Regional judicatory declines to clarify its haste to approve local church’s secession, dismissing all associated litigation, while delaying, denying individuals’ parallel resignation appeals
But what is the only way this can end?
Jean-Siméon Chardin, “The House of Cards” (ca. 1740), The National Gallery, used with permission. https://www.nationalgallery.org.uk/paintings/NG4078
“The committee that Dr. Thompson appointed was of a thoroughly partisan kind. … In general, it would be difficult to imagine a more perfect example of a partisan committee.
From such a committee no impartial report could reasonably have been expected. And yet one could scarcely have anticipated quite such unfairness as that which characterizes the report that was actually produced—the misrepresentation of various kinds, the omission of vitally relevant evidence, the unjudicial tone throughout. It is safe to say that seldom has a more unfair document been submitted to a body such as the General Assembly of our church.
Such a document never could have been submitted with any reasonable certainty of its being adopted if time had been allowed for the commissioners to peruse it with any care and for the persons whom it attacked to prepare their defense. …
The whole action would be stopped if the rank and file of the church were given the slightest real voice in the questions in dispute. …
But the present method of procedure is such that the laity is given little voice.”
— J. Gresham Machen, “The Attack upon Princeton Seminary: A Plea for Fair Play,” 1927
“Shepherding the Whistleblower
Unfortunately, organizations in need of a whistleblower are those most likely to suppress, reject, banish, or destroy messengers. Loyalty to an organization tends to supersede truth. Whistleblowers, like prophets, call their audience to recognize evil and purge it. Reliable, confidential, and anonymous reporting systems capable of instituting intervention are critical.”
“You shall not be partial in judgment. You shall hear the small and the great alike. You shall not be intimidated by anyone, for the judgment is God’s.”
— Deuteronomy 1:17
“If you say, ‘Behold, we did not know this,’
does not he who weighs the heart perceive it?
Does not he who keeps watch over your soul know it,
and will he not repay man according to his work?”
— Proverbs 24:12
“How can you say, ‘We are wise, and the law of the LORD is with us’? But behold, the lying pen of the scribes has made it into a lie.”
— Jeremiah 8:8
OVIEDO, FL — Some institutions can stack procedural contradictions for years, until an official document makes the whole jengaesque edifice visible. In this case, a Presbytery has shown disjunction in how it acts expeditiously in one voluntary-association ruction and slowly or not at all in comparable individual contexts.
1. The January 2026 Action
Central Florida Presbytery recently has acknowledged the plain Constitutional right of a local church to withdraw under BCO 25-11. Yet in preceding cases involving individual members resigning from St. Paul’s Presbyterian Church of Orlando (PCA), Inc. — on the same codified voluntary-association principle — Presbytery either mishandled or ignored lawful appeals. The resulting apparently selective urgency raises questions about not merely inconsistency, but departure from its own judicial treatment.
When queried through official channels to clarify specific questions about this history, especially arising from the most recent General Assembly in 2025, Central Florida Presbytery through its Stated Clerk declined to comment.
“Valuable are the by-products of Christianity, and one of them is the civil liberty of the race.”
— J. Gresham Machen, “Christianity and Liberty,” 1931
“To attack Christian liberty is to attack the Lordship of Jesus Christ.”
— J. Gresham Machen, “Statement to the Presbytery of New Brunswick,” 1935
“One of the most important elements in civil and religious liberty is the right of voluntary association—the right of citizens to band themselves together for any lawful purpose whatever, whether that purpose does or does not commend itself to the generality of their fellow men. Now, a church is a voluntary association. No one is compelled to be a member of it; no one is compelled to be one of its accredited representatives. It is, therefore, no interference with liberty for a church to insist that those who do choose to be its accredited representatives shall not use the vantage ground of such a position to attack that for which the church exists.
… a true Christian church will be radically ethical.”
— J. Gresham Machen, “The Responsibility of the Church in Our New Age,” 1933
“In fact, the Presbyterian Church itself is a voluntary association.
All of its members voluntarily associate themselves with the Church, and maintain their affiliation with it no longer than they voluntarily choose to do so. All that they do for its support, therefore, is a voluntary donation, and there is no power which can compel them to contribute to any ecclesiastical object to which they are not willing to give.”
— Presbyterian Church in the U.S.A. 1934, General Assembly Minutes, as extracted by J. Gresham Machen in “Statement to the Presbytery of New Brunswick,” 1935
“Nothing engenders strife so much as a forced unity, within the same organization, of those who disagree fundamentally in aim.
But is not advocacy of such separation a flagrant instance of intolerance? The objection is often raised. But it ignores altogether the difference between involuntary and voluntary organizations. Involuntary organizations ought to be tolerant, but voluntary organizations, so far as the fundamental purpose of their existence is concerned, must be intolerant or else cease to exist. The state is an involuntary organization; a man is forced to be a member of it whether he will or no. It is therefore an interference with liberty for the state to prescribe any one type of opinion or any one type of education for its citizens. But within the state, individual citizens who desire to unite for some special purpose should be permitted to do so. Especially in the sphere of religion, such permission of individuals to unite is one of the rights which lie at the very foundation of our civil and religious liberty.
