Introduction
“For the mystery of iniquity doth already work” (2 Thess. 2:7). The antichristian power works in the world and is working presently. Its aim is to bring about the antichristian kingdom where man rules and shows himself to be God. It will be a kingdom with a political aspect and a religious aspect, where the man of sin will “be revealed, the son of perdition; who opposeth and exalteth himself above all that is called God, or that is worshipped; so that he as God sitteth in the temple of God, shewing himself that he is God” (vv. 3–4). In this series of articles, I am recounting how in a very specific way, man tried to be God in God’s church. God’s church was not allowed to judge an action to be sin unless or until the magistrate first judged it as a crime. That position is fundamentally antichristian because it robs Christ of his power to rule in his church and puts judgment in the hands of the magistrate.
First Reformed Protestant Church came under a fierce attack. By denying membership to individuals because of impenitent sin, First church was exposed to a lawsuit for judging a spiritual matter spiritually. If the lawsuit would have been successful, it would have marked the end of Christian discipline, for what impenitent sinner who is being put out of the church believes that he is a sinner? And any impenitent sinner, believing that he has been unjustly excommunicated, could take the church to the law for defamation. A sinner is put out of the communion of Christ and his church because he does not believe that he is a sinner. In retaliation he comes against the church with the powers of the government.
The scriptures tell us what was taking place. Men delivered us up to councils. They rose up against former friends and family. They brought us before kings and rulers for Christ’s sake. All the while they thought that they were doing God’s service. They have convinced themselves that God is pleased with them and that they were doing the Lord’s work. It is reported that they have said to each other, “We are suing by faith.” What a strong delusion the Lord has sent that they should believe the lie. They call the truth a lie and the lie the truth. They attempted to cloak their wickedness by suing individual members of the church and not the church itself. Deceitful! The original “Pre-suit Retraction Demand” from Brandon and Alana Oostra came against the church, while the lawsuit itself came against individuals. Perhaps men calculated that it was too nakedly obvious and wicked to sue the church of Jesus Christ, and so they tried to obfuscate the issue by suing men in their so-called personal capacities. The Lord knows the devices, counsels, and plans of the wicked. He determined them as that which he hates but which are for the eternal good of his church.
The church takes comfort in the word of God and does not think it strange concerning the fiery trial that tries her, as though some strange thing happened (1 Pet. 4:12). But she is a partaker of the sufferings of Christ that he left behind for her. When the church is reproached, happy is she, for the spirit of glory and of God rests upon her.
Spiritual Versus Carnal Purposes
The issue in the case was, may the church judge actions to be sin without having a judgment of the civil government?
Mr. Ryan Schipper penned a series of articles, and he asked this rhetorical question: “Has anyone ever witnessed a more appallingly evil situation?…Church members charged with felonies?”1 He asked this question not seeking an answer but to make a point. Ryan’s underlying assumption was that Brandon and Alana Oostra were in fact charged with criminal felonies. However, they never were charged with criminal felonies by the church nor by individuals. The church of Jesus Christ deals with spiritual matters, wielding spiritual weapons with a spiritual goal in view. The church is radically spiritual and is not carnal. Whether the magistrate is involved in a case or not, the church can judge, may judge, and must judge sin.
Later Ryan wrote,
It is well known that there is a pending defamation lawsuit pertaining to the Oostra Case. Now instead of the oath having its proper place to be the end of all strife in the church, God is seeing to it that the oath will be used in its other proper role: when the magistrate demands it of his subjects (Lord’s Day 37). Let all observe and see who will be stripped naked.2
Ryan showed himself to be a carnal man. He looked for vindication in a spiritual matter from a worldly magistrate! He supposed that if Brandon and Alana would have won their case, then the true church would have been “stripped naked.” He failed to understand that it did not matter whether the church won or lost in a court of law.
Whether the church won or lost in court would not have determined the rightness or wrongness of the events, letters, decisions, and sermons that took place at First. Because the matter had everything to do with the truth of the word of God. If you have the truth, it does not matter what anyone says or thinks. What men think, what the world thinks, and what the nominal church world thinks do not matter. The reality of the church in the world is that she only ever loses in this life; but ultimately she never loses a thing, for she always has Christ, his spiritual salvation, and eternal glory. God always blesses the plagued righteous, and his curse is always on the prospering wicked. Nothing can separate the church from the love of God in Christ. In Christ we have peace. In the world we shall have tribulation. But we are of good cheer, for Christ has overcome the world.
