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Church Announces New Title IV Protocols for Bishops

Please email comments to letters@livingchurch.org.

By Kirk Petersen

Presiding Bishop Michael B. Curry has announced a set of modest but politically delicate changes to the church’s process for handing accusations against bishops. The changes come at a time when Curry himself faces a Title IV disciplinary case, and while he continues to be at least partly sidelined by serious medical issues.

Several high-profile accusations against bishops in the past year have raised concerns that bishops may be getting “a free pass on behavioral issues” in a process that is dominated by other bishops.

“Given the current atmosphere, I have chosen to exercise my canonical discretion to adopt a general protocol for transparency in Title IV matters involving Bishops,” Curry wrote, in a February 22 letter to the House of Bishops. Separately, a church commission is developing proposed changes to the canons for consideration at General Convention in June.

The new protocol has three elements:

  1. Creation of an easily accessible section of the Episcopal Church Center’s website, which is now available to the public, with general information about Title IV and information on how to make a complaint against a bishop;
  2. Posting procedural updates on Title IV matters involving bishops when “in [the presiding bishop’s] discretion, public disclosure of procedural progress is warranted”; and
  3. An annual report with statistical information about Title IV processes involving bishops.

The House of Bishops will convene February 27 for a weeklong period of bonding and reflection at Camp Allen in Navasota, Texas. Title IV undoubtedly will be a major topic of discussion — but it is unclear whether Curry will be physically present. Public Affairs Officer Amanda Skofstad declined to comment when asked if Curry would attend, and said she could not provide any update on his health.

Curry, 70, has been hospitalized at least five times in the past year, most recently for emergency brain surgery to relieve a subdural hematoma in early January. It was his third subdural hematoma surgery, with the others in December 2023 and in 2015. Curry is in the final months of his nine-year term as the spiritual and administrative leader of the Episcopal Church. His successor will be elected in June at General Convention in Louisville, Kentucky. He has been recuperating at his home in North Carolina.

Mary Kostel, chancellor to the presiding bishop, worked over the past several months with Curry and others to develop the new protocols. “Achieving the lofty goals of Title IV — promoting healing, repentance, forgiveness, restitution, justice, amendment of life, and reconciliation — tends to become more complex the more public a matter becomes,” Kostel said by email, “but Bishop Curry sees the pastoral wisdom in balancing confidentiality with the need for more transparency and greater trust in the system.”

The first statistical report covers the period spanning August 2023 to February 19, 2024, during which 34 separate formal complaints either were initially lodged against bishops or were continuing to be pursued. This involves fewer than 34 bishops, as some bishops face more than one complaint.

Most of the respondents in those cases are not identified, but the total includes six cases involving five bishops who are identified by name. Even in those cases, the website includes little or no information about the specifics of the allegations — only a list of steps that have been taken in the labyrinthine Title IV process.

Two cases involve the Rt. Rev. Prince Singh, the former Bishop of Rochester, who resigned as bishop provisional for two Michigan dioceses in September 2023, the day after being restricted from ordained ministry. One case is labeled “Abusive Behavior,” and clearly refers to allegations by Singh’s adult sons and ex-wife. The second, not previously reported, is labeled “Improper Behavior,” and was launched about a week after the first. The Rev. Johnnie Ross, who formerly was Singh’s canon to the ordinary in Rochester, told TLC by email that he is a complainant in the second case, but did not provide any details. Prince Singh did not respond to a request for comment.

Two cases involve the Rt. Rev. John Howard, the recently retired Bishop of Florida. One, filed in July 2023, regards allegations that Howard discriminated against LGBTQ clergy in the diocese. The second is labeled “Financial” and has not previously been reported. That complaint was filed in August, and TLC has been unable to determine the nature of the allegations. Howard did not respond to a request for comment. Through a spokesman, the Florida Standing Committee told TLC by email that the committee “is aware of the complaints against Bishop Howard. The Diocese will fully cooperate with the Title IV process.”

Bishop of Wyoming Paul-Gordon Chandler was placed on administrative leave in October 2023, after what the head of the Standing Committee described as “an alleged indiscretion with a member of our Diocesan team.” The new website says only that the case involves “allegations of misconduct.”

The final case involves “allegations of misconduct” lodged in December 2023 against Curry himself, as well as against the Rt. Rev. Todd Ousley, who formerly served as the intake officer for Title IV complaints against bishops. The website provides no specifics, but this case came to light in January after members of the Singh family accused the two bishops of “a pattern of habitual neglect of ministerial duties without good cause,” saying they failed to take timely action when allegations arose about Bishop Singh.

The vast majority of Title IV cases involve priests or deacons, and such cases initially are overseen by the appropriate diocesan bishop. Each of the more than 100 dioceses has its own infrastructure for processing cases involving priests or deacons, including a disciplinary board.

