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Gneex Onrovox TueoLogicaL Review 613-4 2016 ‘The Autocephaly of the OCA: History, Arguments, and Aftermath Alexander G. Drages ‘The Orthodox Church in America, herein abbreviated in its more common form, OCA, is one of many Orthodox ju risdietions that curently exists among the Orthodox faithful the American diaspora, The fact that there are currently multiple “ethnic” Orthodox jurisdictions within the same ‘geographical area is legally unacceptable within the legal framework ofthe Orthodox Church, as is eanon law 3 cally dictates that every individual ecclesiastical jurisdiction ‘mustexist in one specific geographical location. The ancient (Church enforced ths law throughout its history in order to prevent conflict and interference from one Church adm tration over the other, and it was, with some exceptions,’ ‘mostly upheld intact throughout its history until the rise of cthnic division and formation of state nationalism among the Orthodox peoples within the multi-ethnie Otoman Empire during the nineteenth and twentieth centuries. ‘The creation of these new, predominantly homogenous, Orthodox nation states, especially inthe Balkansand Southern Europe, led to the creation of new independent churches in each new respective country. These independence move- ments, however, were quite detrimental to the jurisdiction of the ecumenical patriarchate of Constantinople, whichhad pre- viously complete control overall the Orthodox inthe Balkan region ofthe Ottoman Empire. Although Constantinople ini- tially condemned these ecclesiastical independence move- ‘ments as an ethnic tribal heresy (ethnophyletism) inthe late 167 168 GOTR 61:3-4 2016 nineteenth century, most were eventually granted ecclesias- tical independence (autocephaly) from Constantinople after 1a form of rapprochement was established between the two sides. This action fr the most pat, restored canonical order to the Church until the flames of a much more complicated ccenonieal anomaly would be ignited within the multiethnic ‘makeup ofthe Orthodox immigrants inthe New World. This ‘new anomaly, however, would be far more complicated than the previous one, a it would see the establishment of many ‘multiethnic Orthodox jurisdictions in the same lan that was not subject to the ethnic and religious restrictions of the ho- ‘mogenous nation states ofthe Old World. . ‘The twentieth century sawa large influx of Orthodox immi- ‘rants to the New World from different ethnic backgrounds ‘ho went in order to make money inthe land of opportunity. ‘Alone and unfamiliar withthe English language, these im rants banded together and established their own ethnic communities. Once it was decided that the United States ‘would be their home, these communities collected money to baila parishes and invite priests from their native land to ter'to the spiritual needs oftheir community. Ethnic parishes ‘were created from state to state, eventually leading tothe cre- ation of unified dioceses for each respective Orthodox ethnic group, such as the Greek, Russian, Serbian, Bulgarian, and Romanian Dioceses, to name a few. This phenomenon led to the establishment of “ethnic” jurisdictions in the diaspora, ‘hich although considered uncanonical, is nevertheless eur rently tolerated by the confederation of canonical Orthodox ‘Churches forthe sake of unity in the Church. In order to Justify this action, the Orthodox Church has temporarily ap- plied the use of 2 legal exception to Church law known as “oikonomia” until a binding pan-Orthodox solution to the problem is inevitably found. ‘Understanding the above, however, is what makes the story of the OCA stand out, since it chose to go beyond the status Dragas: The Awocephaly ofthe OCA 169 «quo of existing as one among the many by attempting o be- come the sole jurisdictional hegemon in the United States, ‘The OCA thought it had achieved this after it was granted «disputed and controversial autocephaly by the Moscow Patriarchate along with a small number of independent churches in Soviet satelite states during the 1970s. Its jus- tifeation for having this primacy over the rest was rooted {nthe fat that it saw itself as the historical successor of the Russian mission in Alaska, which was the frst and oldest ion on the continent. This, however, did not sit well with the rest ofthe Orthodox jurisdictions, especially within the largest jurisdiction in the American continent, the Greek Orthodox, which argued against the legitimacy of Moscow's Accision. This confit, however, is much more complicated than the arguments that will ensue, since it was a part of a Power struggle between the Patriarchates of