Debating marriage: marrying the sister of a deceased wife and the Presbyterian church in Canada.

In late Medieval Europe, as Henry VIII discovered, the church reigned supreme in determining who could marry. The state had a limited role in the contracting of marriages. Henry's first marriage, to his deceased brother's wife, was regarded as legitimate in the eyes of the Roman Catholic church, and the desire of Henry, England's head of state, to have it declared void on theological grounds was disregarded by the church. Among the changes resulting from the Protestant Reformation was a new partnership between church and state in the legal contracting and religious solemnizing of marriages. More particularly, in England, Wales, and Scotland, together with the state, Puritan, Presbyterian, and Anglican reformers worked to outlaw and regulate folk marriage practices that included common law forms of marriage and (given high death rates during that era) frequent remarriage.

These rules and laws represented the efforts of modernizing reformers in both church and state to promote a new moral and social order. Calvinists especially, but Protestants more widely (including Anglicans), opposed marriage between close kin.

From the sixteenth to the nineteenth century, bureaucracies of church and state in Great Britain gradually tightened canon and state law related to marriage, notably rules related to incest, not just in terms of consanguinity (blood relations, or kindred) but also affinity (degrees of relationship by marriage). The process began to be written into law with the Scottish Marriage Act of 1567 and continued in England and Wales during the Puritan interregnum and in the Table of Kindred and Affinity in the Anglican Book of Common Prayer (1662). This evolving partnership of church and state culminated in the Marriage Act of 1835 in Great Britain, which forbade appeals for exceptions to rules such as those forbidding marriage to the sister of a deceased wife.

The colonies of British North America and, after 1867, the Dominion of Canada inherited this legal tradition. In Canada, as in Great Britain, individuals forbidden to marry sometimes travelled abroad to obtain a legal marriage contract, leaving clergy back home to decide whether or not to recognize and even solemnize the marriage. Challenges to these laws began in the mid-nineteenth century in both Britain and Canada, particularly over the possibility of a widower marrying his deceased wife's sister. Canadian Presbyterians held a protracted debate regarding this question, as it came up periodically at the meetings of synods and general assemblies for nearly twenty-five years (1867 1889). (2)

The debate among Presbyterians in Canada produced no change in definitions of marriage until 1882, when the government of Canada amended the law about who could marry and in so doing created a crisis for Presbyterians in Canada. (3) Presbyterian leaders turned to the faculty of their theological colleges and a few prominent clergy to find a solution to the crisis. Both those seeking to maintain the ban on such marriages and those hoping to provide "relief" to couples contracting such marriages believed that the legal and moral significance of marriage required the Presbyterian Church in Canada (PCC) to have a singular position on the question. That is, the denomination should either forbid its clergy to perform marriages between a man and the sister of his deceased wife or the denomination should state that such marriages were to be celebrated and therefore clergy could not raise doctrinal concerns as a reason for refusing to perform such marriages. Neither side in the Presbyterian debate fully recognized, let alone directly addressed, the profound social, political, and religious changes taking place in family life and marriage in the Anglo-American world. Instead, they focused more strictly on scriptural questions. Nevertheless, the outcome of the debate, in effect, reflected not just a new legal and moral context for marriage, but also the changing place of questions of morality and religion in law and politics in Canada and other societies in the North Atlantic.

While there had been challenges to the prohibition against widowers marrying the sister of their deceased wife (or requests for an exception to such laws) since the 1500s, the debate took on a new intensity in the latter half of the nineteenth century. (4) This was a time in which women's roles in society were in flux. (5) Changes in family life wrought by industrialization and commercialization put new weight on the role of mothers in the home. The debate about marriage to the deceased wife's sister was wrapped up in wider societal debates about the role of women. In addition, the medical profession and its scientific approach to questions such as the risks of incest and close kin marriages challenged church definitions of "purity" and morality. (6) From a scientific point of view it made little sense to demand a widower not marry the sister of his deceased wife, since the man and the sister shared no common blood. (7) And, legally, the definition of incest increasingly became viewed less as a matter of sin (i.e., of a sexual relationship between people not allowed to marry) and more in terms of crime (i.e., of sexual exploitation of children by adults, especially of young girls). (8)

Debates about the role of women in society also raised questions about the nature and purpose of marriage and the family. As historians Steven Mintz and Susan Kellogg wrote of the American home in the latter half of the nineteenth century, "The family had become a private place, a shelter for higher redeeming values and a shelter from the temptations and corruptions of the outside world." (9) Families were capable of determining, free from outside interference, who would nurture this "private place." Such a view affirmed a companionate understanding of marriage, one into which two individuals entered as a result of their romantic connection and individual choice. This new, more individualistic and private view challenged earlier conceptions of marriage that emphasized communal understandings and highlighted its economic and societal purposes. (10) Furthermore, by the last third of the nineteenth century, North American Protestants believed that the home was, as an institution, as capable as the church of nurturing Christian faith and practice (and perhaps more so). (11) Marguerite van Die neatly summed up the significance of this changing view of the home when she wrote, "Accompanying this shift from institutional to domestic religion was the increasingly sacred character assigned to the home ...; the sacralization of home and family was a break culturally and theologically with Christian tradition." (12) The family, and not the church, had become the arbiter of what was appropriate Christian practice. These trends help to explain why the PCC was so concerned about the morality of family life, and they illuminate the larger context of a debate that may seem arcane to early twenty-first century readers. In this emerging understanding of the family, it was more and more individuals and nuclear families themselves that should arbitrate who would marry and who would not. The church's role was to bless what had been decided by individuals within the home (i.e., family).

As this new understanding of marriage and family grew in the wider society, a group of grassroots Canadian Presbyterians proposed a solution to the crisis over early modern rules about marrying the sister of a deceased wife, a solution that gave individual ministers liberty of opinion and action on whether they would perform such marriages. In so doing, Canadian Presbyterians localized the decision of who would be married in Presbyterian congregations, turning to the conscience of clergy and ruling elders and the stances of local congregations, and leaving the legal definition of marriage in the hands of the state. Unlike historians today, Canadian Presbyterians then almost never referred to the social questions lying behind the issue of marriage to a deceased wife's sister. They focused on Scripture and church order.

