Discipline in the Congregation

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Sources: Bibliographic data for works cited may be found at the end of the article. Unless otherwise indicated Scripture quotations are taken from the NASB Updated Edition (1995). Click here for Abbreviations of Bible Versions.

Terminology: In order to emphasize the Jewish nature of the apostolic writings and message I use the terms Yeshua (Jesus), Messiah (Christ), Tanakh (Old Testament), and Besekh (New Testament).

Legal Notice: This article is intended to provide accurate information on the subject matter covered. However, the reader understands that the author is not a lawyer and is not engaged in rendering legal or other professional service to any person, church, organization or entity.  Whenever an explanation or interpretation of the law or advice on legal alternatives is required, the services of a competent legal professional should be sought.

Introduction

The Biblical Mandate

"If he refuses to hear them, tell the congregation; and if he refuses to listen even to the congregation, treat him as you would a pagan or a tax-collector" (Matt 18:17 CJB).

"For what business do I have judging outsiders? Don’t you judge those who are inside? 13 But those who are outside, God judges. Put away the wicked fellow from among yourselves." (1Cor 5:12-13 TLV).

"Reject a factious man after a first and second warning" (Titus 3:10).

The third step of Yeshua's peacemaking plan in Matthew 18:15-19 reflects the increasing consequences for refusing to repent. The process began with the potential for reconciliation but ends with the loss of relationship with the community of faith. The sequence also began with a private confrontation and ends with a formal public decree of discipline. There are two serious mistakes to avoid in relation to discipline:

Misuse

"I wrote something to Messiah's community, but Diotrephes, who loves to be first among them, doesn't welcome us. 10 So if I do come, I will call attention to what he is doing—slandering us with wicked words. Not even content with that, he refuses to welcome the brethren, and even forbids those who want to do so—throwing them out of the community!" (3Jn 9-10 TLV).

Biblical discipline must not be associated with "legalistic" church courts and intolerance based on personal convictions. Discipline should never be used to get rid of opposition or function as an excuse for anger and hatred of others. True biblical discipline is based on the legal principles of Torah.

Nonuse

"It is actually reported that there is immorality among you, and immorality of such a kind as does not exist even among the Gentiles, that someone has his father's wife. You have become arrogant and have not mourned instead, so that the one who had done this deed would be removed from your midst" (1Cor. 5:1-2; cf. Rev. 2:20).

Many congregations do not practice any form of discipline, whether from a misguided theology of love, ignorance of God's requirements, fear of the consequences or the offender leaves before discipline can be initiated. Nevertheless, failure to discipline is tantamount to toleration of sin and by biblical standards makes the congregation an accessory to evil. Lack of discipline will adversely affect evangelism and neutralize the influence of the integrity and standards of the Body of Messiah.

The Rationale for Discipline

The Holiness of God

The instructions of the Lord and the apostles on discipline have their roots in the Torah. God is adamant that disobedience to His commandments must not be tolerated in the community of faith, and that offenders must be removed "from their people." (See Exodus 12:15, 19; 30:33, 38; 31:14; Leviticus 7:20f, 25, 27; 17:3-4, 9, 14; 22:3; 18:29; 19:8; 20:5, 17f; 23:29; Numbers 9:13; 15:30-31; 19:13, 20; Deuteronomy 13:5; 17:7, 12; 19:13, 19.)

Ignoring sin would be equivalent to committing the crime of misprision (cf. Lev 5:1; 1Cor 5:2). Misprision is a legal term that may denote either: (1) a contempt against the sovereign; (2) neglect in the performance of official duty; or (3) neglect to prevent the commission of a crime, or having knowledge of its commission, to fail to reveal it to the proper authorities (Black 902).

Very early in the book of Acts God gave the clearest demonstration of how seriously He regards sinning by disciples. In Ananias & Sapphira v. Holy Spirit the Court of Heaven ruled against the defendants for conspiracy, contempt and perjury in lying to the apostles about a charitable contribution and permanently excommunicated the defendants from the congregation (Acts 5:1-11).

The Nature of Families

Discipline is the natural order of things in God's family as it is written, "It is for discipline that you endure; God deals with you as with sons; for what son is there whom his father does not discipline? But if you are without discipline, of which all have become partakers, then you are illegitimate children and not sons" (Heb 12:7-8).

