The Presbyterian Church (U.S.A.) has been mired in debates about ordained service by non-celibate gay and lesbian persons since 1976.
 In 1976, two presbyteries (local districts) overtured General Assembly, the denomination’s highest governing body, for “definitive guidance” whether persons who openly acknowledge a homosexual orientation and practice may be ordained. The 1978 General Assembly responded with a “Policy Statement and Recommendations,” that “unrepentant homosexual practice does not accord with the requirements for ordination” as minister, elder, or deacon.1 Over 90% of the commissioners to that assembly voted to approve the statement.
 Despite its exclusionary position on ordination, the 1978 statement contained a number of statements affirming the interests of gay and lesbian persons:
– The value of ministry by celibate gay/lesbian persons was strongly affirmed: “The repentant homosexual person who . . . finds God’s power to control his or her desires and to adopt a celibate lifestyle, can certainly be ordained, all other qualifications being met. Indeed, such candidates must be welcomed and be free to share their full identity. Their experience of hatred and rejection may have given them a unique capacity for love and sensitivity as wounded healers among heterosexual Christians, and they may be incomparably equipped to extend the church’s outreach to the homosexual community.”2
– Inquisitions were discouraged. Examining bodies were urged “to conduct their examination of candidates for ordained office with discretion and sensitivity, recognizing that it would be a hindrance to God’s grace to make a specific inquiry into the sexual orientation or practice of candidates . . . where the person involved has not take the initiative in declaring his or her sexual orientation.” 3
– Presbyterians were challenged “to reject in their own lives, and challenge in others, the sin of homophobia. . . . The Christian community can neither condone nor participate in the widespread contempt for homosexual persons that prevails in our general culture. Indeed, beyond this, it must do everything in its power to prevent society from continuing to hate, harass, and oppress them.” 4
– Presbyterians likewise were called upon “to work for the decriminalization of private homosexual acts between consenting adults . . . [and] for the passage of laws that prohibit discrimination in the areas of employment, housing, and public accommodations based on the sexual orientation of a person.” 5
– Finally, the church expressed its willingness to continue learning in this area: “No opinion or decision is irreformable. Nor do we mean to close further study of homosexuality among the presbyteries and congregations.” 6
 The general principles established in that statement have continued to guide the PC(USA) to this day.
 Adoption of the 1978 “definitive guidance” generated deep and lasting controversy in the church. Much of the debate, obviously, reflected disagreements about whether gay/lesbian relationships are necessarily sinful or should be a bar to ordination. Other objections to the statement came from many quarters. Many felt that the policy violated freedom of conscience, and the duty Presbyterians have to show each other mutual forbearance in matters not “essential” to the faith. Some felt that the prohibition was inconsistent with constitutional requirements that full rights of church membership (including eligibility for lay office) be extended to all persons on profession of faith, and that church sessions and presbyteries be empowered to determine the fitness of their own members.
 Additional controversy focused on governance issues, and whether General Assembly had intended its “Policy Statement and Recommendations” to be binding on congregations and presbyteries. Many felt that if the 1978/79 statements were to be considered binding, General Assembly had acted illegitimately, usurping the power of the presbyteries to ratify or reject any amendments to the standards for ordination set forth in the Constitution.7
 The General Assembly’s Permanent Judicial Commission (GAPJC) ruled in 1985 that the 1978 statement was binding on lower judicatories.8 Then, in 1993, the GAPJC issued a pair of decisions that finally addressed, in a very concrete way, how the policy might be applied to individuals and churches. In the first case, the GAPJC held that a presbytery could not certify, as ready to receive a call, a woman who had graduated from seminary, passed her ordination exams, and declared at examination that she was lesbian, but who was not known to be celibate.9 In the second case, the GAPJC held that a presbytery could not approve a congregation’s call to a “self-affirmed, practicing” lesbian who had previously been found qualified and served as a pastor elsewhere in the PC(USA).10
 A storm of controversy erupted. Efforts by the next annual General Assembly to legitimize these rulings with a new “authoritative interpretation”-that “self-affirming, practicing homosexual persons” cannot be installed in ordained office11-merely added fuel to the fire. The denomination hunkered down for another three-year study of the issues, asking its congregations and presbyteries to learn more, dialogue, and pray together in search of a united way forward.
 In 1996, when General Assembly next took up the issue, the church was primed for a formal addition to the Book of Order. It was clear that the legitimacy of any rule limiting ordained service by non-celibate gay and lesbian persons would be questioned until it had been submitted to, and approved by, the presbyteries. A wave of overtures came in from the presbyteries, twenty-four seeking to affirm the prohibition, and twenty-four seeking to overturn it.12 Disappointingly, the denomination’s offices reported the results of a survey showing that only 5% of congregations reported any study on the issue during the three-year study period leading up to the assembly.13 Many in the denomination held fiercely to sincere beliefs, but there was good reason to question how many had undertaken any serious inquiry into the Scriptural or scientific grounding for their views.