Early in the debate among Canadian Presbyterians, the Rev. John Laing alluded to this emphasis on Scripture and doctrine, writing: "Such marriages are undoubtedly opposed to the general sentiment of Christian Society. It matters not to what that sentiment may be owing; it is the fact that has weight. It is most inexpedient to do violence to the general sentiment of any community on a moral question, and therefore such marriages should be avoided." (13) The PCC and its predecessors in Canada affirmed the Westminster Confession of Faith (WCF), written in the 1640s as a "subordinate" doctrinal standard. The WCF, which is a systematization of Christian faith and practice rooted in the Old and New Testaments, is subordinate to Scripture. In a disagreement between it and Scripture, the latter should rule supreme. Challenges to the standard of faith and practice outlined in the Confession must be rooted in the text of Scripture. Extra-Scriptural challenges fail by their very nature, according to classic Protestant ideas of Sola Scriptura ("Scripture alone"). Ruling and teaching elders in the nineteenth century affirmed publicly ("subscribed") at their ordination that the WCF had been "appointed to be used for the instruction of the people." Ministers (teaching elders) were specially charged with the teaching and defense of the denomination's doctrinal standard. Chapter 24 section 4 of the Confession outlines who cannot be married. It reads: "Marriage ought not to be within the degrees of consanguinity or affinity forbidden in the Word; nor can such incestuous marriages ever be made lawful by any law of man, or consent of parties, so as those person may live together as man and wife. The man may not marry any of his wife's kindred nearer in blood than he may of his own, nor the woman of her husband's kindred nearer in blood than of her own."

The authors of the WCF were influenced by John Calvin and other Reformation thinkers on this issue. As Mar Jonsson has cogently argued, the Reformers regarded consanguinity (blood relationships) and affinity (marriage relationships) as the same kind of relationship. (14) This understanding was rooted in the Genesis 2:24 injunction, "the two shall become one," subsequently quoted by both Jesus (Mark 10:7-8 and parallels) and Paul (Ephesians 5:31) in the Christian Scriptures. Through marriage, a man was considered to be as closely related to his wife's siblings as he was to his own blood siblings; a wife was as closely related to her husband's relatives as she was to her own.

This Reformation-era moral stance increasingly conflicted with the needs and desires of ordinary people caught in the circumstances of practical family life in nineteenth century Canada, where it was not uncommon for an unmarried sister to live with her married sister's family. Neither was it uncommon for a wife to die young (e.g., in child birth), leaving her husband to raise the children. Widowers naturally would turn to their children's aunt for help, if she was nearby and free to help, making marriage to the sister of the deceased wife a pragmatic choice. As van Die points out, the challenge of marriage breakup is not a phenomenon to newly arise in the late twentieth century: "With the high rate of maternal and infant mortality, the remarriage of young widowers and widows, and separation caused by immigration and frequent relocation, people in Victorian Canada, as elsewhere in the Anglo-American world, experienced their own variations of family breakup." (15)

The issue of marriage to a deceased wife's sister was raised at the 1867 meeting of synod of the Canada Presbyterian Church. (16) John Cunningham of the New Glasgow/Kintyre Pastoral Charge, southwest of London, Ontario, had been removed as an elder and was being denied communion because, following the death of his wife, he had married his wife's sister. Cunningham appealed to the synod to overturn the decision of the session and restore his standing so that he might partake of communion. (17) The same meeting of the synod entertained an overture from the session of Knox Presbyterian Church, Woodstock, Ontario (east of London), which was spoken to "at length" by the Rev. William Thomas McMullen, minister of Knox, Woodstock, raising the same issue. (18) While the synod subsequently ruled this overture out of order, a year later fifteen ministers presented another overture to the synod, asking that the section of the WCF referring to marriage to a deceased wife's sister "be carefully reconsidered, and such relief afforded to parties affected, as the Synod may deem to be conformable to the Word of God." (19) Clearly, Mr. Cunningham was not the only person cast "out of church-fellowship" because of such a marriage. The question before the synod was not whether clergy should perform such marriages. A consensus existed that the WCF's prohibition prevented Presbyterian clergy from performing them. Furthermore at the time, Canadian law did not permit such marriages to be contracted in Canada. In a number of congregations, however, couples involving a man and his deceased wife's sister living near the United States had crossed the border to be married. When these couples returned to their Canadian hometowns, they presented a challenge to the congregation in which they worshiped. The questions before the church were pastoral ones: How should congregations respond to couples who had entered into such marriages? Should these couples be allowed to take communion or should they be excommunicated?

Canadian Presbyterians were not the only ones who struggled with the question of marriage to a deceased wife's sister. (20) While such marriages were not strictly illegal in Great Britain prior to 1835, a marriage of this type could be voided on the objection of any party. In adopting the Marriage Act of 1835, the British Parliament codified into law the Anglican Table of Kindred and Affinity, and among other things made it illegal for a man to marry the sister of his deceased wife or for a widow to marry the brother of her deceased husband. By the 1860s there was a concerted attempt by opponents of the act to have the prohibition against marrying a deceased wife's sister removed. On an almost annual basis private members began to introduce bills in the House of Commons calling for such a change; the bills always were defeated in the House of Lords, where twenty-four Anglican bishops had votes. Gilbert and Sullivan's Iolanthe (1882) refers to the debate when the Queen of the Fairies sings, "He shall prick that annual blister, marriage with a deceased wife's sister." Finally, in 1907 both houses of the British Parliament passed a bill, the Deceased Wife's Sister Marriage Act, years after the issue had been decided in the British colonies. Not until 1921 was the Deceased Brother's Widow's Marriage Act passed by British law makers. (21)

In the United States marriage laws are a matter of state law, and a number of American states, recognizing the practical realities of eighteenth century marriage and family life, changed the law to allow previously proscribed marriages. Connecticut in 1750 and Massachusetts in 1785 began loosening the kin restrictions, with Massachusetts allowing marriage with a deceased wife's sister in 1785 and Connecticut making the same change in 1793. By the 1840s, Virginia, with its strong Episcopal (Anglican) heritage, was the only state in which such marriages still were disallowed. As Reformation-era prohibitions had a declining influence on civil law, religious denominations, including Presbyterians, were left to determine how to respond. Barry Waugh has shown, through some high profile cases from the 1820s to the 1840s, that the Presbyterian tradition moved from the excommunication of Donald McCrimmon--a ruling elder of Ottery's Church in Fayetteville, North Carolina, who had contracted a proscribed marriage--to allowing the Reverend Archibald McQueen, a minister in the Fayetteville Presbytery, to remain a minister in good standing despite his being married to his deceased wife's sister. (22) Given that the civil authorities had dealt with the issue years earlier, and that the church was seeking to respond to specific pastoral situations, the debate was about the meaning of the biblical texts and the theological implications of those texts, rather than about how to respond to the actions of the government. While the debate was theologically rooted, Brian Connolly notes that few references were made to the WCF in these American debates. (23)

