1990 RESOLUTION OF THE
     HOUSE OF BISHOPS, AND ALL THOSE BISHOPS WHO SIGNED
     THE 1994 "STATEMENT OF KOINONIA" WOULD BE SUBJECT
     TO PRESENTMENT FOR VIOLATIONS OF CANON IV.1.1(2)........18

III. THE ORDINATION OF THE REV. BARRY STOPFEL TO THE
     DIACONATE IN COMPLIANCE WITH THE CANONS AND IN
     ACCORDANCE WITH THE WORSHIP OF THE EPISCOPAL
     CHURCH WAS NOT A VIOLATION OF BISHOP RIGHTER'S
     ORDINATION VOWS. .......................................19


CONCLUSION ..................................................22


                           APPENDICES


A.   Resolution A053sa, General Convention 1979 

B.   Statement of Conscience In Response to Resolution A053sa

C.   Statement of Presiding Bishop and His Council of Advice, 
     February 20, 1990

D.   Resolution B-1a, House of Bishops, September 18, 1990

E.   Statement of Koinonia, General Convention 1994

F.   Bishop Righter's Ordination Vows, January 12, 1972

G.   Statement of the Presiding Bishop, 1995



INTRODUCTORY STATEMENT

     The Rt. Rev. Walter C. Righter, retired Bishop of Iowa, stands 
accused in a Presentment signed by the Bishops of Dallas, Florida, 
San Joaquin, Central Florida, Texas (since retired), Eau Clare, Fort 
Worth, Quincy, Rio Grande and West Tennessee under Canon 
IV.1.1(2) of "holding and teaching publicly or privately, and advisedly, 
doctrine contrary to that held by this Church" and under Canon 
IV.1.1(6) of "violation of ordination vows".  Bishop Righter has 
submitted an Answer to the Presentment, and this Brief is submitted 
on behalf of Bishop Righter pursuant to the provisions of Section 2 of 
Canon IV.4(b).

     Under the provisions of Section 2 of Canon IV.4(b),

     "The written consent of one-fourth of the Bishops 
     qualified to vote in the House of Bishops shall be 
     required before the proceeding may continue [to trial] 
     as provided by Canon.  In case one-fourth of all the 
     Bishops entitled to act in the premises shall not consent 
     within the period of three months from the date of 
     notification to them by the Presiding Bishop of the 
     proceeding, the Presiding Bishop shall declare the 
     presentment dismissed."  Bracketed text added.

     The Presentment is a gravely serious matter in the life of The 
Episcopal Church.  As each Bishop prayerfully considers whether to 
consent to proceeding with a trial on the Presentment, consideration 
should first be given to the statement contained in the letter 
transmitting the Presentment to the Presiding Bishop, 


     "We have chosen to make this Presentment against 
     Bishop Righter because his action is the least recent 
     ordination within the current five year statute of 
     limitation.  Should this matter be set for trial, it is our 
     intention to file Presentments against the next most 
     recent offender, and so on, until we are current in 
     bringing to trial all those who have knowingly violated 
     the teaching of the Church." 

and to the statement given by the Presiding Bishop at the Special 
Meeting of the House of Bishops at Kanuga on March 3, 1995, 


     "My sisters and brothers, this presentment is not the 
     way ... This presentment can only disrupt us and divert 
     us from the path that we are on. ... I pray we will never 
     be required to pay what this could cost us as a church, 
     not only for now but into the time of the next Presiding 
     Bishop.  I pray we will never be required to experience 
     one presentment, and then another, and another. ... This 
     is not a debating society or a court of law.  This is a 
     community of God's people.  We have another way.  To 
     that way, I commend you. ... I pray that this house will 
     realize that this is not the way."

     This Brief is respectfully and faithfully submitted to urge that the 
members of the House of Bishops not consent to proceeding to trial 
on this Presentment.

                     SUMMARY OF THE ARGUMENT
     
     The Presentment is based on a misunderstanding of the Doctrine 
of The Episcopal Church and the sources of such Doctrine.  
Notwithstanding that the only recognized sources of the Doctrine of 
The Episcopal Church are Holy Scripture, the Apostles' Creed, The 
Nicene Creed and the Book of Common Prayer (the latter alone 
being recognized in the Canons of this Church as the repository of the 
only "authorized formularies of this Church"), the Presentment 
contends that the Doctrine of this Church is found in resolutions and 
"teachings" of the House of Bishops.  Based upon that false premise, 
the Presentment claims that it is the Doctrine of The Episcopal 
Church that non-celibate homosexual persons may not be ordained.

     The Presentment charges Bishop Righter with two acts which it 
alleges constitute heresy ("holding and teaching doctrine contrary to 
that held by this Church") in violation of Canon IV.1.1(2).  
Specifically, the Presentment charges (a) that on September 18, 1990, 
Bishop Righter dissented and voted against a resolution of the House 
of Bishops [along with 75 other Bishops] regarding a 1989 ordination 
by the Bishop of Newark; and (b) that on August 25, 1994, at the 
General Convention in Indianapolis, Bishop Righter [along with 70 
other Bishops] signed "A Statement of Koinonia."

     The Presentment then states that on September 30, 1990 Bishop 
Righter, while Assistant Bishop of Newark, ordained to the diaconate 
the Rev. Barry L. Stopfel, a homosexual man living in a committed 
relationship of long standing with another, and alleges that such 
ordination was "in violation of the Bishop's ordination vow to conform 
to the doctrine of the Church".
 
     There is no DOCTRINE of The Episcopal Church on the issue of 
whether it is permissible or impermissible to ordain non-celibate 
homosexual persons.

     To apply the words of the Court in the only heresy trial of any 
Bishop in The Episcopal Church to the issues raised in the 
Presentment, there is no article of faith stating that it is impermissible 
to ordain a non-celibate homosexual person which must be accepted 
by all members of the Church.   As the House of Bishops 
acknowledged in the Statement issued in September 1990 on the issue 
of "ordination to Holy Orders of sexually active homosexual men and 
women" ... "we are not of a single mind..."  Journal, 1991, p.517.  By 
definition, an issue on which there are such widely divergent views 
cannot constitute the Doctrine of the Church.


