Analysis of the SBC International Mission Board “Examination Update” and Recommendations from Gray Plant Mooty


Post Overview and My Purposes

This purpose of this particular post is to give my analysis of the Examination Update on the Gray Plant Mooty (GPM) legal firm’s independent investigation of the International Mission Board (IMB) of the Southern Baptist Convention (SBC). GPM’s interim report was posted as a news article on the IMB website on May 22, 2019.

As a futurist, two main concerns I have are to: (1) equip individuals and groups to discern and decide their most preferable pathway forward, and (2) give constructive reasoning and resources for having hope. I have invested much time over the last 45 years, studying systems and abuse issues. Many of my writings come out of those studies and my ongoing interest in developing case studies that help identify systemic abuse in organizations, and give some well-reasoned guidance on how to repair past damages to people, dismantle institutional elements that are harmful and replace them with healthier ones, and prevent future abuse.

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Background Reading and References

Background News Articles: 2018

IMB Statement on Child Abuse and Sexual Harassment (IMB; origination date unknown). This may be a repost of an earlier document. Dr. Paul Chitwood referenced this in his December 12, 2018, statement as being posted June 2018. PREAMBLE: “The IMB is committed to zero tolerance for child abuse and sexual harassment among our personnel. Further, the IMB is committed to communicating clearly and cooperating with our partners to guard against child abuse and sexual harassment. ” The statement then has three sections:

* Zero Tolerance Among Our Personnel

* Cooperation With Our Partners

* Confidential Contact

Statement from IMB’s President Platt, by David Platt (IMB; July 25 2018). OPENING: “I just returned from the last couple of weeks in Sub-Saharan Africa, and after meeting immediately with IMB trustee leaders, I want to speak clearly about recent news concerning an internal IMB investigation in 2007 of alleged sexual abuse by a former youth pastor who had become an IMB missionary and then went on to serve in other ministry leadership positions.” This article also includes an open apology to Anne Marie Miller, whose experiences of sexual abuse by an eventual IMB employee, are recounted in the “recent news” report linked to by then IMB President David Platt.

I am commencing a thorough, outside, independent examination of IMB’s handling of past actions, including this case and any other similar situations. In addition, I am commencing a thorough, outside, independent examination of IMB’s present policies and practices to ensure that our current commitment to zero tolerance for child abuse, sexual abuse, and sexual harassment is completely and consistently enforced across IMB today. Further, I am presently in conversations with leaders of other churches and ministries, particularly within the SBC, to establish practical ways we can and must prevent situations like this in the future. Any attempts to minimize, ignore, cover up, or overlook child abuse, sexual abuse, or sexual harassment are absolutely intolerable, and we must take action together now to ensure safety and support for every person employed or affected by a church or ministry.

Chitwood to continue IMB abuse & harassment study, by Baptist Press Staff (Baptist Press News; December 12, 2018). OPENING: “Newly-elected International Mission Board President Paul Chitwood has promised to continue an independent study of “IMB’s handling of past allegations of abuse and sexual harassment and IMB’s present policies and practices,” according to an IMB news release today (Dec. 12).” This article also includes the full text of the IMB’s press release.

Chitwood’s promise to continue the study, launched under former IMB President David Platt, comes amid Southern Baptist Convention President J.D. Greear’s ongoing Sexual Abuse Advisory Study in partnership with the Ethics & Religious Liberty Commission. The promise also coincides with ongoing legal proceedings in a Texas sexual assault case involving allegations against former IMB missionary Mark Aderholt.

After Platt announced the examination in July 2018, IMB trustee officers selected the Minnesota-based law firm of Gray Plant Mooty to conduct the work. According to the IMB release, trustee officers are overseeing the study and will report to the full board when it is complete.

Documents and News: 2019

Examination Update, by Gray Plant Mooty (IMB; May 22, 2019). This article introduces the investigation, then has a section on the Methodology used, and a section on Summary of Conclusions and Recommendations to Date. This is the article that I have used for my analysis below. I have numbered the paragraphs and bullet points for easier reference there.

