Church Order Primer
When a CRC council has a conflict with their senior pastor at some point that buck will stop at the desk of classis. Many times congregations and pastors work out a quiet divorce, (like Joseph tried to do to Mary prior to angelic interference) usually pulling out the language of “feeling called”, but if that doesn’t work classis will get involved.
The CRC Church Order is organized by “articles” and the article that administers a pastor/church separation is Article 17. It is designed to be a “no fault divorce” applied when formal discipline is inappropriate but one or both parties in the conflict has determined that a severance of the relationship is in their best interest. Classis then steps in to try to care for all parties in the separation, to ensure that both parties are treated fairly, and to make provision for long term healing. These are noble and well meaning goals, actual performance, as with all things in this broken world, may vary significantly.
Avoiding Article 17 to Avoid Stigma
The first thing to notice is that Article 17 is only engaged at the initiation of either the local pastor or the local council. Classis cannot force Article 17 on anyone. There is wisdom in this in limiting the power of the classis. We can’t have classis separating pastors from their local churches for something less than the weightiest of reasons. At the same time we find churches and pastors separating without invoking Article 17 leaving both parties in ecclesiastical limbo. In most cases both the local church and the pastor wish to avoid the stigma of having an Article 17 on their record or credential.
For those who don’t work with the church order the mechanics of its system can appear to be an arcane encumbrance that ought to be jettisoned. Why can’t we all just get along?
It’s easy to feel this way until something happens we didn’t intend and then someone says “what do we need to do to make sure this bad thing doesn’t happen again?” That’s when we start making rules and procedures and writing things down. The credential and calling system is designed to afford a certain amount of disclosure and protection in an extended system where we all don’t have face to face relationships or histories.
Carfax for Ministers and Churches
Perhaps a crass example might help clarify what is going on. Anyone who wants to buy a used car wants ultimate disclosure. Was this car ever in an accident? Did the previous owners do the proper maintenance on it? Did the previous owner “baby” it or drive it hard? Highway or city miles?
The seller of the used car also has an agenda. They want to present the car in the best light possible to get the best price for the car. Because of this services like Carfax have come to the market to provide a bit of impartial disclosure. Buyers can ask a third party to examine the insurance record of the car. It won’t tell you everything, but it will tell you something.
The CRC system for pastors and churches creates a sort of a market place when it comes to ministerial matchmaking. Congregations seeking a new senior pastor want the perfect candidate and they want to present themselves in the best possible light. Pastors too who are looking for a place to serve want to find a congregation that fits what they want to do and will treat them well.
Into this mix the CRC credential system and the denominational Ministerial Information System comes as a sort of a Carfax to the conversation. If a minister is separated from a congregation via Article 17 it is noted on his profile. If a church too separates it is noted on their profile in the Ministerial Information service. This operates as a sort of a red flag, inviting prospective pastoral candidates or congregations to do a bit more inquiry into what had transpired. Was this a case of a bad match or does it indicate something in the pastor or the congregation that might be a problem in the next relationship?
Many of us know that disclosure is always a tricky business. In evaluating two cars, one might prefer a car that had never been in an accident over one that has, but people and congregations are a lot more complex than cars and a pastor/congregation relationship is a lot more complex than a driver/car relationship. Not all conflicts are the same and even though it is easy to say that both parties will bear some responsibility in any conflict (as professors of total depravity it’s easy to declare that neither party engaged the other perfectly) it is more difficult to look at one conflict and to know how contributing dynamics of either party will play out in the next relationship.
Upsides and Downsides
Given the ministerial marketplace we can well understand the desire of councils and pastors to avoid having an Article 17 on their record. As with many things in life there is an upside and a downside to this.
The upside is that both sides should be motivated to work on the relationship. Maybe the pastor taking a call to someplace else IS the best choice for a particular situation. Maybe a congregation’s leadership needs to take a look at the leadership culture that has developed and make some changes.
Another upside to the record keeping system is that patterns can become apparent to the broader system and there might be hope for remedial intervention. A downside to our system which balances congregational autonomy with accountability to broader assemblies is that issues with pastors or local churches that may cause repeated trouble are often not addressed well or not addressed at all.
When we see patterns like this responsible adults begin to say “something needs to be done about this situation” and stuff happens. Problems are under the surface and are only addressed after the damage is done. This lag in the system too has both upside (sometimes the remedy is worse than the problem) and downside (pastors and churches are harmed when it could have been prevented).
