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Additional Opinions of the Commission on Constitutional Matters

Authoring body: Commission on Constitutional Matters

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Commission on Constitutional Matters

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The following opinions of the Commission on Constitutional Matters (CCM) were issued since the report included in the Convention Workbook as R61 and are included here as they relate to potential convention business. Full commission minutes are reported at lcms.org/ccm.

Participation in Nonapproved Pastoral Formation Routes (26- 3076) Minutes of May 28–29, 2026 By an email of February 6, a member of the Synod, the president of an educational institution of the Synod, requested an opinion of the commission on three questions (the latter two restated by the commission), to which the commission responds as follows.

Question 1: Acknowledging that, historically speaking, individual members of the Synod have taught in institutions of mixed, other, or secular confession, it seems like there is a difference between teaching, e.g., history or classics in such a setting and teaching theology for the purpose of fulfilling the church’s charge to send pastors into the church and world. In other words, is producing men (and women) together with those of a heterodox confession for ministry in every manner of church body a violation of 2?

Opinion 1: The Constitution of the Synod establishes as an objective of the Synod that it, under the Scripture and Lutheran Confessions, shall “3. r ecruit and train pastors, teachers, and other professional church workers and provide opportunity for their continuing growth” (). Further, the Articles of Incorporation of the Synod state (Article II, Objectives) that a purpose of the corporation is “d. to support the establishment and maintenance of theological seminaries, colleges, universities, and other institutions of learning to train ministers of religion — ordained, ministers of religion—commissioned, and laity for service in the Evangelical Lutheran Church.” Even within the structure of the Synod, reserves to the national Synod itself (and its agencies, including its established seminaries and colloquy committees, in relevant part) jurisdiction over “general supervision of doctrine and practice; foreign missions; institutions of the Synod; qualification for ordination, commissioning, and installation of ordained and commissioned ministers and requirements for individual as well as congregational membership in the Synod; publication of official religious periodicals; conduct of negotiations and affiliations with other church bodies; and the like ” (emphasis added).

For the purpose of serving member congregations of the Synod and their schools, –2 set the clear expectation that all church workers called to or serving in the Office of the Public Ministry, and all church workers to be called to auxiliary off ices, shall be those admitted to their respective ministries and to membership in the Synod only via the definite mechanisms the Synod itself has set forth.

–2 do not speak to the preparation of church workers for service outside the member congregations of the Synod and their schools. The Office of International Mission and sister churches of the Synod operate seminaries beyond the two that the Bylaws authorize to produce church workers for Synod congregations, and participating in these efforts—with the basic presumption that such participation is orthodox—is certainly not contrary to the standards of membership in the Synod, even though the resul t of that preparation, plus a call, does not result in membership in the Synod. Members of the Synod also have taught and teach in educational institutions that are not of the Synod , some of which have participated, and do participate, in preparation of workers for the broader church but not for the roster of the Synod.

Review of the record for possible precedent reveals that the commission has previously found (Ag. 598 and 598A, Minutes of May 16–17, 1974), that a professor at Seminex could “ be retained on the clergy roster of the Synod as a candidate on a renewable annual basis under the terms of ” while at the same time assiduously maintaining (Ag. 682, “Constitutional Comments on the Present Controversy Within the Synod,” Minutes of Oct. 11, 1974; published in Lutheran Witness as “An Analysis of Assertions in Present Controversy”): “The question is not: ‘How may Seminex students be qualified for the ministry in The Lutheran Church — Missouri Synod? ’ The question rather is: ‘How has the Synod decided that it wishes to have pastors trained, qualified, called, ordained, and installed in its congregations? ’ In answer to that question the Synod has spoken again and again. Perhaps no other subject receives as much attention in the bylaws. The Synod has stated in great detail that it will train its own pastors, set its own requirements, do its own certifying, etc. In short, the Synod has made it plain that it will not permit a small group within the Synod to usurp these functions which the Synod has reserved to itself.”

Thus, provided the member teaches and practices entirely in accordance with the confessional standard of the Synod, membership in the Synod is not incompatible with teaching outside the Synod’s designated structures. (Teaching in such capacity does not qualify one to be called or to have an active position on the roster of the Synod, but would be done, in the absence of another contemporaneous position of active service under , as an inactive member, candidate or emeritus. Nor does the fact that members of the Synod are teaching in such capacity confer the ability on a faculty to declare graduates qualified for service in any sort of church work in Synod congregations or schools; the Synod has definite mechanisms for that otherwise.)