Constantinople ‘and Moscow, who both laid claim over the diaspora, Although this topic is too large to address here afew fun= damental points should be made in order to give a brief elari- fication onthe positon of these two important Pariarchates in the Orthodox world. The Ecumenical Patriarchate has, ‘and continues to maintain, that canon 28 of the Fourth Ecumenical Council (henceforth of the Fourth Ecumenical Council) grants it exclusive contol over the diaspore. More specifically, canon 28 states that Constantinople will admin- ister the “barbarian nations,” that is, those which are outside of the “Eeumene” of the Roman Empire. Using this eanon in the present context of the New World, Constantinople hhas come to interpret it as having given its patriarchate the ability o control and administer any Orthodox jurisdictions ‘outside the boundaries ofthe established jurisdictions of the current autocephalous Orthodox Churches, whose territo- ‘ality of jurisdiction is clearly described in the patriarchal tomes of their autocephaly. The patriarch of Moscow, how= ver, blatantly disagreed. Moscow claimed thatthe “barbar- 170 GOTR 61:3-4 2016 jan nations” mentioned in the canon only refer to those “bar- barians” within the territory of the canonical jurisdiction of the ecumenical patriarch, and not outside, as in the case of the diaspora. Instead, Moscow argues that each autocepha- Tous Church has the righ o establish a jurisdiction in a non- Orthodox territory if that particular Church was the first to establish a mission there. Although tis is a general account ‘of a complex issue, itis important to stress that these two Arguments must be kept in the back of one's mind if one is truly to understand the entanglement of the conflict that ‘would ensue. Tn order to better grasp the events that led up to this auto~ cephaly, es well asthe conflict that would occur in the after ‘math, the subject will be broken down into four sections for treater clarity. The first section will begin witha brief his- torical account ofthe Metropoia (the former OCA) and the events leading upto its autocephaly; the second will focus on the historical documents ofthe autocephaly and give a sun mary of their conten; the third section will comprise of two rival theological viewpoints from Fr, Alexander Sehmemann fand Professor Panagiotes Trempelas; and the final section ‘ill give an account of the actions of the OCA, the contro~ versial jurisdictions under it, and its eurent standing today. [BRIEF HisToricaL ACCOUNT ‘The 1917 was @ monumental year of turbulent change in Russia. The Bolsheviks rose up against the tsar to create the Soviet Union, and the Russian Orthodox Church would once again become a patriarchate two huncred years ater itsabol tion under Peter the Grea, Initially, the Church was opti tic that its election of the newly appointed Patriarch Tikhon ‘would finaly allow it to act independently after years of State interference from the Russian tsas, but it soon became Dragas: The Auocephaly ofthe OCA 171 ter plans in mind. The Russian patriarch realized this soon enough, although there was not much he could do to prevent the Communist regime's persecution of the Church once it hhad clenched control of the entire country. The Communist persecution was quick and brutal, leading to the mass clo- sure and destruction of parishes, the execution of clergymen (later Russia's new martyrs), and to the mass emigration of Ramis loyal othe ar ad the White Ary dering the revolution All this turmoil led the patriarch, who had previous! sive s Meroolan of the Rason Diocese ness and Canada, to issue a decree (utase) to the Russian dio- ‘ceses, including the diocese in America, to manage them- selves independently until normal relations could be re- ‘sumed after a loss of communication. This decree, as well ‘as the fact that Tikhon’s successor, who was locum tenens of the Patriarchal see, was a supporter of the Communist regime, led the Metropolia to declare itself “temporally au- tonomous” from its mother Church in Moscow in 1924.° Tikhon’s decree and subsequent fall led the Metropolia to mistrust the mother Church, and the two gradually began to separate from one anothet. This rift was further exacer- ‘bated after the newly elected guardian of the patriarchal see ‘and future Patriarch Sergius, along with Moscow's Holy Synod, placed the Metropolia ina site of schism on January 5, 1935, which was later reaffirmed in 1947 by Patriarch ‘Alexios | (1945-1970) In response, the Metropolia appealed to Constantinople for canonical protection. The later, seeing the dire situe ation of the atheist regime in Moscow, maintained a rela- tionship with the Metropolia, thereby enabling it to be in ecclesiastical communion with the federation of Orthodox ‘Churches.’ This action, however, greaily incensed Moscow, who in 196 waged a crusade against all its Russian ju- risdictions abroad that were not in communion with it im GOTR 61:3-4 2016 Constantinople, seeing this asa direct threat to the delicate ‘makeup of the Orthodox Chureh, prompted the Metropolia to make amends with its mother Church. This push, how- ever, backfired on Constantinople after the Metropotia made ‘amends and was then unilaterally granted autocephaly by the Patriarchate of Moscow and a few of its closest satellites fs the de facto Orthodox Church in America shorly after- ‘ward, April 10, 19702 Nevertheless, this action was reject- ced by Constantinople and most ofthe other primates of the Orthodox Church, and a battle of words ensued that has been, ‘without a resolution to this day for serious eanonical reasons (erttorialty of jurisdictions, ethnophyletism as an eccle- siological deviation, noncanonical procedure of declaring autocephaly, etc.) At this point, we must tur to the histori cal documents to comprehend the conflict and the arguments that arose out of it HisroricaL DOCUMENTS Leer of Ecumenical Parirch Athenagora 19 Pararch Alexis (January 8, 1970)" "The Eeumencl Petar’ eter bens with the uta cereal formas tovards the Patch in Moscow, lepasinghimfor le restblshmentof relatos withthe previosly“schismai” Metopola,Paach Atengoas, Reveve, vies concer over reports tht Moscow intends to antauocehaly fo the Mewopoi sessing that sch Course of acon woud sigoal a ation of rsdion hat ‘ould ineviabiy ea to isastous conseqsenes. This = {ion he contin, cotary to the seed canons, and unter procanation on bea ofthe Orthodox Church tsa whole would be exemely ata." Thi is mainly dhe tote fat ta the Orthodox jurado in Ameri tre subject various ocoutry Churches is deemed ruil tnt no one group, suchas the Metoplis, i placed Dragas: The Autocephaly of the OCA 173 above the others. Since the granting of such an autocephaly would upset the fragile inter-Orthodox relations, he advised thatthe is- sue could only be resolved in due course through a pan- Orthodox proclamation to avoid disturbing this delicate balance. Indeed, the issue of the granting of autocephaly, 1s well as resolution to the current ecclesiastical situation in America, could only be resolved through a future decree of the long-awaited Holy and Great Synod, that is, through the full agreement of the Orthodox Church in its entirety” (On this account, the ecumenical patriarch beseeches the p= triarch of Moscow not to proceed with the autocephaly of the American Metropolia, warning that if Moscow were to continue, Constantinople would have no choice but “nei ther to recognize this action, nor enroll this Church in the Diptychs, i. in the Sacred Catalogue of the Holy Orthodox: ‘Autocephalous Churches.” The Eeumenical Ptsiagch con- cludes that this decision would become the offical postion of Constantinople on the matter, and would be communi cated as such to the other Orthodox Churches as well. Letter of Patriarch Alexis to Feumenical Patriarch Athenagoras (March 17, 1970)" ‘The patriarch of Moscow begins hs leter with the usual formalities and brotherly greetings toward the patriarch of | Constantinople, but makes a note thatthe leter he had re- ceived from Constantinople was a copy of the original, His response to this letter is stright and to the point. Moscow asks, what are these “disastrous consequences” he refers ‘o, and what exactly does “violation of jurisdiction” mean? Furthermore, he claims that he does not understand how the 8granting of autocephaly would be detrimental since there is “no indication of exactly which canons ofthe Ecumenical or ‘Local Councils or ofthe Holy Fathers woul, in such a case, be violated." On the contrary, the patriarch states that ac- 1% GOTR61:3-42016 ‘cording o canonical and ecclesiastical law, cephaly may be received oaly from a legitimate authority. and such authority is [at present in the Russian Orthodox ‘Church, because every autocephalous Church is fully em- powered to give autocephaly toa part of itself." He then adduces few historical examples in order to sup- port his elaim: 1. The original formation of the local churches in the Roman Empire came about asa result ofthe political importance of a city, which led to the unification of smaller provinces into larger jurisdictions. These fac- tors ultimately led to the emergence of the Churches ‘of Rome, Constantinople, Alexandria, Antioch, and Jerusalem. 