The Hope for Change

Yeshua's instruction in Matthew 5:24; 18:15 and Luke 17:3 emphasizes that the purpose of discipline implicit in the commandments is to achieve repentance of sin and to bring about reconciliation between brothers. In fact, sin must be confronted for change to occur. Discipline ultimately occurs because of the unwillingness to repent, not because of the specific sinful act.

The Reputation of the Congregation

The Lord intends that His people be a light to the world (Matt 5:14-16) and, thus, must be blameless in its reputation (Php 2:15; 1Tim 3:7). If restorative efforts with a sinning member fail, then the congregation must maintain its integrity and witness by treating the offender as an unbeliever and revoke membership privileges. Apostolic teaching and example clearly demonstrate the necessity of the congregation following the Lord's commands regarding discipline (cf. 1Cor 5:11-13; Titus 3:10; 1Pet 4:15-17; 1Jn 5:16; 2Jn 1:9-11; 3Jn 1:9-10).

Preparing for the Future

Current Discipline Action

If a discipline action is currently in process, do not change the constitution, congregation procedures, or other courses of conduct unless they are totally inappropriate according to the other suggestions contained in this article.

If anything were to be changed, be sure to follow the approved steps and requirements scrupulously. Many times the form may not need to be changed if the substance can be changed by a turn in direction, purpose, or attitude of those administering the discipline.

If a lawsuit is filed against the congregation, seek an out-of-court settlement or other non-adversarial means of resolving the conflict, particularly mediation or arbitration through faith-based intermediaries.

Congregational Commitment

Congregations must address two objectives when adopting discipline procedures.

● The first objective is to obtain the commitment of current members. The most obvious way to achieve this objective is for current congregation members to sign or agree to a covenant between each other agreeing to both refraining from lawsuits against each other and submitting to discipline procedures.

● The second objective is to inform new members of their rights and obligations when they join the congregation. To achieve the second objective requires acquainting those seeking membership with the constitution or bylaws, including discipline provisions. Inform them that official membership includes the expectation to be bound by the terms of the constitution or bylaws and secure the agreement of the new members as they join.

Teach the Congregation

Members need to understand the purposes and procedures of biblical conflict resolution and discipline, and why they are a necessary part of discipleship. As it is written in Romans 15:14, "And concerning you, my brethren, I myself also am convinced that you yourselves are full of goodness, filled with all knowledge and able also to admonish one another." Each believer can be part of God's process of perfecting all the saints.

Relevant Legal History

Relevant Court Cases

Watson v. Jones (1871): the U.S. Supreme Court ruled that all who unite themselves to a congregational body do so with an implied consent to its government and are bound to submit to it (Hammar 646).

Bouldin v. Alexander (1872): the U.S. Supreme Court ruled that courts will not go into reasons for excommunication of members, but will determine if ouster was an act of the congregation or merely persons purporting to have authority to act for the congregation (Esbeck 1).

Serbian Eastern Orthodox Diocese v. Milivojevich (1976): the U.S. Supreme Court ruled that civil courts may not probe into congregational polity or discipline of clerics (Esbeck 9).

Konkel v. Metropolitan Baptist Church (Arizona, 1977): the court ruled in favor of a member who had been expelled because the congregation did not follow its own bylaws and rules (Hammar 360).

Paul v. Watchtower Bible & Tract Society (1987): the 9th Circuit Court of Appeals ruled that a dismissed member of the Jehovah's Witness society could not sue her former congregation for emotional distress, defamation, and invasion of privacy that it allegedly caused by "shunning" her. The action of the congregation was passive; therefore, no tort occurred (Hammar 366-371).

Guinn v. Church of Christ (Oklahoma, 1989): the Oklahoma Supreme Court ruled in favor of Ms. Guinn because of continued discipline actions undertaken by the church elders after Ms. Guinn's notification to the church of her withdrawal from church fellowship (Hammar 366-374).