The rhetoric of the debate among Canadian Presbyterians followed a pattern different from those in Great Britain and the United States. As in Great Britain, marriage was defined nationally in Canada, not by individual provinces; but the Canadian government did not take up the issue until the 1880s, and then the debate was very brief. Undaunted by the failure of his private member's bill of 1880, which would have allowed widowers to marry the sister of their deceased wife and widows to marry their husband's brothers, Desire Girouard, member of parliament for Jacques Cartier (a Quebec riding), introduced a bill in 1882 which allowed a man to marry his deceased wife's sister. This bill passed. (24) While the passage of the bill was disturbing to Presbyterians and Anglicans, the bill created no ripples among Roman Catholics who had no objections to such marriages. The conversation among Canadian Presbyterians was dominated by theological and biblical references, not political rhetoric. Unlike the American debate, in which discussion of the WCF was largely absent, for Canadian Presbyterians the WCF was a constant presence, even when not explicitly cited.

To frame the conversation among Canadian Presbyterians it is necessary to begin with the 1868 synod meeting of the Canada Presbyterian Church. At that meeting, a group wishing to provide "relief" by allowing couples who had contracted such marriages to remain in good standing in the church, argued that "in the opinion of many learned and eminent Biblical scholars, in the Presbyterian and other churches, such marriage is not forbidden in the Word of God." (25) Sessions thus should be freed, they argued, from the responsibility of exercising church discipline with regard to individuals like Mr.

Cunningham. General agreement existed among those involved in the debate that the only way to provide "relief" was to state that the WCF was in error on this issue. The proponents on either side of the debate saw only two possible ways for the debate to reach a conclusion: either the Confession was upheld as being correct in banning such marriages or it was wrong for prohibiting such marriages. Both sides in the debate were aware that saying the WCF was in error on this matter might open the door for the authority of the Confession being questioned on other matters as well. Defenders of the WCF's prohibition were unwilling to allow any room for the Confession to be in error. They contended that the Confession "gives no uncertain sound-declaring on Scriptural grounds, there referred to, that marriages within certain degrees of affinity . are forbidden by the Divine Law." (26) Among the advocates upholding the WCF's stance were Principal Michael Willis of Knox College, Toronto, and the Rev. William Gregg of Cooke's Presbyterian Church, Toronto, who was to be a lead advocate for adherence to the WCF over the next twenty years. A leading voice calling for "relief" was the Rev. John Laing, in 1868 a minister in Cobourg, Ontario. Laing had done his theological studies at Knox College at the same time McMullen was doing his undergraduate studies at the college. (27) The debate took up much of the synod's time over three days. In the end, on a vote of 52 to 37, the synod upheld the WCF's stance. (28) Many within the synod hoped that this decision would end the discussion. It did not.

Following the meeting of synod, John Laing and William Gregg published (with the same publishing house) pamphlets taking opposite sides on the issue. (29) These documents presented the two sides' central arguments, arguments that changed little over the next twenty years. Laing proposed three questions which were agreed by both sides to be the questions needing answers: 1. Is the marriage in question forbidden by the Confession of Faith? 2. On what ground is the prohibition based in the Confession? 3. Is that ground found in the Word of God? (30) With the questions agreed upon and agreement that the WCF said "no" to such marriages, the debate quickly moved to what the Scriptures, the primary standard, said.

In turning to Scripture, the two sides agreed on many matters. Both argued that biblical marriage patterns prior to the giving of the Law to Moses on Mount Sinai played no role in the debate. The Bible was not to be read flat; there was a flow and direction to the biblical material. The Mosaic Law superseded earlier patterns of life among the people of God. Therefore the story of a succession of Judah's sons marrying Tamar (Genesis 38), which happened prior to the giving of the Law, had no relevance to nineteenth century Canadian Presbyterians. Likewise, both sides in the debate argued that Jesus had not changed the Mosaic Law on incest, and agreed that the Mosaic Law was relevant for Presbyterians in 1868. The protagonists also agreed that the debate rested not on the biblical support cited by the Westminster divines (Leviticus 20:19-21) but rather on differing interpretations of Leviticus 18:18 and the surrounding passage. Leviticus 18:18 reads, "Neither shalt thou take a wife to her sister, to vex her, to uncover her nakedness, beside the other in her life time" (KJV). Finally, in common they acknowledge that God's identity as holy was at stake in who married whom.

With such substantial agreement, the issues in question were greatly reduced. (31) Laing contended that the biblical material was open to more than one interpretation; therefore, it was inappropriate to excommunicate a man from communion for marrying his deceased wife's sister on such uncertain biblical grounds. Gregg argued the biblical material was clear; marrying a deceased wife's sister was prohibited not only by the WCF, but also by the Scriptures, specifically Leviticus 18.

The instructions in Leviticus 18 expand on the general principle laid out in verse 6: "None of you shall approach to any that is near kin to him, to uncover their nakedness: I am the Lord" (KJV). Among the near kin that a man could not marry were these: his mother, step-mother, sister, half-sister, grand-daughter, aunt, daughter-in-law, and sisterin-law (brother's wife). These were absolutely forbidden by Levitical law, Gregg contended. In contrast, Laing noted that verse 18 was constructed differently than the other prohibitions, appearing to apply only during the first wife's lifetime. "To marry a wife's sister during her life is incest, as it is forbidden in verse 18," he acknowledged. "It may not, however, be incest after the wife is dead" (emphasis in original). (32) Laing could therefore conclude,

   though the standards of the Church prohibit marriage with a
   deceased wife's sister, the ground on which this prohibition rests
   is not established either by the proof adduced in the Confession,
   or by the Law of Incest as laid down in Lev. 18. We think,
   therefore, that we are justified in asking the church to reconsider
   its position, and take steps to justify its practice, or alter
   it. (33)

While Laing believed the Scriptures implicitly sanctioned such marriages, he did not believe they were proper. Such marriages were "lawful, but not expedient." (34)

Why then did he go to such lengths to promote a change in the WCF? For Laing it came down to the pastoral question of exercising church discipline. "Give us relief, we implore, from this crushing doom of Excommunication and from the guilt of pronouncing it, if it is not in accordance with the will of Christ." (35) Having raised substantial questions regarding the legal basis for prohibiting such marriages, he could find no justification for casting out of the church "men and women of irreproachable lives, who have heretofore given evidence of an interest in Jesus, and still are living consistently, simply because they cannot see that God has forbidden marriage in this relation, and have contracted such marriages." (36) While Laing would not "even hint at what should be done," the clear implication was while such marriages were not "expedient," they should not be the grounds for removing from church fellowship people whose "only" sin, as he put it, was to be in such a marriage. (37)