2. ‘The Orthodox Church later on granted autocephaly 10 Orthodox peoples who had formed their own indepen- dent ecclesiastical rule through national and politcal means." This autocephaly was ranted by alocal church, tnd not by an ecumenical council, as can be clearly seen in the case of Bulgaria, Serbia, Greece, Romania, ‘Albania, Georgis, Poland, and Czechoslovakia." (On this basis, the Russian patriarch proceeds to his main argument, stating that, “It is very well known that Orthodoxy ‘on the American continent was established, developed and ‘organized by the Russian Orthodox Church,” The Russian Orthodox Greek Catholic Metropolitanate is the daughter of the Russian Orthodox Church.”? This ean be seen in the fact that the Russian Church always had jurisdictional au- thority in America because it had appointed Greek, Serbian and Syria during the 1912 Russian Holy Synod. ‘The muljurisdictional problem, as far as the Russian pati arch is concerned, was ereated in 1921 when the ecumeni cal patriarchate established the Greek Orthodox Archdiocese in America without the canonical approval of the Russian Orthodox Church, which had the right of historical primacy Dragas: The Autocephaly ofthe OCA 175 in America, Moscow, therefore, felt that its actions in grant ing this autocephaly would help unify the different nones nonical Orthodox jurisdictions under one jurisdiction once again” ‘As for the “Great Council of the Orthodox Church,” the Russian patriarch took a more guarded approach on the met- terclaiming that such a Couneil would need alot of time and preparation to address the many issues that concem world Onthodoxy. Therefore, he believed thatthe granting of auto- ccephaly would be the best solution toward solving the prob- Jem of canonical unity in America until such a Council were to materialize. That said, Moscow did stress that the auto- cephaly ofthe OCA would not interfere in the life ofthe oth- er sister churches in Americ, as this should be a matter of concem between mother and daughter churches. The letter then concludes with the decision that “the Russian Orthodox Church arives atthe conviction thatthe Orthodox Church in America has matured sufficiently to become autocephalous and that her independence will assist her development and flowering” This decision was final and would be sent of- ficially to all the Orthodox Churches. Tomos of Alexis, by the Merey of God Patriarch of Moscow ‘and All-Russia (April 10, 1970) On April 10, 1970, less than a month from the Russian, patriarch’s last correspondence with Constantinople, the Russian Church officially proclaimed the autocephaly ofthe OCA. This document recognized the Orthodox Church in ‘America as the true heir to the Russian Chureh’s mission that first spread Orthodoxy onto the American continent, and hoped that its decision would once again unite the Church there via the “suppression of scandalous ecclesiastical divi- sions.” In short, Moscow agreed with Constantinople that the multjurisdictional situation in America was contrary to the canons of the Chureh, but felt that granting of auto- 116 GOTR 61:3-4 2016 cephaly to its “sister” church (the “Russian Orthodox Greek ‘Catholic Church in North America”) may help cure this ‘anomaly. This new autocephalous Church was henceforth 0 bbe known as “The Holy Autocephalous Orthodox Church in “America,” and it would be “independent and self-governing, ‘with the right of electing its own primate and all her bish- ops.” In other words, the newly formed OCA would have the full authority and privilege of an autocephalous ehurch (eg, such as to create its own holy chrism), while pledging to uphold and preserve the divine dogmas and the sacred ‘canons of the Orthodox Church, “The document then goes onto apply certain ules and regu- lations toward this autocephaly, and itis here that one en counters some contradictions in Moscow's rhetoric. Of par ticular note are the four irregularities seen below: 1. The parishes in the USA snd Canada shall remain un- der the Moscow Patriarchate unless they “choose” to ‘g01t0 the OCA.” 2. ‘The Moscow Patriarchate shall not “canonically” pe- rit its members to join any other Orthodox jursdic- tions apart from the OCA* 3. The other Orthodox Churches are invited to acknow'- cedge the autocephaly of the OCA.” 4. The “Other” Orthodox Churches in America are viewed 1s *National Churches." ‘The main paradox can be seen in the fact that Moscow al- lowed its parishes inthe American Continent to stay under the Russian patriarchate, even though it claimed that the sgranting of autocephaly was to foster unity by eradicating the phenomenon of mulijurisdictionalism.” Moreover, the deviation of the necessary recognition, that is, the fact that ‘Moscow “invites” the other Orthodox to acknowledge its de~ cision, whilst at the same