Procedures

Legal Safeguards

Rights of Voluntary Association

Implicit in the freedoms of religion and assembly guaranteed by the First Amendment of the U.S. Constitution is the right of voluntary association and courts have recognized the right of associations created for religious purposes (i.e., congregations) to conduct discipline proceedings against their members. However, a congregation may still be sued for civil torts, such as defamation, invasion of privacy, breach of trust, breach of priest-penitent privilege and breach of confidentiality. In order to avoid these pitfalls lawyers suggest the following steps for reducing the chances of being sued for exercising discipline. (Laney 76. Also, Hammar 371-374; Buzzard and Brandon 236-248.)

Written Procedures

If there is currently an informal process in place, formalize it. If there are no written procedures, then appoint a committee to research the subject and recommend a policy for approval. Spell out completely in your congregational constitution or bylaws your beliefs regarding discipline, including the scriptural and theological basis (Matt 18:15-20; 1Cor 5:1-13; Gal 6:1; 2Th 3:14-15; 1Tim 5:19-21; Titus 3:10-11) and the process that will be conducted. Bringing members under the authority of Scripture regarding conduct and discipline establishes the religious basis for civil courts upholding congregational actions. Avoid "legalese," i.e., using terms like "court," "due process," "rights," etc, which have no legal relevance and may confuse members about the process. (See the Model Discipline Procedures, which may be adapted for local use.)

Non-Suit Clause

Include in the constitution or bylaws an agreement by the members to not file a lawsuit against the pastor, lay leaders, paid staff or officers of the congregation in connection with the performance of their official duties with the justification based on 1 Corinthians 6:1-8.

Formal Membership

If there is no formal membership then the congregation may have difficulty convincing a court that persons being disciplined had in fact voluntarily joined the congregation and accepted the congregation's authority. If there are no current procedures, then the congregation needs to establish the procedure for joining the congregation and set forth the privileges and rights of membership, including voting in congregational meetings and holding office, as well as the duties of membership, such as support of the ministry and submission to pastoral authority.

Consistent Application

The congregation must be committed to applying discipline consistently, regardless of the sin, and without favoritism regardless of the member. When discipline is necessary, follow the written procedures to the letter. Plaintiffs have been successful when there were no long-standing custom or written procedures for handling discipline or defendants did not following existing procedures. Strict adherence will lessen the effectiveness of charges of partiality, prejudice or intentional infliction of emotional distress.

Notice

Any procedure of discipline should provide for clear and timely notice to the accused of discipline hearings, preferably by registered or certified mail to have a record of receipt. The notice should inform the accused of the nature of the complaint and the date and time of the hearing, preferably not less than ten days from the date of the notice. In addition, the notification requirements for holding official meetings as specified in the bylaws should be followed for holding congregational meetings for discipline purposes, unless there is an emergency reason for divergence from the rule. (See the Model Forms for Congregation Discipline.)

Discreet Administration

To whom should the sin be revealed or confessed? The logical answer consistent with the biblical pattern is that the sin be confessed only to those who know about it. Privileged information disclosed to congregational leaders must not be further disclosed to others. Respect the privacy of the one being disciplined. Public statements should be carefully worded to avoid exposing privileged information, including naming the specific sin. If it is a publicly known sin, then the entire congregation (the official membership) should hear the confession. Otherwise, the circle of confession should not be any larger than those affected and those charged with helping restore the sinner.

In any disclosure of sin to the congregation, the pastor needs to ensure that those hearing the report are within the "community of interest." This generally includes at least the adult members of the congregation. If the meeting is conducted after a worship service all visitors, permanent nonmembers, and suspended members should be requested to leave and, if necessary, escorted out of the meeting. The congregation may place any other restriction it desires upon those who will be in the meeting, such as including only those who have been a part of discipling and disciplining the accused.

Don't pass on the results of the discipline action outside the official membership of the congregation, unless the offense involved the commission of a felony or abuse of a minor or mentally incompetent person. When another congregation requests a transfer of membership, the congregation only needs to say "John Doe did not leave our congregation in good standing as a result of a discipline proceeding, and we cannot recommend him for membership in your congregation." For a criminal or other egregious offense as already mentioned, the transfer notice should state the offense for which the member was separated to preclude any potential liability a receiving congregation might incur through employment or involvement of the offender with children's or youth programs. If a minister's ordination credentials are revoked, limit notification to those that have a need to know, such as ministerial leadership within the denominational or association framework.

