On intake officers, episcopal authority, and false dichotomies

Thoughts on Bishop Todd Ousley and Title IV

How should clergy discipline work in the Episcopal Church, and how much leeway do individual bishops have to decide this? This question — frequently mooted over the last few years — been raised anew recently by statements made by Bishop Todd Ousley following upon his nomination to serve as provisional bishop in the Diocese of Wyoming. My friend Arlie Coles has been writing some very careful and insightful commentary on this which I strongly commend to your reading (see her Substack here). I also wanted to reflect upon the situation, because I think that the bishop’s understanding of clergy discipline is indicative of some broader failures in how the Episcopal Church thinks about clergy discipline, the episcopal office, and what it means to be pastoral.

To understand what is going on in the Diocese of Wyoming now, and why it is so concerning, I will need to briefly discuss the church’s handling of disciplinary cases against Bishops Whayne Hougland and Prince Singh. If you’re up to speed on this, feel free to scroll down to the next heading.

Title IV, the Office of Pastoral Development, and the Two Bishops of Eastern and Western Michigan

Before being nominated for bishop provisional in Wyoming, the Rt. Rev. Todd Ousley served as the head of the head of the Office of Pastoral Development (OPD), part of the staff of the Episcopal Church’s Presiding Bishop. Essentially, this position involves facilitating bishop transitions and episcopal search processes along with providing pastoral care and guidance for bishops. When Bishop Ousley took this position, it also included serving as the intake officer for Title IV (clergy misconduct) complaints concerning bishops, a situation that Bishop Ousley inherited from his predecessor.¹

What this meant is that, in the person of the Todd Ousley, the same individual was the initial point of contact for both pastoral care for bishops and complaints about episcopal misconduct. If this strikes you as a potential conflict of interest likely to cause serious problems, well, alas: this is exactly what happened, multiple times.

Two successive bishops of Eastern and Western Michigan, the Rt. Rev. Whayne Hougland, Jr. and the Rt. Rev. Prince Singh, were suspended from ministry for misconduct, and in both cases, there were allegations that Bishop Ousley failed to care appropriately for victims of clergy misconduct in the name of a pastoral approach towards the offenders. In the Hougland case, a group of clergy and laity from the diocese complained that the language of pastoral care, healing, and reconciliation was deployed in favor of their bishop and with little attention to the needs of his diocese (Hougland resigned as bishop towards the end of his suspension and is now in active ministry as a parish priest in another diocese).²

The Singh case was yet more serious. Bishop Singh’s sons made a formal charge of misconduct against Bishop Ousley and Presiding Bishop Michael Curry for how they handled allegations of physical and emotional abuse and alcoholism against Bishop Singh. His sons made these allegations to Curry, with Ousley roped in, in December 2022, but no formal Title IV process was started until they went public with their complaint some six months later (Singh’s process was settled with an accord in December 2024, suspending him from ministry for at least three years).

To simplify a long story, in mid-2023, a full-time Title IV Intake Officer for bishops was hired, meaning that the same person would no longer be simultaneously responsible for pastoral care for bishops and for processing misconduct allegations against them.³ Upon taking office, the Most Rev. Sean Rowe, the new presiding bishop, announced that Todd Ousley would not continue in his role as head of the OPD along with a set of other staff changes.⁴ The Title IV cases against Ousley and Currey were settled in December 2024 with apologies from both of them and additional Title IV training for Bishop Ousley.⁵

Meanwhile, back in March 2024, the Rt. Rev. Paul-Gordon Chandler, Bishop of Wyoming, announced that he was stepping down from ordained ministry to bring to a close a Title IV investigation against him.⁶ In January 2025, the diocesan Standing Committee announced that they had chosen a nominee for a provisional bishop to replace him, to be voted upon at an upcoming diocesan convention. That nominee: Bishop Todd Ousley.

