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Recovering Biblical Manhood and Womanhood
A Response to Evangelical Feminism
Wayne Grudem and John Piper
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Is It Legal for Religious Organizations to Make Distinctions
on the Basis of Sex?
Donald A. Balasa
Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof. . . . (First Amendment, United States Constitution)
[A]lthough Congress permitted religious organizations to discriminate in favor of members of their faith, religious employers are not immune from liability for discrimination based on race, sex, [or] national origin. . . . (EEOC v. Pacific Press Publishing Association, 676 F.2d 1272 (1982) at 1276)
The freedom of individuals and groups to practice their religious beliefs unfettered by government interference is a fundamental right guaranteed by the Constitution of the United States. By enacting landmark legislation such as the Civil Rights Act of 1964, Congress "clearly targeted the elimination of all forms of discrimination as a 'highest priority.'"{1} Balancing the First Amendment right of free exercise of religion with the Congressional mandate to eradicate discrimination has proven a monumental task for the judicial system.
The purpose of this chapter is twofold. First, court decisions determining whether religious organizations are exempt constitutionally from prohibitions of sex discrimination in employment will be examined. An attempt will then be made to derive practical guidelines for religious organizations desiring to make employment distinctions on the basis of sex. Second, the question of whether educational accrediting bodies can lawfully deny a religious school accreditation if the school assigns different roles to men and women will be discussed.
I. Are Religious Organizations Constitutionally Exempt from Prohibitions of Sex Discrimination in Employment?
A. Legislative History
Title VII of the Civil Rights Act of 1964{2} is the backbone of federal antidiscrimination legislation:
Employer practicesIt shall be an unlawful employment practice for an employer-
(1) to fail or refuse to hire or to discharge any individual, or otherwise to discriminate against any individual with respect to his compensation, terms, conditions, or privileges of employment, because of such individual's race, color, religion, sex or national origin; or
(2) to limit, segregate, or classify his employees or applicants for employment in any way which would deprive or tend to deprive any individual of employment opportunities or otherwise adversely affect his status as an employee, because of such individual's race, color, religion, sex, or national origin.
The original House of Representatives' version of the Civil Rights Act exempted all religious entities from the Act's coverage. The Senate rejected this approach and limited the exemption to religious corporations, associations, or societies with respect to the employment of individuals of a particular religion to perform work connected with the carrying on by such corporations, associations, or societies of their religious activities. The Senate version was accepted by the House and became Section 702 of the Act. The "Section 702 exemption" has been analyzed by the courts in many Title VII cases against religious organizations.
In 1972 another attempt was made to remove religious organizations from the coverage of Title VII. This effort was unsuccessful, but the Section 702 exemption was broadened to allow religious employers to discriminate on the basis of religion with respect to all activities, not just religious activities.{3} Congress, however, has never explicitly permitted religious organizations to discriminate on grounds other than religion (e.g., race, color, sex, or national origin).
B. Court Decisions
Although Congress has not exempted religious groups from Title VII's prohibition of nonreligious discrimination, the courts have done so on a limited basis. There are several federal appellate cases that have held that certain employment distinctions made by a religious organization on the basis of sex are protected by the Free Exercise Clause of the First Amendment and thus are beyond the pale of Title VII scrutiny. A review of the most pertinent decisions is instructive.
In McClure v. Salvation Army,{4} a female "officer" (tantamount to a minister in other denominations), charging that she received "less salary and fewer benefits than similarly situated male officers,"{5} initiated a Title VII action. Conceding that Congress did not intend to insulate religious employers from all sex discrimination charges, the Fifth Circuit Court of Appeals nonetheless ruled that application of Title VII to the relationship between a church and its ministers infringed on constitutionally guaranteed religious liberties, and the court denied Officer McClure's claim. The following language from the court's opinion created a "ministerial exception" to Title VII's prohibition of sex discrimination:
The relationship between an organized church and its ministers is its lifeblood. The minister is the chief instrument by which the church seeks to fulfill its purpose. Matters touching this relationship must necessarily be recognized as of prime ecclesiastical concern. Just as the initial function of selecting a minister is a matter of church administration and government, so are the functions which accompany such a selection. It is unavoidably true that these include the determination of a minister's salary, his place of assignment, and the duty he is to perform in the furtherance of the religious mission of the church.{6}
The "ministerial exception" articulated in McClure found fuller expression in Rayburn v. General Conference of Seventh-Day Adventists.{7} Carole Rayburn, who held a Master of Divinity degree from the denomination's seminary, did not receive an appointment as an unordained{8} associate in pastoral care in a Seventh-Day Adventist church and sought relief under Title VII. The position entailed serving as pastoral advisor to the children's Sabbath school, leading Bible studies, counseling and pastoring the singles group, and preaching occasionally from the pulpit. Noting the spiritual importance of the roles assumed by an associate in pastoral care, the Fourth Circuit ruled that "introduction of government standards to the selection of spiritual leaders would significantly, and perniciously, rearrange the relationship between church and state."{9} Ms. Rayburn's Title VII action, therefore, ran afoul of the First Amendment and was dismissed.