Another factor must be considered, that raised most directly by the question as posed, which is the constitutional expectation that all members of the Synod renounce “unionism and syncretism of every description” ( 2). When does an orthodox contribution to a heterodox effort violate the conditions of membership (cf.

2)? To this question, broadly speaking, the commission has spoken in Op. 18- 2875 (Minutes of April 6 –7, 2018): For the purposes of understanding the Constitution— while there may be shades of meaning, with unionism tending more toward commingling practices or services and syncretism toward commingling doctrines or teaching—there is considerable overlap between the two.

An historically defensible, precise dissection of these terms is unlikely to be possible. For the purposes of understanding the Constitution, though, it is not necessary sharply to divide the terms. The phrase “ aller Kirchen - und Glaubens-mengerei” or “unionism and syncretism of every description ” is best understood as an expansive single thought —perhaps a pleonasm, the use of two almost identical terms to avoid any possible misunderstanding or minimization.

While other terms are also used in the literature of the Synod to express the same concept, the Constitution clearly states that it is the expectation of members of the Synod that, because they “accept without reservation the Scriptures and the Lutheran Confessions” (), they would renounce activities of every description that would commingle the confession, teaching, or practice of that true and salutary confession with any contrary (and therefore false and harmful) confession, teaching, or practice. Whether or not any particular activity or “fact situation” would be determined to constitute unionism or syncretism ( Kirchen- und Glaubensmengerei ) and, therefore, to constitute a violation of the conditions of membership in the Synod, falls outside of the authority of the Commission on Constitutional Matters. Such a decision is properly the responsibility of the ecclesiastical supervisor of that member.

… The positive requirement of the Constitution is not only that members avoid the prohibited example activities, but that they renounce unionism and syncretism of every description. Contrary to that required renunciation are any activities inviting the reasonable inference that the exclusive teaching and practice of Synod’s confession () may, as a matter of indifference or insignificance, be laid aside, replaced by, or comingled with other teachings or practices. Such activities violate 2 and give the sort of offense contemplated in 1’s offensive conduct.

This sort of offense presents a second manner (in addition to not teaching entirely in accordance with the confessional standard of the Synod), perhaps not the last imaginable, in which a member of the Synod teaching in a higher education institution—othe r than one regulated by the Synod under its confessional standard—that is preparing individuals for ministry could run afoul of the conditions of membership. As the commission noted in the above-cited opinion, “Whether or not any particular activity or ‘fact situation’ would be determined to constitute unionism or syncretism and, therefore, to constitute a violation of the conditions of membership in the Synod, falls outside of the authority of the Commission on Constitutional Matters. Such a decision is properly the responsibility of the ecclesiastical supervisor of that member.” That said, such teaching per se is not a violation of the conditions of membership in the Synod, even if it contributes to the formation of church workers for service outside the Synod. While the situation is not exactly the same, the commission notes an analogy to the fact that an ordained member of the Synod may, while a member of the Synod, serve a congregation that is not a member of the Synod (as provided for under [c] and in the tradition stretching back to the Synod’s beginning).

Question 2: A congregation establishes a non-rostered “leader” of a “campus” of a congregation, who functions in most if not all ways as the pastor loci (preaching, conducting the service, and providing pastoral leadership). Members refer to him as pastor, though he is not listed publicly as such. Is this contrary to and, if so, what recourse does the Synod have?

Opinion 2: Without commenting on the particular fact pattern, the commission addresses itself to the question of whether a congregation of the Synod may be served in a pastoral capacity by an individual who is not eligible under to be called to do so or to serve otherwise in that capacity. The commission noted the following in its Op. 23- 3009 (minutes of April 28 –29, 2023). This opinion traced the development of from 1969 Res. 5-23, “To Reiterate in Bylaws that Member Congregations Must Be Served by Members of the Synod,” through the changes made by 2001 Res. 7 -12, “To Separate Calling and Service of Clergy from Other Church Workers,” concluding that: The terms call and be served by [in ] are not to be regarded as synonyms. In today’s practice many others are serving congregations by leading worship without a call. Emeritus pastors regularly serve as vacancy pastors, at times for congregations not in the process of calling, or regularly simply serve in vacant congregations every Sunday, often for periods of a year or more, which might include offering the sacraments and conducting weddings and funerals. Ordained ministers on candidate status also are eligible to serve in the same way. Students from the seminaries of the Synod lead worship in congregations that have no pastor. Vicars on occasion are the only one serving congregations with their supervising pastor called by and serving a neighboring congregation.

