Dealing with Shepherdess in the PCA

A Simple Resource

There are two clear constitutional actions elders can take in the PCA to deal with these issues:

BCO 31-2 letters
These are reports concerning the Christian character of an elder—teaching or ruling—sent to the stated clerk of the presbytery (or session). The letter asks the court to investigate an alleged constitutional violation, whether moral or doctrinal. When elders send these letters, presbyteries are bound to take them seriously. If the presbytery finds a “strong presumption of guilt,” the court must bring the elder to trial. If convicted, the elder is censured.

BCO 40-5 letters
These are reports concerning “any important delinquency or grossly unconstitutional proceedings” on the part of a session. They are sent to the presbytery, which must cite the session accused of offending the constitution. The presbytery is then responsible to hear the case and address it—whether by correcting, censuring, or remitting it back to the lower court with instructions to handle it properly.

Side note: Abuse of 31-2
Progressives have learned how to weaponize 31-2 letters. They routinely send them to presbyteries to target conservatives for things that are not genuine constitutional violations. The goal is to force investigations over frivolous matters, silence critics, and make life miserable for anyone who calls out progressive practice. Even when the targeted elder is cleared, “the process is the punishment.”

Here’s the raw constitutional text of 40-5:

When any court having appellate jurisdiction shall receive a credible report with respect to the court next below of any important delinquency or grossly unconstitutional proceedings of such court, the first step shall be to cite the court alleged to have offended to appear before the court having appellate jurisdiction, or its commission, by representative or in writing, at a specified time and place, and to show what the lower court has done or failed to do in the case in question.
The court thus issuing the citation may reverse or redress the proceedings of the court below in other than judicial cases; or it may censure the delinquent court; or it may remit the whole matter to the delinquent court with an injunction to take it up and dispose of it in a constitutional manner; or it may stay all further proceedings in the case; as circumstances may require.

Here is a 40-5 template for any PCA elder(s). You’ll need to adjust as necessary.

TE/RE ______, Stated Clerk

_________ Presbytery (PCA)

Rev. _____,

We are writing to you as the Stated Clerk to bring a report to the _________ Presbytery regarding what we believe constitutes “important delinquencies” and “grossly unconstitutional proceedings” of the Session of ______ Church (PCA), a member church of the _________ Presbytery. This is in reference to BCO 40-5, which reads:

When any court having appellate jurisdiction shall receive a credible report with respect to the court next below of any important delinquency or grossly unconstitutional proceedings of such court, the first step shall be to cite the court alleged to have offended to appear before the court having appellate jurisdiction, or its commission, by representative or in writing, at a specified time and place, and to show what the lower court has done or failed to do in the case in question.

This report concerns ______ Church’s public worship service, in which a woman identified as a “shepherdess” leads worship by _________. This took place at ______ Church Worship Service on September ____, 2025 (see the website _________). At the ____ mark of the video recording, the “shepherdess” leads ______ in the worship service (see Appendix 1).

The Title “Shepherdess”

______ Church’s actions violate the PCA’s Book of Church Order (BCO) in two ways. First, Wildwood’s use of the title “shepherdess” violates BCO 7-3, which states:

unordained people shall not be referred to as, or given the titles of, the ordained offices of pastor/elder, or deacon.

While _____ Church did not refer to the woman leading worship as an “elder,” the use of the term “shepherdess” still violates BCO 7-3. This is because BCO 7-3 prohibits “unordained people” from not only being given the titles of “pastor/elder, or deacon,” but it also prohibits being “referred to” as the ordained offices. Just as a woman should not be referred to as an “elderess” (a feminine form of the term “elder”), she should not be referred to as a “shepherdess” (a feminine form of the term “shepherd”). The term “shepherd” is a title associated with the office of elder, as the elders shepherd the flock of Christ. As 1 Peter 5:1-2 says, “I exhort the elders among you…shepherd the flock of God.” Further, even the “appearance” of female elders should be avoided. As the Larger Catechism teaches, “For the right understanding of the Ten Commandments… That under one sin or duty, all of the same kind are forbidden or commanded; together with all the causes, means, occasions, and appearances thereof, and provocations thereunto” (WLC 99).

