Obviously We’ve Got Them Worried Now: Bishop Stacy Saul’s Memorandum On the Illegal Depsoitions

MEMORANDUM
May 27, 2008
To: House of Bishops
From: Task Force on Property Disputes
Re: Proper Use of Abandonment Procedures for Bishops
Subsequent to our meeting at Camp Allen, some Bishops of The Episcopal
Church1 and some commentators2 have suggested that we may have failed to follow our
own rules for giving consent to the deposition of a Bishop for abandoning the
communion of this Church. A careful analysis and examination of the canon law,
however, confirms that consent to deposition was procedurally appropriate, as the
House’s Parliamentarian ruled and the Presiding Bishop’s Chancellor has advised.3
This memorandum is intended to provide the Members of the House with
necessary legal background and the reasoning supporting that conclusion for the
assurance of the Members as to past actions and in advance of their consideration of any
additional such actions in the future.
Conclusion
The House of Bishops followed the proper canonical procedure for consenting to
the depositions of John-David Schofield and William J. Cox from the Ministry of The
Episcopal Church as provided in Canon IV.9 of the Constitution and Canons of The
Episcopal Church (2006) for the following reasons:
A. The intended meaning of Section 2 of Canon IV.9 of the Constitution and Canons
of The Episcopal Church (2006) is that the consent of a majority of the Bishops
voting at a meeting of the House of Bishops constitutes valid consent for the
deposition of a Bishop.

B. Precedent establishes that the House of Bishops acted appropriately in
considering and acting upon the Presiding Bishop’s referral to it of the
abandonment of communion certified to her by the Review Committee.
C. Procedural safeguards assure fairness and justice in the case of Bishops accused
of having abandoned the Communion of this Church.
Background
The House of Bishops met for its annual, and duly noticed, spring meeting at
Camp Allen, Navasota, Texas on March 7-12, 2008. As is its custom, the House
scheduled a business session during that meeting. Members were notified in advance of
the business session that the certification of the abandonment of the communion of this
Church by the Rt. Rev. John-David Schofield, Bishop of San Joaquin, and the Rt. Rev.
William J. Cox, Bishop Suffragan of Maryland, Res., would be considered. The business
session was held, as planned, on March 12, at which time the subject of consent to
deposition was before the House. With respect to each Bishop, a voice vote was taken,
which was not unanimous and included abstentions but which clearly indicated majority
consent to the depositions of Bishops Schofield and Cox by a wide margin in each case.
Presiding Bishop Katharine Jefferts Schori, as required by Section 2 of Canon IV.9, has
since deposed both from the Ministry of The Episcopal Church.4
Reasoning
A. The intended meaning of Section 2 of Canon IV.9 of the Constitution and Canons
of The Episcopal Church (2006) is that the consent of a majority of the Bishops
voting at a meeting of the House of Bishops constitutes valid consent for the
deposition of a Bishop.

The procedure for deposing a Bishop of The Episcopal Church for abandonment of
the communion of this Church requires, upon certification of the abandonment by the
Review Committee, that the Presiding Bishop “present the matter to the House of
Bishops at the next regular or special meeting of the House.” The Canon goes on to
provide in its next sentence:
If the House, by a majority of the whole number of Bishops entitled to
vote, shall give its consent, the Presiding Bishop shall depose the Bishop
from the Ministry, and pronounce and record in the presence of two or
more Bishops that the Bishop has been so deposed.
The current language of the Canon has evolved over time, and some understanding of
that evolution is necessary to understand the meaning of the Canon’s current language.
The abandonment Canon (currently numbered IV.9) was originally enacted in 1853,
and pertinently amended in 1859, 1874, and 1904.5 It has consistently provided for
Bishops found to have abandoned the communion of this Church, with required consent,
to be deposed by the Presiding Bishop. It is the giving of that consent that is primarily at
issue now.
The method and requirements for giving consent have evolved over the Canon’s 165
year history, as follows:
· 1853: “with the consent of the majority of the Members of the House of
Bishops.”6
· 1859: “with the consent of a majority of the House of Bishops.”7
· 1874: “a majority of the whole number of Bishops entitled at the time to seats in
the House of Bishops” at a duly convened meeting of the House.8