                        PRIOR PROCEEDINGS

     At the meeting of the House of Bishops at the General Convention 
in Phoenix in 1991, a motion was made to "censure" Bishop Righter 
for the Stopfel ordination (and to censure the Rt. Rev. Ronald H. 
Haines, Bishop of Washington, D.C. for the ordination of a non-
celibate homosexual woman to the priesthood).  Journal, 1991, 
pp.321-323.

     The House of Bishops, after lengthy, often emotional debate, chose 
not to act on that motion, but to adopt a substitute resolution calling 
for further study of the ordination issue and to refer the matter to the 
Presiding Bishop and his Council of Advice for consideration by the 
House of Bishops at an interim meeting of the House.  


THE PRESENTMENT

     The Presenters claim that "`doctrine' is the teaching of the Church 
as determined by the formularies of the Church, including 
declarations by the House of Bishops."  Based upon that 
mischaracterization of the "formularies of the Episcopal Church" and 
its sources, the Presenters reach the false conclusion that "The 
Teaching or doctrine of The Episcopal Church ... is that ...  it is not 
permissible to ordain a practicing homosexual."  Brief, p.7.

                         Count I: Heresy

     In "Count I", Bishop Righter is charged with heresy ("holding and 
teaching ... doctrine contrary to that held by this Church") in violation 
of Canon IV.1.1(2).   Specifically, the Presentment alleges are (a) that 
while Assistant Bishop of Newark in 1990, Bishop Righter voted 
against a Resolution of the House of Bishops regarding an ordination 
by the Bishop of Newark; and (b) that Bishop Righter signed "A 
Statement of Koinonia" at General Convention in 1994.

The September 1990 Resolution

     The first act of heresy allegedly occurred on September 18, 1990, 
when Bishop Righter, while present in the House of Bishops in 
Washington, D.C., "dissented from Resolution [No.  B-1a] and voted 
against affirming the February [20, 1990] Statement" [of the Presiding 
Bishop and his Council of Advice].  Presentment, p.5.  Bracketed text 
added.

     The proceedings of the House of Bishops on September 18, 1990 
are found in the Journal of the General Convention 1991 at pages 
498-503.  The Journal indicates that on a roll call vote, only 80 of the 
158 Bishops present voted in favor of adopting the resolution.  A total 
of 76 Bishops, including Bishop Righter, to use the language of the 
Presentment, "dissented from the Resolution and voted against 
affirming the February Statement".  Two Bishops, including the 
Bishop of Newark, who was the subject of the resolution, abstained.  
Among those Bishops who, like Bishop Righter, "dissented from the 
Resolution and voted against affirming the February Statement" were 
The Presiding Bishop and five of the nine members of the Council of 
Advice who had originally signed the February Statement.  See 
Appendix D for a list of those Bishops who joined with Bishop Righter 
in opposing Resolution B-1a.
  
     The Presentment quotes a portion of Resolution A053sa adopted 
by the General Convention in Denver in 1979 (hereinafter "the 1979 
Resolution"), and then quotes a portion of the February 1990 
Statement, quoting an even smaller portion of the 1979 Resolution. 
Presentment, pp.3-5.  See Appendix A for the complete text of both 
the 1979 Resolution and Appendix C for the complete text of the 
Statement of February 1990.  

     The 1979 Resolution did not purport to set forth the "Doctrine" of 
the Church, nor did it state that a non-celibate homosexual person 
cannot be properly ordained or that such an ordination is not 
permitted.  That resolution was merely advisory as to the 
appropriateness of ordination of a non-celibate homosexual or 
heterosexual person engaged in sexual relations outside of marriage 
based upon a reaffirmation of "the traditional teaching of the Church 
on marriage, marital fidelity and sexual chastity as the standard of 
Christian morality." 

     In the 1979 Resolution, General Convention "recommend[ed] to 
Bishops, Pastors, Vestries, Commissions on Ministry, and Standing 
Committees", each of whom has responsibility under the Canons to 
select and approve persons for ordination, a number of 
"considerations" as those persons, "continue to exercise their proper 
canonical functions."  Among those "considerations" which General 
Convention "recommended" was the statement that because 
"candidates for ordination are expected to conform" to "the traditional 
teaching of the Church on marriage, marital fidelity and sexual 
chastity", "we believe that it is not appropriate for this Church to 
ordain a practicing homosexual, or any person who is engaged in 
heterosexual relations outside of marriage."  Journal, 1979, pp.B-96-
97.  Bishop Righter voted in favor of the adoption of Resolution 
A053sa.  Journal, 1979, p.B-95.

     However, in response to the adoption of the 1979 Resolution, 
twenty Bishops issued a Statement which recognized that the 
Resolution was neither prescriptive nor binding, but only made 
recommendations as to various considerations in the ordination 
process.  The Statement of Conscience, quoting from the ordination 
vows of a Bishop in The Book of Common Prayer, provided in part as 
follows:


          "Taking note, therefore, that this action of the House 
     is recommendatory and not prescriptive, we give notice 
     as we are answerable before Almighty God that we 
     cannot accept these recommendations or implement 
     them in our Dioceses insofar as they relate or give 
     unqualified expression to Recommendation 3.  To do so 
     would be to abrogate our responsibilities of apostolic 
     leadership and prophetic witness to the flock of Christ, 
     committed to our charge; and it would involve a 
     repudiation of our ordination vows as Bishops, in the 
     words of the new Prayer Book, boldly [to] proclaim and 
     interpret the Gospel of Christ, enlightening the minds 
     and stirring up the conscience of [our] people, and to 
     encourage and support all baptized people in their gifts 
     and ministries . . . and to celebrate with them the 
     sacraments of our redemption; or in the words of the 
     old, to be to the flock of Christ a shepherd, not a wolf.  
     Our appeal is to conscience, and to God. Amen."  
     Emphasis and brackets in original.