The downside to our record keeping system is that it is “no fault” and a blunt instrument. A flag is a flag and every “buyer” in the clergy marketplace will have their own judgment however poorly informed on any past situation. The system can feel graceless if in one’s judgment past issues have been resolved and won’t likely be repeated.
The system also reinforces the idea that there are spotless pastors and churches and blemished ones. We imagine that a pastor or church with no flag must be better than one with a flag. Sometimes that’s the case, and sometimes it isn’t. Our flagging system will always be imperfect and subject to interpretation. There is no way around any of it. On one hand we act as consumers in a clerical marketplace hoping for a ministerial soul-mate while also professing that all shepherds and flocks are broken.
What do you think?
I think this piece will probably be the first in a series on Article 17 because it is an important function of Classis. One of the things I’ve learned is that there are a lot of stories out there surrounding this. Here are some stats on the use of Article 17. Is this a helpful system? Next time I’ll address more details on how it should be employed.
1980 to 1989: 24 Art 17a, 7 Art 17d
1990 to 1999: 25 Art 17a, 13 Art 17d
2000 to 2009: 146 Art 17a, 26 Art 17d
Comments
Thanks for the article, Paul! Many good thoughts.
I would add that Article 17 is also used when a pastor is released from ministry in a particular congregation for reasons that are not due to conflict at all. When a pastor decides to go back to school for another degree or needs to relocate due to family circumstances, an Article 17 process is used, and hopefully the reasons are made clear in the minutes of classis, to avoid the stigma that you refer to above. The numbers of these types of "Article 17's"--which are included in the totals per year--are also increasing. Maybe if these types of cases continue to increase, the stigma will decrease! :)
At any rate, this also supports your good advice that churches should ask good questions..
Kathy...
I agree with you on that point. My father-in-law helped consolidate three churches in the South Chicago Suburbs back in 05. One church was without a pastor and the other two churches had a pastor. Once the churches consolidated, the two pastors (my father-in-law being one of them) both stepped down in order for the churches to merge together more seamlessly. This technically is an article 17. But it was for a good reason as well.
Thanks, Josh. Another example I know of is that of a clergy couple in which one spouse took a new position, so the other spouse went through an Article 17 release from his congregation. In fact, I know of more than one of these situations, so that could be a new trend. And also a good reason! :)
Indeed, Kathy! There should be a different church order option for pastors who must separate for purposes that do not connote or denote a "divorce" of anykind. Perhaps a leave of absence could allow for a church to search for a new pastor or a pastor to receive a call from another church. As it stands a leave of absence requires the pastor to return to the same church. The Acts of Synod shouldn't be required to report that synodical delegates have heard "weighty reasons" for an Art. 17 when the pastor (with the blessing of his or her council) is going back to school or training for a different sort of ministry (e.g. chaplaincy, church planting, pastoral counseling). The real meaning of the non-divorce Art. 17 isn't reported in the Acts of Synod. So, the stigma sticks... and stinks!
Thanks Kathy, Ken, and Al for pointing out some of the glaring omissions from this post on Article 17. In the interest of “full disclosure,” I am a minister who was released under Article 17 (gasp!)… to go back to school for further studies (whew!).
And while I agree that we should use kinder, more inclusive, and more accurate language, the fact that the primary post about Article 17 on the CRC’s Network site refers to Article 17 as equivalent to a “red flag,” “a divorce,” and a “car accident” shows that whatever anyone might want to claim, there is most definitely a stigma associated with Article 17.
Unfortunately, the perception of Article 17 is far more powerful (and prevalent) than its actual usage or “original intent.” According to the church order, Article 17 is not “our flagging system” nor is it a “no fault divorce” between the pastor and congregation. Obviously there is sin involved (there is sin involved everywhere!), but Article 17 is supposed to be for those cases that are “weighty” but not to the point of requiring “discipline” (that’s Articles 82 and 83). But, that’s not the way Article 17 is perceived—and in some cases, is not how it has been used.
And while churches should investigate more fully why a pastor has been released under Article 17, I think that because many pastors and Classis delegates do see this is a “flagging system,” there needs to be much more work done at the synodical level on how Article 17 should and should not be used (particularly in the cases of ordained ministers going back to school for further studies and those who actually should be released under Article 83 because they were “guilty of neglect or abuse of office”).