IMB Response to External Examination, by Dr. Paul Chitwood (IMB; May 22, 2019). [Editorial Note: This is a statement by IMB President Paul Chitwood in response to the statement by Gray Plant Mooty presented in trustee plenary on May 22.]

IMB pledges to ‘be a leader’ in abuse prevention, by Julie McGowan (Baptist Press News; May 22, 2019).

Frequently Asked Questions about Examination Update, by IMB Staff (IMB; May 22, 2019). Here is the list of 15 questions addressed.

Q: What should I do if someone tells me they are a victim of child abuse or sexual harassment (including sexual assault)?

Q: What should I do if someone asks for a reference on a former IMB personnel? / What should I do if I hear someone is considering hiring a former IMB personnel?

Q: Why is IMB conducting an examination?

Q: Why did IMB hire Gray Plant Mooty?

Q: Who is Kathryn Nash?

Q: What does Paul Chitwood think about the examination?

Q: Will the full report from Gray Plant Mooty be made public?

Q: The statement from Gray Plant Mooty said the examination revealed “significant concerns” to the handling of past cases — what are those, specifically?

Q: The statement from Gray Plant Mooty said the examination revealed “much room for improvement” if IMB is to meet its goal of adopting best practices — what are those, specifically?

Q: What is IMB’s response to the examination findings?

Q: How will this impact churches working with / partnering with IMB?

Q: Will IMB report allegations of abuse to government authorities?

Q: Who will take the lead in implementing these recommendations at IMB?

Q: What does a “trauma-informed approach” mean?

Q: Will IMB continue to conduct its own investigations in response to allegations of abuse?

Analysis by Investigative Reporter, Sarah Smith: 2019

Sarah Smith is an investigative reporter with the Houston Chronicle. She has been one of the main reporters who has interviewed Anne Marie Miller, whose experiences of sexual assault by an eventual IMB employee, were the impetus for then-president of the IMB David Platt to commission an independent investigation. You can follow Sarah on Twitter: @sarahesmith23. There is one of her articles of particular note from the day after Gray Plant Mooty posted their recommendations to date, and also a Twitter thread which includes other links.

Law firm: Southern Baptist missionary group must reform sex abuse reporting practices, by Sarah Smith (Houston Chronicle; May 23, 2019). Updated May 24th. Some key points:

The review is ongoing. The IMB did not release any specific details on past failings, nor did it indicate that it plans to do so.

Neither the International Mission Board nor Gray Plant Mooty responded to requests for comment.

Unlike the IMB thus far, other mission boards have released voluminous reports detailing their past failures after similar outside investigations. Those reports named not only alleged abusers, but enablers in the organizational hierarchy.

The IMB has not said whether it plans to release a similar accounting.

Miller hopes the IMB publishes a full report — but doubts that they will.

“If they summarize the report and keep the meat of it private, there is no way of knowing why they failed in the past and what they strive for in the future,” she said. “Releasing it publicly is a tangible way of saying, ‘We’re sorry we have failed you. Here’s why, and here’s what we are doing in the future.’”

Twitter thread (May 23, 2019), by Sarah Smith, investigative reporter for the Houston Chronicle. In that thread, I noted the following, which I am pasting in here because I believe it is important to publicly thank Ms. Smith for earning our trust by her kind support and diligent reporting.

I’ve just finished reading the recommendations to IMB from Gray Plant Mooty, plus the original statement from David Platt that instigated this outside investigation, response by Paul Chitwood to the examination update, the IMB FAQs, and your @HoustonChron report of yesterday. /1

I’ll save my questions/critiques about the recommendations. Meanwhile, what struck me most in reading this set of documents and news articles is that we (abuse survivors, advocates, and everyday others) owe you our thanks, @sarahesmith23, for providing us with crucial context. 2/

You’ve not only been providing us news as it unfolds, but historical context for IMB & for @girlnamedanne‘s specific situation, & wider Xn cultural context of how other denominations & mission agencies responded to similar investigations of abuse & institutional enablement. 3/

So, thank you, Sarah! Your work helps us track & interpret the scope of what’s happening. Reporting by @HoustonChron writers has proven esp valuable for those of us concerned about how Christian institutions deal with abuse intervention, survivor care, & institutional repair. 4/