The full text of the 1979 Statement is set forth in Appendix B.  Among 
the twenty Bishops who issued that Statement was the then Bishop of 
Hawaii and now Presiding Bishop.  An additional twenty-three 
Bishops signed the Statement in 1988.  Journal, 1988, pp.198-199.

     The only portion of the 1979 Resolution quoted in the Statement 
of the Presiding Bishop and his Council of Advice of February 20, 
1990 was three paragraphs setting forth the "considerations" which 
were "recommend[ed]" to Bishops, Pastors, Vestries, Commissions on 
Ministry, and Standing Committees", as those persons, "continue to 
exercise their proper canonical functions."

     The February 1990 Statement did not set forth the "Doctrine" of 
the Church.  It did not state that a non-celibate homosexual person 
cannot be properly ordained.  It did not state that such an ordination 
is not permitted or that the December 1989 ordination violated the 
Doctrine of the Church.  On the contrary, the February 1990 
Statement was a statement of "disassociation" from the action of the 
Standing Committee and Bishop of Newark in carrying out an 
ordination in December 1989 which, it stated, threatened the "unity" 
and "good order" of the Church, and concluded by calling its readers 
"to join with us in recommitting ourselves to the unity of the church ..."  

     It is also noteworthy that following the adoption of Resolution B-
1a by the House of Bishops in 1990 "affirming and supporting" the 
February 1990 Statement, the House of Bishops adopted a Resolution 
(the introduction of which was approved by a vote of 102-23), which 
referred the Statement to the Commission on Canons "inasmuch as 
the statement raises questions about the authority of General 
Convention resolutions", and to the Commission on Human Affairs 
"inasmuch as the appropriateness of ordaining to the priesthood 
openly gay persons continues to be a vexing issue within the church."  
Journal, 1991, p.503.

     Moreover, the very next day, the House of Bishops adopted a 
Statement which provided in part as follows:


          "We begin by acknowledging that on the issues of 
     human sexuality wide diversity and confusion marks our 
     Church and most Christian communions, to say nothing 
     of society at large.  Two issues in particular rise to the 
     surface - the affirmation of those living in faithful same-
     sex relationships and the ordination to Holy Orders of 
     avowed and sexually active homosexual men and 
     women.

          "We are not of a single mind in our understanding of 
     the demands of Holy Scripture, of faithful obedience to 
     tradition, or informed awareness of the actual lives and 
     choices faced by homosexual men and women. . . ."  
     Journal, 1991, p.517.
 
     Although the Presenters argue that one should look to 
"declarations of the House of Bishops" as determining the Doctrine of 
The Episcopal Church, they cite no resolution or other "declaration" 
of the House of Bishops which states that it is the Doctrine of the 
Church that a non-celibate homosexual person cannot be properly 
ordained or that such an ordination is not permitted.  In any event, to 
hold that voting in the minority in the House of Bishops constitutes a 
heretical dissent from the "declarations of the House of Bishops" 
would be to create a very dangerous precedent indeed.


                     The Koinonia Statement

     The Presentment states that the second act of heresy occurred 
when, while present in the House of Bishops at General Convention 
in Indianapolis, on August 25, 1994, Bishop Righter "joined in the 
signing of `A Statement of Koinonia', made by the Rt. Rev. John S. 
Spong, in which Respondent acceded to the following statement:


     "We pledge ourselves to ordain only those persons 
     whom the testing and screening process reveals to be 
     wholesome examples to the flock of Christ.  But let 
     there be no misunderstanding, our lives and our 
     experience as bishops have convinced us that a 
     wholesome example to the flock of Christ does not 
     exclude a person of homosexual orientation nor does it 
     exclude those homosexual persons who choose to live 
     out their sexual orientation in a partnership that is 
     marked by faithfulness and life-giving holiness."  
     Presentment, pp.5-6.

     The "Statement of Koinonia", signed by Bishop Righter at the 
General Convention in Indianapolis in 1994, was also signed by 70 
other Bishops.  If the Presenters' position were to be sustained, all 
those Bishops would themselves be subject to presentment and trial 
seriatim for "heresy".  See Appendix E for a complete text of the 
Statement and a list of the signatories.

                  Count II: The 1990 Ordination

     In "Count II", Bishop Righter is charged with violation of his 
"ordination vows" under Canon IV.1.1(6) for ordaining to the 
diaconate a homosexual man living in a committed relationship with 
another.  The Presenters allege that ordination was "in violation of the 
teaching of the Church," and constituted "an act in violation of his 
ordination vows to `conform to the Doctrine ... of the ... Church.'"  
Presentment, p.7.  The Presenters contend that the declaration of 
belief and conformity is the "ordination vow" referred to in Canon 
IV.1.1(6).

     A distinction must be made between the declaration of belief and 
conformity required of every person ordained in this Church, whether 
Deacon, Priest or Bishop and the vows or promises made by each 
ordinand at his or her ordination.  Similarly, a distinction must be 
made between a violation of Canon IV.1.1(2) (holding and teaching 
Doctrine contrary to that held by The Episcopal Church) and Canon 
IV.1.1(6) (violation of "ordination vows").  The declaration of belief 
and conformity is made in the ordination rite at "The Presentation."   
The "ordination vows" referred to in Canon IV.1.1(6) are the vows 
taken by the ordinand during the ordination at "The Examination" and 
which are referred to therein as "promises."  Book of Common Prayer, 
p.517f. 

     The erroneous argument advanced by the Presenters is that should 
a Bishop knowingly ordain a non-celibate homosexual man or woman, 
that act would be in violation of the Bishop's ordination vow "to 
conform to the doctrine of the Church".  Brief, p.7.  Failure to 
conform to the "Doctrine" of The Episcopal Church is presentable 
only under Canon IV.1.1(2) ("Holding and teaching publicly or 
privately, and advisedly, any doctrine contrary to that held by this 
Church."), and there is no Doctrine of The Episcopal Church on the 
issue of whether it is permissible or impermissible to ordain non-
celibate homosexual men or women.