So I'll be very interested to see what the future posts have to say about Article 17 and how it should be employed.
The bottom line with Article 17 is (heaven forbid I mention this) sin.
Now the Church is actually the place for sinners; and it is no secret- sinners abound in a church. It is really tragic we should find Article 17 so awful; it was originally designed (imperfectly perhaps) to help sinners negotiate an environment that was created by them!
While it seems we have sinning down to a science, and pretty well understand its function in the article; we really don't have a good handle on the other key facet of Article 17, and it should go hand-in-hand: forgiveness.
We come by sinning so natural, and perhaps that is a reason for an epidemic of "17s" in whatever shape or form. But it is in forgiving that Article 17 lives in such a graceful manner; therein is its greatest strength!
Article 17 indeed serves a necessary purpose in this sinful world made up of imperfect congregants, pastors, and churches; but 17 also leads us to the precipice of forgiveness...are we ready to take the next step?
Maybe the best advice is not to step...but to leap!
Once we discover the healing power that is delivered by forgiveness and grace- all those "flags and tongues will quit flappin’!"
Healing may, yes will take place for both pastor & church.
Perhaps with Article 17 it is time now to focus more earnestly on forgiveness and grace.
Paul, I appreciate your treating this subject, including the statistics for the past several decades. I also appreciate your graphic writing style.
Not knowing what’s coming in your next installment, and not having read other posts when I wrote thisI will make two simple points.
First, today’s Article 17 is written not only for ‘no-fault divorce’ but for a variety of situations that are occurring with increasing frequency. Examples include:
Second, as Article 17 is applied increasingly to varied situations, we need to find more neutral language and images. Article 17 is not a divorce. It is not necessarily a flag. It is a release from one’s call to a specific position, for a variety of possible circumstances and considerations. Relevant positive, negative, and neutral aspects of a release can be recorded in the action taken by classis and in other ways, so that future employers are appropriately in-the-know. However, let’s use kinder, more inclusive, and more accurate language in referring to the use of Article 17.
So let me ask a question that takes this discussion in a different direction. Why do we have an article 17 in the first place? Why is it necessary to identify the leaving of a minister from a particular position if there are no reasons for discipline? We do not have an article 17 for elders or deacons.... Does the article 17 apply to evangelists?
Why not simply stipulate that the termination of a minister's position shall result in two weeks or one month salary for every year of having served with that church? Or simply make that a part of the original contract agreement? There are lots of reasons apparently for termination of an agreement. If some of those reasons make a preacher ineligible for call, then that could be identified. But the calling to ministry and the ability to minister is not limited to a paying occupation or to a readily definable position in all cases.
If a preacher/pastor left a particular job, why would it be so difficult for him to accept a call three or four years later just because he happened to want to be a volunteer carpenter in honduras for three years?
Why not get rid of Article 17 altogether? What would happen if we did?
Thanks for all the good comments. I hope to write one or two more posts on Article 17 as I've been watching it employed at classis.
On the question of the stigma, a good deal of this arises from the disclosure requested by the Ministerial Information service. Both ministers and churches are asked to disclose if they've ever been separated from a congregation by way of Article 17. For me this is what constitutes "the flag" and what contributes to the stigma.
Are you in favor of removing this area of disclosure or keeping it? Perhaps you have a recommendation to have it adjusted? Why or why not? I'd be very interested to hear it. pvk
Many of the comments have asserted that often Article 17 is used for reasons other than a conflict between a church and the pastor. I have no doubt that this is the case. In my experience most of the times I've either seen the Article engaged or avoided it was because there was a conflict. My sample might be skewed and I don't think anyone is taking a survey.
In my next post I'll get more into the mechanics of the article, especially with respect to the prescribed roles of the regional pastor and the classical committee responsible for allowing the congregation to call another pastor. Both of these mechanisms were obviously created to address a situation of conflict, not necessarily a situation where there is formal discipline.
Another wrinkle impacts the church's reticence to use discipline for cases of something other than sexual or financial impropriety. That's a large topic that I probalby won't go into, but it too lurks behind the numbers.