The state does not scrutinize the rightness or wrongness of the religious purpose for which such voluntary religious associations are formed—if it did undertake such scrutiny all religious liberty would be gone—but it merely protects the right of individuals to unite for any religious purpose which they may choose.
Among such voluntary associations are to be found the evangelical churches. An evangelical church is composed of a number of persons who have come to agreement in a certain message about Christ and l who desire to unite in the propagation of that message, as it set forth in their creed on the basis of the Bible. No one is forced to unite himself with the body thus formed; and because of this total absence of compulsion there can be no interference with liberty in the maintenance of any specific purpose—for example, the propagation of a message—as a fundamental purpose of the association.”
— Christianity and Liberalism: Legacy Edition, J. Gresham Machen, 1923, pp. 171-172
“But Machen, ever alert to threats to individual liberty … Machen’s outlook is not grasped at all unless one discerns that he was passionately devoted to liberty and that this commitment was anchored profoundly in his Christian faith and outlook. In an era when the state was encroaching more and more upon the liberty of the individual, Machen was greatly exercised that men should be aroused to pay the price necessary to preserve it.”
— J. Gresham Machen: A Biographical Memoir, Ned B. Stonehouse, pp. 466, 470
2. Demonstrated Capacity for Rapid Action
Whereas, Presbyterianism is often criticized for slowness and inefficiency, the pace of adjudication often is rationalized that Presbyterianism must take its time to reach its righteous outcome. And whereas, a teaching-elder official of Central Florida Presbytery once mused, “I, like the ancient Greek, understand the frustration of waiting for the wheels of justice that turn slow but grind a fine result (a paraphrase)” — the reality seems to suggest that Presbyterian courts often may move and act as fast as they want to act when it suits their purposes.
On Sunday, December 14, 2025, at its Session’s recommendation and at a congregational meeting after morning worship, Saint Andrew’s Chapel elected to sever its formal relationship with the Presbyterian Church in America. The PCA’s official magazine reports, “In a letter, the clerk of session informed the presbytery that the church voted “to dissolve its ecclesiastical connection with the Central Florida Presbytery, effective upon receipt of this notice.” (PDF) The Session notified the Presbytery of the decision the following day.
On December 19, four days later, the Central Florida Presbytery had already responded to the local church’s action, acknowledging its Constitutional prerogative to “withdraw from any court of this body at any time for reasons which seem to it sufficient.” Thus, byFaith quotes Stated Clerk TE Don Mountan: “On behalf of the Central Florida Presbytery, I write to acknowledge receipt of your formal notice of withdrawal from the Presbyterian Church in America, effective December 14, 2025.” (PDF)
Ordinarily, any Church court must deliberate on business at its next regularly scheduled stated meeting. Central Florida Presbytery meets quarterly as a body, and the most recent meeting was hosted at Covenant Presbyterian Church in Oviedo, on January 20. But the time between Saint Andrew’s departure and its former Presbytery’s response to the meeting was only four days while the interval with its own stated meeting was 37 days.
Four days. Just to offer some historical perspective, the Cuban Missile Crisis was diffused and resolved in thirteen days.
The Presbytery’s four-day response demonstrates that delay in other cases cannot be objectively attributed to institutional incapacity.
This is not alleged as a procedural violation. Whatever the motives may be, it was selective haste.
According to official records, not one teaching elder nor ruling elder appeared to have attempted to block Saint Andrew’s’ codified right to withdraw from the Presbyterian Church.
“Clerk’s Report and Recommendations …
7. As Information – SAC notified CFP on Dec 15, 2025 that by congregational vote of 669 to 108 on Dec 14, 2025, SAC voted to withdraw from the PCA.
8. M/S/C – Therefore, that the SAC be removed from the roll of churches in CFP in accord with BCO 25.11
9. M/S/C – that the Commission and Committee appointed by the 199th to process the several 40-5 requests from D Zima against SAC session be discharged (RRO 36) with thanks since SAC is no longer under CFP jurisdiction.
10. M/S/C – that the Commission appointed by the 196th to adjudicate the D Risavy Complaint against the SAC be discharged (RRO 36) with thanks since SAC is no longer has standing to pursue SJC 2025-16, pending SJC affirmation.
11. M/S/C – that Commission appointed by 198th to express good will and communicate with the SAC session be discharged with thanks since SAC has withdrawn”
Also, just this past year, the 51st PCA General Assembly identified “exception[s] of substance” from Central Florida Presbytery’s journal, and accepted the Presbytery’s explanation that agreed with a recent example of a local church’s prerogative to secede.
“That the following responses to the 51st GA be found satisfactory: …
2023-12: Nov 15, 2022 (BCO 25-11; Preliminary Principle 6) — Presbytery approved the withdrawal of a church from the PCA, when withdrawal is not conditional on Presbytery approval.
Response: Presbytery agrees with the exception.”