A more difficult set of facts confronted the Fifth Circuit Court of Appeals in EEOC v. Southwestern Baptist Theological Seminary.{10} Southwestern, a Southern Baptist seminary, refused to file a report used by the Equal Employment Opportunity Commission to ascertain whether unlawful employment practices were being committed. The EEOC sought to compel Southwestern to submit the report; the Seminary contended that compliance with the EEOC request would be repugnant to its First Amendment rights.
Relying upon the decision in McClure, Southwestern argued that the Free Exercise Clause barred the application of Title VII to the employment activities of a seminary. The court agreed in part. It held:
(1) that the seminary was a "wholly sectarian" (i.e., wholly denominational) institution;
(2) that it was entitled to the status of "church" for First Amendment purposes; and
(3) that the seminary's employment relationship with "ministerial" personnel should be afforded the same protection as the church/pastor relationship.{11}
The court then grappled with the thorny question of which employees would be considered "ministers" according to the McClure standard. Faculty were deemed to be intermediaries between the Southern Baptist Convention and future SBC pastors. As a result, Title VII did not apply to the employment relationship between the seminary and its faculty. Members of the administrative staff were classified as either "ministerial" or "non-ministerial," with only the former being entitled to McClure-type protection.{12} Finally, support staff were considered non-ministerial and could seek redress under the antidiscrimination provisions of Title VII.
The end result of the case was that the Equal Employment Opportunity Commission was not constitutionally forbidden from obtaining information from Southwestern Baptist Seminary about its non-ministerial employees. The seminary, however, could not be ordered to provide information to the EEOC about ministerial employees.
Yet another matter balancing free exercise and Title VII considerations made its way to the Fifth Circuit. In EEOC v. Mississippi College,{13} Mississippi College---a Southern Baptist-affiliated four-year liberal arts institution---was accused by a female part-time assistant psychology professor of violating Title VII. The college allegedly discriminated against her on the basis of sex by hiring a male to fill a full-time position in the psychology department. In its defense, Mississippi College asserted that the male professor was selected because his educational and research background was a better fit for the vacant position. Moreover, the college had a written policy of preferring to hire Baptists---a practice unquestionably protected by the Section 702 exemption---and the male professor was a Baptist, but the female complainant was not.
Since Mississippi College's hiring decision was arguably based on religious factors, the court dismissed the case and did not reach the sex discrimination question. The court nevertheless did seize the chance to distinguish the facts in Mississippi College from the McClure scenario and left the unmistakable impression that the female professor would have had a full hearing on the merits of her sex discrimination charge had she been a Baptist.
The College is not a church. The College's faculty and staff do not function as ministers. The faculty members are not intermediaries between a church and its congregation. They neither attend to the religious needs of the faithful nor instruct students in the whole of religious doctrine. That faculty members are expected to serve as exemplars of practicing Christians does not serve to make the terms and conditions of their employment matters of church administration and thus purely of ecclesiastical concern. The employment relationship between Mississippi College and its faculty and staff is one intended by Congress to be regulated by Title VII.{14} [emphasis added]
Another passing comment by the court in Mississippi College sheds some light on whether religious institutions may---without fear of legal reprisals---make employment distinctions on the basis of sex. The court remarked, "The only practice brought to the attention of the district court (i.e., the trial court) that is clearly predicated upon religious beliefs that might not be protected by the exemption of Section 702 is the College's policy of hiring only men to teach courses in religion. (Footnote 12: . . . Dr. Nobles [the President of the College] explained that the practice of not hiring women to teach religion courses was based upon Bible scriptures indicating that pastors and deacons should be men.)"{15} If the EEOC did attack the hiring of only male faculty to teach theology, the school would have the opportunity "to litigate in a federal forum whether Section 702 exempts or the First Amendment protects that particular practice."{16}
The final two cases move even more sharply away from the holdings in McClure and Rayburn and should be given careful heed by religious entities.