time declaring these jurisdictions ‘as “national churches,” would lead to greater division rath te than promote unity among the autocephalous Orthodox Drogas: The Auocephaly ofthe OCA 177 Churches. Indeed, this deviation led to contradictory reac~ tions ofall the Orthodox Churches. Letter of Patriarch Athenagoras to Metropolitan Pimen une 24, 1970)" Tnresponseto the proclamation of autocephaly, the patriarch ‘of Constantinople reportedly had 10 write to Metropolitan Pimen, the locum tenens of the patriarchal throne of Moscow, instead of the patriarch since there was a lack of communi cation from Moscow. After the usual formalities, the letter begins by addressing a concem over a ‘missing letter’ to the then recently deceased Patiarch Alexi, attaching a copy of | the letr’s receipt to prove that it had indeed been sent 10 ‘Moscow. The Ecumenical Patriarchate expressed its sorrow lover Moscow's persistence in following an incorrect and noncanonical procedure on its tomos of autocephaly, and once again reiterated its postion that autocephaly must be granted by the Church as a whole. To back up this claim, Constantinople substantiated its position through the fllow- ing arguments: 1. The examples of Church history, as wel as guidelines, provisions and Tomes all show that “the granting of autocephaly is a right belonging to the Church as ‘whole, and cannot at all be considered aright of ‘each Autocephalous Church." 2. Canons 6 and 7 of the First Ecumenical Council ac~ ‘knowledged the valid status of the Churches of Rome, “Alexandria, Antioch, and Jerusalem, 3. Canon 2 ofthe of the Second Ecumenical Council es- tablished the independence of Asia, Pontus, and Thrace. 4. Canon 8 of the Third Ecumenicel Council secured the utocephaly of the Church of Cyprus. 5. Canon 28 of the Fourth Ecumenical Council regu- lated the Dioceses of Asia, Pontus, and Thrace under the Throne of Constantinople. Furthermore, the same 178 GOTR 61:3-4 2016 ‘Synod settled the difference ofthe boundaries between ‘Antioch and Jerusalem. 6. ‘The Fifth and Sixth Ecumenical Synods were also con- ‘cemed with jurisdietional boundaries. 7. The Churches of Mediolana (Milan), Lyons, First Justiniana, Ochrid, Tymovo, Ipek, Iberia, and others did not receive their autocephaly through ecumenical validation, and thereby lost their status through the ‘passage of time, The Churches that have received au- tocephaly through ecumenical recognition, however, hhave retained their eutocephalous status to this day 8 Autocephaly, therefore, can only be granted by a syn- ‘od representing the entire Orthodox Church, and the ultimate expression of this is through an ecumenical synod. ‘As far as Constantinople was concerned, the above points ‘were enough to prove that Moscow did not have the rights it claimed as & local church, but went further adding that the Thirty-Fourth Apostolic Canon gives a local church the right to petition for autocephaly, but “it is not eanonical for a local Autocephalous Church to declare autocephalous @ ‘branch Church detached from its ecclesiastical realm." The patriarchal tomos of autocephaly clearly specifies the limits ofthe territariality ofall jurisdictions according tothe deci- sions of the Great Synod of Constantinople (1872). In other words, Constantinople censured the Russian Church for go- ing beyond its jurisdictional boundaries, adding that: 1. Apostolic Canons 14 and 34 state that “no Bishop be permitted to pass over into the Province of another"* 2. Canons 6 and 7 ofthe First Ecumenical Council declare ‘that “the old custom be kept” and that “each throne rule ‘over the Provinces belonging toit"* 3. The Second Ecumenical Synod goes on to say that “bishop should not invade the Province of another ishop exceeding his jurisdiction.” Dragas: The Autocephaly of the OCA 179 ‘Thus, Constantinople censured the Church of Russia of ex- ceeding its boundaries by unilaterally taking decisions on the ‘American issue without the approval ofthe other Orthodox (Churches. This, however, was notte first time that Moscow hhad gone beyond its boundaries according to the patriarch, Moscow was also accused of having exceeded its jurisdic tion by interfering into the affairs of the Churches of Poland and Czechoslovakia in the 1920s, eventhough they were n= der the jurisdiction of the ecumenical patriarchate. But going ‘back othe topic at hand, the ecumenical patriarch added that there were also historical factors tht went against Moscow's claim of jurisdictional right in America, For example: 1. Alaska was Russian territory, and not teritory of the United States of America, at the time of its mission therein 1794. 