To earn trust, the IMB needs those tracking their progress to understand their full trajectory, which requires their starting point, goals, & pathway forward. I agree w/ Anne & hope the IMB releases a more full report of findings, plus details on implementing recommendations. 5/

As Anne stated: “Releasing it publicly is a tangible way of saying, ‘We’re sorry we have failed you. Here’s why, and here’s what we are doing in the future.’” Trust is built on credible, behavioral evidence; I’m watching how the IMB repairs past damage done & prevents more. 6/

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Notes on My Analysis

COMMENTS. Analysis of documents like this require finding and reflecting on background materials. So, points of analysis may show up far later than in the first layer of looking at a document. I did that first go-through on May 23-24, 2019. The indented segments noted as “COMMENTS” are from that period. I may well come back to this material with other thoughts later. If so, I’ll mark them as add-ons.

“FAIR USE” OF QUOTATIONS. In this particular post, I will quote the full Evaluation Update, and then analyze it. For those who may be concerned, it is my understanding that such a quote is within “fair use” law because I am using the full text for the purposes of critical analysis. Regarding quotes:

  • When quoting others, whenever possible I link to the source’s website so you can see the whole context of what they said.
  • When I quote other sources, I seek to abide by the U.S. rules of “fair use.” This means short quotations, not wholesale copying-and-pasting–with the exception of extensive analysis referenced above.

NUMBERING SYSTEM. I’ve numbered the paragraphs and lists so that I can reference specific items as needed.

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IMB “Examination Update”Article and My Analysis

Examination Update

Gray Plant Mooty | May 22 2019

Link to the original article on the IMB website.

Paragraph #1. In late July 2018, then-president David Platt announced the commencement of a thorough, outside, independent examination of the International Mission Board’s (“IMB”) handling of past matters and its current policies and practices related to its prevention of and response to allegations of physical and sexual abuse of a child (“child abuse”) and sexual harassment (including sexual assault). IMB retained Gray Plant Mooty (“GPM”) to perform the examination.  Since being retained, GPM has been conducting a methodical examination of IMB’s past actions and current prevention and response policies and procedures.

Paragraph #2. Throughout the examination, GPM has provided members of IMB senior leadership and an officer of the Board of Trustees with periodic updates. In April, GPM presented recommendations in detail to all officers of the Board of Trustees. This week, GPM presented an overview of the recommendations to date to the full Board of Trustees.

Paragraph #3. This statement provides a summary of the work conducted in the examination so far, the work that remains, and GPM’s recommendations to IMB to date.


Paragraph #4. GPM’s examination consists of two parts: (1) reviewing individual past cases involving allegations of child abuse or sexual harassment (including sexual assault), and determining whether any additional actions are needed as to those individual cases; and (2) making recommendations for changes to IMB’s current policies and practices, considering lessons learned from the review of the individual cases, interviews with key personnel, and a review of current policies.

COMMENTS. This looks like good goals: Intervention/remediation of past cases and instituting better prevention measures against future cases of child abuse, sexual harassment, and sexual assault.

Paragraph #5. During the examination, GPM is reviewing all known cases involving allegations of child abuse or sexual harassment (including sexual assault). GPM’s review of individual cases is not limited to any particular time frame and GPM is reviewing cases regardless of whether there was a finding of misconduct. To date, GPM has been given access to any files that the team has requested, including, among other documents, personnel files, appointment files including applications and reference checks, investigation reports, internal communications related to IMB’s response to allegations, and human resources and other support services records.

Paragraph #6. As GPM reviews individual past cases, GPM has identified whether any actions are needed in each specific matter, such as reporting an allegation to government authorities, following up to ensure victims received care, sending communications to those who had contact with perpetrators, gathering additional information, and conducting investigations. GPM is consulting with other experts as needed during the examination.