Gregg took the opposing position, arguing it was necessary to look at the direction and spirit of the entire text of Leviticus 18. He insisted the list of prohibitions was not exhaustive, but was rather a series of examples from which parallels were to be drawn. (38) Gregg claimed that verse 16 prohibited the marriage of a woman to her deceased husband's brother. So, he argued, if it was wrong for the widow to marry her husband's brother, then it was wrong for a widower to marry his wife's sister. Gregg acknowledged Scripture provided an exception to the prohibition against a widow marrying her deceased husband's brother when the husband died childless. (39) The case of Levirate marriage as described in Deuteronomy 25:5-10 and in the biblical story of Ruth, Gregg argued, applied only to those cases where the husband died without an heir, having very narrow application in nineteenth century Canada. At the heart of Gregg's argument was the contention that there should be equality between husbands and wives on who they could marry after the death of their spouse.

Laing and others who supported changing the WCF were unable to mount an effective rebuttal to Gregg's call for parallel treatment of widow and widower, choosing instead to keep the issue focused on the widower and who he could marry. (40) They hung tenaciously to the phrase in Leviticus 18:18, "in her lifetime," arguing that it made marriage to a deceased wife's sister different from marriage to a deceased husband's brother. On the other side, Gregg and the supporters of the WCF's prohibition were unable to take advantage of this gap, because they were unable to effectively deal with the contention that the two cases were in fact treated differently in the Scripture. Gregg did make use of a textual variant in the verse to try and broaden the scope of the prohibition from "in her lifetime" to "for all time," but this attempt never gained traction. (41) There was an irony in the debate. Defenders of the WCF's prohibition and Reformation-era tradition appealed to the spirit and broader meaning of the biblical text, while those who wanted the church to take a more liberal approach to this issue appealed to the literal words of the biblical text.

Those wanting a change in the church's practice did not take the decision of the 1868 synod as the final word. The Presbytery of Cobourg sent an overture in 1869 asking that steps be taken "as might secure uniformity of practice throughout the Church, and afford direction to Sessions in dealing with parties [so married] ... with a view of effecting a separation, or restoring them to the privileges of the Church, in accordance with the Word of God." (42) Again those seeking change in the church's practice had framed their request in pastoral terms. Laing, in speaking to the overture, proposed that a committee be established which would do three things: explore the pastoral implications of the church's doctrine; examine the civil law on this matter; and "prepare such a vindication of the doctrine and practice of the Church as may aid in removing doubts." Following two and half hours of debate on the matter, the general assembly of 1870 agreed in a 94 to 5 vote that there was "no sufficient ground for modifying the ecclesiastical rule of its communion, in this particular, which is also in harmony with the Civil Law of Great Britain." The state and the church were agreed on the definition of marriage; any change in the church's definition would produce a collision between church and state. Marriage was a public matter upon which it was important for church and state to agree, and since no compelling reasons had been given for changing the church's definition, there was no need to bring church and state into conflict on this matter. While the answer to marriage to a deceased wife's sister would remain a firm "no" and there would be no provision of liberty of opinion for those who wanted to offer relief, the assembly in wishing "to treat with respect the difficulties of some" agreed to appoint a committee whose mandate was "elucidating the Scriptural basis of said law" and "showing . to parties aggrieved by our rules of discipline, that these do not rest on slight or arbitrary grounds." (43) It named a six member committee, including Gregg as convener, Alexander Topp of Knox Church, Toronto, and William Caven, all of whom had indicated their clear opposition to any change in the doctrinal stance of the church. William McLaren was also on the committee; given his connections with Laing, he was likely to propose offering "relief." The committee brought a draft report to the general assembly in 1871 and a final document in 1872. The document, which supporters of the WCF hoped would be the last word on the issue, upheld the doctrinal standards of the church and maintained that the excommunication of parties who contracted such marriages was pastorally warranted. (44)

By 1872, however, conversations were underway in the diverse branches of Presbyterianism in Canada about church unification. As Canada was now one, Confederation having taken place in 1867, many Presbyterians in Canada believed that they should become one. (45) It would have been unwise at this time for one party in the unity discussions, the Canada Presbyterian Church, to be engaged in a divisive public debate about the doctrinal standards of the church. With union discussions underway, the marriage debate took a back seat. The Basis of Union, which created The Presbyterian Church in Canada, stated that the WCF "shall form the subordinate standard of this Church," while giving "liberty of conscience" (i.e., "relief") on the exact nature of the relationship between the church and the state. (46) The two largest groups in the conversation, The Presbyterian Church of Canada (Church of Scotland) and the Canada Presbyterian Church (Free Church) could not agree on how the church was to relate to the state. The desire for union was so strong, however, that the parties chose to leave it up to individual ministers and elders to follow their own opinion on this matter. The rest of the WCF was understood to be binding on all elders, teaching, and ruling as the doctrinal standard of the church, subordinate only to Scripture itself.

The statement of 1872 ended the marriage debate until 1880 when Gregg, now a professor at Knox College, brought it to the attention of the general assembly of The Presbyterian Church in Canada that a private member's bill had been introduced in the Canadian House of Commons seeking "to legalize marriage with the sister of a deceased wife, and with a deceased brother's wife." Gregg wanted a committee "to watch legislation on this subject . with a view to avert such legislation." (47) A fourteen member committee, including four members of parliament and senators, was appointed. The committee was pleased to report in 1881 that while Parliament had been petitioned on the issue, the feared legislation had not been introduced, so "no further steps needed to be taken by them to avert the threatened evil." (48) The "evil" having been avoided, church and state remained agreed on the legal definition of marriage.

A year later Principal Alexander McKnight of Pine Hill Divinity School, Halifax, informed the assembly that earlier in 1882 the Parliament of Canada had passed legislation allowing for marriage with a deceased wife's sister. McKnight noted, "the law of the land and the law of the Church are thus at variance, and difficulties may be expected to arise from collision between them." Therefore a committee should be appointed "to investigate the scriptural authority on which the marriages referred to are condemned, and report their judgment, with reasons for it, to next Assembly." (49) This was no longer an internal church debate. Church and state were no longer in agreement on the definition of who could marry; how was the church to respond? The assembly, recognizing the significance of the situation, appointed four theological college principals, six theological college professors, and three clergy to the committee, with Gregg serving as the committee convener; and it gave the committee one year to report back. The tight timeline indicated the urgency that the church felt about this issue--a decision on the matter should not be delayed.