Anyway, thanks for the comments. Keep them coming. pvk
Paul,
In my experience most of the time Article 17 was also because of conflict between the pastor and the church--until I decided to go back for my Ph.D. That's the very reason why several of us who have gone back to school over the last few years first attempted to avoid Article 17 and its stigma by seeking any other possible route (e.g. Article 12 or 16). But, there is no other way.
There's no question that based on Classis experience, the disclosure requested by the Ministerial Information service, and the prescribed roles of the regional pastor and the classical committee, that Article 17 is primarily (and almost exclusively) used to address a situation of conflict. But even where it is not used that way, it is still perceived (at least, in general) as a "red flag."
I think the sheer fact that from 2000-2009 the use of Article 17 went from 3-4 per year in the previous two decades to 17 per year(!) should call for Synod to re-evaluate how it is being used and why this drastic spike happened.
Hi Jeff, and the rest,
One additional reason for the spike in the past decade may be the fact that Synod 1998 added the line to Article 16 about ministers being given a leave of absence to require them to return to service in that congregation. Churches sometimes were using leaves of absence as a way of accomplishing the release of a minister from service in a congregation, which is what Article 17 does.
Article 17 itself is not written in negative language--though it is used for difficult situations. So the stigma arises from the difficult situations and the number of them. I really think (and hope!) that as the other uses increase, such as Al Mulder describes, the stigma will lessen. And when there are difficult situations, then Art 17 and its supplements provide a way for a careful process of dealing with them.
Maybe the MIS forms could be stated better. (You can find them online at http://crcna.org/pages/pastorchurch_index.cfm)
The Minister's Profile Form asks the question this way:
2. Has your relationship with a congregation ever been terminated by you, by the governing board or jointly?
_____ Yes _____ No
Explanation:
It seems to me that any congregation that reads an explanation like Jeff's would be quickly satisfied, and if there is an explanation indicating that there had been a conflict, then they have opportunity to ask questions and explore more. That's for the benefit of all involved. But I wish the word "terminated" was not used, since that's not in the Church Order.
The Church Profile form says:
b. Has there ever been an Article 16 or 17 termination in the history of your church?
_____ Yes _____ No
Explanation:
Again, I wish the form used the Church Order's language of release, not termination. I do think it's good that such releases are only for "weighty reasons." Such releases should not be done lightly, for whatever reason. And actually, Article 16 is not about a termination at all, but a temporary leave of absence, so that part of the question is not accurate.
On the forms, I'll even volunteer to bring it up to the Ministerial Information Service committee that advises Pastor-Church Relations. I happen to be on it. :)
So much to read...so much to contemplate, and shucks- Article 17 takes up such a small place in the Church Order!
Can we "can" 17- no, I don't think so. "Should we can" 17- no, I don't think so!
Article 17 is there for a good reason, so why all the bad publicity? For those that have used it with a spirit of understanding it has seemed to work; but for those who perceive it as an "end to a means"...they are terrified by it.
Does it create a stigma, it most certainly does- especially for those who are clergy in this denomination; what about the laity- from my experience with council people, and pew sitters if you ask them their feelings on 17, one of their immediate responses is: "SAY WHAT?"
One of the reasons we need Article 17 is contained in the Letter of Call (excerpts only- emphasis mine)-
"...we extend to you this letter of call and urge you to come and help us...should it please the Lord to send you to us...that you may arrive at a decision that is pleasing to him..."
This is what makes a minister different than one who is "hired and fired," and what confuses the average disenchanted pew sitter that figures if you just don't like the minister- "out with the bum!"
We take this "Calling" business in our denomination rather seriously, and the church is not just run like a business with a transient worker that is looking for upward mobility; even when "upward mobility" may be one of the desired ends for all that enter the house of God.
We need 17 in order to negotiate the troubled waters of pastor and congregation seeking a separation; after all these are the same people who at one time said "this is God's will."
I’m sorry…God does not make a whiff; he does not make a miss; so therefore without proper disengagement, how are we going to seek an amiable, and sometimes a necessary separation and departure?
When Article 17 is explained and understood, most laity say- "OK, let's move on"; however, I have yet to find a minister to rally around the call for 17. That number for "people of the cloth" is anathema- it is avoided by all means and by all costs because it equals the number of failure- especially when you factor in "the Call!"
So how are we going to make it work like it should; because folks, if we do take the Calling process seriously we really can't get along without- the number 17?