This is the forty-second (42nd) General Assembly since 1978, a span of 46 years of audits, that the Review of Presbytery Records Committee reports material errors, omissions, or disorganization of Central Florida Presbytery’s records (Benyola.net: ‘This is a repeat finding’: PCA General Assembly reports problems in 91% of official recordkeeping audits for Central Florida Presbytery’s 48-year existence). That is a ratio of 9 out of 10 Presbytery official audits having problems.
3. Contrast: Individual Resignation Handling
Amid this endless hydra of exceptions and Presbytery’s equally endless rejoinders, at least everyone agrees with this recent basic reminder that a local church obviously needs no “approval” from a presbytery to leave the denomination. Evidently, it is not that Saint Andrew’s’ right to leave the denomination is in dispute by anyone (including this author). Any local church’s prerogative to leave the denomination is irrefragably codified in the PCA’s Book of Church Order. Moreover, such a right is so integral to the fundamental governance of the denomination, that historically, the denomination itself was born out of such right to depart from its parent denomination in 1973.
Rather, what is evident is how Presbytery’s acknowledgement of this orderly decision of the local church seems to tergiversate from its own repeated failure to consistently acknowledge such a basic right in its preceding cases pertaining to the same Constitutional question. Particularly, these juridical failures manifest in Presbytery’s mishandling — or not handling at all — the legitimate appeals of individuals who resigned their membership on the very same Constitutional basis from St. Paul’s Presbyterian Church of Orlando (PCA), Inc., yet whose resignations arguably were illegally denied ultra vires by the church’s governing board, contrary to the heteronomous authority of the PCA BCO and SJC precedent. The attempted denial also raises civil-law implications under Florida nonprofit corporate law. Ironically, such resignations sometimes were tendered in direct consequence to problems surrounding Saint Andrew’s Chapel: its initial unpresbyteration, then subsequent presbyteration, and then its most recent re-unpresbyteration again.
In further irony, the same Presbytery currently enjoys the rather appreciable fruits of certain of its resigned former members’ labors in helping to domesticate Saint Andrew’s Chapel, although ending in its ultimate release back into autonomous prelacy. This, even as Presbytery remains inert in its denial that such resigned former members, in resigning their St. Paul’s voluntary membership, indeed draw from the True Vine as Christians of credible profession, yet somehow bear “Spiritual fruit” even as “wild olive branches.”
4. Recent Related Developments
The Permanent Committee Reports continue,
“Minister and His Work Committee
M/C without objection – that TE Burk Parsons be changed to ‘without call’ until his current appeal is adjudicated by the SJC. [in accord with Standing Rules Art V – Acceptable Calls]
Information – the withdrawals were received of TE Stephen Adams (12/17/2025), TE Don Baily (12/15/2025), and TE Kevin Struyk (1/12/2026) from the PCA per their request to continue membership with St Andrew’s Chapel, an Independent Church. Per BCO 38-3a, their withdrawal is recorded and acknowledged.”
(Stated Minutes of the 200th Stated Meeting of PCA Central Florida Presbytery, p. 8, emphasis original, typographical errors original)
Of course, even teaching elders are permitted to resign at any time without contest even when their entire church is facing formal review and control by the higher courts in connection with their own deportment — as much as such resignation may be “irregularity.” And how exactly what or whose activities have been widely attributed for the Presbytery’s Standing Rules having been changed to prohibit ecclesiastical out-of-bounds calls in the first place? Presbyterian amnesia is possible, but this improvement is less than three years old.
Prior to the local church’s particularization as a PCA congregation on June 4, 2023, Saint Andrew’s publicly stated,
History & Identity
Saint Andrew’s was founded in 1997 as an independent congregation in the Reformed tradition. As such, Saint Andrew’s is not affilliated with a particular denomination. That is not to say, however, that we are non-denominational or inter-denominational. On the contrary, Saint Andrew’s is an independent congregation on account of our desire to remain steadfast in the Reformed tradition without the influence of denominational governance. Nevertheless, our pastors are ordained ministers in the Presbyterian Church in America (PCA). …
Dr. R.C. Sproul (1939–2017) was the founding pastor of Saint Andrew’s Chapel.”
(https://www.sachapel.com/about/who-we-are/history-identity.html, PDF)
Currently, Saint Andrew’s presents,
“History & Identity
Saint Andrew’s was founded in 1997 as an independent congregation in the Reformed tradition. In 2023, the congregation was received into the Presbyterian Church in America (PCA). In 2025, the congregation voted to withdraw from the PCA, and as a result, Saint Andrew’s is currently an independent congregation in the Reformed tradition.
Dr. R.C. Sproul (1939–2017) served as the first minister of preaching and teaching at Saint Andrew’s Chapel.”
At its 188th Stated Meeting on 04/18/2023, the Central Florida Presbytery passed proposed changes to its Standing Rules which circumscribe “out-of-bounds” calls for its teaching elders, effectively ending Presbytery’s 25-year program supplying PCA-credentialed ministers to Saint Andrew’s Chapel.