· 1904: the consent of the House as determined by a majority of the Members
entitled to vote at that meeting (not entitled to vote whether or not present)13
The interpretation of the 1904 language is governed by five considerations: (1) the
issue of who gives consent, (2) canonical context, (3) evolutionary context, (4) analogous
provisions, and (5) the actual purpose of the word whole in Canon IV.9.
(1) The Issue of who Gives Consent
The 1904 amendment replaced the consent of the Members acting individually with
the consent of the body itself. This is a significant difference with practical implications.
The election of Bishops, for example, requires the consent of certain individual Members
(those Bishops having jurisdiction) and not the consent of the House of Bishops
expressed in a vote thereof, even when the consents are given during General
Convention.14 When the Members act individually, the majority is determined based on
the total number of individuals and not based on the number of those individuals present
at the meeting. On the other hand, when the House acts as a body, a majority is
determined based on the number of those eligible to vote who are present.15 In changing
who gives consent from the individual Members (1874) to the House itself (1904), a
difference in how a majority is to be determined was presumably intended. Otherwise,
there would be no practical difference between the 1874 language and the 1904 language.
Not only is there not clear intent to the contrary, on the whole, evidence of intent favors
the general rule as set forth in Canon V.3, as explained below.
(2) Canonical Context

It is noteworthy that the reference to “a majority of the whole number of Bishops
entitled to vote” in the current Canon immediately follows the requirement of a meeting
of the House and is specifically linked to the House itself and not to the individual
Members thereof. Therefore, the plainest reading in context is that it means “a majority
of the whole number of members entitled to vote” at that meeting.
(3) Evolutionary Context
In its evolutionary context, “the whole number of Bishops entitled to vote” (1904
language) must mean something different than “the whole number of Bishops entitled at
the time to seats in the House of Bishops” (1874). The 1904 amendment was enacted as
part of a process of comprehensive constitutional and canonical revision. One of those
revisions was making allowance for suffragan bishops,16 which were constitutionally
authorized for the first time in 1910 under Article II, Section 4 of the Constitution.17 The
contemporaneous constitutional revision of 1901 did not, however, extend the right to
vote in the House of Bishops to suffragan bishops. Thus, suffragan bishops were legally
entitled to seat and voice but not vote. In these circumstances, it was necessary to amend
the 1874 language of the abandonment Canon,18 which had set the standard for
determining abandonment based on the number of bishops entitled to seat rather than
those entitled to vote.
The operative phrase in the 1874 Canon for determining the standard for
determining abandonment, “a majority of the whole number of Bishops entitled at thetime to seats in the House of Bishops,” was altered with this change in mind in two
important ways. First, “to vote” replaced “to seats.” Indeed, before Suffragan Bishops
became entitled to vote in 1943,19 there were as many as 24 of them serving in the House
of Bishops at one time,20 which would have radically altered the standard for determining
abandonment were it not for the 1904 amendment.
The 1901 constitutional amendment also deprived bishops resigning for nonconstitutionally
specified grounds of both seat and vote, although the House itself,
through Rule XXV, makes it possible for those resigned Bishops, when moral reasons are
not involved in the resignation, to be granted seat and voice. House rules also make it
possible to seat honorary and collegial Members (Rule XXIV) as well as guests (Rule
XXVI). Guests with seat and voice, as opposed to honorary and collegial Members, are
not entitled to be present during Executive Session. Again, were it not for the 1904
amendment to the abandonment canon, the presence of these non-voting Members would
have an impact, potentially significant, in the determination of abandonment.
Second, and very significantly, the 1904 amendment revised the 1874 language in one
other crucial respect. The amended Canon omitted the important words “at the time”
from the operative phrase as used in 1874. Their omission in 1904 meant that the
standard for determining abandonment was not the whole number entitled at the time to
vote, thus not requiring that those entitled to vote but not present at the meeting be
counted as had been the case with respect to those entitled to a seat theretofore. It is a
change that makes sense given the 1904 amendment’s decision to vest the responsibility
for determining abandonment in the House as a body and not in the Bishops as
individuals.