While these other instances of serving reflect a wide variety, what is consistent is that those serving are either ordained members of the Synod, or students authorized by a seminary of the Synod and under the supervision of an ordained member of the Synod.

In regard to the question posed in Op. 23-3009, as to whether a congregation that has “ as its worship leader a pastor, not called by the congregation, who is Lutheran and has promised to teach completely in line with LCMS teaching but is on neither the roster of the Synod nor that of a church body in altar and pulpit fellowship with the Synod” is “in violation of 3 and ,” the commission understanding “ the term worship leader as used in this question to mean the individual performing the role of the pastor in the public worship of the congregation, proclaiming the Word and/or administering the Sacraments ,” the commission found: A pastor who is not a member of the Synod or of a church body with which the Synod is in altar and pulpit fellowship is ineligible either to be called by a congregation or to serve a congregation by leading worship. For a congregation to so call or be served would be a violation of the conditions of membership under 3.

requires congregations to “call and be served only by” individuals listed in the three following categories (i.e., ordained ministers on the roster of the Synod; ca ndidates certified for initial placement, for example, by successful completion of colloquy; and ordained ministers in good standing on the roster of church bodies in altar and pulpit fellowship with the Synod), the word “only” highlighting the exclusive nature of this requirement. A congregation may not call an excluded individual. The words “and be served by” indicate that a congregation also may not be served by an excluded individual in a pastoral capacity (such as by his leading worship), even if it do es not call him (Cf. Op. 20 -2957).

By calling or being served by an excluded individual, the congregation puts its membership in the Synod in jeopardy (; 3; XIII 1).

The commission finds this opinion to be directly applicable here. A district president who “becomes aware of information or allegations that could lead to expulsion of a member from the Synod,” which the above would constitute, “shall commence” the action of , “Expulsion of Congregations or Individuals from Membership in the Synod.” Part of this process is admonition and reproof, in the hope that the offensive conduct may cease and expulsion prove unnecessary.

Question 3: Rostered workers establish a seminary “in response to requests from congregations and church leaders for a quality, affordable, effective online degree program that would equip potential pastors and church workers for missional ministry in areas that are not currently being served.” Is this contrary to and/or , and if so, what recourse does the Synod have?

Opinion 3: Again without commenting on the particular fact pattern, the commission distills two distinct questions and a broader concern. All of them it addresses under one fundamental presumption, namely, that the doctrine and practice taught by a member of the Synod in any such scenario is in every respect consonant with the doctrine and practice of the Synod; otherwise this alone would constitute a clear violation of the expectations of membership in the Synod.

First, do the conditions of membership in the Synod prohibit a member of the Synod from participating in or promoting the training of church workers, outside institutions approved by the Synod for this purpose, who are either not drawn from, or not to be commended for the service of, Synod congregations?

This question the commission has answered above under Opinion 1. Provided the member’s teaching and practice is orthodox and free of “ activities inviting the reasonable inference that the exclusive teaching and practice of Synod’s confession () may, as a matter of indifference or insignificance, be laid aside, replaced by, or comingled with other teachings or practices,” such participation or promotion is not contrary to the conditions of membership in the Synod.

Second, do the conditions of membership in the Synod prohibit a member of the Synod from participating in or promoting the training of church workers, outside institutions approved by the Synod for this purpose, who are drawn from and to be commended for the service of congregations of the Synod?

As stated in , “The Constitution, Bylaws, and all other rules and regulations of the Synod apply to all congregational and individual members of the Synod.” Further, “While congregations of the Synod are self -governing (Constitution Art. VII), they, and also individual members, commit themselves as members of the Synod to act in accordance with the Constitution and Bylaws of the Synod under which they have agreed to live and work together and which the congregations alone have the authority to adopt or amend through conventions” (). As stated above under Opinion 1, those Bylaws under which all have agreed to “live and work together” and which “apply to all congregational and individual members” require workers to be called for commissioned service () and those to be called or simply who will be serving in a pastoral capacity () within the Synod to be admitted to the ministry by the Synod for said purpose.