Relevant Information

The congregation needs to avoid the revelation of past acts that have no bearing on the present situation. The discipline process should be close in time to the sin in order to fully protect the privileged nature of the discipline and any disclosure. It would be permissible to declare past offenses only in showing the habit pattern of the accused and to better inform the congregation of what needs to be changed in the life of the sinner in order to be restored.

Process of Congregational Discipline

The instruction of Matthew 18:17 consists of two parts: (1) an appeal from the congregation to repent, and (2) a determination of appropriate discipline and/or the status of membership.

Last Appeal

Biblical instructions provide for confronting and rebuking a believer who has sinned by breaking the commandments of God. As with the confrontation by the complainant in Matthew 18:15 and the witnesses in Matthew 18:16, the confrontation by the congregation, or more properly, the leadership of the congregation (2Tim 4:2; Titus 1:13; Rev 3:19), should be restricted to describing the exact nature of the offense, the evidence that substantiates the accusation of the offense and an appeal to the accused for remedial action to avert some form of punitive discipline.

The appeal from the congregation may be in person, such as in a meeting of the congregational membership, the pastor and elders making an appointment to visit the accused or inviting the accused to meet with congregation leadership (1Tim 5:20). The appeal may also be in writing, as exemplified by the apostles who used letters to admonish unacceptable behavior, appeal for repentance and exhort a return to godliness (Rom 15:15; 1Cor 5:9, 11; 2Cor 2:3f, 9; 5:20; 7:12; Heb 13:22; 3Jn 1:9). In particular, Paul wrote such letters of appeal to the congregations at Galatia and Corinth and Yeshua wrote letters of appeal via John to Ephesus, Pergamum, Thyatira, Sardis and Laodicea (Rev 1:11). A letter of appeal needs to be written with great care, following the apostolic example of sorrow and compassion, yet with directness and firmness, and sent by certified or registered mail.

Disciplinary Hearing

If the appeal from the congregation does not yield repentance, then the congregation must complete the instruction of Yeshua and expedite an appropriate hearing to determine the form of discipline to be imposed, including the status of membership in the congregation. See instructions below on conducting disciplinary hearings.

Conducting Discipline Hearings

Congregational leadership needs to ensure that the disciplinary process conforms to biblical principles of justice as well as commonly expected legal principles of due process. See the procedural guidelines in the Model Discipline Procedures.

Impartiality

God does not show favoritism, and He expects people to do the same (Ex 23:3, 6; Lev 19:15, 33-34; Deut 24:17). The accused should have the assurance that the members of the discipline panel will not prejudge the case, but wait until all the evidence has been presented.

Orderliness

Insults, threats, quarreling and any other kind of negative communication should not be allowed during the hearing. The meeting should be conducted with all the seriousness, dignity and decorum required for the occasion.

Disciplinary Hearing

The agenda of a disciplinary hearing should generally follow this outline.

● Introduction – review ground rules, read Scripture, pray, etc.

● Presentation by complainant and witnesses. The complainant presents the case or claim in brief and offers documentary evidence or testimony by witnesses. No interruptions are allowed.

● Rebuttal by accused. The accused is granted equal time and if he denies the charge he may offer his defense and cross-examine the complainant and witnesses.

● Summation by complainant and accused, if necessary, granting the two sides equal time.

● Closing. The moderator of the disciplinary panel makes a formal declaration of the closing of the hearing. The disciplinary panel may recess to discuss their verdict and then reconvene to issue the verdict. The panel's verdict should be unanimous and either acquit the accused or find the accused guilty and specify the appropriate form of discipline.

Evidence

The complainant and the accused should be permitted to offer any factual evidence that they consider relevant to the charge. In addition, both parties may be required to produce any evidence requested by the disciplinary panel. Conformity to legal rules of evidence is not necessary. A discipline panel needs to remember that without a confession God requires the testimony of at least two witnesses to convict someone of wrongdoing (Num 35:30; Matt 18:16; 2Cor 13:1; 1Tim 5:19). Assumptions and feelings do not constitute evidence. Those overseeing discipline need to be watchful for the malicious witness (Deut 19:16-20; Matt 26:60). Doing justice means requiring allegations of wrongdoing to be demonstrated with evidence and believing the best of a person until proven otherwise (1Cor 2:11; 13:4-7).