Paragraph #7. GPM has also reached out to victims when the team determined it was necessary to speak with those individuals to complete the examination. In addition, this examination has been made public and, as a result, multiple individuals have reached out to GPM to share their experiences and concerns. GPM and IMB have communicated that the team is willing to speak with any individual who believes they have information relevant to the examination. Out of respect for victims’ privacy and because of the risk that in some instances revisiting these matters may be traumatic, GPM does not plan to affirmatively contact each individual who made an allegation of child abuse or sexual harassment (including sexual assault). Regardless of whether an individual has been contacted as part of the examination, GPM and IMB encourage anyone who has experienced or witnessed child abuse or sexual harassment (including sexual assault) to report those allegations to IMB, and in the case of child abuse or other unlawful conduct, to government authorities.

COMMENTS. Isn’t the potential problem here that all of these actions ARE unlawful and should be/have been reported to government authorities? Why isn’t that first, instead of contacting GPM and IMB? GPM says they may report to government authorities, but IMB has not yet been shown trustworthy to contact police.

Paragraph #8. In the second part of the examination, GPM is making recommendations for changes to IMB’s prevention and response policies and practices going forward. These recommendations are based on the lessons learned from the review of individual cases, including the information provided by those individuals GPM speaks to as part of the review of individual files, along with the review of current policies and interviews with key personnel at IMB.

Paragraph #9. IMB is a unique organization that places families all around the world, often in remote and isolated locations. Unfortunately, that isolation has the potential to put children at greater risk of abuse. Because of that reality, IMB’s charge to GPM in conducting the examination and making recommendations was not focused on the minimum requirements under the law, but on contemporary best practices for protecting children. Accordingly, GPM’s concerns and recommendations go above and beyond what is legally required and strive to meet the highest standards for keeping children safe.

Paragraph #10. For similar reasons, GPM’s recommendations related to sexual harassment (including sexual assault) focus not on minimum legal requirements, but on contemporary best practices for prevention and response.

Paragraph #11. A summary of GPM’s recommendations follows. GPM will continue its work to finalize the recommendations, including revising IMB policies to reflect the accepted recommendations, and will work with IMB to complete remaining actions needed on individual files.

Summary of Conclusions and Recommendations to Date

Paragraph #12. IMB’s child abuse and sexual harassment (including sexual assault) prevention and response efforts have improved over time. There is, however, much room for improvement if IMB is to meet its goal of adopting best practices for prevention of and response to child abuse and sexual harassment (including sexual assault). GPM has identified a number of significant concerns with IMB’s handling of past cases. Even with the improvements that have been made over time, IMB’s current policies and procedures fall short of contemporary best practice standards.

Paragraph #13 and List. With those concerns in mind, GPM has concluded that IMB’s prevention and response efforts will be greatly improved by the regular involvement of individuals with expertise in child safety, preventing and responding to child abuse and sexual harassment (including assault), and a trauma-informed approach to prevention and response. Accordingly, GPM is recommending three steps to ensure that those with this expertise are involved in overseeing IMB’s prevention and response efforts.

  • 13-1. Create a new full-time position to oversee prevention and response efforts. This new senior staff member would have a broad range of responsibilities, including overseeing training, receiving reports of child abuse or sexual harassment (including sexual assault), and overseeing the investigation process;
  • 13-2. When IMB receives a report of child abuse or sexual harassment (including sexual assault), involve outside legal counsel with expertise in this area to provide advice throughout the process;
  • 13-3. Continue the current practice of using a forensic psychologist with expertise in interviewing children to conduct investigation interviews of children.

COMMENTS. There seems little doubt that independent investigations clearly are best practices as viewed by survivor advocate communities, but not yet by SBC entities including the IMB. Requiring the newly established position to “[oversee] the investigation process,” ignores the inherent bias of an internal investigation. Why does GPM advocate what looks to be internal investigations by the IMB instead of requiring independent investigations? Not just “involve outside legal counsel … to provide advice” but outside independent agency to conduct such investigations?