The ground had shifted dramatically in two years. The committee appointed in 1880 had sought to stop government action and therefore included political figures; the new committee was made up entirely of theological thinkers. The relationship between church and state had changed. The church was no longer acting as a watchdog on the state's actions, ensuring that the state did not change the marriage law; rather, the state had set the agenda and the church had to respond.

The complexity of the situation was clear as the committee, with so many strong theological voices, reported to the 1883 assembly, noting that the views of its members "were so divergent that no definite conclusion had been arrived at." Upon hearing this, the assembly took a decisive step, removing Gregg, known for his firm opposition to changing the WCF, as convener of committee and replacing him with Laing, a champion of offering "relief" on the issue. In so doing, the assembly indicated the direction it wished the committee to take. The committee was also reduced in size from thirteen members to nine, in hopes of streamlining and speeding up the process. (50)

The revamped committee's report of 1884 presented a detailed analysis of the WCF section 24.4 and a study of Leviticus 18, contending that the central question was what scriptural support could be mustered for a prohibition against being married to a spouse's "kindred nearer in blood" than one's own kindred? The report concluded that Scripture did not say "no" to such marriages, arguing that a man should be allowed to marry the sister of his deceased wife. The authors did not question the prohibition against a woman marrying the brother of a deceased husband (Lev. 18:16). (51) A suggestion that the four "parent" churches (the Free and United Presbyterian Churches of Scotland, the Presbyterian Church of England, and the Presbyterian Church in Ireland) be informed of the discussion taking place within the Presbyterian Church in Canada, "so that, if possible, harmonious action on this important matter may be secured, and difficulties which may arise from want of unity of disciple may be obviated," was defeated. (52) The Canadian church wanted more time to think through the issues raised by this change in the church's doctrinal standards regarding the definition of marriage before being committed to a course of action. (53) Canadian Presbyterians were also well aware of doctrinal debates taking place in the United States, but since American Presbyterians had already changed the WCF to allow for such marriages, there was no reason to inform the Americans. (54) Even though a number of the Presbyterians in Canada had come from the United States, the American church was not considered a "parent" church. The assembly decided to send the rest of the report, "without committing itself to the conclusions," down to local presbyteries for their consideration. (55) The debate was still being framed in "yes-no" terms. If the report was adopted there would be no grounds for any Presbyterian minister or congregation to say "no" to marriages between a widower and the sister of his deceased wife. The Presbyterian Church in Canada would have a public definition of marriage in line with the state's definition, just as had been the case before the 1882 actions of the government of Canada.

Gregg, still a member of the committee, dissented from the report and shortly after the close of the assembly published a scathing pamphlet on the committee's work. Only five of the committee's nine members had participated in drafting the report, Gregg contended. Further, the committee's convener had unilaterally decided there would be a single report, with no minority report permitted. The convener's decision was unusual for the time, as groups or individuals who found themselves in minority on a committee often submitted reports which challenged the views of the majority on the committee. Gregg argued that a deep division existed among the five actively involved members: three favored the report as it was presented to the assembly and two were opposed. (56) The division in the committee was to be writ large within the church as the presbyteries struggled with the question.

The thirty-eight presbyteries spent a year debating the three propositions in the report and reporting their conclusions to the assembly. By the assembly of 1885, thirty-four presbyteries had responded to the questions. (57) On the first question of whether the Mosaic law of incest was a permanent obligation and that marriages "forbidden in the Word" ought not to be contracted, twenty-seven presbyteries said "yes" and seven held "no opinion." The response to the second question was less clear cut. Thirteen presbyteries agreed that the final clause of WCF 24.4 was not sustained by Scripture; nine presbyteries believed there was scriptural warrant for saying "no" to such marriages. Eleven had "no opinion," likely indicating they were too deeply divided to come to a conclusion. There was clarity on the third question--whether discipline (barring individuals from taking communion and serving as elders of the church) should be exercised against couples so married. Twenty-six presbyteries indicated there should be no discipline; six said there should be discipline; and one presbytery had "no opinion." (58)

Laing stood up at assembly and argued that the clarity among the presbyteries on the issue of discipline indicated that no discipline should be exercised in these cases. Others countered that until "the statement in the Standards of the Church on the subject shall have received attention" it was not possible to pass a motion directing any particular action. Doctrine was the basis of the church's action; to act without a clear theological understanding in place was to put the cart before the horse. In addition, the response to the second question raised a deeper question. What were the implications of declaring that part of the WCF was "not sufficiently sustained by the authority of Scripture"? This question suggests that by the 1880s, compared to the earlier American decisions to change church policies on marriages to the sibling of a spouse, larger theological concerns about scriptural authority and doctrinal authority shaped the Canadian discussion. Some Canadian Presbyterians might have worried that a change in the church's stance toward the WCF on a seemingly small issue such as rules regarding marriage would open the door to greater, more worrisome doctrinal changes. In any case, this concern brought the debate on the floor of the assembly to a halt. (59) With insufficient time for further debate it was "agreed to leave the question over to the next Assembly." (60)

While the brakes had been put to any immediate change, it was evident that those arguing to uphold the WCF's prohibition were now on the defensive. Principal Caven of Knox College, an influential figure in the denomination, had changed his mind on the issue at some point between his 1872 support for the prohibition against such marriages and the 1886 assembly. He proposed a committee of four people be appointed to develop a question (a remit) to be sent down to the now forty-two presbyteries to consider, vote on, and report back to the assembly. The committee consisted of Caven; McKnight (whose intervention in 1882 had started the shift in momentum); John Scrimger, professor at Presbyterian College, Montreal; and W. T. McMullen, who had been a leader in the request for "relief" back in 1867. The statement to which presbyteries were to express their assent or dissent was: "The discipline of the Church shall not be exercised in regard to marriage with a deceased wife's sister, deceased wife's aunt, or deceased wife's niece." (61) The pastoral issue was again put to the fore. Thirty presbyteries agreed discipline should not be exercised, in comparison to seven who said discipline should be exercised. Five presbyteries did not respond. (62)