Forms of Punitive Discipline

There is considerable difference of interpretation within the Body of Messiah as to the meaning of the phrase "let him be to you as a Gentile and a tax collector" in Matthew 18:17. The mention of both "Gentile" and "tax collector" means that the tax collector was a Jew, like Matthew and Zacchaeus. The mention of "Gentile" alludes to the layout of the Jerusalem Temple. The Temple grounds were enclosed by a barrier, and at the entrances to it were warning notices forbidding entry by any uncircumcised person on pain of death. Inside the barrier courts were identified by those permitted to enter with increasing restricted access (Court of the Women, Court of the Israelites and then the Court of the Priests). Anyone was allowed to enter the area outside the barrier, euphemistically called the Court of the Gentiles. The Jewish tax collector faced the same restriction at the Temple, but he was also barred from attending synagogue services.

At the very least the Lord's instruction describes a change in status. It does not necessarily mean denying the person the privilege of attending public worship services since even Gentiles and Jewish tax collectors were permitted to pray in the Court of Gentiles. The practical application of changing the offender's status may occur in one or all of the following ways.

Denial of Eucharist Privileges

Perhaps the simplest change of status is described in the Book of Common Prayer, which contains the administration of the sacraments and other ceremonies of the Episcopal Church:

"If the priest knows that a person who is living a notoriously evil life intends to come to Communion, the priest shall speak to that person privately, and tell him that he may not come to the Holy Table until he has given clear proof of repentance and amendment of life.

"When the priest sees that there is hatred between members of the congregation, he shall speak privately to each of them, telling them that they may not receive Communion until they have forgiven each other. And if the person or persons on one side truly forgive the others and desire and promise to make up for their faults, but those on the other side refuse to forgive, the priest shall allow those who are penitent to come to Communion, but not those who are stubborn.

"In all such cases, the priest is required to notify the bishop, within fourteen days at the most, giving the reasons for refusing Communion." (409)

Suspension

Suspension consists of temporary or permanent surrender of rights to serve as an officer or ministry leader in the congregation, and to vote in congregational meetings. Even after suspension the offender is not to be treated as an enemy but admonished as a brother and shown the compassion of Yeshua. If the offender is willing to seek restoration, then the suspension will include a plan, as approved by the pastor or rabbi and the congregation's governing board, for discipling the offender during the period of suspension in order to prepare him for full restoration.

Separation

It is right and in harmony with the Scriptures for the congregation to declare an unrepentant member to be an unbeliever and exclude him or her from continued fellowship or membership in the local congregation (1Cor 5:13; Titus 3:10; Heb 10:26-31). Formal separation may occur if the offender fails to respond in repentance to suspension or may be enacted without prior corrective steps if the offense is of a sufficiently serious nature. Under special circumstances the pastor or congregation board may seek an injunction from the court of jurisdiction to forbid the separated offender from entering the congregation's property.

Responding to Withdrawal

"Demas, having loved this present world, has deserted me" (2Tim 4:10).

"They went out from us, but they were not really of us; for if they had been of us, they would have remained with us" (1Jn 2:19).

Legal Considerations

Those who withdraw after the commencement of discipline may be acting out the familiar emancipation of an employee anticipating termination – "You can't fire me – I quit!" Just what can a congregation do about it legally and does the withdrawal have any effect on the discipline process?

Withdrawal by a member during the course of discipline may pose a dilemma for the congregation as to whether to formally recognize the withdrawal. Some congregation bylaws may not even address the issue in the context of discipline and many congregations would likely breathe a sigh of relief that the problem was taken out of their hands. However, the discipline process once started needs to be completed. Hammar recommends that the congregation bylaws contain a provision prohibiting a member from withdrawal while discipline is being actively conducted (372).