“ARTICLE V – ACCECPTABLE CALLS [typographical error is original]
CFP will only approve calls for existing Teaching Elders or ordain new Teaching Elders to serve in CFP PCA churches. This policy does not impact our current practice of ordaining men to serve out-of-bounds in non-ecclesiastical ministries within our Presbytery. PCA Teaching Elders who currently serve at a non-PCA church are exempt from this requirement until they change their current position.”
(Central Florida Presbytery Governing Documents, Standing Rules, 2023)
As this Presbytery may be at risk of historical amnesia, it is reasonable just to ask: whence the instrumentality of this revelation and its subsequent events?
4. Structural Implications
In a recently published adminicle to the PCA BCO, Dr. C.S. Per Almquist notes on BCO 25-11,
“As an ecclesiastical entity, the local church is subject to the Constitution of the PCA. As a civil entity, the local church has complete legal authority to act in civil matters as it sees fit in accordance with applicable laws.”
(Our Bond of Union: A Commentary on the Book of Church Order of the Presbyterian Church in America, p. 229)
In contrast, Central Florida Presbytery’s actions demonstrate:
1. BCO 25-11 is treated as dispositive when a congregation departs.
2. All litigation related to the congregation which may bog down the Court could then be conveniently jettisoned.
3. The same voluntary-association principle was not consistently honored when individuals resigned.
4. This apparent dissimulation produced what seems to be aberrant precedent and procedural injustice in comparable, justiciable cases.
5. The Court can move quickly when it chooses — so delay elsewhere is not necessity but preference.
Institutions can forget their own moral memory — and when they do, obligations that once seemed obvious suddenly become “complicated.” If selectivity were a motive at play, then the most efficient way to evade settled and binding precedent would be for the institution to pretend it could not remember it.
This might take some readers aback, but the same Presbytery Stated Minutes summarize yet another judicial case arising from St. Paul’s Presbyterian Church of Orlando (PCA), Inc. appealed by a church member; and in an unbroken pattern, Presbytery resolved to “deny the appeal and affirm in whole the decision of SPPC … The appeal is denied in its entirety.” (Stated Minutes of the 200th Stated Meeting of PCA Central Florida Presbytery, pp 9-10, emphasis original)
No one disputes that church discipline is a mark of the true church and has its proper function. But among PCA sesssions in general, St. Paul’s’ Session generates a volume of formal judicial cases against its members that is significantly above average. Of that unusually large sample size over 35 years since that church was founded, and as a matter of mere empirical fact: Can history produce a single case when Central Florida Presbytery has ever not upheld any censure of St. Paul’s Presbyterian Church of Orlando (PCA), Inc.?
Despite this Presbytery maintaining lockstep claims of flawless judicial process in literally every case ascending from St. Paul’s, the Committee on Review of Presbytery Records has found “exceptions of substance” in Central Florida Presbytery’s recordkeeping no less than forty-two (42) times since the fifth General Assembly in 1978 — 91.3 percent of audits in the same period — also Citing Central Florida several times, especially in 2009 and 2010, around the very time Presbytery approved calls of more TEs to labor out of bounds at Saint Andrew’s Chapel (Benyola.net: ‘This is a repeat finding’: PCA General Assembly reports problems in 91% of official recordkeeping audits for Central Florida Presbytery’s 48-year existence).
As recently as this same Stated Meeting, Presbytery has prepared a response for similar serialized exceptions in which it apparently affirms that it is “cited.”
“Responses to RPR …
2025-01: General 2024 (BCO 13-9.b; BCO 40-1 — Incomplete record of review of records of church.
Response:
Presbytery agrees with the exception and promises to be more careful in the future. We have established a Review of Session Records Commission and procedures to correct such oversights. Every Session record has been reviewed except one, which has been cited for delinquency.
2024-01: Jan. 7, 2023 (BCO 20-8) — No record commissioners appointed by the church presented and prosecuted the call of a TE before Presbytery. …
2024-02: Apr 18, 2023 (BCO 20-8) — No record commissioners appointed by the church presented and prosecuted the calls of TEs before Presbytery.”
(Stated Minutes of the 200th Stated Meeting of PCA Central Florida Presbytery, pp. 18-19)
While Church courts such as Central Florida Presbytery and its subordinate Session continue purporting impeccability in their process, they claim as bodies of overseers to pronounce public judgments against Christians formerly entrusted to their care. In contrast, when the same Courts, whose responsibility is diffused among many elders, are themselves repeatedly Cited for the same chronic delinquencies — even at times having their censures overturned by the General Assembly — their mistakes are reduced to “procedural error,” with no personal responsibility falling on anyone, the same unfulfilled promise of improvement, no redress, and never any apology. But throughout this judicial, procedural, and moral asymmetry between multiple shepherds and individual sheep, such Presbyterian courts claim to be exercising the keys of the Kingdom.
It is not as if the author did not explicitly remind the Court of its own cantilevered variance before it transpires publicly. The communication with the Chairman of the Minister and His Work Committee, copying the Stated Clerk, also was recorded, yet not deliberated, much less acted upon.