Paragraph #14 and List. In addition, GPM is recommending an expansive approach to reporting allegations of child abuse to government authorities, going beyond IMB’s legal duties to report. To that end, GPM is making the following recommendations, among others:

  • 14-1. Adopt protocols for consistently reporting allegations of child abuse committed by IMB personnel or others affiliated with IMB to U.S. government authorities, even when there is not a legal duty to do so;
  • 14-2. Adopt protocols for reporting allegations of child abuse to foreign government authorities;
  • 14-3. Revise policies and trainings to make clear that in addition to personnel’s obligations to report suspected child abuse internally to IMB, personnel also have the option, and sometimes the obligation, to report directly to government authorities;
  • 14-4. Report every known incident of alleged child abuse by IMB personnel or others affiliated with IMB that has not previously been reported.

COMMENTS. The two initial recommendations look good, but seem in effect negated by the third recommendation. Why not a policy that requires all IMB personnel to be the equivalent of mandatory reporters of known or suspected abuse/assault to government authorities directly, personally, and immediately—not to the IMB first? With IMB personnel traveling across state lines to teach, train, confer, etc., would it not be best to have a policy of reporting regardless—not decide based on whether the state the incidents occur in have mandatory reporting laws or not? If this is not addressed, couldn’t the proposed policy create a spectacular case that could lead to legal liability because it occurs in a mandatory report state where the witness(es) are required to personally report to authorities and that responsibility cannot be assigned to a superior or a subordinate?

Do the recommendations and related trainings cover child pornography possession and/or viewing as an automatic issue of child abuse that must be reported? The situation with Jordan Root (The Village Church) is relevant here, though this was not with IMB as the mission board. [See this article on Legal But Harmful Institutional Tools of Conformity and Control for an overview of this situation that happened in 2015 when The Village Church leaders welcomed “repentant pedophile” Jordan Root but put his ex-wife under church discipline for getting the marriage annulled. The article has 20+ links so you can track the unfolding events and outcomes, plus see some analysis and lessons learned as posted by others who are concerned for abuse survivors.]

Paragraph #15 and List. GPM is also making specific recommendations related to many other aspects of IMB’s prevention and response efforts, including the following recommendations:

  • 15-1. Revise the screening process for employees to more thoroughly screen for concerns related to child abuse or sexual harassment (including sexual assault);
  • 15-2. Provide increased training, incorporating additional content, for expanded audiences, and with greater frequency. Topics should include child safety, sexual harassment, sexual assault, and domestic violence, as well as more frequent age-appropriate education for children of IMB personnel to help children recognize and report abuse;
  • 15-3. Implement a consistent, centralized process for screening volunteers including effective oversight from IMB personnel;
  • 15-4. Modify the investigation process to use trauma-informed interview techniques and a trauma-informed approach to weighing evidence;
  • 15-5. Adopt additional policies to enhance the resources and support available to victims during and after the investigation;
  • 15-6. Publicize IMB’s current reference policy to encourage employers considering working or partnering with former IMB personnel to contact IMB to receive accurate information;
  • 15-7. Encourage reporting to IMB leadership when individuals are aware that perpetrators are working in a position that would provide access to children following the end of their affiliation with IMB;
  • 15-8. Adopt a clear process by which IMB will provide affirmative safety warnings when individuals report to IMB leadership that perpetrators are working in a position that would provide access to children following the end of their affiliation with IMB;
  • 15-9. Implement overall changes to policy and practice aimed at eliminating or reducing barriers to reporting and strengthening IMB’s prevention and response efforts.

Paragraph #16. The focus of all of GPM’s recommendations is the protection of children, as well as adults, from abuse and harassment and responding appropriately when incidents of child abuse or sexual harassment (including sexual assault) do occur to provide care to the victims and ensure accountability for the perpetrators.

Paragraph #17. IMB has an opportunity to be a leader within the Southern Baptist Convention in prevention and response efforts. GPM’s recommendations will enable IMB to improve its efforts to protect its personnel and their families and those who interact with its personnel and their families and to effectively and appropriately respond when there is an allegation of child abuse or sexual harassment (including sexual assault).

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My General Comments and Questions

On the Examination Update Document

How might the SBC Constitution relate to systemic issues of sexual abuse in the IMB?

Article IX. Missionaries’ Qualifications: All missionaries appointed by the Convention’s boards must, previous to their appointment, furnish evidence of piety, zeal for the Master’s kingdom, conviction of truth as held by Baptists, and talents for missionary service. [Emphasis added.]