To all -- a few additional thoughts about the function of Art 17 or something like it.
An underlying principle at work is that ordination is granted only in relation to ministry functions that the church regards as sufficiently important to warrant ordination. Elders and deacons are considered ordained only when they are serving on council, or perhaps under mandate of council in some way. SImilarly, ministers are eligible for ordination only after they have received a call. If they receive another call, they can (usually) simply be released from one call to accept and minister under another call.
When an ordained minister is released from one call without having another call in place, this is when Art 17 comes into play. It provides additional structure, accountability, and support for the minister without call -- in collaboration with the classis and synodical deputies -- to remain eligible for call so long as reasonable opportunities exist for receiving another call. Generally there is a two year grace period, and eligibility for call can be extended on an annual basis for weighty reasons. Eventually, however, a minister cannot retain the status of minister without being under call to a specific ministry.
In principle, the only exception to this is when a minister reaches retirement age and may be granted emeritus status, i.e., retain the status of ordination without a specific call.
I'm thinking we should rethink this article. If a preacher is really called by a congregation at a point in time (remember he was not called prior to that, but at that specific point in time), then he can later decide he is uncalled, or rather, called by another church which takes priority. The church apparently can make no decisions about calling whatsoever; it apparently cannot normally uncall a preacher/pastor at any time, except for very "weighty" reasons, which may be considered weighty only by classis, apparently. This used to make sense to me. But I'm not sure it still makes sense to me.
As far as stigma is concerned, it may be in some cases that what appears as stigma, may be exactly what another church may desire or need for their situation. If the mere mention of an article 17 or a separation of congregation and preacher is what is keeping a church from investigating a preacher, then it is certainly not doing its homework. And if it does not do its homework, it probably deserves whatever it gets, a nice preacher without an article 17 who is very nice, and complacent, and friendly and politically savy. Probably not a prophet. (Of course, in some other cases, an article 17 greatly understates the problems that led to its being used.)
Underlying all of this, although it is not mentioned, I am guessing is a concern about eligibility for the pension fund. Eligibility for call can always be restored, but loss of access to the pension fund is a serious matter indeed. It's that unstated unmentionable, in my view.
The business of elders only being ordained during their term, and not otherwise, is somewhat contradicted by the fact that they are re-installed, not re-ordained for new terms. But in so far that they lose their ordination (for reasons that are not weighty at all), this would appear to have no biblical purpose whatsoever. The distinction between the treatment of elders and preachers in this regard is a contradiction of the equal honor the church order mandates for the offices. The establishment of this distinction in this way accomplishes three things: it encourages the depreciation of the office of elder, and it encourages the solicitation of unqualified people to be elders, and it encourages the people occupying office of elder to consider it a temporary task rather than a calling.
We shoud\ld imagine to ourselves what would be the effect if we were to eliminate article 17 altogether, and instead simply accept that congregations and pastors are always in a position to review their relationship. That a calling to be a preacher does not mean the calling is to be exercised only in one orginal church only at the whim or perogative of the pastor. That the potential release of service ought not to be seen as a depreciation of the preacher as pastor, but rather that the task of that preacher has accomplished its purpose in that situation. Or in some case, might appear to never actually be able to accomplish its purpose for various reasons. Either way, God is not finished yet with either the preacher or the church, and it is His puposes that must predominate, more so than the procedures and officialdom of our present practices.
This type of paradigm shift would also lift the stigma from the simple exercise of the release of a minister from a congregation, and would not change his actual educational credentials, nor his years of experience, which could be highly valued by a seeking congregation. The fact that such a release is not always convenient, nor pleasant, should not prevent the usefulness of it from happening.
The language of "calling" sounds quite pious, but the orientation towards job security and financial security brings it much closer to something entirely different.
Please correct me if I'm wrong (with evidence).
I have one suggestion for alleviating the "stigma" somewhat, namely, to be absolutely specific and accurate in the minutes of the classis that approves the Article 17 request, stating in straightforward terms why the separation is sought: like "entering a Th.M. program longer than what the congregation can afford to give in terms of sabbatical," or "the council believes that a change is needed after x number of years in order to enliven the ministry to the congregation: or "spouse has received a ministry position in another province or state," etc.
Stated Clerks of classis, council clerks, ministers all have a copy. One should also be furnished to Pastor-Church Relations so that it can become more specific about what was involved in the separation.