“CLERK’S NOTES …
12/23 Email cc’d by P Benyola re pursuing reversal of past actions
… Attested by Stated Clerk
(Print Name) ___TE Donald Mountan ____Date: _
Attested by Moderator
Print Name) ___TE John Tweeddale _____ Date _”
Central Florida Presbytery apparently became so hidebound in its resolve to jettison a specific PCA member’s orderly submitted requests, that it made a matter of policy — the Court’s own word — to automatically dismiss any warnings sent from such person on any pertinent problems. This, even though in connected issues, eventually “Between May 12–28, 2025, the Commission conducted over 45 hours of trial proceedings, hearing 40 testimonies from 55 witnesses,” which led to that very Presbytery itself charging, indicting, prosecuting, and suspending one of the teaching elders from the gospel ministry (Judicial Commission Report to the Central Florida Presbytery Concerning TE Burk Parsons, June 12, 2025; Benyola.net: “PCA Central Florida Presbytery suspends ‘inaccessible’ pastor Burk Parsons amid violations triggering its 2022 whistleblower-retaliation scandal”).
So, on 02/09/2026, the Plaintiff of the 03/15/2022 Credible Report which preceded that outcome, reapproached the Stated Clerk of Central Florida Presbytery offering the opportunity to clarify the present investigative report prior to its publication (copying his assistance, TE Dominic Aquila).
“Dear Rev. Don,
I pray you are well. I continue to update the public record as events unfold and it seems only fair and charitable to respectfully ask if you as Stated Clerk would like to comment on my findings prior to publication of a newly drafted report.
Rather than try to achieve answers on a lengthy extract of recordkeeping audits from 46 years of General Assembly minutes, it seems prudent to respect your time and reduce what is manageable by addressing the most recent and germane concerns.
We find in M51GA, Central Florida Presbytery responded to the Committee on Review of Presbytery Records,
‘2023-9: Apr 26, 2022 ES (BCO 31-8) — Presbytery policy that accusations from a specific communing member be ‘automatically denied’ on the basis of BCO 31-8 exceeds the scope ‘great caution’ permitted.
Response: Presbytery respectfully disagrees with the exception. This action was taken after a three-year period of numerous complaints and charges that, in the judgment of presbytery, rose to the level of exhibiting ‘a malignant spirit’ and a ‘litigious, rash or highly imprudent’ character (BCO 31-8). The action was not all-encompassing but was specifically limited to complaints ‘that are in any way connected to [the complainant’s] ongoing vendetta against [church name omitted] and/or their Teaching Elders.’ Later unrelated complaints from this individual were admitted. Further, the issue is now moot as the individual has been excommunicated from the Church.
…
2023-12: Nov 15, 2022 (BCO 25-11; Preliminary Principle 6) — Presbytery approved the withdrawal of a church from the PCA, when withdrawal is not conditional on Presbytery approval.
Response: Presbytery agrees with the exception.”
(Minutes of the Fifty-First General Assembly of the Presbyterian Church in America, pp. 479-481)
In light of recent events which seem to clarify the factual landscape, I attempt with humility to receive substantive answers to these specific questions:
1. The Church member who submitted the 03/15/2022 Credible Report referred it to the General Assembly and enclosed reasoning as to why BCO 31-8 had been misapplied by the Presbytery that dismissed that Report. Upon review, the Committee on Review of Presbytery Records at least initially agreed with that reasoning.
At this time, does Central Florida Presbytery and/or its Stated Clerk maintain that BCO 31-8 should have been used to automatically dismiss an individual’s Credible Report although that representation inquires into its verifiable facts?
2. At this time, does Central Florida Presbytery and/or its Stated Clerk maintain that it was warranted to concretize such automatic dismissal as a matter of ‘policy’ (Presbytery’s own term) because ‘a three-year period of numerous complaints and charges that, in the judgment of presbytery, rose to the level of exhibiting ‘a malignant spirit’ and a ‘litigious, rash or highly imprudent’ character (BCO 31-8).’?
3. At its 188th Stated Meeting on 04/18/2023, Presbytery changed its Standing Rules: ‘CFP will only approve calls for existing Teaching Elders or ordain new Teaching Elders to serve in CFP PCA churches.’ (Central Florida Presbytery Governing Documents, Standing Rules, 2023)
At this time, does Central Florida Presbytery and/or its Stated Clerk maintain that the 2020 to 2022 Complaints ‘that are in any way connected to [the complainant’s] ongoing vendetta against [church name omitted] and/or their Teaching Elders’ are not connected to Presbytery’s subsequent policy change to circumscribe ‘out-of-bounds’ calls for its teaching elders?
4. Eventually, ‘Between May 12–28, 2025, the Commission conducted over 45 hours of trial proceedings, hearing 40 testimonies from 55 witnesses. … The Commission voted unanimously to indefinitely suspend TE Parsons from office.’ (Judicial Commission Report to the Central Florida Presbytery Concerning TE Burk Parsons, June 12, 2025).