It is one thing for a member of the Synod to advocate for changes to the Bylaws or even Constitution of the Synod, which may be made by the congregational member delegates in convention if so persuaded (). It is another thing for a member of t he Synod to advocate for or participate in the circumvention of the Bylaws or Constitution of the Synod, for example, by facilitating and promoting to member congregations a route to pastoral ministry that is incompatible with the requirements of . As noted above from Ag. 682, “The Synod has stated in great detail that it will train its own pastors, set its own requirements, do its own certifying, etc. In short, the Synod has made it plain that it will not permit a small group within the Synod to usurp these functions which the Synod has reserved to itself.”

The Synod has provided exclusive mechanisms for preparing and qualifying workers to serve in the ordained and commissioned ministries of the Synod (), apart from which no one can be qualified for such service. makes clear that congregations, as regard the ordained ministry, are to call and be served only by those who have been so qualified. The contemplated seminary cannot so qualify men for service as one of the Synod’s own seminaries could. As far as members of member congregations being prepared for such service are concerned, neither can colloquy complete what such a seminary began. states clearly that members of Synod congregations are not permitted to seek pastoral training elsewhere and then to enter onto the roster of the Synod by colloquy. By this prohibition, the Synod fully closes the door on the idea that members of member congregations should be so induced. There is no legitimate route to ordained ministry in a Synod congregation for a member of a member congregation other than through a seminary authorized by the Synod for such formation and qualification. Participating in and promoting an unauthorized seminary for individuals who are drawn from and to be commended for the service of congregations of the Synod is therefore contrary to the order set forth in the Bylaws of the Synod.

The commission has held previously (Ag. 729 H, J, “Opinion re Removal of District Presidents from Office,” Minutes of Feb. 21 – 22, 1975) that “the first object of the Synod is the conservation and promotion of the unity of the true faith and a united defense against schism and sectarianism ( 1)” and that “a district president who deliberately acts contrary to the Bylaws may have the effect of creating an unrest and a schism in the Synod,” and that “any member of the Synod (which includes Distr ict Presidents) whose deliberate acts have the effect of creating a schism in the Synod may be guilty of an offensive conduct ( –18), which, if persisted in after proper admonition, may lead to expulsion.” ( 1). The “regular call o f pastors and any commissioned ministers” is a condition of membership in the Synod ( 3). Inducing or facilitating a Synod member congregation to call or be served otherwise (contrary to ) risks separating that member from the Synod (see especially ), creating, in effect, a schism. For at least this reason, participation in or promotion of the training of church workers, outside institutions approved by the Synod for this purpose, who are drawn from Synod congregations and to be commended for the service of congregations of the Synod is an activity that could result in removal from the roster of the Synod, provided that the ecclesiastical supervisor and subsequent panel conclude that this is, in fact, an offensive conduct. The commission’s former opinions have indicated this conclusion to be possible.

Finally, the commission notes, considering questions 2 and 3, a broader concern. Can a member congregation extend the Office of the Holy Ministry to “others” by way of men not admitted to ministry under ? A congregation in relation to “others” is not acting alone but as a member of the Synod. A congregation establishing some relationship with “others” as the congregation acting independent of its synodical commitments, as it would in such a case, would seem to be engaged, at least, in “selective fellowship.” Where a member congregation of the Synod arranges for some other group to be served with pastoral ministry, the congregation gives of that with which it is served —that is, of ministers admitted to the ministry by the Synod under —an d not of something else.

Relative Force of 1989 Res. 3-10, 2005 Guidelines, and 2016

Res. 5-14, regarding Man and Woman in the Church (25-3071)

Minutes of May 28–29, 2026 By an email of August 15, 2025, a member of the Synod, a pastor, requested an opinion on the following question(s). The commission requested and received input from the Commission on Theology and Church Relations (CTCR).

Background: 1989 Res. 3-10, “To Address Questions re: Service of Women in Congregational Offices,” included, among other actions, the directive: “…that the congregations of the Synod be urged to conform their practice to [the] counsel [provided by the CTCR in this m atter],” namely, that it “strongly recommends that to avoid confusion regarding the office of the public ministry and to avoid giving offense to the church, such assistance [with communion distribution] be limited to men .”