Bishop Ousley on Title IV and Intake Officer Responsibilities

Once his nomination was announced, Bishop Ousley and the Standing Committee released a set of videos, which included extended commentary on Bishop Ousley’s experience with Title IV and the OPD. He has also held two public fora, in which he was further asked about clergy discipline. Arlie has prepared transcripts of each of these, to which I have linked just above.

In these videos, Bishop Ousley defends his conduct in the Prince Singh case (and other episcopal misconduct cases), and argues for an understanding of Title IV which prioritizes “pastoral” over “judicial” response at all levels, including in the intake officer position he formerly held.

Now, Bishop Ousley did admit in one of the opening videos that his dual positions as OPD head responsible for pastoral care and intake officer were in tension.⁷ But in that same opening video, he went on to argue for the appropriateness of how he treated the Bishop Singh allegations. When he and Presiding Bishop Currey received the allegations against Singh, he says, both men decided that it was “something that needed to be dealt with internally, pastorally, and therapeutically.” But these attempts to deal with matters pastorally failed, he says, and so ultimately charges were filed against him and PB Curry “for failure to respond appropriately, pastorally, and to follow a very narrow reading of the Intake Officer's role: to always write a report.” He goes on — and please note these words — “I would contend that, and will continue to contend, that the Intake Officer must have pastoral discretion to to deal with these matters early on in a pastoral matter, or go straight to the report and a judicial handling.”

When questioned about this in the public fora, he continued to advance this idea that those overseeing the Title IV process, including the intake officers, have the capacity to decide upon a “judicial” or “pastoral” response, given Title IV’s ambiguity. He stated that, by “interpreting [the canons] in a more expansive way,” you can have those overseeing the disciplinary process decide which of those paths they want to take — including at the first level of the intake officer. This strongly suggests that he thinks he did no wrong in his handling of the Bishop Singh case⁸ and that he would support handing disciplinary cases in a similar way as bishop.

Unfortunately, I fear that this response indicates, first of all, an inaccurate understanding of the church’s disciplinary canons and bishops’ responsibility to uphold them, and secondly a deeply worrying construal of the relationship between pastoral care and church discipline. And I worry that this response is not just a matter of one bishop, but is in fact indicative of how Episcopal Church leadership broadly thinks about clergy discipline (although I have hopes that Presiding Bishop Rowe will take a stronger line!).

On Canons, ‘Expansive Interpretation,’ and Episcopal Authority

As far as I can tell, Bishop Ousley is wrong about canonical leeway in the Title IV process for a “pastoral” approach, at least at the level of the intake officer. I will certainly grant that Title IV is confusing. I find the website that the Episcopal Church put together to help people navigate it almost impenetrable. But there are some things that the disciplinary canons are quite clear about, and one of them is the duties of intake officers. Arlie demonstrates this very conclusively here, with reference not only to the text of the canons but also to instructional material put out when the intake officer position was established in 2011 and guidance from the official Episcopal Church Title IV website. Simply put, the canons make it clear that the role of an intake officer is to determine, upon receiving an allegation, whether or not the allegation if true would constitute an offense, and if so to send it to the Reference Panel. That is all. Indeed, bishops are explicitly forbidden from assigning intake officers to provide pastoral responses to the subjects of complaints (IV.8.5).

Now, there is plenty of room within the Title IV process for a non-punitive resolution. Indeed, reforms to Title IV over the last decades have stressed making it less adversarial. But the canons do not give intake officers acting independently the ability to decide upon the appropriate resolution of a complaint which would, if true, be an offense. Rather, this power is assigned to the multi-person Reference Panel which receives intake officer reports (IV.6.8, IV.6.12). This provides an important degree of accountability while also broadening the decision-making about how to handle misconduct beyond just one person. And, more to the point, whatever its advantages or disadvantages, this is what the canons demand.