In context, then, it is highly likely that the canonical drafters in 1904, in choosing
the language “whole number of Bishops entitled to vote,” did so with the primary
intention of correcting the 1874 language so as to provide for the new potential (and
actuality) of significant numbers of Members with seats but without vote and making the
finding of abandonment an action of the House as a body and not of the individual
bishops.
(4) Analogous Provisions
Similar canonical language and situations support interpreting the phrase “whole
number of Bishops entitled to vote” as meaning entitled to vote at that meeting. Canon
IV.9 itself uses the phrase “all the Members” with respect to the Review Committee
when it means a majority of the total number of Members and not the phrase “the whole
number of Members.” The constitutional provision for defining a quorum for a meeting
of the House of Bishops states: “A majority of all Bishops entitled to vote, exclusive of
Bishops who have resigned their jurisdiction or positions, shall be necessary to constitute
a quorum for the transaction of business.”21 Similarly, both Canons I.12.2 (regarding
Diocesan Standing Committees in some circumstances) and Canon V.3 (regarding bodies
of General Convention) successfully define quorums with reference to all Members
without using the word “whole” as an adjective even when using the word “whole” as a
noun to describe the total number of Members for purposes of giving notice. The use of
the word “whole” as an adjective is not necessary to define the set of Members necessary
for a quorum, and since it is unnecessary for that purpose, cannot be held to require such
an interpretation in Section 2 of Canon IV.9. Indeed, it has a different purpose therein.
(5) The Actual Purpose of the Word Whole in Canon IV.9

If the word whole in Section 2 of Canon IV.9 is not intended to refer to the total
number of Bishops entitled to vote whether or not present, what is its purpose? It would
be improper to interpret the Canon in a way that rendered the language chosen by the
1904 General Convention, in whole or in part, meaningless if doing so would be
unnecessary. It cannot be ignored that the General Convention, while making significant
changes in the definition of the consent requirement for deposition, chose to retain the
word whole. Again, however, the meaning of that word is completely consistent with the
interpretation of this memorandum. Indeed, the word whole has important application in
the Canon thus understood in that it requires counting abstaining Members present at the
meeting, for the purpose of determining what constitutes a majority at a meeting, thus
making failures to vote, or abstentions, have the same net effect as a negative vote, which
has the effect of making a majority more difficult to obtain than would otherwise be the
case. It is not difficult to posit a situation in which Members might express their
displeasure at a given Bishop’s conduct and at the same time refuse to consent to the
sanction of deposition by registering an abstention. Indeed, the 2008 votes included
several abstentions.
B. Precedent establishes that the House of Bishops acted appropriately in
considering and acting upon the Presiding Bishop’s referral to it of the
abandonment of communion certified to her by the Review Committee.
In recent history, the House of Bishops has taken similar action regarding two
Bishops, Donald Davies of Ft. Worth (1993) and Neptali Larrea of Ecuador Central
(2004). In both cases, the exact procedure followed with respect to John-David Schofield
and William Cox was used. Decisions were taken based on a majority vote of those
present at a meeting of the House of Bishops. Although the minutes of both meetings
leave much to be desired, it appears that 131 Bishops of the 276 total eligible to vote

attended the 1993 meeting and of that 143 Bishops of the over 300 total22 eligible to vote
attended the 2004 meeting. In neither case did a majority of those eligible to vote attend.
Very tellingly, no objection was made at all. Even more tellingly, no objection was made
at the time by either Schofield or Cox, or by any Bishop present at the time, which
included, in the case of Bishop Larrea, many current Members of the House. There is no
legitimate distinction to be made between the former cases and the present ones. Indeed,
a fundamental unfairness would arise were Bishops similarly situated as to the Review
Committee’s findings and certification treated differently. Impartial administration of the
Canons of The Episcopal Church requires recognizing the legitimacy of the present
depositions and not the contrary as some have argued.23
C. Procedural safeguards assure fairness and justice in the case of Bishops accused
of having abandoned the Communion of this Church.
Canon IV.9 provides several important safeguards to assure a fair and just
consideration of the cases bishops accused of abandoning the communion of this Church.
Those assurances of due process begin before deposition is even a remote possibility.
First, abandonment is carefully defined by Section 1 of the Canon. A Bishop may
abandon the communion in one of three ways:
(i) by an open renunciation of the Doctrine, Discipline, or Worship of this
Church, or (ii) by formal admission into any religious body not in
communion with the same, or (iii) by exercising episcopal acts in and for a
religious body other than this Church or another church in communion
with this Church, so as to extend to such body Holy Orders as this Church
holds them, or to administer on behalf of such religious body
Confirmation without the express consent and commission of the proper
authority in this Church.