This confronted the assembly of 1887 with a problem. The church had clearly spoken. Discipline was not to be exercised on this matter. But the WCF condemned such marriages as incest. Gregg and Caven engaged in a battle of motion and amendment and procedural maneuvering, seeking to win the day on the floor of the assembly. Given that both men taught at Knox College, one can only imagine that there must have been some tense moments during these years for the two of them, other faculty, and students at the college. "After long reasoning," the assembly "proceeded to give judgment." On a vote of 87 to 53, it decided to immediately end all church discipline against marriages to a deceased wife's sister, aunt, or niece. Further, on a vote of 76 to 28 (some of the opposition seeing that the die was cast chose to remain silent rather than vote), it agreed to send down to the presbyteries the following remit: "Chapter 24, section 4, of the Confession of Faith shall be amended, by striking out the last sentence thereof, contained in these words: 'The man may not marry any of his wife's kindred nearer in blood than he may of his own, nor the woman of her husband's kindred nearer in blood than of her own.'" While both motions introduced by Caven, as convener of the special committee, passed, it was a difficult moment in the assembly. Thirty-three commissioners (twenty-seven clergy and six ruling elders) who had voted against one or both motions recorded their names as voting "no" along with the reasons for their dissent. Not surprisingly, Gregg gave the most extensive list of reasons for his dissent. Caven had the last word, however, as he was appointed spokesperson for the committee charged with responding point by point to Gregg's dissent. Gregg had no right to rebuttal. (63)

The WCF, which was central to the basis of union among the various Canadian Presbyterian bodies, was to be amended. The amendment was not simply a rewording of a hard-to-understand phrase. Instead, part of the document was to be removed. Here a number of presbyteries had difficulty. By 1888, there were forty-three presbyteries in the denomination; only twenty-seven responded to the remit. The fact that more than a third of presbyteries did not respond to the question does not appear to have disturbed anyone at the assembly. The denomination followed a long standing practice among Presbyterians: those not voting are assumed to have voted with the majority. The editor of the Presbyterian Record felt some sympathy for the Committee on Remits, which "necessarily introduced this vexed question and landed the House in a labyrinth of motions and amendments." (64) Eighteen presbyteries had said "yes" to amending the WCF; nine said "no." Of the "no" presbyteries, four proposed an alternative approach. Led by the presbytery of Huron, in south-western Ontario, they suggested that "the clause in question be not expunged from the Confession of Faith, but that in our subscriptions thereto it be understood that the subject matter of the Remit be an open question." (65) In the end, the assembly of 1888 sent a new question down to the presbyteries for their consideration: "Subscription of the Formula in which the office-bearers of the Church accept the Confession of Faith shall be so understood as to allow liberty of opinion in respect to the proposition that 'The man may not marry any of his wife's kindred nearer in blood than he may of his own.'" (66) The editor of The Presbyterian Record, the denomination's magazine, reported that "feeling on this subject still runs pretty high and we are as yet far from having arrived at a settlement of it." (67) The editor was wrong; the compromise proposal won the day. In the year leading up to the general assembly of 1889 there was sufficient support from the presbyteries for it to change the vows that elders and ministers took upon their ordination, giving liberty of opinion on this matter. Canadian Presbyterians would no longer have a singular public position on such marriages; rather, there would be a patchwork of practices across the country. Some clergy would be willing to perform such marriages, following their liberty of opinion; other clergy would not be willing to perform such marriages, also following their liberty of opinion. The same would be true of congregations, as some sessions believed that such marriages were not permissible, according to their understanding of the biblical material, while other sessions would open their church buildings for the wedding celebrations of such couples, according to their understanding of the biblical material.

In a case of history being stranger than fiction, the moderator of the general assembly in 1888 was the Rev. William Thomas McMullen, who more than twenty years earlier had pushed for relief on this precise issue. He was in the moderator's chair as "relief" was brought to those who saw no impediment to a man marrying the sister of his deceased wife.

The partnership The Presbyterian Church in Canada, among other churches, and the government of Canada had shared in maintaining the public definition of marriage had changed, as had the moral-legal stance of each party. The state felt free to act independent of the blessing of church denominations on a matter that some denominations held as morally, spiritually, and institutionally important. The state was in a process of freeing itself from the power of churches in an increasingly religiously diverse Canada. The historic national churches (Church of England and Church of Scotland) had been financially disestablished when the government decided to cease its funding of religious institutions; the state would further limit the influence of churches over public policy. However influential they remained, churches had become diverse voices among many to be listened to by political leaders, rather than being able to directly influence the actions of the state on issues they believed important to the spiritual and moral health of society.

The state had taken the lead and churches had been forced to react. It was clear where the power lay and that disestablishment and ethno-religious diversity had changed the place of religion in public life and politics. The definition of marriage worked out by states and churches in the Anglo world during the early modern era had remained unchanged when those within the church had questioned and critiqued and had sought "relief" for couples who had contracted proscribed marriages. Canadian Presbyterians maintained their part of the social contract with the government, and in fact used the state's support of the commonly held definition of marriage to hold off any change to the church's definition of marriage. In 1882, when the Canadian government redefined who could be married, the situation changed. Many in the PCC believed the church had to find a way to respond. The dynamic is worth noting that rather than church action producing state response, this was state action leading to church response.

Many Canadian Presbyterians believed there was little choice but to make provision for a man to marry his deceased wife's sister. Others argued that the church should maintain all of its doctrinal standards with strict exactitude. Unable to come to an agreed upon position on the question, the church was unable to offer a clear answer to a question that troubled many within the denomination. Unable to find agreement on how to respond, the church opted to give freedom to couples, congregations, and clergy on this "vexed question." As Colleen McDannell has noted, "important Victorian values" such as "individuality, personal morality, [and] piety" were not only blessed in the home, they also became the pattern for public life. (68) Those were exactly the values that lay behind the "liberty of opinion" offered to elders, both ruling and teaching; individual church leaders and their congregations could exercise their individual, local rights to their personal morality and personal piety. No longer would there be a singular Presbyterian answer to the question of who could marry; rather, there would be a collection of answers. While this decision ended the contentious debate at the denominational level by giving local freedom, it did so at the expense of the denomination speaking with a unified voice on the matter. In so doing, The Presbyterian Church in Canada opened the door to a new moral understanding of marriage that fostered diverse practices and gave more power to the personal opinions of individual clergy, local congregations, and individual members.