EEOC v. Pacific Press Publishing Association{17} involved a conflict between a Seventh-Day Adventist publishing house and a married female employee working as an editorial secretary. Pacific Press paid married men a higher rental allowance than single men, who in turn received more than female employees. The plaintiff, Lorna Tobler, objected to this practice, as well as to the facts that she was not given the annual utility allowance received by married men and was not paid the automobile allowance that married men, single men, and single women were given. Tobler filed a Title VII complaint with the Equal Employment Opportunity Commission.
During most of her tenure with Pacific Press, Mrs. Tobler's duties included administrative and discretionary responsibilities as well as secretarial tasks. Drawing upon the reasoning of McClure, Southwestern and Mississippi College, the Ninth Circuit decided that Tobler's duties did not "go to the heart of the church's function" as do those of a minister or a seminary teacher.{18} The court likened Tobler's duties to those of non-ministerial staff at Southwestern Baptist Theological Seminary. In addition, the court considered Pacific Press to be less sectarian than a church or a seminary.{19} Consequently, Pacific Press was not insulated by the First Amendment from Title VII charges and was held liable for discrimination.
The court took note of the fact that the Seventh-Day Adventist denomination "does not believe in discriminating against women or minority groups, and that its policy is to pay wages without discrimination on the basis of race, religion, sex, age, or national origin."{20} Not surprisingly, the nondiscrimination policy of the Adventist denomination worked to the disadvantage of Pacific Press. The court reasoned that applying Title VII's prohibition of sex discrimination to Pacific Press could not possibly abridge its free exercise rights, since the policy of the denomination supported equal treatment of the sexes.{21}
EEOC v. Fremont Christian School,{22} a Ninth Circuit decision, is a most unsettling case and has decidedly negative precedential value for religious organizations.
Fremont Christian School, a private school owned and operated by the Fremont Assembly of God Church, provided instruction from preschool through the twelfth grade. Because of its adherence to the belief that only the husband can be the "head of the household,"{23} the school provided health insurance to married men and single persons, but not to married women. A married female employee brought action against Fremont Christian School on the basis of the Equal Pay Act{24} and Title VII of the 1964 Civil Rights Act.
Emphasizing that wages and other conditions of employment at Fremont Christian School were comparable for all employees regardless of sex and that married female employees were eligible for group life and disability insurance, the court found that requiring the school to provide health insurance benefits to married females would not infringe on the free exercise of its religious beliefs. Even though the district (trial) court assumed the school's policy to be based on religious belief,{25} the Title VII action was allowed to go forward despite the fact that a plausible religious rationale for different treatment of the sexes was offered by the school. The court almost invites the inference that, if there had been a more consistent pattern of higher pay and more benefits for heads of households, a stronger argument for First Amendment protection could have been made.{26}
C. Practical Principles
What overarching principles can be gleaned from these diverse cases? How can a religious organization avoid challenge to its employment policies without compromising its doctrinal convictions? Are there certain practices that tend to arouse the curiosity (and the hostility) of the Equal Employment Opportunity Commission?
There appear to be three factors that the courts take into account in determining whether employment distinctions made by a religious entity on the basis of sex are immunized by the First Amendment from attack under antidiscrimination statutes:
1. The nature of the religious institution.
2. The nature of the employee's position and duties.
3. The religious institution's rationale for treating males and females differently.
The Nature of the Religious Institution and the Nature of the Employee's Position and Duties
Confronted with the assignment of preventing the anti-discrimination protections of Title VII from colliding with the free exercise of religion, the courts in the aforementioned cases have resorted to two devices:
(1) Ranking religious organizations according to how "sectarian" they were, and
(2) Determining how central the role of the employee allegedly discriminated against was to the religious character of the organization.
Mindful of how scrupulously the Supreme Court has sought to avoid meddling in internal church disputes, the courts in McClure and Rayburn treated churches as the most sectarian of all religious entities and refused to tamper with a church's selection of a pastor. Prima facie evidence of sex discrimination did not dislodge the courts from a hands-off posture toward the thoroughly religious position of pastor.
