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Title IV Compromise Leads to Earlier Retirement in Easton

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The Rt. Rev. Santosh Marray, Bishop of Easton, who has been the subject of two ongoing Title IV cases, announced on February 11 that he plans to effectively conclude his ministry in October, a year earlier than previously planned.

Marray said his decision was “endorsed” by Presiding Bishop Sean Rowe, who participated electronically in a joint meeting of the diocese’s Standing Committee and Diocesan Council on February 10, during which the bishop announced his decision.

“During my time with family in the Bahamas last month, I spent much time in prayer. It was during these times of prayer that I heard God’s voice clearly directing this decision. First, in calling me to spend more time with my family in these latter years of my life, as husband, father and grandfather, without the constant pull of work. And second, to continue my physical, emotional, spiritual and psychological healing,” Marray said.

His decision was also shaped, he said, by the decision of Easton’s Standing Committee in December to begin a formal process of discernment about whether to continue as an independent diocese or to seek merger with one of its neighbors, a process specifically requested and underwritten by Presiding Bishop Rowe.

“It is customary, practical, and ecclesiastically prudent and responsible that this vital exercise be conducted without the physical presence of the incumbent ordinary/bishop,” he said, adding that this decision reflects his commitment to “accountability and transparency in the spirit of kenosis (self-emptying — where the interest of others/church are placed before the individual’s self-interest) as modelled by our Lord and Savior Jesus Christ (Philippians 2).”

The bishop’s announcement follows a message sent the previous day by Easton’s chancellor, Regan Smith, which stated that the Reference Panel assigned to his disciplinary cases had decided “that there were no Title IV Offenses committed by Bishop Santosh Marray.”

An attempt at conciliation, a mediation process between Marray and numerous complainants in the two cases, was recommended last June, but ultimately failed. The records about Marray’s cases on the Episcopal Church’s website for Title IV cases involving bishops (as of February 13) said the Reference Panel had “issued determination concluding matter with pastoral response” on January 21. The later decision to dismiss the charges entirely has not yet been added to the site.

One case, dating from July 2023, was filed by multiple complainants, and involved “allegations of inappropriate public statements and behavior,” reportedly including comments made by Marray during Easton’s diocesan convention in March 4, 2023, about the appearance of women clerics and harsh words against those who voted against changes to the diocese’s constitution. A second case, filed by a single complainant in February 2024, involved “allegations of inappropriate public statements and misrepresentations.”

Six congregations that have been involved in the Title IV matters, Smith said, have been placed under delegated episcopal pastoral oversight (DEPO) for the remainder of Marray’s ministry, and will be overseen by Bishop Kevin Brown of the neighboring Diocese of Delaware and Marray’s predecessor, Bishop James Shand. The request for DEPO had been granted by Marray on September 18, 2024, but previously unannounced by the diocese.

DEPO has been used for decades in the Episcopal Church to accommodate situations when a bishop and congregations under the bishop’s care (usually only a handful) have divergent convictions about same-sex marriage. Using it for so many congregations (15% of the diocese) and for issues involving pastoral leadership is highly unusual.

“The Diocese considers these matters to be concluded, and will continue to work with all its members and clergy towards bringing together everyone with a singular mission to faithfully serve God’s mission in the communities we serve on the Eastern Shore and in the global Anglican Communion,” Smith added.

The pragmatic settlement in Easton, sources tell TLC, was brokered by Presiding Bishop Sean Rowe, who during his first three months in office has been actively clearing the deck of Title IV cases involving bishops, and making use of the broad powers assigned to his office in disciplinary matters.

TLC asked the Rev. Nathaniel Pierce, a retired priest who was a complainant in the 2023 case, about the Reference Panel’s ruling that “no Title IV offenses had been committed” by Bishop Marray.

“We were surprised by that,” he responded. “After all, on two previous occasions the Reference Panel had indicated that Title IV offenses were indeed present: when they accepted the report from the Intake Officer and when they referred our complaints to Conciliation. My sense is that this statement was the end result of a compromise which enabled us to get where we are today.”

Pierce, who described himself as “pleased” with the outcome, said that he and several other complainants agreed to withdraw two resolutions that they had submitted for consideration at the diocesan convention scheduled for March 6-8 after the diocese announced that DEPO had been granted by Bishop Marray.

One of these resolutions gave thanks for the granting of DEPO while another urged that the diocese pay all the legal bills incurred by Bishop Marray during the proceedings (by canon, the diocese commits to fund 50% of legal expenses for all respondents in Title IV case). Pierce said the expense incurred by Bishop Marray was estimated at $40,000.

Asked about the legal bills resolution, Pierce said, “It came from old-fashioned Episcopalians like me who believe we should honor the Office of Bishop even if we are having problems with the incumbent.”

“There are no winners in a Title IV process for a Bishop; everyone loses,” Pierce reflected. “The collateral damage to the Diocese is enormous. My advice to others: if appropriate, first explore the resources offered under Canon III.12.11. We tried to do exactly that for three years and failed. A Title IV complaint should be the last resort; for us, it was the only as well as the last resort.”

Marray’s formal date of resignation will be February 2, 2026, but he plans to give his farewell service in October. He will step down from his duties on October 31, and will close his time of service with a month of vacation and a terminal sabbatical. He had previously announced that he planned to continue in office until the fall of 2026.

A native of the South American nation of Guyana, Marray served in his native country, in the Bahamas, and in Florida before being elected as Bishop of Seychelles in the Province of the Indian Ocean in 2005. After five years there, he served as assistant bishop in the Dioceses of Alabama and East Carolina before being elected as Easton’s eleventh bishop in 2016.

TLC reached out to Bishop Marray about his retirement decision and the dismissal of Title IV charges, but he declined to comment.

The Rev. Mark Michael is editor-in-chief of The Living Church. An Episcopal priest, he has reported widely on global Anglicanism, and also writes about church history, liturgy, and pastoral ministry.

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