The lawsuit served one purpose for the church. It was a measurement of where she stands in relationship to Christ’s return. Christ said that he comes quickly and does not delay. He comes according to God’s eternal counsel and in the perfect realization of God’s will that not one of his elect goes lost but that his entire church is gathered unto him. The lawsuit and its consequent verdict were a measurement—nothing more, nothing less. Does the church have a place in the world anymore? Has her place become so despised that at the hand of former members, she will be hauled before the judge, thrown into prison, and soon be killed? Does the church have the freedom to preach the gospel that man is nothing and God is everything? May the church judge sin without fear of a lawsuit every time she does so? Can she even administer discipline according to the law of God? Will the government peel back the separation of the church and the state? The lawsuit served no other purpose than as a sign of the coming of Christ. A falling away must come first, and on the wings of that apostasy must the antichrist ride in order that he might be destroyed with the brightness of Christ’s glory and the breath of his mouth. There must be a terrible persecution of the church that has not been since the beginning nor will be in the world.
Various Points Regarding the Case
The argument of Brandon and Alana and company hung on a strange distinction between the term theft and the term stealing. One term was for sin, and the other was reserved for criminal activity. But the eighth commandment literally reads, “Thou shalt not steal” (Ex. 20:15). And Lord’s Day 42 of the Heidelberg Catechism says, “God…comprehends under the name of theft all wicked tricks and devices” (Confessions and Church Order, 132). The terms stealing and theft are interchangeable. They are synonyms. There is no distinction. Unrepentant sin against the eighth commandment makes one the object of discipline. If a man abuses and wastes God’s gifts—something for which the government will never punish—and he will not turn after his sin is pointed out, he is the proper object of discipline. Brandon and Alana did not turn from their wickedness. They instead went on the offensive against Second Reformed Protestant Church, who, like a good parent who asks his child what he did that was wrong, told Brandon and Alana,
You seek membership into the body of Christ, the church. Your request for membership is the occasion of strife among the members of the body of Christ. Why is this? Tell us from your perspective where the sin lies. What are the sins that lie in the way of your membership which need to be resolved. With whom are there conflicts? What occasioned these conflicts? We ask that you retrace your steps and examine your actions and your motives, as these are the fruits of the heart, and see if there is any sin that needs to be addressed and resolved. And analyze also who you may have sinned against.3
What love! Entirely despised!
To use an analogy, a loving father sits down his child who sinned, often knowing full well what sin was committed, and asks, “What did you do, and who did you hurt?” And the father wants to hear that child say, “I did this, and I hurt this person.” Then the father disciplines that child in love. He tells the child that what he did was wrong and why and how he can make it right with the neighbor.
Brandon and Alana refused to acknowledge their sin. They would not turn from their sin, and they had a whole pack of individuals who strengthened “also the hands of evildoers, that none doth return from his wickedness” (Jer. 23:14). So much so that Brandon and Alana filed a lawsuit against the church. It is the absolute height of wickedness to persecute God’s church. By the persecution of God’s beloved church, the world fills God’s cup of wrath and makes itself ripe for God’s fierce judgment and avenging anger.
In the lawsuit Brandon and Alana alleged essentially two things: first, that Reverend Ophoff harmed their names and reputations by statements that charged them with secular crimes; and second, that Reverend Langerak, Mr. Altena, and Reverend Ophoff colluded together to defame Brandon and Alana. Part of what condemns this whole business as wicked are the repeated appeals throughout the documents to Brandon and Alana’s reputations. It became abundantly clear that their names and reputations are very important to them. Everywhere throughout their documents can be read names, names, names, reputations, reputations, reputations! There was a time when I heard that sound before—in the Protestant Reformed Churches. Brandon and Alana are indignant at the alleged defamation of their names and reputations, and that is all one really needs to condemn their lawsuit.
Are the believer’s name and reputation important to him? Does he act atrociously and rise up in holy horror when his own name is slandered, maligned, and reproached? No! It is God’s name and God’s glory that are important and all-consuming to the believer. In a controversy the question is, is the truth at stake? Is the lie ascendent? If so, let my name be nothing, for God is everything!
For months after the lawsuit was filed, there was a back-and-forth between all the parties involved through their respective attorneys. Sometimes months would go by without any correspondence, but generally things moved forward, albeit at a snail’s pace. During the majority of this phase what took place was something called discovery. Discovery is a pretrial process where both sides in the case gather information, documents, and evidence against each other. This takes place through requesting documents, correspondence, and written answers.
Belonging to that process was Brandon and Alana’s demand that any correspondence that was sent between the defendants be delivered over to them. The problem with their request? There was no such correspondence. Brandon and Alana were looking for a smoking gun of defamation-collusion that never existed. They were constantly probing for anything they could dredge up. They found nothing because there was nothing. And that is how the discovery process concluded.