2. Russia sold its tersitories to the United States in 1867, thereby making Alaska a part of America from that point on. That essentially meant thatthe mission was no longer under Russian jurisdiction. 3. The open immigration policies ofthe United States in the twentieth century brought in the greatest infiux of Orthodox peoples to the continent, in contrast to the Alaskan Mission that was created to Christianize the pagan peoples ofthat particular Russian region. Having said that, the patriarch did at least agree with Moscow on one point. Namely, that the multijurisdictional development of the Orthodox in America was contrary to ceanon 21 ofthe Fourth Ecumenical Council. That is why, the patriarch argued, the Church should view the existing situ- ation through the application of “oikenomia” until a resolu- tion to the problem is found through a great synod.” Thus, by choosing one relatively small section of the Russian dias- pra as the de facto Church in America, the Russian Church ‘was in effect jeopardizing the fragile unity that curently ex= isted amongst the different jurisdictions. Consequently, the 180 GOTR 61:3-4 2016 patriarch of Moscow was warned not to go beyond the terr- torial boundaries that were granted to him by the ecomenical patriarch, whom he acknowledged as head and frst in rank, land the other senior patrirchates. The patriarch then ended his letter with the following statement: “the Sister Russian Orthodox Church, retaining her canonical order and hi ing in mind and desiring the peace of the Church, will not only proceed no futher inthis matter now under judgement, ‘but will also make every effort to dispel the confusion it has caused in reference to canoniciy...We consider as valid only a Pan-Orthodox decision concer entire issue ofthe Orthodox in the “ Letter of Metropolitan Pimen to Patriarch Athenagoras (August 11, 1970)” “The metropolitan's letter begins with the usual formalities towards the ecumenical patriarch, but further adds titles of recognition such as Your Holiness, Beloved to the Lord, and Most Holy Master. He is essentially writing the leter to an- swer all the questions raised, as well asthe censures made by the ecumenical patriarchate. He starts by acknowledging the Church of Russia's indebtedness to Constantinople for its independence, but reminds the Patriarch that the Church is primarily indsbted to Jesus Chuis, the Lord of al, for its ex- jstence. Moreover, he adds that the Russian Church, which hhad been independent since 1448, and elevated tothe status of Patriarchate in 1589 by the ecurnenical patriarch Jeremias HU Tranos, has the same attributes and limits as all the other Patriarchates, regardless ofthe Patriarch of Constantinople's rank as frst in honor. ‘The metropolitan, then, tackles the issue of autocephaly arguing thet the ecumenical councils never intended to per manently list the established jurisdictions as autocephalous Churches like the Church does today. He does admit, how- ever, much like the recently deceased at that time Russian Drogas: The Autocephaly ofthe OCA 181 patriarch did before him, that Constantinople did grant auto- cephaly to Churches that were established in certain or new- ly formed geographical areas, but argues that this was only done out of respect for Constantinople’ rank rather than any extra power it might claim to have. Likewise, be argues that the dissolution of some autocephalous Churches throughout the history of the Church was usually done via interference fom neighboring autocephalous Churches since an ecu- ‘menical council had not convened for over twelve hundred years to solidify ther status. A future council would remedy this problem by listing the present autocephslous Churches, bat it would be inconsistent with the sacred canons if such 1 Council were to confirm the rights of an already existing autocephalous Church" The fact that an ecumenical council is such a rare event led dim to assert that the “Local Church ean, when need aris- ¢s, proclaim the new autocephaly of a part ofits own local is based on, and explained in, the sa- ‘red canons, which setno limitations to rights of local synods of autocephalous provinces (First Ecumenical Synod, eanon 2.& others) It is for this reason that he sees the aetions ‘of Constantinople as steeped in vanity because it presumes to have primacy and supremacy overall the local churches. ‘Moreover, the metropolitan disapproves of the notion thet Constantinople has the right to be called the “Mother” of the Churches, since this right is exclusively reserved forthe Patriarchate of Jerusalem, which he considers to be the true Mother ofall Churches. ‘With all the above in mind, the metropolitan gives his view ‘on what criteria are needed forthe granting of autocephaly: 1. sufficient numberof bishops. 