                  THE ANSWER TO THE PRESENTMENT

     Bishop Righter denies holding and teaching publicly or privately, 
and advisedly, any Doctrine contrary to that held by this Church.  
Bishop Righter affirms, without reservation or exception, the Doctrine 
of The Episcopal Church.
  
     Bishop Righter was in attendance at the General Convention in 
Denver in 1979 when Resolution A053sa was adopted.  Bishop 
Righter voted in favor of the adoption of that resolution.

     Bishop Righter, along with 75 other Bishops, including the 
Presiding Bishop, dissented from House of Bishops Resolution B-1a, 
and voted against affirming the February 20, 1990 Statement of the 
Presiding Bishop and his Council of Advice.

     While present in the House of Bishops at General Convention in 
Indianapolis, on August 25, 1994, Bishop Righter, together with 70 
other Bishops, joined in the signing of "A Statement of Koinonia."

     Bishop Righter does not deny the allegation in the Presentment 
that on September 30, 1990, while serving as Assistant Bishop in the 
Diocese of Newark, he ordained the Rev. Barry L. Stopfel to the 
diaconate, and that, at the time of such ordination, Bishop Righter 
was aware that Barry Stopfel was a homosexual man living in a non-
celibate committed relationship of long standing with another.  Bishop 
Righter denies that such ordination violated his ordination vows.

     At the time of his ordination to the diaconate by Bishop Righter, 
the Rev. Barry Stopfel had the support of a congregation with which 
he had worked and who came to trust in his ministry, and had satisfied 
all of the canonical requirements for such ordination, including

(a) certification from the Rector and Vestry of the Parish of which 
Barry Stopfel was a member certifying,

     "After due inquiry, we are well assured and believe that 
     Barry L. Stopfel, for the last three years, has led a sober, 
     honest and godly life, and is loyal to the Doctrine, 
     Discipline and Worship of this Church, and does not 
     hold anything contrary thereto.  And moreover, we 
     think Barry L. Stopfel a person worthy to be admitted to 
     the Sacred Order of Deacons."

(b) the resolution of the Standing Committee of the Diocese of 
Newark recommending that Barry Stopfel be ordained to the 
Diaconate, testifying that,

     "Barry Lee Stopfel has lived a sober, honest and godly 
     life, and is loyal to the Doctrine, Discipline and 
     Worship of this Church, and does not hold anything 
     contrary thereto," and

(c) the approval of the Bishop of Newark to such ordination.

     Moreover, the aforesaid testimonial of the Standing Committee, in 
addition to the canonically required testimonial, included the 
following language,

     "We find him fully qualified and do recommend him to 
     the Bishop for Ordination to the DIACONATE in June, 
     1990, unless the Presiding Bishop states to us in writing, 
     upon legal advice of his Chancellor, that such 
     Ordination would violate the Canons of The Episcopal 
     Church."

     The Bishop of Newark delayed the diaconal ordination until after 
the September 1990 meeting of the House of Bishops at the request of 
the Presiding Bishop, as a commitment to collegiality; and, to avoid 
unnecessary complications, he chose not to perform the ordination 
himself.  As a result, Bishop Righter, then the Assistant Bishop of 
Newark, was called upon and agreed to perform the ordination.

                            ARGUMENT

I.   WHETHER IT IS "IMPERMISSIBLE" TO ORDAIN A NON-CELIBATE
     HOMOSEXUAL PERSON IS NOT A QUESTION OF DOCTRINE.

     A.   DOCTRINE CONCERNS FUNDAMENTAL MATTERS OF THE
          SUBSTANCE OF THE CATHOLIC FAITH.

     Article VIII of the Constitution contains the declaration of belief 
and conformity required of all ordinands, Bishop, Priest or Deacon, 
"to engage to conform to the Doctrine, Discipline and Worship of this 
Church," and each may be presented for holding and teaching 
"Doctrine" contrary to that of this Church under Canon IV.1.1(2).  
The "Doctrine" to which the declaration of belief and conformity calls 
all ordained persons, concerns fundamental matters of the substance 
of the Catholic Faith.

     In the first official defense of what became Anglicanism, Bishop 
John Jewel, in An Apologie of the Church of England, 1564, writing 
on behalf of the Bishops of the English Church, defended the Church 
of England against its Roman detractors by stating that it was not a 
new church, but a church which had restored the faith and practice of 
the early church as expressed in the Creeds and the first four 
ecumenical councils.  Thus, Anglican doctrine was defined by Bishop 
Jewel as nothing more and nothing less than the historic faith of the 
Catholic Church:


     "We have searched out the Holy Bible, which we are 
     sure cannot deceive, one sure form of religion, and have 
     returned again unto the primitive church of the ancient 
     fathers and apostles, that is to say, to the first ground 
     and beginning of things, as unto the very foundations 
     and headsprings of Christ's church.  Apologie, 
     "Recapitulation" Folger Edition, p.135.

     When The Episcopal Church was independently organized in 1789, 
it declared itself "far from intending to depart from the Church of 
England in any essential point of doctrine, discipline or worship; or 
further than local circumstances require."  Preface to the Book of 
Common Prayer, 1979, which first appeared in the 1789 Book of 
Common Prayer.  The opening paragraph of that Preface refers to 
"Doctrine" as "the substance of the Faith."
     
     1.   THE DOCTRINE OF THE EPISCOPAL CHURCH IS FOUND IN HOLY
          SCRIPTURE, THE APOSTLES' AND NICENE CREEDS, AND THE BOOK
          OF COMMON PRAYER

     The Episcopal Church, unlike some other churches, has produced 
no confession of faith setting forth a body of distinctive doctrinal 
teaching.  Rather, its doctrinal development has been carried out with 
reference to its authoritative sources.  The "Doctrine" of The 
Episcopal Church is to be found in Holy Scripture, the Apostles' 
Creed, the Nicene Creed and the Book of Common Prayer, the latter 
alone being recognized in the Canons of this Church as the repository 
of the only "authorized formularies of this Church". Canon II.3.4.  See 
Canon Law: A Handbook, Daniel B. Stevick, 1965, p.113f.  There are 
no other officially recognized sources of the doctrine of The Episcopal 
Church.