But this, it seems, is what Bishop Ousley would call a “very narrow reading of the Intake Officer’s role.” Against it, he wishes to oppose an “expansive” understanding of the canons. This expansive reading, he says, is to be grounded in “the ideals of Title IV, which are about healing and reconciliation.” If we read the canons expansively according to the ideals of our approach to church discipline, then — though not via a “very narrow reading” of the text itself — he argues that one can find this alleged capacity for intake officers to decide between a pastoral and a judicial response. As far as I can tell, this is what it comes out to: on the basis of what he understands this spirit of the canons to be, Bishop Ousley thinks that he is empowered to overrule the actual text of canons.

The problem is that bishops in the Episcopal Church do not have this power. The bishops, whether acting alone or in concert, simply are not the highest (human) authority in our church. Rather, this authority is vested in the General Convention, which brings together the laity, lower clergy, and bishops to deliberate and legislate for our common life. If Bishop Ousley wishes to advocate for an approach to Title IV that seeks to avoid “judicial” approaches by enabling intake officers to choose a “pastoral” route, he is entirely within his rights to propose legislation, stump for it, and do his best to have it passed at the next General Convention. What he is not free to do is make an “expansive” canonical interpretation governed by “the ideals of Title IV” which contradicts the text to which he has sworn an oath to conform.

It is a strength of our polity that bishops cannot ignore or re-write the canons as they will. It grieves me that in this case, as in other cases such as communion without baptism or noncanonical liturgical usages, our bishops use the progressive-coded language of pastoral accommodation to increase their authority beyond what we collectively have given them. I don’t know what to call this except clericalism. And I suspect that it strengthens the culture of clerical deference that contributes to our long-standing problems with clergy abuse and misconduct.

Pastoral vs Judicial?

The second aspect of Bishop Ousley’s commentary that jumps out at me is his sharp dichotomy between “pastoral” and “judicial.” I do not think that this is a dichotomy that we should grant, and in fact I think implicit in it is an unhelpful account of the proper subject and nature of pastoral care.

First of all, when we talk about pastoral resolution of clergy misconduct, I think we need to ask the question of for whom the resolution is pastoral. I fear that, more often than not, a pastoral resolution means one that is as gentle and non-punitive as possible for the cleric against whom an allegation has been made. This is indeed how the members of the Dioceses of Eastern and Western Michigan experienced Bishop Ousley’s handling of the case against Bishop Hougland. As they put it in their statement discussed above, “when our former bishop had an affair, the system not only took care of him, it did so in extremely expensive ways, to the financial and emotional cost of those whom he had vowed to pastor, in the name of ‘healing’ and ‘reconciliation.’” It’s also, for what its worth, how the “pastoral” nature of Title IV was explained to me in the training I received in seminary: that the “pastoral” approach means taking care of accused clerics.

Now, of course, I think that accused clergy deserve pastoral care as much as anyone else. Further, I do not doubt that in many accusations of clergy misconduct, non-punitive mediation is possible and genuinely the best outcome for everyone involved. But to stress a pastoral approach towards the cleric and (alleged) perpetrator rather than towards the laity and (alleged) victim — to fail to recognize that a pastoral approach towards (allegedly) misbehaving clerics may well mean unpastoral results for their laity and especially the complainants — is to get things backwards. Bluntly, we clergy are there to serve the laity rather than the other way around. The fundamental responsibility has to be to the flock which we clergy are called to shepherd. The “thin black line” that muzzles criticism in the name of pastoral gentleness towards erring clergy harms the people of God for whom Christ died. And, ultimately, such a soft-touch pastoral approach isn’t necessarily good for the cleric in question either. If the cleric has genuinely fallen into grievous sin while holding an office of leadership in Christ’s church and the “pastoral” approach fails to move them to repentance and amendment of life, their soul is endangered. To paraphrase Jesus in Matthew 5, better to go through life deposed than be cast into hell in a clerical collar!

This leads me to the broader point I want to make. I don’t think that the dichotomy that Bishop Ousley draws between “pastoral” and “judicial” approaches is sustainable, because I think that sometimes a judicial approach is the truly pastoral one. I believe that in the Episcopal Church, and in the mainline broadly, we often operate with a seriously impoverished conception of what pastoral care means. It often seems to mean something like the unconditional positive regard and active listening that we’re taught in the first unit of Clinical Pastoral Education. As a result of this impoverishment, as I’ve written before, we often operate with a division between ‘being pastoral’ and doctrine, ‘being pastoral’ and moral instruction — and now, ‘being pastoral’ and exercising church discipline.