The Southwestern court deemed the seminary to be a "wholly sectarian" institution and thus on a par with a church. Faculty and "ministerial" administrators were analogous to pastors and beyond the reach of Title VII. But the Fifth Circuit would not allow the seminary to escape its Title VII obligations vis-à-vis support staff and "non-ministerial" administrators.
A Christian college was assigned a lower rank on the "sectarian scale." An examination of the purpose and operation of Mississippi College resulted in the Fifth Circuit classifying the school as "pervasively sectarian" rather than "wholly sectarian." Faculty teaching nonreligious courses (such as experimental psychology) could not be discriminated against without legal consequences.
Religious publishing associations (Pacific Press) and religious elementary and secondary schools (Fremont Christian School) were assigned an even lower station on the sectarian continuum. A female editorial secretary at the publishing house and a female rank-and-file employee of the school could prosecute sex discrimination claims against their respective employers without constitutional impediment.
Two general principles can be formulated from this line of cases:
1. The more sectarian a religious entity, the more likely it is to be shielded by the First Amendment from sex discrimination actions.
2. The more directly the employee's responsibilities are related to the religious purposes and practices of the employer, the less likely a Title VII action could withstand constitutional attack.
These two principles distill the case law into its essential elements. They also provide religious institutions with a practical framework for assessing the legality of their employment policies. But how will these principles be applied in marginal situations? Does a church face less legal peril than Fremont Christian School if it gives salary and benefits preferences to male heads of households holding non-ministerial positions? Even though a seminary's dealings with its faculty are beyond the reach of Title VII, is a Christian college courting a lawsuit if it prohibits women from holding certain positions in its theology department? Where would a court place a parachurch organization on the "sectarian continuum," and what constitutional privileges would it be accorded?
These questions are not easily answered. Indeed, the United States Constitution created a judicial branch for the very purpose of resolving controversies of this nature, and a case-by-case determination of the proper balance between the First Amendment and Title VII is inevitable. The third factor weighed by the courts in establishing boundaries between freedom of religion and the right to equal employment opportunities, however, may be the most determinative.
The Religious Institution's Rationale for Treating Males and Females Differently
For those situations in which the employment practices of a religious organization are not clearly sheltered by the First Amendment, it is imperative that the organization demonstrate that the distinctions between males and females are predicated on religious tenets. If the sex distinctions are motivated by prejudice or are the vestiges of nonreligious traditions, they probably will not pass muster under Title VII and other anti-discrimination laws. If the distinctions are solidly grounded on fundamental doctrines of the faith and are clearly articulated in the organization's governing documents and policies, a disgruntled employee would be hard-pressed to overcome a free-exercise defense raised by the religious body.
Pacific Press Publishing Association could not show that the smaller benefit package Mrs. Tobler received was necessitated by Seventh-Day Adventist beliefs. In fact, the denomination stated that its policy was to not discriminate between men and women. Given these facts, a finding for an employee like Mrs. Tobler was virtually a foregone conclusion.
Fremont Christian School's defense to the Title VII allegations was better conceived. Its views of headship in the family were well supported by the doctrines of the church, and the school did justify its denial of health insurance to married women by pointing to religious tenets reflected in the school's written policies. Nevertheless, its failure to consistently carry out its "head of the household" beliefs proved to be its undoing.
The practice of paying married male employees more than married female employees was abandoned by the school because it was thought to be illegal. Ironically, Fremont Christian School's good-faith effort to abide by the law backfired. The district court opined that the school's policy of providing comparable wages to male and female employees, as well as its practice of extending eligibility for disability and group life insurance to married females, constituted an "implicit nondiscrimination policy." Limiting health insurance to married men, therefore, was inconsistent with the school's otherwise egalitarian practices and was sufficient to convince the court that doctrinal convictions could not have been the basis for denying health insurance to married females.
Religious organizations can learn from the mistakes of Pacific Press and Fremont Christian School. Employment distinctions on the basis of sex must be predicated on previously articulated religious principles. Furthermore, these principles must be documented by the religious body and must be applied universally and consistently.