     This identification of the Scriptures and the two most ancient 
creeds as occupying a unique place of authority for doctrine is 
distinctive of Anglicanism, as witnessed by the Chicago- Lambeth 
Quadrilateral.  When, in the 19th Century the separated Christian 
churches began to work towards unity, The Episcopal Church, and 
then the entire Anglican Communion, proposed this "Quadrilateral" 
as a basis for ecumenical discussion and negotiation.  This 
formulation had its origins in a book, The Church-Idea, written in 
1870 by William Reed Huntington, then put forward by the House of 
Bishops in Chicago in 1886 and finally endorsed, in slightly altered 
form, by the Lambeth Conference of Bishops in 1888.  It sets forth 
four essentials: Holy Scripture, the Apostles' and Nicene Creeds, the 
dominical sacraments of Baptism and the Lord's Supper, and the 
historic episcopate.  Book of Common Prayer, pp.876-878.  In this 
proposal for Christian unity, the Anglican Churches were saying that 
the only doctrinal authorities to which they seek to hold others were 
the Scriptures and the two Catholic Creeds. 

     The Chicago-Lambeth Quadrilateral has been described in a book 
written by one of the Presenters as containing "the basis of our faith."  
Foundations of the Faith, The Rt. Rev.  William C. Wantland, 1993, 
p.6.

     This identification of the sources of doctrine in The Episcopal 
Church was made clear in the 1924 heresy trial of Bishop William 
Montgomery Brown.  The Presentment of Bishop Brown made 
explicit reference (in Section 23) to the "Doctrine" that is "held by the 
Protestant Episcopal Church, as contained in the Book of Common 
Prayer and especially in the Apostles' and Nicene Creeds." 

     The Court for the Review of the Trial of A Bishop, considering the 
appeal of Bishop Brown's conviction, defined the "doctrine of the 
Church" as the "articles of faith" which "must be accepted by all 
members of the Church."

     At its meeting in Montana in September 1965, the House of 
Bishops adopted a resolution on the recommendation of its 
Theological Committee in response to a request from several Bishops 
that the then Bishop of California, James A. Pike, be presented for 
holding and teaching Doctrine contrary to that of the Church.  That 
resolution restated the long-recognized sources of the Doctrine of this 
Church, providing in pertinent part,


     "Because of the misunderstandings which so easily 
     occur, we say to those outside and inside the Church 
     that THE CHURCH'S FAITH IS EXPRESSED IN ITS 
     TITLE DEEDS - THE SCRIPTURES, AND THE 
     CREEDS WHICH GUARD THEM - AND IN THE 
     PRAYERS AND SACRAMENTAL ACTS IN THE 
     BOOK OF COMMON PRAYER, WHICH 
     EXPRESSES CHRIST'S MINISTRY WITHIN THE 
     CHURCH." Emphasis added.  Minutes of House of 
     Bishops, 1965, pp.23-24.  Reprinted in The Bishop Pike 
     Affair, Scandals of Conscience and Heresy, Relevance 
     and Solemnity in the Contemporary Church, William 
     Stringfellow and Anthony Towne, Appendix, pp.199- 
     200.

     The Presenters ignore 450 years of Anglican tradition and 
understanding of the Doctrine of this Church and its four universally 
recognized sources.  Instead, the Presenters misrely upon outdated 
texts, an encyclopedia by a theologian of little scholarly distinction, 
and even a secular dictionary in an attempt to redefine the sources of 
the Doctrine of The Episcopal Church to include resolutions of 
General Convention and "teachings" of the House of Bishops, which 
they have erroneously chosen to describe as "formularies of this 
Church."  The Presenters even describe a 1977 resolution of the 
House of Bishops as "doctrinal principles." Brief, p.4.
   
     The only Episcopal authority cited by the Presenters is their 
acknowledgement that "White & Dykman's Annotated Constitution 
and Canons, ... cites the Book of Common Prayer, the Apostles' Creed 
and the Nicene Creed as three places where the doctrine of the 
Church may be found." Brief, p.2.  Presenters fail to note that neither 
White & Dykman, nor any other accepted authoritative source, has 
ever suggested that resolutions of General Convention, much less 
resolutions of the House of Bishops, acting alone, establish the 
"Doctrine" of The Episcopal Church. 

     None of the accepted doctrinal sources and nothing in the 
authoritative discussions that have arisen from them has anything to 
say about the issue in this Presentment, viz. whether it is permissible 
to ordain a non-celibate homosexual person.  It is difficult to see how 
one can violate doctrinal standards on a matter on which they are 
entirely silent.

     2.   THE DOCTRINE OF THE EPISCOPAL CHURCH IS NOT THE SAME
          THING AS ITS MORAL AND SOCIAL TEACHING.

     In addition to Doctrine, there is also a body of moral and social 
teaching which explicates and applies the Christian fundamental 
message to the particular circumstances of human life in society.  
However, as important as this moral and social teaching is, it is not 
that fundamental Doctrine which is the subject of the declaration of 
belief and conformity taken at Ordination or the basis for the 
canonical charge in Canon IV.1.1(2).

     The moral and social teaching of the Church, unlike its 
fundamental Doctrine, is open to modification (e.g., remarriage after 
divorce; relations with South Africa); development (e.g., the role of 
women in the Church) and even repudiation (e.g., slavery), in light of 
changing perceptions and understandings of the human condition.  It 
is continuously under review and the subject of regular legislation by 
General Convention, but it is not the Doctrine of The Episcopal 
Church.    