2. Asuffcient numberof priests 3. Asuffcient number of flock, Furthermore, the metropolitan fels offended by Constanti- nople’s censure that autocephaly separates a sister Church 182 GOTR 61:3-42016 ‘rom its mother, as well as by the censure that Russia over- stepped its jurisdictional boundaries in the cases of the Churches of Poland, Czechoslovakia, and now in America. Ti response to the first censure, he argues that the Russian Orthodox Greek Catholic Church “has fulfilled all these re quirements and conditions in full, in connection with which, hier Mother-Church, the Patriarchate of Moscow, granted this ‘Church autocephaly.”® In this way, the sister church has not been separated from its mother, neither through province, nor through its canonical relationship with i. In regards to ‘Moscow overstepping its boundaries in Europe, he contends ‘that it was Constantinople that frst interfered inthe jurisdic tion of the Holy Church of Russia by creating a noncanoni cal situation in Poland, and by having “violated and scored. the rights of the Holy Autocephalous Church of Serbia” the case of Czechoslovakia. Having made his above points, the metropolitan concludes his letter by reafirming the le titimacy of Moscow’s decision to grant autocephaly to the OCA, and urges Constantinople to renounce its disagree- ments, which ultimately “contradicts the Holy eanons and the tradition of the Catholic Orthodox Church."** Report on Auocephaly of Metopolon Irene, Archbishop Now ork and Meropolian afl America and Conde ne Fa At mercan Coc oft Orhodox Catch in ‘tmeriea (Oxober 20-22, 1970 ‘Musca refine by Moos the OCA wet onto ponent fst enunl as nly formed albeit di Sic aocepanus Church Ini our, Metropol ete (19701977) then pinata he OCA, begs is Spon by raisin he OCA fr having matured to sich a e- tie troughou te tenet cet to become slo Eire Church, even how ad faced many obstacles in seat fr aocepaly He believed hat most of ese ob sles weteadiesed inte 1967"All-Amercan Couel” Dragas: The Autocephaly ofthe OCA 183 but were finally overcome afier the Moscow Patriarchate granted the OCA its autocephaly in 1970. The metropoli- tan deemed this action as a “decisive step in the direction of canonical clarification” as the past schism between the ‘Moscow Patriarchate and the Metropolia had been disas- tous forthe two parties who had been separated for approxi mately fifty years.©’ The reconciliation between the “sister” to its “mother” Church had thus once again reinforced their historic union and continuity, which had originated in Alaska approximately two hundred years ago. In order to celebrate the event, as well as to honor the past work ofits mi is, the metropolitan saw it as only fitting to commemorate Father Herman as the “First American Saint” of the OCA.* The metropolitan claimed thet this union would serve as a significant step toward the future formation of “One United Church in America,” bute did acknowledge that there were still many obstacles before the realization of such a dream. He considered the existence of the muljursdictional ele- ‘ments in America to be the greatest obstacle, which he felt was fueled by the political passions and misunderstandings ‘of the Continents other Orthodox.” He also considered the stance ofthe ecumenical patriarch to be negative and a major disappointment, since the “ierarch first in honor” and their ‘ecumenical throne neglected their duty of being the center of | unity and love through its actions. The metropolitan equal- ly found it perplexing thatthe ecumenical petriarch would chose to acknowledge the “jurisdictional and anti-canonical chaos that exists in the New World,” which he equates 10 nationalistic phyltism, but refused to acknowledge the au- tocephaly of the OCA that sought to extinguish this chaos through the ereation of one American Orthodox Church* Finally, the metropolitan made the following confession in his near-fnal address the “Autocephaly of the Church is ca- nonical, because it corresponds perfectly to the age-old and. univers doctrine of the Church It confirms and realizes the 184 GOTR61:3-42016 growth in America ofa local Orthodox Church-founded not fn the earthly, the temporal, the transitory, but on Christ and (on unity in him. The Autocephaly of our Church is eanoni- cal, because it was rightly received from the Church which planted Orthodoxy in America and which is the Mother Church in Americe.”