Motion for Summary Disposition
In November 2025 I filed a motion to dismiss the case on the grounds of the First Amendment and the ecclesiastical abstention doctrine. The following excerpt is from the first motion that was filed for summary disposition on my behalf:
Plaintiffs Brandon and Alana Oostra allege that Reverend Tyler Ophoff defamed them in two sermons delivered at First Reformed Protestant Church (“First RPC”) and in an article he authored for a denominational magazine. These claims arise from the Oostras’ efforts to obtain membership at First RPC following the closure of their previous church, Sovereign Reformed Protestant Church (“Sovereign RPC”). After several church leaders raised concerns about the Oostras’ religious qualifications—and as their involvement in Sovereign RPC’s closure sparked division within First RPC’s membership—Rev. Ophoff addressed the controversy in two sermons. In those sermons, he stated that the Oostras’ conduct was sinful according to the Heidelberg Catechism and the doctrinal principles of the Reformed Protestant Church. The article he authored contained ecclesiastical discussions among church leadership regarding the Oostras’ membership and the congregational split that ensued.
None of Reverend Ophoff’s statements constitute actionable defamation. Under the First Amendment’s church autonomy doctrine, also known as the ecclesiastical abstention doctrine, courts are precluded from adjudicating claims that would require a fact finder to delve into matters of religious doctrine, church governance, or ecclesiastical discipline. The claims brought by the Oostras against Rev. Ophoff fall squarely within this category of protected speech. Accordingly, their claims against Rev. Ophoff must be dismissed as a matter of law.
The Oostras’ Complaint asserts two claims against Reverend Ophoff, both of which also fail on the merits. Count III alleges defamation but does not identify any statement capable of bearing a defamatory meaning. Count IV alleges civil conspiracy and fails for two independent reasons. First, the allegedly defamatory statements made by the co-defendants were directed to First RPC, not Rev. Ophoff, and therefore he cannot be part of a conspiracy to produce those statements. Second, Rev. Ophoff’s sermons and discussions concerning the alleged defamatory content were conducted solely in his capacity as a pastor and were not coordinated with the co-defendants. Accordingly, because there is no genuine issue of material fact supporting either claim, Rev. Ophoff is entitled to summary disposition of all claims asserted against him by the Oostras.4
The plaintiffs’ counsel responded to the above motion for dismissal and narrowed down the plaintiffs’ allegations against me to the sermon preached on November 20, 2024, titled “No Stealing.” The contention of the plaintiffs’ counsel was that the statements in the sermon do not belong to protected religious speech under the First Amendment of the United States Constitution. The following excerpt is the reply that was filed on my behalf in response to the plaintiffs’ narrowed-down allegations. In summary the church has the right to teach the truth and apply that doctrine to the lives of the members of the congregation, and the state has no business entering into the spiritual matters of the church.
Reply in Support of the Motion for Summary Disposition
Introduction
The plaintiffs’ response has substantially narrowed the issues concerning Rev. Ophoff. First, the plaintiffs now contend that the only allegedly defamatory statements at issue are those made in his November 20, 2024 sermon: “that was theft” and “that money was taken.” (Response at 14–15 & n.9). Second, the plaintiffs concede that the facts relevant to whether these statements are actionable are undisputed, which is why they seek partial summary disposition in their favor under MCR 2.116(I)(2). Rev. Ophoff agrees that no further discovery is necessary to determine whether his sermon was defamatory. It was not. A minister cannot be liable for defamation for expressing, from the pulpit, his belief that certain conduct is, or that a congregant engaged in, sin. Accordingly, Rev. Ophoff’s motion should be granted.
Argument
I. None of the statements in Reverend Ophoff’s sermon are actionable.
In their response, the plaintiffs attempt to conflate various allegations involving Mr. Altena and Rev. Langerak, hoping that the resulting confusion will allow them to keep Rev. Ophoff in the case as an alleged civil co-conspirator. The plaintiffs ultimately concede, however, that only two statements made by Rev. Ophoff from the pulpit are alleged to be defamatory. (Response at 14–15 & n.9). For the Court’s convenience, a partial transcript of Rev. Ophoff’s sermon is attached as Exhibit 1, with the two statements at issue highlighted on page 2. Both statements are purely and unequivocally religious. Rev. Ophoff’s sermon explained that, under Reformed Protestant interpretation of Scripture and the Heidelberg Catechism, the prohibition against theft in the Eighth Commandment encompasses not only conduct punishable by the state but also conduct the state does not regard as criminal. (Ex. 1, at 1). Rev. Ophoff specifically articulated the following Reformed Protestant interpretation of the Eighth Commandment’s prohibitions:
This is what the catechism says: “all abuse and waste of his gifts.” Do you want to know how simple this whole thing is, beloved? It’s this simple: believers gave gifts that God had given them to God’s kingdom and to His church. And those goods were confiscated for the kingdom of man. That’s how simple this whole thing is. (Ex. 1, at 2).