Relying on the constitutional right of voluntary association, the Oklahoma Supreme Court ruled in the Guinn v. Church of Christ case that a member of a voluntary association may unilaterally withdraw or resign at any time, including a member being disciplined (Buzzard and Brandon 190, 198). Buzzard and Brandon also cite the ruling in Church v. Gibson (Delaware, 1941) that stated, "It is incontestable so far as the individual defendants are concerned. Their right, individually or collectively, to withdraw themselves from the Parent Church is protected to the fullest extent by the Constitution of this State." The authors note similar decisions from Illinois, Michigan, Louisiana, West Virginia and New York.

The Court also took strong exception to the church's unwillingness to recognize Ms. Guinn's written notification of withdrawal and affirmed that a congregation is not immune to tort liability for acts committed after receipt of such notice. Thus, the bylaws provision Hammar proposes would be difficult to enforce in a practical sense and the congregation may have to prove in court that the member had waived the right to withdraw. Moreover, it seems contradictory for a congregation to claim the legal benefits of a voluntary association and yet deny one of those benefits to its members (Buzzard and Brandon 190, 199). The authors cite several cases where the courts have ruled against associations that created similar rules to deny or reject attempted resignations either by affirmative rejection or refusal to act on a letter of resignation.

Conversely, even if the offender withdraws from the congregation, there does not appear to be any legal impediment to the congregation completing its own procedures for removing a person from membership, imposing specific conditions for restoration or seeking other remedies provided by law. While a congregation should be cautious about publicizing private facts about the offender after the withdrawal, the congregation still has a duty and the right to inform its members of the results of discipline and request prayer for the offender.

The congregation's discipline procedures should direct the accused to clearly communicate to the congregation any intention to withdraw from membership and specify that with or without notice the discipline process can continue in absentia. The procedures should also state that if a member withdraws from membership after a discipline process has commenced, then the congregation will notify any other congregation seeking a letter of transfer that the member did not leave in good standing. (See Rule 29 of the Model Discipline Procedures.)

Pastoral Considerations

Perhaps nothing is more emotionally painful than divorce, even divorce between believers. It is a natural response to want to pursue the one leaving. In marital crisis pursuit rarely works to win back the spouse who flees the marriage. (See my resource My Mate Wants a Divorce ~ What Do I Do? Yet, isn't there a biblical obligation to go after erring brothers to bring them back to the fellowship?

The parable of the Shepherd who seeks the lost sheep (Matt. 18:12-14; cf. Luke 15:4-7) serves as an important illustration of the Lord's mission to seek and save the lost (Luke 19:10). Surely, pursuing a member who flees the congregation when faced with discipline would fit within the Lord's overall mission, regardless of prior court decisions. Ken Sande supports "pursuit" without further definition, but he intends that such pursuit should be done with the greatest love, tact and care shown for the offender in the spirit of Messiah (59f).

In the view of this writer such pursuit needs to be carefully defined and limited in length of time. Aggressive pursuit is not biblically required, and in some cases continued association with the sinning member is actually prohibited (cf. 1Cor 5:11). In fact, judicious shunning or avoidance may do more to motivate repentance than pursuit (cf. 2Cor 2:5-8). Much, of course, depends on the prior relationship of the accused with other members of the congregation and the nature of the charges. A congregation should keep lines of communication open in case God does prevail on the errant member to repent at some point in the future. Members must especially guard against any form of gossip or open criticism about the offender, because it will surely reach his ears and the door to reconciliation will certainly close. If there be any impediment to restoration and reconciliation let it be on the side of the former member and not the congregation.

Biblical and Theological Considerations

● Covenant and Free Will. In the apostolic era there was no essential difference between expelling a member from the Body of Messiah and expelling a member from a particular assembly of believers. The only reason the distinction matters today derives from the legal status given to congregations. Nevertheless, the theological relationship between God and His people is one of covenant. Thus, if one can't withdraw from the Body of Messiah (or its local expression), then man has no free will (cf. Josh 24:15); and if God can't remove individuals from the Body of Messiah for rebellion, then He has no free will (cf. Matt 20:15; John 15:6). A true covenantal relationship requires the free choice of both sides.