     The modification, development and even repudiation of what had 
been traditional stands on specific moral or social issues is not 
distinctive to The Episcopal Church.  It is the nature of Anglicanism 
which looks to tradition and reason as interpreters of Scripture in 
ever-changing circumstances and cultural settings.  In times of internal 
conflict when different insights are being applied to particular moral 
or social teachings, the Church continues to exist and to recognize and 
live through those conflicts.

     "Acceptance of anomaly is not the compromise of truth.  It is to 
take seriously the imperative to maintain the unity of the Church."  
Report of the Eames Commission (The Archbishop of Canterbury's 
Commission on Communion and Women in the Episcopate), 1989.

     3.   THE DOCTRINE OF THE EPISCOPAL CHURCH IS NOT ESTABLISHED
          BY RESOLUTION OF GENERAL CONVENTION OR THE HOUSE OF
          BISHOPS.

     Article I, Section 1 of the Constitution of The Episcopal Church 
declares:  "There shall be a General Convention of this Church, 
consisting of the House of Bishops and the House of Deputies, which 
Houses shall sit and deliberate separately; and in all deliberations 
freedom of debate shall be allowed.  Either House may originate 
proposed legislation, and all acts of the Convention shall be adopted 
and authenticated by both Houses."

     The laws of the church, like those of the state, are made such "by 
consent of the governed."  This principle was established through the 
leadership of Bishop William White, who was following Hooker:  
"Laws they are not which public approbation hath not made so...Laws 
human, of what kind soever, are available by consent."  The Laws of 
Ecclesiastical Polity, I.x.8. Such consent is exercised by representation.  
The orders of the church, gathered in plenary synod, adopt laws that, 
only when duly considered and passed, are binding on all.   

     To quote from Phillimore's The Ecclesiastical Law of the Church 
of England, Second Edition, Volume II, 1873, an English text cited by 
the Presenters (Brief, p.2),


     "Matters of doctrine, in which the church has prescribed 
     no rule, may be discussed without penal consequences; 
     and no rule is to be ascribed to the church which is not 
     found expressly and distinctly stated, or which is not 
     plainly involved in, or to be collected from the written 
     law of the church."  Id., p.1100.

     The Constitution establishes the Book of Common Prayer, the only 
"recognized formularies" of this Church, and one of the four 
recognized sources of this Church's Doctrine. The General 
Convention, with its two Houses, as the highest legislative body of The 
Episcopal Church, can amend the Constitution and the Book of 
Common Prayer through a time-consuming process including 
approvals at two successive meetings of General Convention.   
Accordingly, while it is possible for the General Convention acting 
through Constitutional means and with the required deliberative 
process, to amend the Constitution to establish other or different 
formularies, or to amend the Book of Common Prayer, it is extremely 
time consuming and a very rare event indeed.

     The Presenters argue that resolutions of General Convention, 
including a resolution which makes a mere "recommendation" as to 
certain "considerations", should be considered as establishing the 
Doctrine of this Church.  Prior to this Presentment, no one has 
seriously argued and no respected authority states that resolutions of 
General Convention, which do not even amend the Constitution or 
Canons, should have the "force of law," much less Doctrine.

     More than a century ago, the General Convention of 1877 received 
a report on the significance of resolutions of General Convention.  
That report stated that such resolutions "have never been deemed to 
have, and ought not to be construed as having, the force of law, but as 
merely being the expression of an opinion ... of great weight but not 
obligatory."  Journal 1877, pp.141-43, 205.

     At the 1880 General Convention, a committee commented about 
the 1877 report, pointing out that "These very resolutions [about the 
`force' of joint resolutions], if passed, would themselves become joint 
resolutions, neither more nor less, and ... it is difficult to see how any 
relief could come to embarrassed minds from our passing them." 
Journal, 1880, pp.114-115. See also Annotated Constitution and 
Canons, 1954 ed., vol. 1, 351-361.  New Wine, Pamela W.  Darling, 
1994, Note 4, p.247.

     More recently, the 1964 General Convention adopted a resolution 
on the subject of the levels of authority within The Episcopal Church.  
That resolution recognized that the Church "accepts as its authority 
the Holy Scriptures, the Nicene and Apostles' Creeds, and speaks 
through the Book of Common Prayer and the Constitution and 
Canons of the Church."  Journal, 1964, pp.312-314.

     While that resolution recognized the importance of resolutions, 
statements and actions of General Convention, and to a lesser extent 
the teachings of the House of Bishops, the resolution does not suggest 
that any such resolution, statement or action could conceivably 
establish the Doctrine of this Church as argued by Presenters. 

     The Presenters make reference to the 1924 trial of Bishop William 
Montgomery Brown where pursuant to Canon Law, the House of 
Bishops acted as the "Ultimate Court of Appeal" after a finding of 
heresy by both the trial and appellate courts, to attempt to support 
their claim that "matters approved by the House of Bishops as to 
doctrine have the highest sanction possible."  Brief, p.3.  

     The Presenters fail to note that there has been only one such 
"judicial" determination of "doctrine" in the history of The Episcopal 
Church (the Brown case); that such a finding can only be made after a 
trial, a conviction and an appeal; and that such a finding requires the 
approval of two-thirds of all Bishops canonically assembled and 
entitled to vote. Canon IV.6.5.

     While it is true that the entire House of Bishops acts as a final 
"court of review" of any Bishop convicted of heresy, it is a 
mischaracterization of the Canons and the notes of its standard 
commentators and a grotesque exaggeration to suggest that every 
resolution of the House of Bishops carries with it the force of 
Doctrine, and the risk of a presentment for heresy for dissent.

     B.   QUALIFICATIONS FOR ORDINATION ARE PART OF THE DISCIPLINE
          OF THE CHURCH.

     Anglicanism has long made a distinction between Doctrine and 
Discipline.  The distinction is at least as old as Richard Hooker, who 
argued in The Laws of Ecclesiastical Polity, 1594-7 [especially 
E.P.III.iii], that his Puritan opponents sought to treat as matters of 
Doctrine things which really belonged to Discipline.