The Review Committee, composed of five Bishop peers of the accused (a majority of the
Committee) along with two Priests and two confirmed adult lay communicants,24 must
first find by a majority vote of all its Members that at least one of the three circumstances
constituting abandonment is present and certify that fact to the Presiding Bishop.
Inhibition of a Bishop so certified is possible only with the consent of the “three senior
Bishops having jurisdiction in this Church.”
Even after the certification and, in some cases, inhibition, the certified Bishop has
two months to make a Verified written statement to the Presiding Bishop that the facts
alleged in the certification are false. If the Presiding Bishop finds that the statement is a
good faith retraction or denial, she or he may, with the consent of a majority of the three
senior Bishops, dissolve the inhibition and drop the matter. The Presiding Bishop’s
discretion is limited (in favor of the accused) by a standard of good faith, to which she or
he is canonically accountable. The accused is protected by the necessity of majority
consent in the House of Bishops, composed entirely of his or her peers to whom the
accused is presumably well known. The House has the right to initiate further
investigation, which indeed the accused might request. It should also be noted that a
Bishop accused of abandoning the communion of this Church can also avoid further
proceedings by renunciation pursuant either to Canon III.7.12 or Canon IV.8.
In the present cases all the procedural safeguards were followed. It is particularly
noteworthy that neither Bishop certified as having abandoned the communion at any
point whatsoever disputed the allegation of the abandonment as certified by the Review
Committee, renounced the actions, denied the actions in any way, requested a further
hearing, made any rebuttal, issued any defense, or contested the allegation whatsoever.
Nor did either do so despite having an affirmative canonical duty to do so to avoid

deposition.25 The fair opportunity to do so having been provided, but ignored, the right
must at this point be considered waived.
Finally, it must be noted that no Member of the House of Bishops, present or not
present, requested further action, investigation, or hearing as permitted under House
rules. No challenge was made to the Parliamentarian’s ruling on the meaning of Canon
IV.9. Similarly, no Member of the House of Bishops, as permitted by Rule XVII,
requested reconsideration of the House’s action. Again, no request having been made at
the time, the right to do so must now be considered waived.
Under the circumstances, then, the House can only conclude that a fair and lawful
procedure was followed, as provided by the Canon, and that the decision canonically
made stands as the legitimate judgment of the House.
1 “Diocese of South Carolina Protests Presiding Bishop’s failure to follow the Canons,” (Diocese of South
Carolina, 27 March 2008) http://www.dioceseofsc.org/mt/archives/000337.html.
2 See, e.g., George Conger, “Call for Review after Trial ‘Flouted Church Rules,’” Church of England
Newspaper, 28 March 2008, p. 5.
3 “House of Bishops’ Votes Valid, Chancellor Confirms,” (Episcopal News Service, 15 March 2008)
http://www.episcopalchurch.org/79901_95735_ENG_HTM.htm.

4 The Deposition of a Bishop (John David M. Schofield) dated March 12, 2008 and the Deposition of a
Bishop (William J. Cox) dated March 12, 2008, in both cases signed by the Most Rev. Katherine Jefferts
Schori and witnessed by the Rt. Rev. Richard S. Chang and the Rt. Rev. Kenneth L. Price, Jr.

5 Edwin Augustine White and Jackson A. Dykman, Annotated Constitution and Canons vol. 2 (1981 ed.)
(New York: Office of the General Convention, 1985) 1079-1082 (herewith cited as White and Dykman).
6 White and Dykman (n 5) 1079.
7 White and Dykman (n 5) 1080.
8 White and Dykman (n 5) 1081.