 What went to the floor of the General Assembly in 1996 became known as the “fidelity and chastity amendment,” or “Amendment B.” It stated that:
Those who are called to office in the church are to lead a life in obedience to Scripture and in conformity to the historic confessional standards of the church. Among these standards is the requirement to live either in fidelity within the covenant of marriage between a man and a woman . . . or chastity in singleness. Persons refusing to repent of any self-acknowledged practice which the confessions call sin shall not be ordained and/or installed as deacons, elders, or ministers of the Word and Sacrament.
 The measure passed at the General Assembly, with roughly 60% of the commissioners in favor and 40% opposed. When the measure went to the presbyteries, it was ratified, with 57% of the presbyteries voting in favor of it. However, unofficial counts of the roughly 26,000 individual presbyters (elders and ministers) voting in presbytery demonstrated just how divided the denomination really was: the measure passed by only % to 49%.1414
 At the 1997 General Assembly, progressives introduced a new overture calling for the replacement of “fidelity and chastity”-which had become new section G-6.0106b of the Book of Order-with a measure known as the “fidelity and integrity” amendment. That measure stated that:
Those who are called to office in the church are to lead a life in obedience to Jesus Christ, under the authority of Scripture and instructed by the historic confessional standards of the church. Among these standards is the requirement to demonstrate fidelity and integrity in marriage or singleness, and in all relationships of life. . .15
 The measure was intended to accomplish several things:
– First, it was intended to replace what its proponents saw as legalistic adherence to old texts with a requirement that all persons live first and always in obedience to Christ.
– Second, the proponents of “fidelity and integrity” sought to establish a higher standard for all relationships than one focused solely on the sexual conduct of a small segment in the church. 16
 The measure was approved by the General Assembly. However, the presbyteries failed to ratify it, with 67% voting against the change. Again, unofficial counts of individual presbyters’ votes showed a far closer division: the measure was defeated 55% to 45%.
 Debates across the presbyteries indicated that at least some of the voting on “fidelity and integrity” was motivated by a desire to respect the recent vote on Amendment B, as a matter of good process, rather than by presbyters’ views on human sexuality. For whatever reason, the defeat of “fidelity and integrity” brought a temporary halt to most legislative initiatives. Although some progressive groups continued to introduce overtures seeking more inclusive ordination standards at each General Assembly, these were not approved.
 The dispute moved instead to the judicial realm. A number of churches adopted “statements of dissent,” declaring their intention not to be bound by G-6.0106b. Some adopted statements simply refusing to comply as a matter of conscience. Others, seeking to come more clearly within the bounds of Presbyterian polity, argued that they could not enforce G-6.0106b as a practical matter, because it conflicted with a number of other mandates in the Constitution requiring that the church show Christ’s love and justice to all persons, that all persons be entitled to full church membership (with opportunities to serve in ordained leadership) upon profession of faith, that churches and presbyteries determine the fitness of their ordained leaders, that minorities be fairly represented in all governing bodies, and that the church remain open to reform.
 There was little enforcement of G-6.0106b while the validity of such dissent was judicially tested. 17 In summer of 2000, however, the GAPJC finally ruled that sessions and presbyteries cannot ignore any part of the Constitution, but must interpret all parts of the Constitution-including G-6.0106b-so that they work together.18
 The GAPJC handed down this decision just as a new legislative effort to change the PC(USA)’s ordination standards was gathering steam. At the end of a voluntary, three-year period of forbearance, twenty-eight presbyteries sent thirty-five overtures to the 2001 General Assembly, seeking more inclusive ordination standards for non-celibate gay and lesbian people.19 The Overture Advocates for these measures pooled their efforts in a common presentation, organized around an overture submitted by the New York City Presbytery and an hour-long PowerPoint presentation that focused on the tensions between G-6.0106b and Presbyterian traditions favoring freedom of conscience. 20Given obvious differences in the church about sexual ethics, the advocates side-stepped this and focused instead on traditional principles of Presbyterian polity, requiring mutual forbearance in matters of difference not deemed “essential” to Reformed faith and polity. The overture sought to restore as the sole standard for ordination a provision already in the Book of Order, that-
In addition to possessing the necessary gifts and abilities, natural and acquired, those who undertake particular ministries should be persons of strong faith, dedicated discipleship, and love of Jesus Christ as Savior and Lord. Their manner of life should be a demonstration of the Christian gospel in the church and in the world.21
 The General Assembly amended and adopted the New York City overture, voting 60% in favor of it and 39% against-a virtual reversal of the ratio by which “Amendment B” was adopted in 1996.