At this time, does Central Florida Presbytery and/or its Stated Clerk consider that such an outcome potentially could have been mitigated or even obviated without the aforementioned ‘policy’ against the Complainant and its attendant dismissals?
5. Presbytery itself ended up charging, indicting, prosecuting, and suspending one such teaching elder, but not before the local church multiplied litigation and substantial resources were expended. At its most recent Stated Meeting, Presbytery changed this TE’s status to ‘without call’ while he has appealed his censure, also accepting the resignations of the other three TEs at Saint Andrew’s Chapel, and summarily dismissing all connected representations in process. Presbytery only later, after many witnesses, hearings, complaints, charges, and credible reports, reached this denouement.
At this time, does Central Florida Presbytery and/or its Stated Clerk maintain that its framing of the Plaintiff’s older alerts and requests are unrelated to its recent conclusions and as a ‘vendetta’?
6. Presbytery, in a little more than a month, recorded and acknowledged Saint Andrew’s Chapel’s withdrawal under BCO 25-11 as well as its TEs under BCO 38-3a from denominational membership. In other cases on the same Constitutional question which eventually were carried to the highest Court (SJC 2019-13, SJC 2022-09,-17,-18,-19, 2024-29), Presbytery either denied those appeals or left them with Commission for many months, receiving no action, eventually necessitating their elevation.
At this time, does Central Florida Presbytery and/or its Stated Clerk maintain that ‘later … complaints from this individual’ were ‘unrelated’?
Though ‘admitted’ and justiciable, does the Court maintain that these Complaints were timely and rightfully adjudicated?
Does the Court maintain that those Complaints concerning BCO 25-11 and 38-4 are incommensurable with the more recent matter of a local church, its congregation, and its teaching elders voluntarily disassociating from the PCA, and Presbytery quickly and summarily recording and acknowledging those withdrawals?
Does the Court still maintain that ‘the issue is now moot’?
Does the Court still maintain that ‘as the individual has been excommunicated from the Church’ irrespective of the facts of the PCA Constitution and judicial precedent, the circumstances of the orderly and legal resignation, and the Court’s own actions on similar cases, all repeatedly equiponderated before this Court by the same individual?
In sum: does Central Florida Presbytery still stand by the narrative it has presented even to the General Assembly up to this point?
Especially since the GA minutes recount that a Central Florida church’s inviolable ‘voluntary association’ was reaffirmed as recently as 2022, no one disputes that Saint Andrew’s Chapel was well within its Constitutional prerogative to disunite from the denomination in 2025. So, I am encouraged by the apparently lucid capacity of Central Florida Presbytery — at least, its Administrative Committee — to publicly acknowledge such lawful exercise in a mere four days.
Since three weeks now have elapsed since Presbytery’s disposition in related matters, and due to the time-sensitivity of recent news as well as my appurtenant research, it seems reasonable to ask: will you and/or Presbytery feasibly please respond to this request for input by this Friday evening, in about four days?
If no response is received, I will note that Presbytery has no comment.
Gratefully,
P Benyola”
On 02/13/2026, within the four days requested, Central Florida Presbytery acknowledged the inquiry, copying TE Aquila as well as Presbytery’s present Moderator.
“Dear Peter,
I am well, by God’s grace and I hope you are also.
Thank you for offering the opportunity to respond prior to publication.
You may, as you indicated in your email, note that Presbytery has no comment.
Don
Rev. Donald L. Mountan
Prov. 3:5,6
Central Florida Presbytery
Stated Clerk”
5. Foundational Background: The PCA Top Court’s Historical Stream of Judicial Cases Propounding its “Voluntary Association” Principle
Since all three levels of the denomination’s courts frequently seem to either forget or ignore their own decisions, it is hardly redundant to rehearse the Church’s historical stream of judicial precedent asserting and reasserting Christian liberty, continuing to quote the ipsissima verba — “the very words.”
Exhibit A — 06/19/1991: The Standing Judicial Commission asseverates the PCA’s fundamental principle of “voluntary association,” because its historical background as a 1973 departure from the mainline Presbyterian Church in the United States underlies the very origin/existence of the denomination.
“MINUTES – WEDNESDAY AFTERNOON
June 19, 1991
Fifth Session
19-48 Standing Judicial Commission …
REPLY TO GENERAL ASSEMBLY ON JOHN M. WARREN, JR. MEMORIAL
I. STATEMENT OF THE ISSUES
The Standing Judicial Commission files this Report and Recommendation with the 19th General Assembly on the Memorial from TE John M. Warren, Jr. seeking clarification of the effects of the action of the 17th G.A. as it affects the action of the 16th G.A. relating to the Carl Fox matter. …
PCA is a voluntary association of people committed to a common faith and order. The BCO § 25-11 explicitly expresses this voluntary principle as it applies to the association of a local church with the denomination:
25-11: ‘… Particular churches need to remain in association with any court of this body only so long as they themselves so desire. The relationship is voluntary, based upon mutual love and confidence, and is in no sense to be maintained by the exercise of any force or coercion whatsoever. A particular church may withdraw from any court of this body at any time for reason which seem to it sufficient.’