     A classic expression of this distinction is the opening paragraph of 
the Preface to the Book of Common Prayer, 1979, which first 
appeared in the 1789 Book of Common Prayer:


     "It is a most invaluable part of that blessed `liberty 
     wherewith Christ hath made us free,' that in his worship 
     different forms and usages may without offense be 
     allowed, provided the substance of the Faith be kept 
     entire; and that, in every Church, WHAT CANNOT BE 
     CLEARLY DETERMINED TO BELONG TO 
     DOCTRINE MUST BE REFERRED TO 
     DISCIPLINE; and therefore, by common consent and 
     authority, may be altered, abridged, enlarged, amended, 
     or otherwise disposed of, as may seem most convenient 
     for the edification of the people, `according to the 
     various exigency of times and occasions.'" Emphasis 
     added.  Id., p.9.

     Although the Preface was concerned about Liturgy as the new 
American Church was claiming the liberty to modify the Book of 
Common Prayer, the words draw the essential distinction between the 
permanent nature of Doctrine, which dealt with "the substance of the 
Faith" (or, as Hooker spoke of it, "necessary things"), and the 
changeable nature of Discipline about which the Church could be 
more flexible and pragmatic.

     None of the sources of the Doctrine of this Church set forth any 
prohibition to the ordination of a non-celibate homosexual man or 
woman or limitations on Bishops performing ordinations.  Rather, the 
qualifications of ordinands are found in the Canons and the 
prerequisites to ordination are found in the Constitution (the 
declaration of belief and conformity required in Article X) and the 
Canons.  The qualifications for ordinands and other prerequisites for 
ordination to the diaconate (in preparation for eventual ordination to 
the priesthood) are set forth in Canon III.7.

     There is no provision in the Constitution or the Canons which 
prohibits the ordination of non-celibate homosexual candidates or 
which would make any such ordination "impermissible" to use the 
term of the Presentment, although there have been repeated 
unsuccessful attempts to secure the enactment of such Canonical 
prohibitions, the most recent coming from two of the Presenters, the 
Bishop of Central Florida in 1991 and the Bishop of San Joaquin in 
1994.  

     Under the historic legal principle of legislative construction 
inclusio unis, exclusio alterus, the inclusion of detailed, specific 
requirements, qualifications and prerequisites to ordination excludes 
any others not included.  Indeed, the failure of attempts to enact 
canonical prohibitions against such ordinations shows that the mind of 
the Church has been not to make such ordination unlawful, much less 
a violation of the Doctrine of The Episcopal Church.


     II.  TO ACCEPT THE PRESENTMENT WOULD BE TO HOLD THAT ALL
          THOSE BISHOPS WHO SIGNED THE STATEMENT OF CONSCIENCE
          IN RESPONSE TO THE 1979 GENERAL CONVENTION RESOLUTION,
          ALL THOSE BISHOPS WHO VOTED AGAINST THE 1990 RESOLUTION
          OF THE HOUSE OF BISHOPS, AND ALL THOSE BISHOPS WHO
          SIGNED THE 1994 "STATEMENT OF KOINONIA" WOULD BE SUBJECT
          TO PRESENTMENT FOR VIOLATIONS OF CANON IV.1.1(2).

     Apparently recognizing that Bishop Righter was but one of many 
Bishops to have undertaken the "public action" and "public teaching" 
which forms the basis for the alleged violation of Canon IV.1.1(2) in 
the Presentment, the Presenters warn,


     "Should any Bishop preach or otherwise publicly 
     proclaim that it is permissible and right to ordain 
     practicing homosexuals, that teaching or doctrine would 
     be directly contrary to the declared teaching of the 
     Church, and would be a violation of Canon IV.1.1(2) 
     prohibiting teaching contrary to the doctrine of the 
     Church."  Brief, p.7.

     The Presenters contend that 1979 General Convention Resolution 
A053sa establishes the doctrine of this Church.  If they were correct, 
the Statement of Conscience issued in response "would be a violation 
of Canon IV.1.1(2) prohibiting teaching contrary to the doctrine of the 
Church", and all 43 of the Bishops who signed the Statement of 
Conscience would be liable to Presentment along with Bishop 
Righter.

     At the meeting of the House of Bishops in Washington, D.C., on 
September 18, 1990, 75 Bishops, in addition to Bishop Righter 
"dissented from Resolution [No. B-1a] and voted against affirming the 
February [20, 1990] Statement" [of the Presiding Bishop and his 
Council of Advice], including The Presiding Bishop, and five of the 
nine members of the Council of Advice who had originally signed the 
February Statement.  The Presenters charge that this "public action" 
constitutes "holding and teaching doctrine contrary to that held by this 
Church." If they were correct (that voting against Resolution B-1a 
constituted "public action"  in "violation of Canon IV.1.1(2) 
prohibiting teaching contrary to the doctrine of the Church"), then all 
75 of the Bishops who, along with Bishop Righter, "dissented" would 
also be liable to Presentment.

     On August 25, 1994, at the General Convention in Indianapolis, 71 
Bishops signed "A Statement of Koinonia".  The Presenters charge 
that signing the Statement of Koinonia constitutes "public teaching" of 
"doctrine contrary to that held by this Church."  If the Presenters were 
correct, then all 70 of the Bishops who, along with Bishop Righter, 
signed the Statement of Koinonia would also be liable to Presentment 
for "violation of Canon IV.1.1(2) prohibiting teaching contrary to the 
doctrine of the Church".

     In 1924 the Court for the Review of the Trial of A Bishop, 
considering the appeal of the heresy conviction of Bishop William 
Montgomery Brown (the only trial of any Bishop in The Episcopal 
Church for "holding and teaching doctrine contrary to that held by this 
Church"), defined the "doctrine of the Church" as the "articles of faith" 
which "must be accepted by all members of the Church."
  
     There is no doctrine of this Church on the issue of whether it is 
permissible or impermissible to ordain non-celibate homosexual 
persons.  To put it in the precise words of the Court in rejecting 
Bishop Brown's appeal, there is no article of faith stating that it is 
impermissible to ordain a non-celibate homosexual person which must 
be accepted by all members of the Church. 