Though the debate over marriage law in The Presbyterian Church in Canada may seem obscure and is easily forgotten from the viewpoint of the twenty-first century, it was part of a larger set of changes in the late nineteenth century in Canada and the wider Anglo-American world. During this era, as in the wider Anglo-American and European world, Victorian-era Canadians responded to a more religiously, morally, ethnically, and culturally diverse public sphere, sacralized the home, and debated the relationship between medicine-science and religion-tradition in defining and legitimizing the nature of the family, roles of women in the home and society, and the very notion of virtue. In choosing to avoid a singular policy on marriage and in valorizing private definitions and personal opinion of clergy and lay people on the question of men marrying the sister of a deceased wife, Presbyterians in Canada contributed to ideals of individual conscience and diversity of moral opinion and practice and made a choice to become modern.

Peter Bush, Winnipeg, Manitoba (1)

(1) The author wishes to thank the anonymous reviewer for helpful suggestions and the editor of Fides et Historia, William Katerberg, for his patience and suggestions for improving the essay.

(2) For more on the history of marriage law in Great Britain, see Chris Durston, "'Unhallowed Wedlocks': The Regulation of Marriage during the English Revolution," The Historical Journal 31:1 (1988): 45-59; and Adam Kuper, "Incest, Cousin Marriage, and the Origin of the Human Sciences in Nineteenth-Century England," Past and Present 174 (2002): 158-83. For the American story, see Barry G. Waugh, "The History of a Confessional Sentence: Inclusion of the Affinity Sentence in the Westminster Confession of Faith, Chapter 24 Section 4, and the Judicial History Contributing to its Removal in the American Presbyterian Church" (PhD diss.: Westminster Theological Seminary, Philadelphia, 2002).

(3) Ronald C. Stevenson, "Federal Marriage Legislation," Canadian Parliamentary Review 20:1 (Spring 1997): 11-12.

(4) Stevenson, "Federal Marriage Legislation," 11.

(5) Elizabeth Rose Gruner, "Born and Made: Sisters, Brothers, and the Deceased Wife's Sister Bill," Signs: Journal of Women in Culture and Society 24:2 (1999): 423-47. Gruner uses Victorian novels to show the debate "raised issues central to the Victorians sense of themselves." Further Margaret Gullette reminds readers how strange this whole debate seems at the distance of more than a century in "The Puzzling Case of the Deceased Wife's Sister: Nineteenth-Century England Deals with a Second-Chance Plot," Representations 31 (1990): 142-66. She notes this particular kind of second marriage was minimally disruptive to the home.

(6) Nancy F. Anderson, "The 'Marriage with a Deceased Wife's Sister Bill' Controversy: Incest Anxiety and the Defense of Family Purity in Victorian England," Journal of British Studies 21:2 (Spring 1982): 67-86, explores the definition of incest and the opposition to these marriages. See also, Brian Connolly, "Historicizing the Incest Prohibition: The Deceased Wife's Sister Controversy in Nineteenth Century America" (paper presented at Sixth European Social Science History Conference, March 2006).

(7) Discussion of marriage to the deceased wife's sister also has taken place on the internet recently. In these discussions, the nineteenth and early twentieth century debates about who could marry are compared to late twentieth and early twenty-first century debates about same-sex marriage. See www.crookedtimber.org/2005/10/24/ the-craving-for-forbidden-fruit-and-the-craving-for-legality (accessed 7 August 2006).

(8) See Kuper, "Incest," 180-1.

(9) Steven Mintz and Susan Kellogg, Domestic Revolutions: A Social History of American Family Life (New York: The Free Press, 1988), xv.

(10) Mintz and Kellogg, Domestic Revolutions, 43-65.

(11) Margaret Lamberts Bendroth, Growing Up Protestant: Parents, Children, and Mainline Churches (New Brunswick, New Jersey: Rutgers University Press, 2002), 4, 5, 13-20, 24-37, 59.

(12) Marguerite van Die, Religion, Family, and Community in Victorian Canada: The Colbys of Carrollcroft (Montreal: McGill-Queen's University Press, 2005), 5.

(13) John Laing, Marriage with the Sister of a Deceased Wife, Considered in Connection with the Standards and Practice of the Canada Presbyterian Church (Toronto: Adam, Stevenson & Co., Publishers, 1868), 32.

(14) Mar Jonsson, "Defining Incest by the Word of God: Northern Europe 1520-1740," History of European Ideas 18:6 (1994): 853-67. See also John Witte, Jr. and Robert M. Kingdon, Courtship, Engagement, and Marriage (Sex, Marriage, and Family in John Calvin's Geneva, vol. 1), (Grand Rapids, MI: Eerdmans, 2005), esp. 310-53.

(15) van Die, Religion, Family, and Community, 4.

(16) The Canada Presbyterian Church was the result of the 1861 merger of the Free Synod of The Presbyterian Church of Canada (a result of the 1844 Disruption) and the United Presbyterian Church (a collection of Presbyterians not aligned with the Church of Scotland, most Secessionists) formed in 1834. The Canada Presbyterian Church grew through the 1860s so that by 1870 the synod evolved in a general assembly, showing the confidence the leadership of the Canada Presbyterian Church had in its strength and future. In 1875, the Canada Presbyterian Church, the Synod of The Presbyterian Church in Canada (Church of Scotland), the Presbyterian Church of the Lower Provinces (Free Church and Secessionist), and Church of the Maritime Provinces (Church of Scotland) merged to form The Presbyterian Church in Canada.

(17) Canada Presbyterian Church, Minutes of Seventh Synod, 1867, 15.

(18) Canada Presbyterian Church, Minutes of Seventh Synod, Special Meeting, 1868, 19.

(19) Canada Presbyterian Church, Minutes of Eighth Synod, 1868, 45-46.

(20) In "Marriage in the Anglican of Canada 1860-2004 and beyond," Journal of the Canadian Church Historical Society 47 (2005): 197-221, Alan T. Perry touches very briefly on the response of Canadian Anglicans to the issue. Perry is more interested in how Anglicans dealt with divorce and the implications for the same-sex marriage debate.

(21) For further details on the British debate, see Bruce Bennett, "Banister v. Thompson and Afterwards: The Church of England and the Deceased Wife's Sister's Marriage Act," Journal of Ecclesiastical History 49:4 (October 1998): 668-82.

(22) Barry G. Waugh, "The History of a Confessional Sentence: The Events Leading Up to the Inclusion of the Affinity Sentence in the Westminster Confession of Faith, Chapter 24, Section 4, and the Judicial History Contributing to its Removal in the American Presbyterian Church," (PhD diss., Westminster Theological Seminary, 2002), 154-220.

(23) Brian Connolly, "Domestic Intercourse: Incest, Family, and Sexuality in the United States, 1780-1870," (PhD diss., Rutgers University, 2007), 42-106, 140fn.

