Quis custodiet ipsos custodes?

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Rev. Philip Levant
Iglesia Bautista La Vid

Rev. Kevin Ueckert, Senior Pastor
First Baptist Church, Georgetown, TX

Dr. Lash Banks, Pastor
Murphy Church, Murphy, TX

Dr. Hance Dilbeck, Executive Director
Baptist General Convention of Oklahoma

Rev. Steven James, Pastor
Trinity Baptist Church, Lake Charles, LA.

Dr. John Mark Caton, Senior Pastor
Cottonwood Creek Baptist Church, Allen, TX

Mr. Geoffrey Kolander, President & CEO
Citizens, Inc., Austin, TX

Dr. T. Van McClain, Professor of Old Testament
Mid-America Baptist Theological Seminary

Dr. David Galvan, Senior Pastor
Primera Iglesia Bautista Nueva Vida

Dr. David Allen, Dean of the School of Preaching
Southwestern Baptist Theological Seminary, Fort Worth, TX

Dear Sirs:

On May 22, 2019, a former female student of Southwestern Baptist Theological Seminary was granted leave by a federal magistrate judge to file an amended complaint under the pseudonym “Jane Roe” in a civil action against the seminary’s former president, Leighton Paige Patterson, and the school.  The case, which is styled 4:19-cv-00179-ALM-KPJ, alleges “multiple violent sexual assaults…on the campus of SWBTS by a fellow student and SWBTS employee,” as well as “Leighton Paige Patterson’s negligent and intentional acts that resulted in further harm to her.”[1]

In the complaint, Plaintiff Jane Roe alleges that a fellow student and SWBTS employee sexually assaulted her on campus, resulting in blood loss due to her injuries. She further alleges that the male student violently forced her to the floor, called her profane names, brutally pulled her hair out in clumps, and engaged in mock strangling to the point that she nearly lost consciousness. After raping her, the male student is alleged to have forced her to take the morning after pill. [2]

The details of Jane Roe’s rape are gruesome. The troubling allegations that a former seminary president – a man ostensibly serving under the authority of and accountable to the seminary’s board of trustees – characterized the girl’s mother as “nuts” when she demanded a meeting about the rape, inquired about whether the rapist “ejaculated,” pressed if the victim had “her monthly period,” and told the victim that it was a “good thing” that she had been raped now warrant your full attention.[3]

As successive chairmen of the seminary’s Board of Trustees, each of you was uniquely responsible for the oversight, supervision, and annual performance evaluation(s) of the seminary president.

In fact, the Business and Financial Plan of the Southern Baptist Convention states:

Entity boards of trustees should oversee the operations of the entity in such a manner as will assure effective and ethical management(emphasis added).[4]

Additionally, the Constitution of the Southern Baptist Convention states:

All [board] officers shall be subject to the control and direction of their directors in matters pertaining to the work and obligations of the board institution, or commission.


The executive head of each board, institution, and commission shall be responsible to the directors for all the work of the entity and shall carry on the work as the directors may direct.[5]

Moreover, the seminary’s bylaws state:

The Convention has committed to the Board the responsibility to manage the Seminary for the Convention and the trustees have full authority in all matters of its management, except to the extent that powers are vested in the Convention by law.


The Executive Committee [of the Board] shall be composed of the Chairman, the Vice Chairman, and the Secretary of the Board, and the Chairman and one other member of each standing committee for a total of thirteen members…


The Executive Committee will conduct an annual performance review of the President, and shall review the President’s performance evaluation of the other officers of the Seminary, in accordance with the procedures in the Policy Manual. The Secretary will maintain a written record of these reviews.


The President shall be elected by the Board. His term of office, duties, and administration of the affairs of the Seminary shall be under the direction and authority of the Board. (emphasis added).


The President reports directly and is accountable only to the Board.