 Conservatives organized swiftly to oppose ratification of the measure. Many threatened schism if the measure were ratified. Others urged that any vote on ordination reform be delayed until a Theological Task Force, established in 2001 to consider causes of denominational unrest, could report back in 2005. Conservative activists commissioned a professional video to rebut the PowerPoint presentation, and many of the presbyteries saw, for the first time, a ratification debate waged in large part by “duelling videos.” And, immediately after the ratification voting began, Muslim extremists flew two airliners into the World Trade Center-almost certainly dooming the prospects of a contentious reform while parishioners sought security and calm in the church.
 In the final voting, the presbyteries rejected Amendment 01-A almost 3-to-1. However, the results in a number of presbyteries were very close (some decided by a tie or single vote or two), and the majority opposed to reform was made up of only 57% of the roughly 23,000 presbyters voting on the measure. The church clearly continues to be closely divided on the issue.
 The PC(USA) has now entered another “judicial” season. Congregations and presbyteries pursuing inclusive ordination standards have begun to grapple with the many ambiguous terms in G-6.0106b, considering ways in which its exclusionary impact might be lessened. Some have argued that “chastity” may require something different than “celibacy”-for example, monogamy or moderation, whatever the gender of the partners in a relationship. Others have argued that the Confessions do not call all homosexual conduct “sin”-that condemnations of “unnatural lust” and “homosexual perversion” no more condemn loving, same-sex relationships than prohibitions of “heterosexual perversion” or “unnatural lust” would proscribe all loving heterosexual relationships. Still others argue that “refusing to repent” (a prerequisite for a candidate’s disqualification under G-6.0106b) means something akin to contumacy-wilfully disregarding an inward conviction of the wrongfulness of one’s acts-and not mere persistence in conduct that, though condemned by a majority, the candidate believes is right. In the next several years, sessions, presbyteries, and PJCs around the country will be grappling with these and other interpretative arguments.
 It has been the rule since the 1970s, that an examining body may not inquire about a candidate’s sexual practice unless the candidate takes the initiative in declaring a homosexual orientation. While this rule for a long time meant that candidates were forced to remain “in the closet,” that is no longer the case. The GAPJC recently ruled that examining bodies may not probe into a person’s sexual practice merely because s/he affirms a homosexual orientation-that “[t]o single out a category of persons above and beyond other persons as more likely to sin violates the doctrine of total depravity.”22 The critical question in this respect remains whether a candidate who is in a committed, same-sex relationship may be deemed to have “self-acknowledged” sexual practice with sufficient clarity to merit inquiry. The answer in the Synod of the Northeast appears to be “no,”23 while the other synods have yet to rule on this issue.
 If local governing bodies reject all of the interpretative options now being explored, gay/lesbian persons who choose to “self-acknowledge” the fully sexual nature of their relationships may be forced to fall back on the declaration of “scruples.” This is a traditional form of protest allowing a candidate to declare that s/he cannot and need not comply with a denominational rule because it is not an “essential” of Reformed faith and polity. Such a strategy may well be tested before long, as some appear to be rejecting nuanced interpretation of G-6.0106b in favor of outright defiance.
 The PC(USA), like most mainstream denominations, remains deeply troubled about possible participation by non-celibate gay and lesbian persons in its ordained leadership. However, the denomination has reached a greater degree of consensus and clarity in other areas.
 As noted earlier, the PC(USA) long has supported secular reforms that would protect gay and lesbian persons from criminal sanctions for private, consensual sexual conduct and from discrimination in employment, housing, and public accommodations. In addition, the PC(USA) long has supported same-sex unions, in both the secular and the ecclesiastical realms.
 The PC(USA) has affirmed on five occasions in the past decade that its ministers may bless same-sex unions, and that ceremonies celebrating such relationships may be held in Presbyterian churches, so long as such ceremonies are not held out as services of Christian marriage. What “crosses the line” of permissibility has yet to be determined, but it appears that what is required is to avoid undue confusion between the two types of ceremonies. The most recent affirmation of same-sex unions came with a GAPJC decision in 2000, where the court suggested that same-sex union ceremonies might find express warrant in the denomination’s Directory for Worship.24 It therefore is increasingly common for pastors in the PC(USA) to conduct formal, same-sex union ceremonies, while announcing at the start of such services that the PC(USA) does not treat the relationship being affirmed and blessed as a “marriage.” The pastor and the congregation often promise, at the same time, to afford the couple the same support and nurture in their life together as they afford heterosexual couples.