9 White and Dykman (n 5) 1082.
10 The canon was originally enacted in response to the decision of Bishop Levi S. Ives, Bishop of North
Carolina, to become a Roman Catholic in 1852.
11 The language of the amended Canon does not explicitly require a meeting, but does change the consent
required from that of the Members thereof to being that of the House itself. There seems to have been
some dispute, possibly relating to the change in language, over whether a meeting was required when the
Bishops were forced to consider the abandonment of Bishop George D. Cummins, the Assistant Bishop of
Kentucky, in order to found the Reformed Episcopal Church in 1873. Presiding Bishop Benjamin
Bosworth Smith (Bishop of Kentucky) obtained the consent of a majority of the total number of Bishops
without calling a meeting after which Bishop Smith deposed Cummins. Concern that the intention was to
require the action at a meeting of the House led the House, meeting at the General Convention of 1874, to
reaffirm the consent in the context of a meeting, and in October of 1874, Bishop Smith repeated the
deposition. [White and Dykman (n 5) 1081]. A logical argument can be made that the change from the
definite article the to the indefinite article a in the 1859 amendment together with the change to requiring
the consent of the House as such implied that a meeting was required and redefined the consent
requirement as meaning as given by a majority at a meeting.
12 The extraordinary requirement of a majority of the total number of Bishops entitled to a seat was likely a
reaction to the crisis of the Reformed Episcopal Church schism and confusion surrounding the deposition
of Cummins.

13 The 1904 languages was originally proposed to 1895 Convention by the Joint Commission on Revision
of the Constitution and Canons [General Convention, Journal of the General Convention of The Episcopal
Church, 1895 (General Convention, New York 1895) 679]. The report was taken up by the Convention in
sections, the abandonment canon being revised in 1904 [General Convention, Journal of the General
Convention of The Episcopal Church, 1904 (General Convention, New York 1904] 325-326, 598.
14 Cf. Canon III.11.3 (c) and (d).
15 Canon V.3.
16 The title “suffragan” had been previously but rarely used in TEC, but the so-called suffragan bishops
functioned as canonical “assistant” bishops.
17 White and Dykman (n 5) 62.
18 Although the office of Suffragan Bishop was not created constitutionally until after the 1904 amendment
to the abandonment canon (the creation of the office of suffragan having been passed on first reading in
1907, the next General convention, and on second reading in 1910), the creation of the office had long been
contemplated. It had been proposed as early as 1847, and gained serious interest for missionary reasons at
the General Convention of 1871 (the year after the Church of England began again appointing Suffragan
Bishops) and thereafter [White and Dykman (n 5) 60-62].

19 White and Dykman (n 5) 21.
20 The Episcopal Church Annual: 2008 (Harrisburg: Morehouse Publishing, 2006).

21 Constitution of The Episcopal Church, Art. I, Sec. 2 (2006).

22 The Episcopal Church Annual 2004 (Harrisburg, Pa.: Morehouse Publishing, 2004) 429-436.
23 “Western Louisiana Bishop: ‘Two Sets of Rules for One Church,’” The Living Church (17 April 2008)
http://www.livingchurch.org/news/newsupdates/2008/4/17/western_louisiana_bishop_two_sets_of_rules_
for_one_church.

24 Canon IV. 3.26.

25 White and Dykman (n 5) 1082.

18 Responses to “Obviously We’ve Got Them Worried Now: Bishop Stacy Saul’s Memorandum On the Illegal Depsoitions”


  1. 1 Matthew May 28, 2008 at 10:04 pm

    It must be correct. It has footnotes and everything. Yet more proof, if it were really needed, that all attorneys are not created equal.

    It’s not convincing and doesn’t really address the plain meaning of the words or the prior usage of similar terms, but it is probably enough for the party faithful to hang their mitres on.

  2. 3 robroy May 28, 2008 at 11:24 pm

    Well, I am convinced. The “majority of all bishops entitled to vote” clearly means “majority of all bishops entitled to vote, at that meeting.”

    Doesn’t it?

    Actually, Mr. Sauls is merely regurgitating an argument that a guy at Jake’s joint proposed and was summarily disposed of by the Anglican Curmudgeon. Add plagiarism to Mr. Saul’s sins.

  3. 4 Rick Arllen May 29, 2008 at 1:06 am

    This is pure, unadulterated bovine scatology. And, unfortunately, I have been acclimated to expect nothing less from +Sauls.

    “The floor of hell is paved with the skulls of bishops.” St. John Chrysostom

    May God have mercy on his soul.