● Silence on Pursuit. The biblical law imposed by Yeshua in Matthew 18:15-19 speaks of an expeditious though deliberate process and summary judgment in changing the member's status upon failure of the offender to repent, but there is no mention of continuing to pursue the offender. In the parable of the unforgiving servant (Matt 18:23-35) other servants noticed the churlish response to the request for debt forgiveness and reported the matter to the king (v. 31). It was the king (a symbol of God) rather than the fellow servants who took immediate action to deal with the offender's unforgiveness. It may be that the most important thing congregational leaders can do for a withdrawing member is earnest intercession. When Judas departed from Yeshua to betray Him (John 13:21-30), there was no effort to restrain Judas or to send someone to prevent the betrayal. Demas deserted Paul (2Tim 4:10), and though there is no mention of any proposed discipline action, neither did Paul ask for anyone to pursue him.

● Waiting for Repentance. In the parable of the prodigal son (Luke 15:11-24), the father (who is generally recognized as symbolizing God) did not pursue the son, but patiently waited for the son to come to his senses and return of his own volition. The declaration of the father than his son had been "found" could only refer to a pursuit by God, which explains the intent of Yeshua's parable of the shepherd who pursues the lost sheep (Luke 15:3-6).

● Limited Appeal. Biblical teaching and practice emphasize repeated efforts to seek and save the lost (meaning the unsaved), but Scripture is equally clear in limiting the amount of effort expended in trying to gain the repentance of a member who has the knowledge of God and willfully sins. (See Matthew 10:6, 12-14; 18:17; 1 Corinthians 5:3-5, 11-13; 7:15; 2 Corinthians 13:1-2; 2 Thessalonians 3:11-15; 2 Timothy 2:12; 3:5; 4:10; Titus 3:10.) Perhaps the most extreme example of limited appeal is in the parable of the rich man and Lazarus (Luke 16:19-31). The rich man in Hades appeals to Heaven to send Lazarus back from the dead to warn the rich man's brothers, but Abraham replies, "They have Moses and the Prophets; let them hear them" (Luke 16:29). There is clearly a higher standard expected of members who know God's standards (cf. Heb 10:26-31).

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Works Cited

Black: Black, Henry Campbell. Black's Law Dictionary, 5th ed. West Publishing Co, 1979.

BCP: The Book of Common Prayer. New York: The Seabury Press, 1979.

Buzzard and Brandon: Buzzard, Lynn R. and Thomas S. Brandon. Church Discipline And The Courts. Tyndale House Publishers, 1987.

Esbeck: Esbeck, Carl. U.S. Supreme Court Decisions Relating to Religious Liberty. Private paper, 1995.

Hammar: Hammar, Richard. Pastor, Church & Law, 2nd ed. Christian Ministry Resources, 1991.

Laney: Laney, J. Carl. "Church Discipline Without a Lawsuit," Christianity Today, November 9, 1984.

Sande: Sande, Ken. Managing Conflict in Your Church Seminar. Institute for Christian Conciliation, 1993.

Other Resources

Lynn Buzzard & Laury Eck, Tell It To The Church. Tyndale House Pub., 1985.

John Eidsmoe, The Christian Legal Advisor. Baker Pub., 1987.

Kenneth O. Gangel & Samuel Canine, Communication and Conflict Management In Churches and Christian Organizations. Wipf & Stock Publishers, 2002.

Hugh F. Halverstadt, Managing Church Conflict. Westminster John Knox Press, 1991.

Marlin Jeschke, Discipling The Brother. Herald Press, 1979.

David Kale and Mel McCullough, Managing Conflict in the Church. Beacon Hill Press, 2003.

Carl F. Lansing, Legal Defense Handbook: For Christians in Ministry. NAVPRESS, 1992.

Cynthia S. Mazur & Ronald K. Bullis, Legal Guide for Day-To-Day Church Matters : A Handbook for Pastors and Church Members. Rev. ed. Pilgrim Press, 2003.

John MacArthur, Jr., The Elements of Church Discipline. Word of Grace Communications, 1984.

Ken Sande, The Peacemaker: A Biblical Guide to Resolving Personal Conflict. 3rd ed. Baker Book House, 2004.

Mary A. Shaughnessy, Ministry and the Law: What You Need to Know. Paulist Press, 1998.

Thomas F. Taylor, Seven Deadly Lawsuits: How Ministers Can Avoid Litigation and Regulation. Abingdon Press, 1996.

Copyright © 2003 and 2013 by Blaine Robison. All rights reserved.