This division would have baffled our forbears in the faith, for whom teaching doctrine, exhorting people to holy living, and exercising church discipline were central to the office of pastor because ‘being pastoral’ was fundamentally about fostering and protecting the Christian faith and life of the people under their charge. The very point of the ‘judicial’ processes of church discipline, after all, is not punishment for its own sake, but rather to restore the sinner to repentance and protect the Christian people from sin! It’s hard to get more pastoral than that. Bishop Ousley isn’t wrong to see the goal of Title IV or any church disciplinary procedure as healing and reconciliation. But he does err in assuming that the judicial exercise of church discipline somehow excludes that.

I believe that the Episcopal Church’s failure to rightly discipline its clergy and especially its bishops is a profound scandal. If my analysis above is right, it seems to me that a restoration of a high standard of canonical obedience and of a thickly Christian account of pastoral care which includes the disciplining of sinners are two pieces of addressing this failing.⁹ May God raise up bishops for us who will do exactly this!

1. Title IV is the name of the Episcopal Church’s clergy discipline canons. In the church’s disciplinary system, the intake officer is responsible for receiving complaints of misconduct and assessing whether or not such complaints, if true, would constitute a violation of the disciplinary canons. If so, the intake officer passes the complaint along to the next step of the process, a body called the Reference Panel.

2. This complaint was made in the context of a General Convention resolution calling for an examination of the Office of Professional Development and how it handled church discipline. You can read the resolution and the whole explanation here.

3. It is not entirely clear what specifically drove this change. The decision seems to have been made in an executive council meeting in late 2022 or early 2023, according to the report to the 2024 General Convention by the Standing Committee on Structure, Governance, Constitution and Canons.

4. I do not know whether this was in response to his handling of episcopal disciplinary matters, an example of the typical staff shake-up that happens when a new Presiding Bishop takes office, or due to something else entirely. I do not mean to suggest any of these to be the most likely.

5. The Singh family describes these responses as “deeply inadequate.”

6. Bishop Chandler took pains to note that his leaving ordained ministry was not an admission of guilt. This is how he construed being deposed from ordained ministry: “This decision, as difficult as it is, allows me to stay true to myself, as well as to be faithful to my calling: ‘Seeking to enable others to enter a deeper dimension spiritually and experience the beauty of God in fresh ways.’”

7. “At the time I was wearing at least two hats on the Presiding Bishop's staff. One was pastoral support for those involved in Title IV, all those around and affected by it, as well as being a member of the Reference Panel as the Intake Officer: roles that can be in in conflict, and — I shouldn't say "can" be in conflict, but are readily and very quickly in conflict with one another, because you have a a regulatory judicial kind of role and you have a pastoral role to all of those within the system. It's a complexity that the church had struggled with for a number of years and had never fully resolved. It has since been resolved, that the roles have been separated.”

8. He describes in one of the initial videos that in his apology letter to the Singh family, he apologized for “any hurt that I may have caused and for continuing — possibly continuing to leave them in a place of deep pain and lack of healing and reconciliation.” Note well that this is apparently not an apology for failing to fulfill his responsibilities under Title IV, but rather for causing hurt. “I’m sorry if my actions hurt you”, however sincerely meant, does not indicate that the Bishop sees anything wrong with his behavior.

9. Necessary though not necessarily in themselves sufficient. I am less competent to discuss this, but I also think that the church has a lot to learn from research on the experiences of both abusers and survivors to craft an approach that is trauma informed, meets survivors’ needs, and makes it harder for abusers to offend. We need, I think, traditional Christian conceptions of canonical obedience and the pastoral ministry coupled with more modern insights about abuse, trauma, how large power imbalances warp relationships, and so forth.