1 This is presumed to remain in force. Synod’s “Task Force Guidelines for the Service of Women in Congregational Offices” (2005), in their section on women assisting in the distribution of Holy Communion (pp. 21–22), quote verbatim from 1989 Res. 3-10 the phrases to which the congregations of the Synod were “urge(d) to conform.” 2016 Res. 5-14, “To Reaffirm Biblical Teaching on Man and Woman in the Church,” also resolved: “That the three specific recommendations from the 2005 Task Force Guidelines for the Service of Women in Congregational Offices (pp. 21–22) be commended to the people of the Synod.”

Question: Does the “urge to conform” directive from 1989 Res. 3 -10—having been adopted by the Synod and never rescinded—retain its original force and expectation for the congregations of the Synod, even when re -presented within later documents that are merely “comm ended” (e.g., the 2005 Guidelines as commended in 2016 Res. 5-14)? In other words:

  • Does the act of commending a document in which an

adopted and still -in-force resolution is quoted alter the binding or advisory force of the quoted material?

  • Or does the quoted language retain its original status and

effect as adopted by the Synod in 1989, regardless of the softer term “commend” used in later resolutions?

  • As a result, should congregations continue to be “urged to

conform” on the question of women distributing communion, or are they merely “commended”? How does the difference between these words affect our action as congregations of the LCMS?

Opinion: 1989 Res. 3 -10 noted a “divergence of opinion in the Synod concerning women serving as assistants in the distribution of Holy Communion” and that “the Commission on Theology and Church Relations (CTCR) has stated in its 1983 report Theology and Practice in the Lord’s Supper (p. 30) and reaffirmed in the 1985 report Women in the Church that ‘the commission strongly recommends that to avoid confusion regarding the office of the public ministry and to avoid giving offense to the church, such assistance be limited to men’ (p. 47).” As does the 2016 resolution, 1989 Res. 3-10 commended 2 the former CTCR report to the congregations for “study and guidance in this matter” and resolved “that the pastors and congregations of the Synod be urged to conform their practice to this counsel” ( Proceedings, 116). The language of item 14 in the noted 1983 CTCR report is as follows: May women serve as assistants in the distribution of the Lord’s Supper?

While some might argue that assisting the presiding minister in the distribution of the elements is not necessarily a distinctive function of the pastoral office, the commission strongly recommends that, to avoid confusion regarding the office of the public ministry and to avoid giving offense to the church, such assistance be limited to men.

This “distinctive function” language echoes that of 1969 Res. 2-17, “To Grant Women Suffrage and Board Membership,” which “accepted” the following “declaration” as a “guide”: 1. Those statements of Scripture which direct women to keep silent in the church and which prohibit them to teach and to exercise authority over men, we understand to mean that women ought not to hold the pastoral office or serve in any other capacity involving the distinctive functions of this office.

1989 Res. 3-10 thus “strongly recommends”—for the stated reason of avoiding “confusion regarding the office of the public ministry and to avoid giving offense to the church”—to limit those assisting the presiding minister in distribution of the elements to men. 1989 Res. 3-10 stops short of establishing as a position of the Synod that women assisting in distributing the Lord’s Supper are engaging in a distinctive function of the pastoral office. Had it drawn that conclusion, such participation by women would be a prohibited activity in accordance with the position of the Synod expressed in 1969 Res. 2-17, namely, that on the basis of definite statements of Scripture women “ought not to hold the pastoral office or serve in any other capacity involving the distinctive functions of this office.” Neither did it state the opposite conclusion, that the service of women in this capacity is a definite adiaphoron, a thing neither commanded nor forbidden. Rather, it urges seriously upon the congregations that —to avoid any confusion or offense about the practice either being or suggesting such prohibited service —it not be practiced.

With regard to 2016 Res. 5 -14, the commission notes from the minutes that the floor committee changed “be endorsed” to “be commended” in the key fourth resolve, as to the recommendation “that lay assistance in the distribution of the elements in the celebration of Holy Communion, in order ‘to avoid confusion regarding the office of the public ministry and to avoid giving offense to the church,’ [1989 Res. 3-10] be limited to lay men.” This restatement in other words does not alter the force of the strong recommendation of 1989. At the same time, that recommendation remains just that.