 As Presbyterian law has moved to embrace the lives and aspirations of gay and lesbian persons, so it may move in the not-too-distant future with respect to ordained leadership in the church. Such is the trend indicated in General Assembly voting-from over 90% in favor of a prohibition in 1978, to only 60% in favor of prohibition in 1996, to 60% in favor of lifting that prohibition in 2001. Argument continues about whether the “plain sense” of Scripture condemns all same-sex conduct, with many in the church believing that change is inevitable (as the church has changed its position with respect to slavery and segregation, interracial marriage, divorce, and women’s rights). The insistence of some on freedom of conscience ensures that confrontations over respect for Presbyterian polity will continue. These are rocky times in the PC(USA). But the news is not all gloomy. At a time when society evidences widespread indifference and even antagonism toward organized religion, this protracted debate, painful as it is, demonstrates that Presbyterians take their faith and the gospel seriously enough to really care about how the church approaches this critical issue.
1 As a technical matter, this action was taken by a predecessor of the PC(USA), the so-called “northern church,” or United Presbyterian Church in the United States of America (UPCUSA). UPCUSA Minutes, 1978, Pt. I at pp. 213-67 (quotation at p. 265). In 1979, a similar statement was adopted by the Presbyterian Church in the United States (PCUS), the so-called “southern church” that had split from the northern church in the 1860s over the question of slavery (PCUS Minutes, 1979, Pt. I at pp. 200-10). The UPCUSA and PCUS were merged into a single denomination, the PC(USA), in 1983.
2 UPCUSA Minutes, 1978, Pt. I at p. 264.
4 Id. at 264, 266.
5 Id. at 266.
6 Id. at 264.
7 Under the Presbyterian form of government, amendments may be made to the Book of Order only if they are approved by a majority in General Assembly, and then ratified by majority vote in a majority of the presbyteries before the next General Assembly.
8 Union Presbyterian Church of Blasdell v. Presbytery of Western New York, PC(USA) Minutes, 1985, Pt. I at pp. 118-123.
9 LeTourneau v. Presbytery of Twin Cities Area, PC(USA) Minutes, 1993, Pt. I at pp. 163-166.
10 Sallade v. Presbytery of Genesee Valley, PC(USA) Minutes, 1993, Pt. I at pp. 166-170.
11 PC(USA) Minutes, 1993, Pt. I at pp. 75-77, 127.
12 See PC(USA) Minutes, 1996, Pt. I at pp. 80, 679-760.
13 PC(USA) Minutes, 1996, Pt. I at pp. 156-161.
14 While the PC(USA) has no official clearinghouse for the reporting of presbytery votes, interest groups from across the theological spectrum typically collect and publish such information on their websites. Vote tallies on “Amendment B” and subsequent issues of this nature are available at http://www.covenantnetwork.org/home.htm.
15 PC(USA) Minutes, 1997, Pt. I at pp. 89-90.
16 Notwithstanding its apparent breadth, which technically applies to all unmarried persons, G-6.0106b was generally understood as an effort to prohibit gay and lesbian people from holding ordained office. Indeed, it appears that all judicial cases brought to enforce the rule since its passage have related to gay or lesbian candidates for office.
17 As in the US court system, the PC(USA) includes several levels of permanent judicial commissions, with cases moving from courts having jurisdiction over limited areas (presbyteries) to appeal before courts covering larger regions (synods) and ultimately to the GAPJC, which rules on behalf of the national church.
18 Rem. Case 213-2, Londonderry Presbyterian Church v. Presbytery of Northern New England (GAPJC, slip op. July 7, 2000).
19 In addition, one presbytery sent an overture seeking to reinforce the current rules.
20 The PowerPoint presentation and related materials prepared by the Overture Advocates remain available on the websites of a number of progressive Presbyterian groups, including http://www.covenantnetwork.org/home.htm.
21 Book of Order § G-6.0106a.
22 Rem. Case 214-5, Wier v. Second Presbyterian Church (GAPJC, slip op. April 14, 2002).
23 See Rem. Case R-1998-1, Hair v. First Presbyterian Church (PPJC-Southern New England, slip op. March 5, 1999), upheld in relevant part, Case No. 99-5, Hair v. First Presbyterian Church (SPJC-Northeast, slip op. Oct. 9, 1999).
24 Benton v. Presbytery of Hudson River, PCUSA Minutes, 2000, Pt. I at pp. 586-589. Warrant was found, in particular, in § W-6.3010, which provides for services recognizing significant life events, when “households are established . . . [and] people are empowered, restored, make new commitments. . . . The ministries of pastoral care support people in . . . celebrating these and other such times of adjustment, assisting them in working toward a new role in life and affirming their identity through transition.” This decision led to a legislative effort by conservatives to add a prohibition on same-sex unions to the Book of Order. However, that effort was defeated in the presbyteries.