II. May Accrediting Bodies Deny Accreditation on the Basis of School Policy Regarding Distinct Roles for Men and Women?
Another pressing issue of concern to seminaries and religious colleges is whether private accrediting bodies can lawfully make the granting of accreditation contingent on the abolition of distinct roles for men and women. The case law on this specific point is sparse; some broad legal concepts and one pertinent decision will be treated cursorily.
A. Broad Legal Concepts
Antitrust is the area of law relevant for this analysis. The foundation of American antitrust jurisprudence is the Sherman Act,{27} which was adopted by Congress in 1890. Section 1 of the Act states, in part:
Every contract, combination in the form of trust or otherwise, or conspiracy, in restraint of trade or commerce among the several States, or with foreign nations, is hereby declared to be illegal.
An immediate interpretive problem confronted the courts. Which contracts, combinations, or conspiracies constituted "restraints of trade" as envisioned by the drafters of the Sherman Act? In the strictest sense, any contract restrains trade! Since the outlawing of all contracts was obviously not the intent of Congress, the United States Supreme Court created a "rule of reason" in evaluating Sherman Act cases. In United States v. American Tobacco Co.,{28} the Court pointed out that it had construed the words "restraint of trade" as embracing "only . . . acts or contracts or agreements or combinations which operated to the prejudice of the public interests by unduly restricting competition or by unduly obstructing the due course of trade or which, either because of their inherent nature or effect, or . . . evident purpose . . . injuriously restrain trade."{29}
How do antitrust principles impact accrediting bodies? First, the courts have ruled that all private sector associations, including accrediting entities, are automatically "combinations" within the meaning of Section 1 of the Sherman Act.{30} The activities of accrediting groups, therefore, can be reviewed to determine whether they are unreasonable restraints of trade.
Second, any standards of an accrediting body that exclude applicants must be rationally related to the purposes such standards are designed to further.{31} If, for example, an accreditor were to require the board of directors of a school to have female members and the school was denied accreditation for failure to comply with this criterion, the school might have grounds for antitrust action against the accrediting agency.
B. Case Law Precedent
Marjorie Webster Junior College v. Middle States Association of Colleges and Secondary Schools{32} remains the leading case applying antitrust law to accreditation.
Marjorie Webster was a proprietary junior college for women in the District of Columbia. Middle States was a nonprofit corporation accrediting secondary schools and institutions of higher learning in its geographical region. Marjorie Webster's application for accreditation was denied because it was not a nonprofit organization. The college sued Middle States on antitrust grounds, claiming that the denial of accreditation because of its for-profit status was an unreasonable restraint of trade. Because Middle States was assertedly a quasi-governmental entity, Marjorie Webster also maintained that it was deprived of property without due process of law in contravention of the Fifth Amendment of the United States Constitution.
The District of Columbia Court of Appeals refined and enunciated two points of law germane to the question at hand:
1. The more important the credential (e.g., accreditation) for the successful operation of the applicant, the greater the extent of judicial scrutiny of the exclusionary standard.
2. All standards must be reasonable, applied with an even hand, and not in conflict with the public policy of the jurisdiction.{33}
Turning to the facts, the court noted that denial of accreditation by Middle States was not crucial to the successful operation of Marjorie Webster. Middle States accreditation was voluntary, and the college had been granted the credentials mandated by the state and federal governments. Many proprietary schools, including Marjorie Webster, had thrived without Middle States accreditation. Furthermore, for-profit schools were free to organize their own accrediting organs and could promulgate standards more suitable for proprietary education. Because withholding this particular accreditation would not appreciably hinder the viability of the college, the substantive reasonableness of the standard was not adjudicated.
C. Application to Religious Schools
What recourse does a religious educational institution have if it is denied accreditation because of differentiated roles for men and women? Assuming that the particular accreditation at issue has direct economic impact and that the distinctions on the basis of sex are founded on religious dogmas (see I.C. above), a school has a good chance of winning an antitrust suit if it can prove at least one of the following three points:
(1) The criterion invoked to deny different roles for men and women is not reasonably related to the purposes of the accreditor.
(2) The criterion is not "applied with an even hand."
(3) The criterion is not consistent with public policy.
Of these three bases for antitrust action, the third holds the most promise. Fortified by the decisions exempting religious organizations from certain antidiscrimination statutes (see I.B. above), a seminary or religiously affiliated school could contend that---if a certain distinction on the basis of sex is not unlawful---it would be contrary to the public policy to allow a private sector accrediting body to deny a valuable accreditation status because of the very same distinction.