The commission feels a further word clarifying the force of these resolutions may be helpful, as some may question, on the one hand, how the convention can make a strong recommendation against a practice that it seems to concede may be adiaphorous, that is, neither commanded nor forbidden by God (FC Ep X 1, FC SD X 2). Or, on the other hand, if this is simply advice, some may question what value it has. To understand the constitutionality and the weight of such convention actions, it is necessary to understand the confession on which the Constitution is based. The Formula of Concord, which is “a true and unadulterated statement and exposition” () of that Word of God that is to govern “all matters of doctrine and conscience” ( C) provides regarding adiaphora: We believe, teach and confess that the community of God in every place and every time has, according to its circumstances, the good right, power, and authority to change and decrease or increase ceremonies that are truly adiaphora. They should do this thoughtfully and without giving offense, in an orderly and appropriate way, whenever it is considered most profitable, most beneficial, and best for good order, Christian discipline, and the Church’s edification. Furthermore, we can yield and give in with a good conscience to the weak in faith in such outward adiaphora. Paul teaches this in and proves it by example (see ; 21:26; ).

(FC SD X 9; see also 7–8) It is thus entirely consistent with the Constitution of the Synod for the convention—without elevating human rules to have supposedly divine authority (ctr. FC SD X 26 and C) —to take even a strong and unqualified advisory stance with regard to its membership on a matter that may be (or even on a matter that is) an adiaphoron, because, as the remainder of FC X makes clear—in the particular context of persecution but with a sense applicable generally—adiaphora communicate, even confess , in “works and actions” what is in the “words” (FC SD X 10).

3 In this instance, the convention has taken the unqualified advisory stance, with regard to a practice that may be adiaphorous (it has not definitively said that it is), that the practice is to be avoided.

4 While the convention is “not an ecclesiastical government exercising legislative or coercive powers, and with respect to an individual congregation’s right of self -government it is but an advisory body,” and while, “accordingly, no resolution of the Synod imposing anything upon the individual congregation is of binding force if it is not in accordance with the Word of God or if it appears to be inexpedient as far as the condition of a congregation is concerned” (), the advice of the convention in such a matter is an important part of what the Synod exists to give (see also 6–7). That is, it is an advisory body and congregations participate in the Synod to share and receive such advice. Where the convention has given such advice, the officers and agencies of the Synod are bound, as part of their carrying out the direction given by the convention, to offer it to the member congregations and individuals of the Synod.

1 The original form of the question cited 1989 Res. 3-10 as saying “that the congregations of the Synod be strongly urged to conform their practice to the counsel provided by the CTCR in this matter,” but this is not a quotation but a paraphrase or conflati on of the CTCR’s “ strongly recommends” with the convention’s “urge to conform.”

2 Note that the “commendation” language of the first resolve of 1989 Res. 3-10 corresponds exactly to the “commendation” of the language from 1989 Res. 3-10 in 2016 Res. 5- 14. The use of “commendation” language in the 2016 resolution can hardly, therefore, be understood to diminish the sense of urging in 1989 Res. 3-10, since these two were already juxtaposed in 1989. Neither does the 2016 resolution conflict in any sense with, or rescind any part of, the 1989 resolution.

3 The convention has done so from the beginning: Consider the Synod’s first Constitution, Chap. V 14: “Synod holds in accordance with the 7th article of the Augsburg Confession that uniformity in ceremonies is not essential; yet on the other hand Synod dee ms such a uniformity wholesome and useful, namely for the following reasons: a. because a total difference in outward ceremonies would cause those who are weak in the unity of doctrine to stumble; b. because in dropping heretofore preserved usages the Chur ch is to avoid the appearance of frivolity and a desire for innovations; Furthermore Synod deems it necessary for the purification of the Lutheran Church in America, that the emptiness and the poverty in the externals of the service be opposed, which, havi ng been introduced here by the false spirit of the Reformed, is now rampant. All pastors and congregations that wish to be recognized as orthodox by Synod are prohibited from adopting or retaining any ceremony which might weaken the confession of the truth or condone or strengthen a heresy, especially if heretics insist upon the continuation or the abolishing of such ceremonies. Where private confession is in use, it is to be kept according to Article 11 of the Augsburg Confession. Where it is not in use, the pastor is to strive through teaching and instruction to introduce it. Yet in congregations where the total abolishing of general confession and absolution is hindered by unsurmountable obstacles, general confession may be kept along with private confess ion. The desired uniformity in the ceremonies is to be brought about especially by the adoption of sound Lutheran agendas (church books).”

4 Contrast the same 1989 convention’s distinct treatment of what may seem to be a similar issue in its Res. 3 -14, detailed helpfully in the Commission on Theology and Church Relation’s October 2025 report, “Unity in Doctrine, Uniformity and Variety in Practice.”