Rev. Ophoff then cited the situation in Iowa as an example of what the Eighth Commandment prohibits. In his view, funds given to the church in Iowa were intended solely for church purposes—not for educating children who were no longer part of the church community. Rev. Ophoff characterized this conduct not as a secular crime, but as a “spiritual” theft: taking funds dedicated to God’s purposes and using them for something else:
The government’s not always going to punish for that. Is the government going to come and punish you for being a faithless steward of God’s gifts in the church? No, of course not. The church may judge, and the church doesn’t need the government to judge a spiritual thing spiritually, to make a spiritual evaluation of something, and to say, “That was theft.” (Ex. 1, at 2).
Likewise, Rev. Ophoff characterized the money involved as “taken” not because it was a criminal act under secular law but because it was “taken from the Lord” according to Reformed Protestant theology:
That’s how simple it all is, and I’m going to just say it one more time: money that was given by believers to God’s kingdom—money that you gave, the Spirit so moved you—that you gave to the general fund there in Iowa, and you paid and funded the teaching of the world. You funded a public school. There was no Reformed Protestant school there. You’re not angry for your sake, because…if it was a dollar or if it was 10,000 or a million dollars or $750,000, you ought to be angry—mad at that, that it was taken from the Lord. That money was taken. (Ex. 1, at 2).
Rev. Ophoff, in other words, was not asserting that the Oostras committed any crime. He was simply expressing his belief that, under his understanding of Scripture, what occurred during the wind-down of Sovereign was sinful and spiritually improper—even if secular authorities might not view it as wrongful. Such statements are squarely protected by the First Amendment. Religious sermons are “unequivocally ecclesiastical in nature.” Hullibarger v Archdiocese of Detroit, unpublished per curiam opinion of the Court of Appeals…Ministers are entitled to state that congregants have engaged in sin and to deny the privileges of membership to them. Maciejewski v Breitenbeck…Any other outcome would be untenable, as it would require courts to adjudicate whether certain conduct is “sinful” and would expose pastors to civil litigation whenever they deliver unpopular religious messages to their congregants. Kavanagh v Zwilling…
The plaintiffs rely heavily on the unpublished decision in Ogle v Hocker…But in Ogle, a bishop stated in a sermon that another bishop had sexually propositioned him. Resolving that claim required no inquiry into religious doctrine: either the proposition occurred, or it did not. Id. Here, by contrast, the dispute centers on whether an individual’s receipt of funds intended for church purposes constitutes a violation of the Eighth Commandment according to the Heidelberg Catechism. The only way for the Oostras to prevail is for this Court to determine that Rev. Ophoff’s statements “that was theft” and “that money was taken” are false according to Reformed Protestant theology. Because that analysis would require the Court to take sides in a theological dispute, it is barred by the First Amendment.
II. All of the communications pertaining to the Oostras’ membership request and the church discipline process are protected by the First Amendment or a qualified privilege.
The plaintiffs next argue that Rev. Ophoff is liable for allegedly “amplifying” Altena’s and Rev. Langerak’s accusations of sin against them. But even if Rev. Ophoff mentioned their statements or attached the original documents in a letter sent to the First RPC congregation, that does not make Rev. Ophoff liable for defamation. If it was, then Alana Oostra—who was the first person to tell First RPC that Altena was accusing her of “stealing”—would be liable for defaming herself. In the same way, Rev. Ophoff’s transparency with his congregation about what he received from other church leaders is not defamatory “amplification.” In any event, these distinctions are immaterial because it is undisputed that all of these discussions occurred within the context either of Rev. Ophoff’s sermons or the church membership and discipline process. Michigan has long recognized that statements made by church leaders and members during the church membership and discipline process are protected by a qualified privilege. See, e.g., Van Vliet v Vander Naald…(publishing a church tribunal’s findings in the church’s official newspaper); Westerhouse v De Witt…(meeting called to reconcile two church members); Konkle v Haven…(church members wrote a letter about a former pastor to members of another church); Howard v Dickie…(statements regarding plaintiff’s fitness for election as church leader). That is consistent with the many other cases that recognize that the First Amendment’s church autonomy doctrine prevents defamation claims from being asserted with respect to ecclesiastical communications in church discipline and membership processes, as well. See, e.g., McRaney v N Am Mission Bd of the S Baptist Convention, Inc. (collecting cases); Kavanagh…
The alternative is untenable: disappointed membership applicants could pursue defamation claims against churches that rejected them for theological reasons or unresolved “sin.” Such a regime would force churches to pay damages simply for enforcing the doctrinal boundaries of their own faith community. That outcome is fundamentally incompatible with the First Amendment, which guarantees churches the unfettered right to define and govern the contours of their faith.
Conclusion
Rev. Ophoff is entitled to summary disposition under MCR 2.116(C)(10).5
Next time, the Lord willing, I will conclude this series with some final thoughts and closing remarks and give thanks to the Lord for the deliverance of his beloved church that was caught in the fowler’s net.