Final SJC Decision on the Leithart Case

Pacific Northwest Presbytery's not guilty verdict has been affirmed

The Complainant alleged that TE Leithart’s views strike at the fundamentals of the system of doctrine. Members of the SJC did express concerns about some of TE Leithart’s formulations as they related to the Westminster Standards. It is clear that, at least at some points, Presbytery recognized some of these concerns.


The Standing Judicial Commission (SJC) of the Presbyterian Church in America (PCA) has announced its decision on the case known as RE Gerald Hedman v. Pacific Northwest Presbytery (Case 2012-05) to the parties, which now makes the decision public. The SJC decided to deny the complaint which means that the action of Pacific Northwest Presbytery that found TE Leithart not guilty of all charges has been affirmed. The vote of the SJC was 15 concurring, 2 dissenting (also, 1 was not qualified, 1 was recused, and 5 were absent.).

The case arose in Pacific Northwest Presbytery over some of the views of TE Peter Leithart. The charges against TE Leithart alleged that he held and promoted views that were contrary to the Westminster Standards, which express and define the PCA’s theological positions. There were five charges touching on baptism, the covenants, imputation, justification, and union with Christ (read the SJC decision for more details).

In June 2011, Pacific Northwest Presbytery held a trial. The outcome of the trial was to find TE Leithart not guilty of the five charges. In November 2011, one month after the presbytery met and adopted the judgments on the five charges, a complaint was filed against the actions of Pacific Northwest Presbytery. Last April, the presbytery denied the complaint at which point a complaint was filed with the SJC.

The Summary of the facts, Statement of the Issues, and Judgment are shown here. To read the full SJC decision,  go here.


10/2010 At its Stated Meeting, in response to the decision of the Standing Judicial Commission (SJC) in Case 2009-06 Bordwine v. PNW (M38GA pp. 208-213), Pacific Northwest Presbytery appointed a prosecutor to conduct a trial of TE Peter Leithart.

06/03/11 A two day, 15-hour trial was held before Presbytery’s nine-man Standing Judicial Commission (5 TEs & 4 REs) (the “Trial Commission”). In addition to the main pre-trial briefs filed by the two parties, the defense filed 12 exhibits before the trial (324 pages). The prosecution did not file any exhibits before trial. Below are the five charges in the indictment:

1. Baptism – That TE Leithart in his views and teachings contradicts both the Westminster Standards and Scripture by attributing to the sacrament of baptism saving benefits such as regeneration, union with Christ, and adoption (WCF 28:5-6 and John 1:12-13; Rom 2:28-29; Heb 4:2; Heb 11:6).

2. Covenants – That TE Leithart in his views and teachings rejects the covenant of works/covenant of grace structure set forth in Scripture and in the Westminster Standards (WCF 7:2-3, 5-6; WLC 20 and Gen 2:16-17; Hosea 6:7; Rom 5:12-14; 1 Cor 15:21-22; Gal 3:12).

3. Imputation – That TE Leithart in his views and teachings rejects the teaching of Scripture and the Westminster Standards that the obedience and satisfaction of Christ are imputed to the believer (WCF 8:5; WCF 11:3 and Rom 4:1-8; Rom 5:17-18).

4. Justification – That TE Leithart in his views and teachings fails, contrary to Scripture and the Westminster Standards, to properly distinguish justification from sanctification (WLC 69, 75, 77 and Rom 3:28; Rom 4:4-8; Rom 12:1; Titus 3:4-8).

5. Union – That TE Leithart in his views and teachings contradicts Scripture and the Westminster Standards by teaching that people may be truly united with Christ and receive saving benefits from him, and yet fall away from Christ and lose those saving benefits (WLC 65-66, 69, 79 and John 6:38-40; John 10:28-29; Rom 8:28-39; Phil 1:6; Heb 7:25).

10/07/11 At Presbytery’s next Stated Meeting following the trial, and after the Trial Commission distributed its 33-page Report, Presbytery adopted the following five judgments recommended unanimously by the Trial Commission (Presbytery votes shown in parentheses):

A. That Presbytery adopt the Judicial Commission’s judgment of not guilty on charge 1, concerning baptism. (33-4-3)
B. That Presbytery adopt the Judicial Commission’s judgment of not guilty on charge 2, concerning the covenant of works and the covenant of grace. (32-3-3)
C. That Presbytery adopt the Judicial Commission’s judgment of not guilty on charge 3, concerning imputation. (32-5-1)
D. That Presbytery adopt the Judicial Commission’s judgment of not guilty on charge 4, concerning justification and sanctification. (30-5-1)
E. That Presbytery adopt the Judicial Commission’s judgment of not guilty on charge 5, concerning union with Christ and apostasy. (30-5-2)

11/01/11 Complaint was filed by RE Wes Witt, RE Gerald Hedman, and RE Clinton Seidenburg against the October 7, 2011 action of Presbytery (the “Witt Complaint”). The Complaint was assigned to a Complaint Commission of Presbytery that included seven (7) elders from the Trial Commission and two (2) additional presbyters who attended the trial and read the briefs and all exhibits (the “Complaint Commission”).

04/27/12 The Complaint Commission recommended denying the Witt Complaint. Presbytery adopted the recommendation of the Complaint Commission.

05/20/12 RE Gerald Hedman and TE Sy Nease filed a Complaint with the SJC against the April 27, 2012 decision of Presbytery in denying the Witt Complaint (the “Hedman Complaint”).

06/14/12 The 722-page Record of the Case, along with the Hedman Complaint, was filed by the Clerk of the Presbytery with PCA Stated Clerk’s office.

10/03/12 TE Nease withdrew as a Complainant on the Hedman Complaint.

03/06/13 A Hearing on Case 2012-05 was held before the full SJC in Lawrenceville, GA during the March Stated Meeting of the SJC.


Did the Complainant demonstrate, based on the record in this Case, that the Pacific Northwest Presbytery violated the Constitution of the PCA when it concluded that the accused was not guilty of holding and teaching views that are in conflict with the system of doctrine taught in the Westminster Standards?



To read the full SJC decision,  go here.

All the documents from the 722-page Record of the Case can be found here.  They’re posted under “Notices.”

Pacific Northwest Presbytery’s 10-page brief that was filed with the SJC for the Hearing can be found here.

To read Complainant’s Brief, go here.