The term “shepherdess” is a confusing category, and it sounds like the female counterpart to a male elder who is a “shepherd” of the church. And since male elders are ordained in the PCA, the language of “shepherdess” gives the appearance of a woman either being ordained to office or holding a position similar to a male elder. The BCO does not speak of “shepherdess,” and therefore neither should any PCA church. If the PCA’s Constitution intended for churches to have “shepherdesses,” then it would mention them. The BCO clearly states that the church’s leaders are teaching elders, ruling elders, and deacons. All are ordained. No one should be appointed to hold an officer-like position without being ordained as an actual officer. To do so is to usurp the office and the constitutionally-designated means for establishing church officers. A shepherdess is an officer-like position, or at least gives the appearance of being such. This is even more so the case when the “shepherdess” is leading the public worship service and is presented as a leader in the church, as is the case with Wildwood’s “shepherdess” leading public worship. The language of “shepherdess” is confusing to both church officers and laity. And “God is not a God of confusion but of peace” (1 Corinthians 14:33).

Public Worship and the Pastoral Prayer

Second, ______ Church’s permitting of a woman identified as a “shepherdess” to lead public worship violates the BCO’s requirement that the church’s elders guard the worship of God. The duties to lead public prayer in the worship service belong primarily to the elders of the church, as elders “should pray with and for the people, being careful and diligent in seeking the fruit of the preached Word among the flock” (BCO 8-3). While not officially part of the Constitution, BCO 52 on “Public Prayer” assumes public worship is led by ordained men.

Furthermore, the elders have the duty to teach the congregation, and the leading of public prayer models how to pray. Therefore, the leading of public prayer is a duty that belongs to the elders. As the BCO says, “The elders jointly have the government and spiritual oversight of the Church, including teaching” (BCO 7-2). Leading the congregation in public prayer exercises authority over the congregation, but it also teaches the church by example. Women are not allowed “to teach or exercise authority over a man,” but are instead “to remain quiet” while qualified men are leading the public worship service (1 Timothy 2:12). Our sisters “are to keep silent in the churches…as the Law also says…for it is improper for a woman to speak in church” (1 Corinthians 14:34-35). Therefore, the leading of public prayer should be limited to men, primarily elders.

The Larger Catechism teaches that the Second Commandment requires “the receiving, observing, and keeping pure and entire, all such religious worship and ordinances as God hath instituted in his word” (WLC 108). Public worship should only entail that which is commanded—“The sins forbidden in the second commandment are, all devising, counseling, commanding, using, and any wise approving, any religious worship not instituted by God himself” (WLC 109). God has not instituted the office of “shepherdess,” and He has prohibited women from leading the worship service (1 Timothy 2:12; 1 Corinthians 14:34-35).

Therefore, ______ Church’s public worship service with “shepherdesses” leading worship is not in accord with the Scriptures or the BCO, and the failure of the church’s Session to correct this constitutes an “important delinquency” and “grossly unconstitutional proceeding.”

We, the undersigned, believe these are grave violations of the PCA Constitution and a serious matter that reflects poorly on ______ Church and, by extension, the _________ Presbytery and the Presbyterian Church in America. The above-named practice violates the Westminster Standards that ______ Church’s Session vowed to uphold and the form of government that the Session vowed to approve (BCO 21-5). No elder or Session may be granted an exception to the BCO, but rather they are duty bound to follow the BCO.

We implore the _________ Presbytery, in keeping with BCO 40-5, to thoroughly investigate this report against ______ Church and its Session, thereby providing the Presbytery the opportunity to correct an erring church in love, for the peace and purity of the PCA and the glory of Christ.

Your fellow servants in Christ,

RE ______, _____ Church, ______ Presbytery

TE ______, _____ Church, ______ Presbytery