     As the House of Bishops acknowledged in the Statement issued in 
September 1990, on the issue of "ordination to Holy Orders of 
sexually active homosexual men and women" ... "we are not of a single 
mind..."  Journal, 1991, p.517.

     III. THE ORDINATION OF THE REV. BARRY STOPFEL TO THE
          DIACONATE IN COMPLIANCE WITH THE CANONS AND IN
          ACCORDANCE WITH THE WORSHIP OF THE EPISCOPAL CHURCH
          WAS NOT A VIOLATION OF BISHOP RIGHTER'S ORDINATION
          VOWS.

     In "Count II" of the Presentment, Bishop Righter is charged with 
violation of Canon IV.1.1(6) ("violation of ordination vows") based 
upon the assertion that ordaining the Rev. Barry Stopfel to the 
diaconate violated the declaration of belief and conformity given by 
Bishop Righter at the time of his ordinations (which Presenters 
characterize as his "ordination vows to `conform to the Doctrine ... of 
the ... Church.'"  Presentment, p.7.

     The "ordination vows" referred to in Canon IV.1.1(6) are not the 
declaration of belief and conformity, but the vows taken by the 
ordinand during the examination at his or her ordination.   The 
declaration of belief and conformity requires all ordinands to 
"solemnly engage to conform to the Doctrine, Discipline, and Worship 
of The Episcopal Church," and the failure to conform to the Doctrine, 
or the Discipline, or the Worship of The Episcopal Church can be the 
basis for a presentment under Canon IV.1.1, but not under Canon 
IV.1.1(6) for "violation of ordination vows."   

     Canon IV.1.1(6) is intended to address conduct not included in any 
of the other sections of Canon IV.1.1, e.g., failure to obey a godly 
admonition by a priest or a deacon.  The "Doctrine, Discipline and 
Worship of The Episcopal Church" are each covered by different 
sections of the disciplinary Canon.  Were Canon IV.1.1(6) ("violation 
of ordination vows"), to mean failure to obey the declaration of belief 
and conformity (failure to conform to the "Doctrine, Worship and 
Discipline of The Episcopal Church"), then it would be duplicative 
and redundant.  In addition, the Presenter's argument that failure to 
conform to the Doctrine of the Church is presentable under both 
Canon IV.1.1(2) and Canon IV.1.1(6) creates a fundamental 
procedural paradox under Canon IV.4(b).  It is not possible to comply 
with the inconsistent procedural requirements of both sections.

     Even were it proper under Canon IV to bring charges under both 
IV.1.1(2) and IV.1.1(6) based upon a breach of the Doctrine of The 
Episcopal Church, there is no such breach herein. As indicated above, 
there is no Doctrine of this Church on the question of whether it is 
permissible or impermissible to ordain non-celibate homosexual 
persons or establishes limitations on Bishops performing such 
ordinations.  The required qualifications of ordinands and the 
prerequisites to ordination are found in the Constitution and Canons 
of this Church, and there is no provision in the Constitution or the 
Canons which prohibits the ordination of non-celibate homosexual 
candidates.

     The qualifications and other prerequisites for ordination to the 
diaconate (in preparation for eventual ordination to the priesthood) 
are set forth in Canon III.7.  At the time of his ordination to the 
diaconate by Bishop Righter, the Rev. Barry Stopfel had satisfied all 
of the canonical requirements for such ordination, including (a) the 
required certification from the Rector and Vestry of the Parish of 
which Barry Stopfel was a member; (b) a resolution of the Standing 
Committee of the Diocese of Newark recommending that Barry 
Stopfel be ordained to the Diaconate; and (c) the approval of the 
Bishop of Newark to such ordination.

     The ordination of the Rev. Barry Stopfel to the diaconate did not 
violate the DOCTRINE of this Church, because there is no Doctrine 
of this Church pertaining to the qualifications of ordinands or 
imposing limitations on the authority of Bishops to ordain.  Such 
qualifications and limitations are matters of discipline under the 
Constitution and Canons.  The ordination of the Rev. Barry Stopfel to 
the diaconate did not violate the DISCIPLINE of this Church in that 
all of the prerequisites to such ordination required under the 
Constitution and Canons were satisfied and the ordinand met all of 
the Canonical qualifications for ordination.  The Rev. Barry Stopfel 
was ordained to the diaconate in accordance with the WORSHIP of 
this Church as set forth in the Book of Common Prayer.

     The ordination of the Rev. Barry Stopfel was not contrary to the 
declaration of belief and conformity given by Bishop Righter to 
engage to conform to the Doctrine, Discipline and Worship of The 
Episcopal Church, nor did such ordination violate any ordination vow 
given by Bishop Righter.




                           CONCLUSION

     There is no basis for bringing Bishop Righter to trial on a charge of 
holding and teaching Doctrine contrary to that of The Episcopal 
Church in violation of Canon IV.1.1(2) or on a charge of violating his 
ordination vows under Canon IV.1.1(6).  This attempt to use the 
Church's judicial process to resolve an issue on which there is no 
agreement must fail. Accordingly, it is respectfully submitted that the 
House of Bishops should not consent to proceeding to a trial and the 
Presentment should be dismissed.


                                   Respectfully submitted,


                                   MICHAEL F. REHILL
Of Counsel and                     Chancellor, Diocese of Newark
On the Brief:
                                   Counsel for Respondent
                                   The Rt. Rev. Walter C. Righter
                                   Retired Bishop of Iowa
WILLIAM C. BULLITT                      
Chancellor, Diocese of Pennsylvania
                                   
JOHN K. CANNON                     
Chancellor, Diocese of Michigan         
                                   
PAUL E. COONEY                     
Chancellor, Diocese of Washington  
                                   
RICHARD J. HOSKINS                 
Chancellor, Diocese of Chicago     
                                                       
                                   
Dated: May 10, 1995                 



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