Unless an agreement can be reached among the parties, a Title IV case will go through four stages: intake officer, reference panel, conference panel, and hearing panel. Each successive stage takes on more of the trappings of a secular prosecution. The canons governing Title IV run to more than 23,000 words — longer than the Book of Deuteronomy. The church launched an extensive website several years ago to explain all the twists and turns of the process.

Each diocesan bishop designates an intake officer for the diocese. For complaints against bishops, the intake officer is the Rev. Barbara Kempf, who started in her newly created role in mid-2023. The full-time position was authorized by the 2022 General Convention to relieve Ousley of the workload associated with serving as intake officer. Ousley, who has headed the office of pastoral development since 2017, oversees pastoral guidance and training for all levels of ministry, as well as bishop search processes, among other things.

Intake officers are responsible for performing an initial inquiry to determine whether the allegations, if true, would constitute an offense against the canons “of clear and weighty importance.” Of the previously noted 34 cases against bishops, seven have been dismissed for failing to meet this test.

An additional nine bishop cases have been referred to a reference panel consisting of Kempf, Curry, and Bishop Chilton Knudsen, who heads the Disciplinary Board for Bishops. (A corresponding diocesan reference panel would include the diocesan intake officer, diocesan bishop, and head of the diocesan disciplinary board.) Reference panels have a variety of options, including ordering a formal investigation, working toward conciliation or other agreement among the parties, and referring the matter to the next stage, a conference panel. None of the nine cases have yet been sent to a conference panel.

The remaining 18 cases are still in the initial-inquiry stage, reflecting a backlog that began developing before Kempf was hired.

The conference panel is the stage at which a case is escalated beyond the relationship between a clergy member and his or her bishop. The conference panel consists of members of the appropriate disciplinary board, and they oversee the case along with a church attorney, who essentially acts as a prosecutor. Even at this advanced stage, the proceedings are intended to be confidential under most circumstances, and no records are maintained by the conference panel. The conference panel can dismiss the matter, recommend disciplinary action that can include suspension or deposition from ordained ministry, or pass the case on to a hearing panel for a full-fledged ecclesiastical trial — which is open to the public.

The most recent bishop to face a hearing panel was the Rt. Rev. William Love, who resigned as Bishop of Albany in October 2020 after a hearing panel ruled that he had violated his vows by refusing to adhere to church policy regarding same-sex marriage, a practice he opposes. Love subsequently left the Episcopal Church, and now serves as a bishop in the Anglican Church in North America.

Most of the current cases involving named bishops are at the reference panel stage. The exception is the case against Curry and Ousley, which has not made it that far. The case against Curry illustrates how misconduct allegations get more complicated the higher they reach into the church hierarchy.

Under the canons, a case involving the presiding bishop would initially be overseen by the vice president of the House of Bishops, Mary Gray-Reeves, the former Bishop of El Camino Real who now leads the College of Bishops. But Gray-Reeves, a longtime member of Curry’s inner circle, has been providing pastoral care to Curry and his family during the presiding bishop’s health problems, and she quickly recused herself. She designated Herman Hollerith IV, the former bishop of Southern Virginia, to oversee the proceedings involving Curry and Ousley.

Kempf also recused herself as intake officer, because she reports to Curry. The Rev. Mary Sulerud, a Maryland priest with extensive experience in Title IV matters, was named intake officer-designate.

In addition to the named bishops whose cases are mentioned above, the call for greater transparency was turbo-charged in August 2023, when President of the House of Deputies Julia Ayala Harris alleged that a bishop, whom she did not initially name, had touched her inappropriately on the day she was elected in July 2022. She said her Title IV case against the bishop had ended in July 2023 after the church attorney, in what she called “an obvious abuse of discretion,” referred the case for a pastoral response instead of discipline.

Ayala Harris’s announcement prompted an ad hoc group of dozens of bishops to sign a letter saying “We are angered by and deeply concerned about the perception — or the reality — that bishops get a free pass on behavioral issues.” The public outcry largely stopped after TLC revealed that the bishop in question was Ed Konieczny, the prominent retired Bishop of Oklahoma who had been Ayala Harris’s bishop.

Konieczny’s case is not mentioned among current cases because it has been resolved. It also is not listed as a past case involving a bishop, because it never reached the hearing panel stage.

The Standing Commission on Structure, Governance, Constitution and Canons plans to submit a resolution at General Convention ending the ability of the church attorney to dismiss a case on his or her sole authority, according to the Rev. Steve Pankey, a commission member from Kentucky. Pankey disclosed this plan in a podcast interview, where he was interviewed by Ayala Harris.

Kirk Petersen began reporting news for TLC as a freelancer in 2016, and was Associate Editor from 2019 to 2024, focusing especially on matters of governance in the Episcopal Church.

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