  4. 5 Timothy Fountain May 29, 2008 at 1:45 am

    Just scrolling down this thing is like falling into a bottomless pit. This poor church. And I mean that. It has fallen a long, long way just in the couple’o decades I’ve been a priest.

    I don’t make fun of “lawyer bishops” – there have been fine bishops from all kinds of backgrounds. But this thing is a burlesque.

  5. 6 MikeS May 29, 2008 at 2:00 am

    Bp Sauls is positing that because it was done outside of the canonical requirements previously, it is ok to do so at this time?

    So how come that didn’t work for the consents of Mark Lawrence?

    Does the same logic work in a court of law? “Your honor, I’ve run that stop sign dozens of times and never got a ticket before now. Clearly that alone sets a precedent to toss this citation and any future citation I may receive at the same intersection. I should not have to face a penalty in this case.”

    Even though no one pointed out the previous errors, we are now allowed to set the errors into concrete?

    If this is the great legal argument that will be put forth, I can’t wait to see what new contortions the canons take after 2009. Everyone did what was right in their own eyes will look positively peaceful, God-honoring and non-chaotic.

  6. 7 JamesW May 29, 2008 at 2:14 am

    This reads like a tortured backwards rationalization engaging in ridiculous sophistry. It certainly is not a convincing legal argument about the legislative intent. His points are entirely unconvincing. He makes assumptions about changes in language that simply are not warranted, in a vain attempt to make similar language mean something different.

    But the true foolishness of this memo is that he is using legislative intent and precedent in the wrong way. Legislative intent is not intended to be a way of rationalization to defeat the plain meaning of a statute. And that is exactly what Sauls is attempting to do here. Further, you can’t cite past violation of a statute as precedent to break the law in the future.

    What a pathetic defence this is. Why not just say “yeah, we heard that we violated the canons. So what? What are you gonna do about it?” At least then they would have some intellectual credibility.

  7. 8 JWW May 29, 2008 at 3:33 am

    At least they are consistent in their perverted methods. They distort the plain meaning of the canons to their own ends in the same sick and tortured manner in which they twist the scriptures, traditions, and reason of the Church in subservience to the spirit of the age.

  8. 9 Pat Briney May 29, 2008 at 10:16 am

    “In context, then, it is highly likely that the canonical drafters in 1904, in choosing
    the language “whole number of Bishops entitled to vote,” did so with the primary
    intention of correcting the 1874 language so as to provide for the new potential (and
    actuality) of significant numbers of Members with seats but without vote and making the
    finding of abandonment an action of the House as a body and not of the individual
    bishops.”

    We should not be surprised that a Bishop of the Episcopal Church is capable of this specious rationalization when it comes to applying the Church’s Canons. They’ve had a lot of practice applying similar “reasoning” to remold God’s intentions to justify theirs.

  9. 10 robroy May 29, 2008 at 10:42 am

    The Episcopal denomination is blessed with many who are legally trained. This sad tale stinks to high heaven, especially to those with such training. It is very important to relate these legal shenanigans to our lawyer brothers and sisters. The Anglican Curmudgeon site, the ACI “presentment” document, the statements of Western La and other dioceses, etc., are good resources.

  10. 11 Canon Gregg L. Riley May 29, 2008 at 2:01 pm

    Obviously the good bishop of Lexington has nothing better to do with his time.

    Canon G+

  11. 12 Paul May 29, 2008 at 2:24 pm

    I missed that it was written by the property comittee

    Itis always interesting to see a “liberal” appealing to the original intent of the writers rather than take the living document approach. He could be better off switching his approach ie it is a living document and this is how we have interperted it for years (this is in essence the life we (past generations)have breathed into it). No one was attacked using special treatment in this case. Everyone would scream but the position is much harder to “logically” attack.

  12. 13 Randy Muller May 29, 2008 at 10:24 pm

    Maybe there is a reason why Sauls is a bishop now, instead of a lawyer.

  13. 14 Alice C. Linsley May 30, 2008 at 12:29 am

    Who is running Church House on the corner of Martin Luther King and 4th Street in Lexington? I see Canon Ross running in and out of the building and occasionally there’s a light in the bishop’s window.

  14. 15 Tom Dupree May 30, 2008 at 6:10 pm

    Poor Stacy. He just wants to seem important.

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