Why not, in other words, be specific and speak the truth in love.
Dr. DeMoorm ...
Looking over Art 17, one of the "flags" that strikes me is the language of "weighty reasons". Is it possible for Synod to admend that to being "weighty and non-weighty" reasons.
Or would it work to add a new subpoint?These wold then encompas what you wrote for situations such as "stating in straightforward terms why the separation is sought: like "entering a Th.M. program longer than what the congregation can afford to give in terms of sabbatical," or "the council believes that a change is needed after x number of years in order to enliven the ministry to the congregation: or "spouse has received a ministry position in another province or state," etc." Other reasons for Art 17 would be for life situational changes that aren't so weighty as they are just a need for change, as you afor mentioned. Could this be a new subpoint "e"? I know that this would take an overture to Syond. Or, would it be better to have a new article all together?
Where's the "like" button on here? This is definitely the best solution in the current situation.
Jeff,
It's at the top of the sidebar on the right-hand side of this page:)
Thanks. But that is for the whole article, isnt't it? I wanted to "like" Dr. DeMoor's comment.
I hear a few different streams in this comment thread:
1. How to administratively differentiate conflict and non-conflict Article 17s.
2. How do we talk about, think about, experience "calling". Where is it located? How is it recognized? How can we process it as a community in a credible, clear and intelligible way?
3. How do we process conflict? How do we heal from conflict? Do we learn productively as a result of conflict? Are we experiencing more conflict (Art. 17 stats)?
Josh,
I don't think we need any church order change here. The reason for the word "weighty" is that we are talking here, theologically, about a person being called to a specific ministry in a specific place and a minister cannot just ignore or reject that calling without really good reasons nor can a council "go back on" what was an indefinite call channeled through that local assembly without really good reasons. My contention is that if the reasons are clearly stated, we'll be able to "differentiate conflict and non-conflict."
On Paul's question about experiencing more conflict: the situations of conflict I most meet in my conversing with people in different places throughout the continent are those that involve a minister who keeps denying that he/she is part of the problem. Our society is getting incredibly narcissistic, in my view, and this doesn't leave us untouched in our church roles. Where is the dedication to ministry, succesful communal ministry, even if to be successful I (the minister) may have to step aside for the good of this congregation. Ministers can be so un-servantlike sometimes ......... Ah, just a "cri de coeur," as the French would say it ....
Henry, thanks for joining this thread regarding Art. 17!
Now herein lies a problem that "voices a load"-
Where is the dedication to ministry, successful communal ministry, even if to be successful I (the minister, or council person[my add]) may have to step aside for the good of this congregation.
Changing church order, rephrasing with kinder more gentle language, initiating a new approach all deal with the symptoms- but not the problem!
Issue here is either a minister or council(individually or whole) that refuse to see beyond the forest; the church is not about me, it is about the ministry that has been given us...once we start to figure out this, while Art 17s may not become extinct- but at least understood with more compassion.
Start with the heart of the minister, or with the hearts of the council...the correct words will fall into place once that happens; IMHO.
While, in theory I agree that we shouldn't need a change in the Church Order, it seems to me that the language (jargon) of Article 17 and its supplements functionally operates as if the article is primarily for cases of conflict.
The word "weighty" has come to have the connotation of “heavy, serious, grave, solemn, or burdensome" rather than something that is "sufficiently significant" for a minister of the Word to be released from the specific calling to this congregation.
The questions from the Ministerial Information Service which refer to this as a "termination" also carry a negative connotation, which undoubtedly perpetuates the associated stigma (hopefully, at Kathy's request, the committee can remedy this).
I definitely think we must keep Article 17 and its reason for existence. And I agree that it is good that such releases are only for very significant reasons. It makes us take seriously our theology of calling.
But, as this original post (and many Classis meetings) show, there is something wrong with the way Article 17 is understood. As much as it is applied correctly in a wide variety of cases, it is still assumed/perceived that Article 17 is for irreconcilable problems (and thus, the comments that wording changes would only deal with symptoms and not the root problems).
I'm not sure exactly what that something is, but it seems to me that if the Church Order is "wisdom literature" meant to help the church function in healthy and wise ways, then it may be wise of us to consider ways to clarify and more accurately communicate in Article 17 (and/or its supplements) the purposes and cases for which it is to be used.
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