For example, the Southwestern Baptist Theological Seminary court allowed a Christian educational institution to restrict theology faculty appointments and ministerial administrative positions to males. As a result, a strong argument could be made that it would be unconscionable for a private accreditor to withhold accreditation from a Christian school because of the accreditor's uniformitarian view of the proper roles of men and women.
* * * * *
It is likely that legal challenges to distinctions on the basis of sex by religious organizations will become more common. This author's hope is that this chapter will help religious entities develop policies and procedures that will avoid legal entanglements.
Endnotes to Chapter Nineteen
{1}EEOC v. Pacific Press Publishing Association, 676 F.2d 1272 (1982) at 1280. See also Senate Report No. 872, 88th Congress, 2d Session. pt. 1 at 11, 24 (1964).
{2}Title VII, Section 702, 78 Stat. 255 (1964).
{3}This expansion of the Section 702 exemption to all activities of the religious entity withstood constitutional challenge in Corporation of Presiding Bishop v. Amos, 107 S.Ct. 2862 (1987). The United States Supreme Court held that the 1972 amendment did not violate the Establishment Clause of the First Amendment.
The current version of Section 702 reads thus:
This subchapter shall not apply to an employer with respect to the employment of aliens outside any State, or to a religious corporation, association, educational institution, or society with respect to the employment of individuals of a particular religion to perform work connected with the carrying on by such corporation, association, educational institution, or society of its activities.
{4}460 F.2d 553 (1972).
{5}Ibid. at 555.
{6}Ibid. at 558, 559.
{7}772 F.2d 1164 (1985).
{8}The Seventh-Day Adventist Church does not permit the ordination of women.
{9}Ibid. at 1169. The court's sensitivity toward a church's right to control employment decisions is reflected in the following statement from its opinion:
It is axiomatic that the guidance of the state cannot substitute for that of the Holy Spirit and that a courtroom is not the place to review the church's determination of God's appointed. (At 1170)
{10}651 F.2d 277 (1981).
{11}Ibid. at 281.
{12}The President and Executive Vice President of the Seminary, the chaplain, the deans of men and women, the academic deans, and those other personnel who equate to or supervise faculty should be considered ministers as well. On the other hand, those administrators whose functions relate exclusively to the Seminary's finance, maintenance, and other non-academic departments, though considered ministers by the Seminary, are not ministers as we used that label in McClure." Id. at 285.
{13}626 F.2d 477 (1980).
{14}Ibid. at 485.
{15}Ibid. at 487.
{16}Ibid.
{17}676 F.2d 1272 (1982).
{18}Ibid. at 1278.
{19}Ibid. at 1282.
{20}Ibid. at 1279.
{21}Ibid.
{22}781 F.2d 1362 (1986).
{23}The tenets [of the Fremont Assembly of God Church] include the belief that the Bible is to be taken literally. Among the doctrinal beliefs held by the Church is the belief that, while the sexes are equal in dignity before God, they are differentiated in role. In light of this conviction, the Church believes, based on, inter alia, Ephesians 5:23, that in any marriage, the husband is the head of the household and is required to provide for that household." Ibid. at 1364.
{24}29 U.S.C.A., Section 206(d).
{25}609 F.Supp. 344 (D.C.Cal. 1984) at 349.
{26}All of the cases dealt with in this section were decided by federal circuit courts of appeals, the courts immediately below the United States Supreme Court. These decisions carry great weight, and---although subject to limitation and refinement by the Supreme Court---are unlikely to be reversed outright.
{27}15 U.S.C.A. Section 1-7.
{28}221 U.S. 106 (1911).
{29}Ibid. at 179.
{30}Eastern States Retail Lumber Dealers Association v. United States, 234 U.S. 600 (1914): American Tobacco Co. v. United States, 328 U.S. 781 (1946).
{31}Jerald A. Jacobs, Association Law Handbook (Rockville, MD: BNA, 1981), pp. 216-223.
{32}Marjorie Webster Jr. College v. Middle States Association of Colleges Secondary Schools, 432 F.2d 650 (D.C.Cir. 1970).
{33}Ibid. at 655.
Copyright 1997 Council on Biblical Manhood and Womanhood. All rights reserved.
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