COMMENTS. We need to be reminded that the main governing document for the SBC–its corporate constitution–requires the IMB to vet missionary candidates for piety, i.e., their personal-moral-ethical character, and not just their doctrine, gifts, and determination to serve. [This struck me when I reviewed the SBC Constitution on June 7, 2019. Comment added June 11, 2019.]

What else could/should be added or specified in these recommendations?

COMMENTS. How about the IMB refuses to receive recommendations for potential personal from any SBC or other denomination local church that has not implemented – and been evaluated for – child safety and harassment/assault prevention and reporting standards that are at least commensurate with those of the IMB?

The same should apply to IMB personnel activities and assignments – not allowing them to teach, train, etc., in a local church or other SBC entity that does not have such standards in place and practiced. Such churches declare by their actions they are not safe according to the standards the IMB will be using. So, the accountability consequences include no IMB availability unless and until certified safety/reporting issues have been resolved and evaluated. [First go-through comment from May 23-24, 2019]

Here is a relevant question from the FAQs about the Evaluation Update:

Q: How will this impact churches working with / partnering with IMB? Partnering with churches continues to be essential to the work of the IMB. We are committed to implementing a consistent, centralized process for screening and training volunteers in partnership with local churches with oversight from the IMB. We will communicate with churches as these processes are established.

COMMENTS. Let local churches have all the autonomy they desire–it is core to Baptist polity–but that does not give them automatic right to access all cooperative program resources and privileges. For instance, just because an SBC church wants an intern, that doesn’t mean they qualify to serve as a host site for Theological Field Education. They have to meet certain standards and personnel trainings before they qualify. [First go-through comment from May 23-24, 2019]

Some questions [list developed during first go-through on May 23-24, 2019]:

How can the IMB demonstrate to survivors and advocates that they are now capable of implementing these recommendations for repair of past failures and prevention of future situations? While the recommendations of GPM seem appropriate overall, there seems to have been a consistent disconnect in the SBC and IMB with survivors and victim advocates.

To what degree do the “best practices” as promoted by GPM coincide with those promoted by survivor/advocate communities? Some of them seem to keep the IMB institution in a position of at least partial control where they should not be, such as in reporting.

How much of this remains “in house,” and what functions are to be transferred to outside experts who will have independence from the IMB?

What exactly do they mean by “accurate, informed references” on former IMB personnel and why is it the responsibility of potential next hirers to seek IMB input? Doesn’t this get right back to the issue of some kind of clearinghouse or database of people who should not be granted access to a ministry platform due to abuse, harassment, and/or assault?

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4 thoughts on “Analysis of the SBC International Mission Board “Examination Update” and Recommendations from Gray Plant Mooty

  1. Recommendations would appear to be “Building a Bigger Bureaucracy.” The Roman Catholic Church has a huge bureaucracy.

    As a cynic, the bureaucracy’s number one agenda is to protect the bureaucracy.. I would anticipate a new bureaucracy will be less efficient that hoped. They almost always are.

    • There is truth in what you say. And yet, issues like abuse prevention are crucial to address, regardless of the size of the organization. There are many possibilities for responses:

      * Too little, too late.

      * Better late than never.

      * Something’s better than nothing.

      All of those are flawed. Better to do something well conceived, carefully monitored, with course corrections as needed.

      And also, failures to do the right thing on this set of issues should be considered grounds for negligence lawsuits–even to the point of dismantling the organization for its assets, which have been misused by the bureaucracy. Just in case those charged with direction of the corporation need any more motivation.

      • Thanks for your interest, Seneca. I have several posts planned, and had been working toward a big-picture introduction to capture the main points. Much of that happened this morning on Twitter. You’ll find the thread here.

        I will be eventually (hopefully next few days) transferring this material into blog posts and adding chunks on autonomy and how it does not mean freedom from all outside authorities, a general list of what any institution needs to accomplish to dismantle systemic sexual abuse and then compare where SBC is to that list, the unique ways that a system of local-autonomy-plus-national-cooperation would likely have to work to implement and monitor the dismantling of systemic abuse, etc.

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