(24) Stevenson, "Federal Marriage Legislation," 11-12. Not until 1923 did the Canadian Parliament change the law to permit a widow to marry her deceased husband's brother. This was two years after the British Parliament allowed such marriages. In Canada, the definition of marriage (determining who can marry) is a federal matter, while the administration of marriage (including determining who may perform marriages) is the responsibility of the provinces.

(25) Canada Presbyterian Church, Minutes of Eighth Synod, 1868, 45.

(26) Canada Presbyterian Church, Minutes of Eighth Synod, 1868, 45-46.

(27) T.G.M. Bryan, with Gordon H. Allison, Biographical Dictionary of Graduates and Students of Knox College, Toronto, 1845-1945 (Toronto: n.p., 1982), 119, 170.

(28) Canada Presbyterian Church, Minutes of Eighth Synod, 1868, 51.

(29) Laing, Marriage with the Sister. This is a 36 page document. William Gregg, Marriage with a Deceased Wife's Sister Prohibited by the Word of God (Toronto: Adam, Stevenson & Co., Publishers, 1868). The title of this 16 page pamphlet gives little room for confusion about the author's stance on the question.

(30) Laing, Marriage with the Sister, 10.

(31) Laing, Marriage with the Sister; Gregg, Marriage with a Deceased Wife's Sister.

(32) Laing, Marriage with the Sister, 20.

(33) Laing, Marriage with the Sister, 31.

(34) Laing, Marriage with the Sister, 32.

(35) Laing, Marriage with the Sister, 36.

(36) Laing, Marriage with the Sister, 35.

(37) Laing, Marriage with the Sister, 34-36.

(38) The example Gregg uses to prove his point is a man marrying his niece. It is not explicitly prohibited, but a man is prohibited from marrying his aunt. The niece and the aunt are equally distant relatives; if marriage to the aunt is prohibited it can be assumed to be prohibited for the niece as well. Gregg, Marriage with a Deceased Wife's Sister, 7.

(39) Gregg, Marriage with a Deceased Wife's Sister, 7-8.

(40) A sixth of Laing's Marriage with the Sister (23-28) argues that a woman marrying two brothers in succession was in a different position than a man who married two sisters in succession. He was virtually alone in attempting such an argument.

(41) "Report of Committee of the General Assembly on Marriage with the Sister of a Deceased Wife," Acts and Proceedings (A&P) of the General Assembly of The Presbyterian Church in Canada (n.p., 1884), Appendix, cxlvii-cl.

(42) Proceedings of the General Assembly of the Canada Presbyterian Church, 1870, 26.

(43) Proceedings of Canada Presbyterian Church, 1870, 28. My discussion here refers to both "synod" and "assembly;" note that the synod of the Canada Presbyterian Church became the general assembly of the Canada Presbyterian Church in 1870--it had achieved a size to justify having a general assembly.

(44) Proceedings of Canada Presbyterian Church, 1871, 50; 1872, 20. Neither the preliminary report nor the final report are, to the best of my knowledge, extant.

(45) For further discussion of the link between Confederation and the creation of a unified Presbyterian church in Canada, see Barbara Murison, "'From Ocean to Ocean': Presbyterian Union and Confederation," British Journal of Canadian Studies 15:1-2 (2002): 1-13.

(46) "Basis of Union (1875)," Chapter X, Book of Forms (Toronto: The Presbyterian Church in Canada, 1993). The relief was provided in the following way: "it being distinctly understood that nothing contained in the aforesaid Confession or Catechisms, regarding the power and duty of the civil magistrate, shall be held to sanction any principles or views inconsistent with full liberty of conscience in matters of religion" (Book of Forms, 406.2).

(47) The Presbyterian Church in Canada, Acts and Proceedings, 1880, 56.

(48) The Presbyterian Church in Canada, Acts and Proceedings, 1881, 47.

(49) The Presbyterian Church in Canada, Acts and Proceedings, 1882, 52.

(50) The Presbyterian Church in Canada, Acts and Proceedings, 1883, 55.

(51) "Report of Committee on Marriage with Sister of a Deceased Wife," The Presbyterian Church in Canada, Acts and Proceedings, 1884, Appendix, cxlvii-cl.

(52) The Presbyterian Record, July 1884, 183.

(53) See Kaori Nagai, "A Harem in the Home: The Deceased Wife's Sister Bill and the Colonisation of the English Hearth," Australasian Victorian Studies Journal 8 (2002): 45-59, who argues that decisions made in the British colonies on this issue raised the temperature of the debate in Great Britain. This was particularly true as British couples, who would not have been allowed to marry in Britain and who had the financial wherewithal, traveled to the colonies to get married and then returned home.

(54) Canadian Presbyterians were very aware of what their American cousins were doing on a variety of issues, and were quite critical of American Presbyterians for rewriting sections of the Westminster Confession with which the American Presbyterians had difficulty. See for example Presbyterian Record, June 1902, 245-6.

(55) The Presbyterian Church in Canada, Acts and Proceedings, 1884, 44.

(56) William Gregg, The Marriage Question: Facts, Opinions and Decisions of Church Courts (Toronto: Presbyterian Printing and Publishing Co., 1885), see esp. 3-7.

(57) While we don't know which presbyteries did not respond to the questions, it is easy to surmise that some of the presbyteries on the Prairies were more concerned about the Riel Rebellion which occurred in 1885 than with the issue of marrying the siblings of deceased spouses.

(58) The Presbyterian Church in Canada, Acts and Proceedings, 1885, 58.

(59) The Presbyterian Church in Canada, Acts and Proceedings, 1885, 59.

(60) The Presbyterian Record, July 1885, 193.

(61) The Presbyterian Church in Canada, Acts and Proceedings, 1886, 25.

(62) The Presbyterian Church in Canada, Acts and Proceedings, 1887, 26. This would almost certainly have been a difficult moment for Gregg. As convener of the Committee on Remits, he had to report to the assembly that the majority of the church disagreed with him on this issue.

(63) The Presbyterian Church in Canada, Acts and Proceedings, 1887, 50-52, 66-67.

(64) The Presbyterian Record, July 1888, 190.

(65) The Presbyterian Church in Canada, Acts and Proceedings, 1888, 34.

(66) The Presbyterian Church in Canada, Acts and Proceedings, 1888, 34.

(67) The Presbyterian Record, July 1888, 190.

(68) Colleen McDannell, The Christian Home in Victorian America, 1840-1900 (Bloomington, IN: Indiana University Press, 1986), 49.