We believe this same voluntary principle applies to an individual’s association with a local PCA congregation.
…
STANDING JUDICIAL COMMISSION
A. PRESENT PERSONNEL:
Class of 1994 …
Ruling Elder
John B. White, Jr., N. Georgia”
(M19GA, pp. 91, 96-97, 104, 462)
The fact that BCO 46-5 was later vacated and replaced with BCO 38-3 is irrelevant to the current question, as the PCA’s basic principle of “voluntary association” originates/survives in BCO 25-11.
Takeaway: The SJC explicitly grounded voluntary association in BCO 25-11 and extended it to individuals—not merely congregations.
Exhibit B — A PCA historian later recounts the genesis of the SJC’s precedent for the PCA denomination’s fundamental principle of an individual’s “voluntary association.” Though the issues setting this precedent have multiple dimensions and are not without controversy, Dr. Frank Smith writes,
“The 1990 Assembly assigned the memorial to the newly-created Standing Judicial Commission (SJC), which reported the next year. …
The SJC stated that a ‘clarifying’ amendment of the Book of Church Order, adopted after the [Carl] Fox case had been adjudicated in 1988, was the controlling law of the church. The passage of the amendment to BCO 46-5 ‘made clear that it was the intention of this denomination that a simple voluntary resignation of a local church member could be handled by the session under its general powers.’ The SJC then maintained that the same voluntary principle enunciated with regard to congregations applies to individual members—that is, that a person may withdraw from the jurisdiction of the church and the church may accept that resignation, without the infliction of censure. The Commission also stated ‘that the power of the Presbytery and General Assembly in matters of this type, admitting and dismissing members from a local congregation, is purely ministerial and declarative, moral and spiritual. … It must be remembered that the power to take action, to receive and dismiss members of a local congregation, is invested in the Session of the local church. … The SJC committed itself to a ‘voluntaristic’ notion of church membership—an idea to which the Commission would appeal in the Chen case in 1994 (see below). …
Dr. & Mrs. Stuart Chen vs. Ascension (1994)
… In its ruling, the SJC overturned the censure of the Chens, and urged the Session ‘to consider deleting the names from the church roll under BCO 46-5 as requested by the Chens in their letter of April 26, 1992.’ The SJC referred to the Carl Fox case, and posited that the PCA ‘is a voluntary association of people committed to a common faith and order.’ It then stated that the same voluntary principle by which a congregation may elect to disassociate with the denomination ‘applies to an individual’s association with a local PCA congregation.’
An attempt to refer to the Commission’s interpretation of BCO 46-5 to a study committee failed; and the Assembly adopted the SJC report.”
(The History of the Presbyterian Church in America: The Silver Anniversary Edition, Dr. Frank Joseph Smith, pp. 409, 411, 426)
Exhibit C — 01/21/1994: Ruling Elder John White, of Westminster Presbyterian Church, authors the Reasoning and Opinion of the next PCA Standing Judicial Commission Case in the historical stream eventually continuing in Benyola’s 2022 Cases.
“On April 26, 1992, Dr. Chen wrote a letter to the Session of the Church of the Savior in response to a suggestion by a Ruling Elder (ROC p. 51). In this letter he stated that he and his wife did not intend to return to the Church of the Savior; that he and his wife were looking for another church; and that they were worshipping at evangelical churches every Sunday; but they had not yet found a church home. He further stated in said letter:
‘Be assured that we believe that active and committed local church membership is very important. So important, in fact, that thorough study is needed before a commitment can responsibly be made. This means we will not rush to transfer our membership.’ (ROC p. 51)
Dr. Chen then concludes with this paragraph:
‘If this creates a problem for you regarding what to do with our membership status, please declare us inactive as spelled out in CSPCA [local church] Bylaws, or simply remove our names from the rolls.’ (ROC p. 51) (Emphasis added)
We conclude that this request of Dr. Chen is analogous to the resignation letter of Carl Fox. We further conclude that it certainly meets one of the conditions set out in BCO 46-5, i.e. ‘when a member … has made it known that he or she has no intention of fulfilling the church vows.’ But instead of granting Dr. Chen’s request to ‘simply remove our names from the rolls’, the Session of the Church of the Savior instituted judicial process against them and on December 5, 1992 suspended them from the sacraments. We think the Session should have followed BCO 46-5 which states that under this condition ‘then the Session should delete such names from the church rolls …’ … Respondents thus ignore the plain language of the BCO and the judicial interpretation thereof by the 18th General Assembly in the Carl Fox matter.
… PCA is a voluntary association of people committed to a common faith and order. The BCO 25-11 explicitly expresses this voluntary principle as it applies to the association of a local church with the denomination:
25-11: ‘… Particular churches need to remain in association with any court of this body only so long as they themselves so desire. The relationship is voluntary, based upon mutual love and confidence, and is in no sense to be maintained by the exercise of any force or coercion whatsoever. A particular church may withdraw from any court of this body at any time for reason which seem to it sufficient.’