It shall be the duty of the President to report to the Board or the Executive Committee all matters connected with the operation of the Seminary which may be of interest to the Board or which the Board, as the manager of the Seminary should know.[6]

For more than fifteen years, and under the immediate supervision of each chairman listed above, Leighton Paige Patterson served as president of the seminary. The present federal civil action raises significant questions about the fiduciary oversight of trustees during his tenure as president.

Notwithstanding such questions, the seminary has now filed a response to the civil complaint in Roe v. Patterson. That response, which is now public record, asserts that  “Leighton Paige Patterson was not in the course and scope of any alleged employment with SWBTS, and was not otherwise an agent for SWBTS at the time of the alleged acts or omissions at issue.”[7]Moreover, SWBTS denies that it “ratified any conduct of Leighton Paige Patterson at the time of the alleged acts or omissions at issue.”

Simply put, the seminary’s defense in the present civil suit hinges on the following claims:

  1. Paige Patterson was not authorized by the trustee officers to whom he was solely accountable for actions alleged in the lawsuit.
  2. Paige Patterson’s alleged conduct was inconsistent with the duties and responsibilities granted to him by the trustee officers.
  3. Trustee officers were unaware of the events described in the lawsuit, and were not informed of them in violation of the seminary’s bylaws.

As the seminary frames its defense in the lawsuit and moves toward a potential discovery phase, it will be incumbent on each of you as present and past trustee officers to cooperate fully with the seminary’s new president, Dr. Adam Greenway, and legal counsel. Specifically, you may be asked to provide corroborative evidence that substantiates the seminary’s claim that trustee officers were not aware of the president’s actions, were not informed of the events described in the lawsuit, and would have taken action to safeguard the institution against the president’s alleged acts and omissions had they known of them.

In fact, the entire process of trustee oversight of Paige Patterson may become relevant to this case as it proceeds. With that in mind, you may consider the importance of turning over to Dr. Adam Greenway and the seminary’s legal counsel any exculpatory trustee correspondence or other records in your possession that might serve to bolster the seminary’s defense in this case.  Specifically, the seminary president and legal counsel should know the following:

  1. Did the seminary president ever communicate with trustee officers concerning misconduct by students and employees?
  2. Did the seminary president ever inform trustee officers of criminal investigations conducted against seminary students and/or employees?
  3. Did trustee officers ever express to each other concern about the president’s ethical management of the school?
  4. Did trustee officers ever express to other parties concern about the president’s ethical management of the school?

It is possible that each of you gentlemen may be deposed in a discovery phase or even be called as a trial witness should this case advance to that point. As former trustee chairmen, your testimony could serve to corroborate the seminary’s assertion that Leighton Paige Patterson exhibited a pattern of acting without trustee authorization, supervision, or notification.  On the other hand, your testimony could demonstrate that the former president was, in fact, acting fully within the scope of his employment and trustee officers were routinely apprised of matters like those described in the amended civil complaint.

As men who were elected by the Southern Baptist Convention and entrusted to safeguard the institution and not protect its former president, it is incumbent upon you to carefully compile all relevant communications and other records, disclose them to the current seminary president and legal counsel as soon as possible, and prepare yourselves to be fact witnesses in the case of Roe v. Patterson.

Until He comes,

The Baptist Blogger








3 thoughts on “Quis custodiet ipsos custodes?

  1. Jesus said “I am the Truth”. May each and every one of these trustees, who claim to be followers and disciples of Jesus, speak absolute truth, not seeking to protect themselves or Paige Patterson. May they be true to God, who hates violence and harm to the vulnerable. May The Holy God’s true Justice be done to the monstrous man who violated Jane Roe as well as to each and every person who, through negligence or willful deceit covered up this heinous crime. Let repentance and Justice cleanse God’s house and people. May God’s mercy heal Jane Roe and her family and all who have been harmed by the injustice at SWBTS and throughout the community of believers.

  2. It deeply angers me these trustees allowed this ego-driven destruction at my beloved alma mater. Sickening and disgusting what they allowed and did nothing to stop. Complete and total failures in their fiduciary responsibilities. I pray one day they all will be held accountable.

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