We believe this same voluntary principle applies to an individual’s association with a local PCA congregation. …
In the light of the above, our Judgment of the case is that Respondents erred; and we reverse the judgment of the Session of the Church of the Savior and remove the censure of Stuart and Pam Chen in suspending them from the Sacraments.
We urge the Session of the Church of the Savior to grant the Chens a letter of dismissal to an evangelical church, if they have requested the same, or, if not, to delete their names from the rolls under BCO 46-5.
Heard on August 19, 1993 and signed this 21st day of January, 1994.
Respectfully submitted,
/s/RE John B. White, Jr.
/§/ TE John Montgomery
/s/ RE W. Jack Williamson”
Takeaway: The Chen Case clarifies that a session should not weaponize process to punish what the BCO treats as a straightforward departure.
Exhibit D — Three years later, Robert C. Cannada and W. Jack Williamson, ruling elders and founding fathers of the PCA, again affirmed the spirit of the courts’ and congregations’ voluntary association in BCO 25-11 as appurtenant to emancipatory rights of individual members.
“The concept expressed in 25-11 of the BCO dealing with the relationship between a Presbytery and its members is also the concept applicable to the relationship between a congregation and its members and between the General Assembly and the presbyteries. This concept is expressed in 25-11 as follows:
‘Particular churches need remain in association with any court of this body only so long as they themselves so desire. The relationship is voluntary, based upon mutual love and confidence, and is in no sense to be maintained by the exercise of any force or coercion whatsoever.
A particular church may withdraw from any court of this body at any time for reasons which seem to it sufficient.’ (Emphasis added [by the authors, Cannada and Williamson])
Likewise, a member of a congregation may withdraw from membership or may be dismissed from membership by appropriate action of the session, and a presbytery may withdraw from the PCA or may be dismissed by the General Assembly. This is in accord with the concept contained in the eight basic principles as approved by the first General Assembly of the Presbyterian Church in America in 1789.”
(The Historic Polity of the PCA, Robert C. Cannada and W. Jack Williamson, p. 44)
In the same text, the same authors later asserted that a PCA church session, acting through its civil entity organized by state law, is subject to applicable civil laws of the state in the dismissal of members.
“Church courts should respect the decisions of other church courts. Lower church courts should comply with the applicable decisions of higher church courts subject to the ultimate guidance of the Scriptures and of Christian conscience.
Each presbytery and each session has the power, acting through the civil entity that each has formed and organized, to dismiss members from its membership for such reason as it determines to be appropriate subject to the applicable civil laws of the State.”
(ibid., p. 78)
Exhibit E — 02/04/2021: RE John White, at the SJC’s in-person Stated Meeting, concurs with the Reasoning and Opinion in the Complaint of Ms. Colleen Gendy v. Central Florida Presbytery (SJC 2019-13) — which in the SJC’s disposition, is explicitly founded on RE White’s very own Reasoning and Opinion in its preceding Case, 93-3. In Case 2019-13, Decision on Complaint, February 4, 2021 — a Case arising from the very same Session of St. Paul’s Presbyterian Church of Orlando (PCA), Inc. — the SJC declared on application of the BCO Rules of Discipline,
‘The circular nature of the Presbytery’s argument is obvious when it is considered from the Complainant’s perspective. The Complainant is being told that she cannot complain about her removal from membership because she has been removed from membership. Put differently, fundamental fairness requires that a member facing formal process or removal without process retains standing to complain about the process or removal. Any other conclusion would permit a Session to remove any church member from membership for any reason or no reason without allowing that person to challenge the removal. …
In addition to the wording of the provision itself, the history of BCO 38-4 illustrates this distinction. Following the SJC decision in the case of Chen vs. Ascension Presbytery, which interpreted a predecessor BCO provision dealing with removal of a member’s name from the roll to mean that a member of the PCA essentially had a right to withdraw from church membership unilaterally, the General Assembly adopted the current language in BCO 38-4, moving the section from BCO chapter 46 (‘Jurisdiction’) and to BCO chapter 38 (‘Cases Without Process’) and adding the statement that ‘This erasure is an act of pastoral discipline,’ thus emphasizing that the action is a true ‘case’ of discipline, not merely an administrative procedure. Therefore, if a Session may sever a person’s membership in the church, surely that person should have the right to complain about it. Ms. Gendy had standing to bring her Complaint. Presbytery should have so ruled and remanded the case to the St. Paul’s Session for consideration of Ms. Gendy’s original Complaint. Thus, we now remand the case to Presbytery so that it may take such action.”
Takeaway: The SJC rejects the “you can’t complain because you’re already removed” circularity — standing must remain to challenge the act.
A house of cards exists almost solely to test how tall it can become before the inevitable. Indeed, as Friedrich von Logau once articulated, “Though the mills of God grind slowly, yet they grind exceeding small; Though with patience He stands waiting, with exactness grinds He all.”
Perhaps put differently, it is the fate of glass to break.