*" The Position ofthe Other Autocephalous Orthodox Churches ‘Theancientpatriarchates ofAlexandra, Antioch, Jerusalem; the newer Patriarchates of Serbia and Romania; and the au tocephalous Churches of Cyprus and Greece all wrote letters, agreeing with the decision of Constantinople against the au- tocephaly of the OCA* Only the Patriarchate of Bulgaria, the autocephalous Church of Poland, and the disputed auto- ‘cephalous churches of Georgia and Czechoslovakia” agreed ‘with Moscow's autocephaly:™ It should be pointed out that ‘the Churches in agreement with Moscow were all part ofthe Soviet sphere of politcal influence. Georgia was the only Church out of the four that was actually part of the Soviet Union, whereas the other three were close Soviet satelite states in what many called the Easter bloc. The Churches that rejected Moscow's granting the OCA autocephaly made rather general statements about their disapproval, whereas the Church of Greece responded directly to Metropolitan men's leter in a more detailed manner which deserves to be noted here. The Church of Greece made the following points: 1, Russia could not claim jurisdictional primacy over ‘come and reside in America (New Smyrna, Florida) is 1767, whereas the Russians came to the Russian te tory of Alaska in 1793, which was obviously not part of ‘America at that time, 2, ‘The Greeks established the first Orthodox parish in America in 1864 in New Orleans, which was four Dragas: The Autocephaly ofthe OCA 185 ‘ears before « Russian Church was established in San Francisco. 3. ‘The Russian patriarch only has authority over his own, Jurisdiction, as was granted to him by the ecumenical Patriarch andthe other ancient patriarchates.” 4. The Ecumenical Patriarchate, as the “first” in order of | seniority isthe only patriarchate that has authority over the Orthodox faith ouside its jurisdictional bound- 5. Russia's autocephaly did not come about in 1448; rath- er, it began when the Russian Church was fully recog nized as autocephalous by the whole Church in 1589." 6. The Patriarchate of Jerusalem isnot the Mother Church of all as it has never granted autocephaly to any other Church, Jerusalem, however, was honored with the ttle “Mother ofthe Churches” in honor of Christ, who lived and worked there * 7. In 1971 there were approximately four million Orthodox Christians in America, seven hundred thou- sand of which were under the Russian Church, The ‘Church of Greece then begs the question, how then can ‘one jurisdiction with less than a quarter of the faithful lead the rest and be called the head of the American Church" ‘THEOLOGICAL DEBATE ‘The polemic discourses between the patriarchs and the ‘other Onthodox prelates also spawned controversy among, some ofthe leading Orthodox theologians at the time. The ‘two most instrumental theologians on this matter were Father Alexander Schmemann, who was under the OCA and therefore supported Moscow's decision, and Professor Panagiotes Trempelas of the University of Athens, who ‘as against it, Apart from the arguments already mentioned 186 GOTR 61:3-42016 above, Schmemann made arguments against the jurisdic- tional elaims of the ecumenical patriarchate in his article “Meaningful Storm," whereas Trempelas defended the po- sition and role ofthe ecumenical patriarchate in his extended ‘essay “The Autocephaly of the Metropolia in America."® In order to root out the core of these arguments, we will proceed by summarizing both theologians, stating with Schmemann's arguments and then outlining Trempelas’sre- sponse to each argument. Schmemann firmly believed that the autocephaly granted to the OCA from its Russian mother Church paved the way toa viable solution, thats, the formation ofa geographically independent American Orthodox Church. Nevertheless, he also conceded that this action simultaneously caused a storm amongst the entire Orthodox Church that ultimately led to @ great rift. This dilemma steered him to research the underin- ing problems of the matter, which led him to the following conclusions. Argument 1: Local Church and Jurisdiction ‘Schmemann’s first conclusion led him to angue that the terms “autocephaly” or “jurisdiction” were generally absent from the Orthodox Canonical tradition. This, in turn, led him tohypothesize thatthe Church had two traditions on them ter: the older, or essential tradition, as he called it, which did ‘not focus on the notion of autocephaly or jurisdiction; and the later tradition that did so. The olde tradition maintained that the independence of a Church was based on the ecclesi- astical notion ofa “Local Chureh,” which was "a community ‘gathered around its bishop and ‘clerus" asa full church” that had been ultimately built on is fith, unity, tradition and lite The local Church was therefore not subordinate to, nor un- det the control of any other Church, since Apostolic Canon 534 specifically stated that all Bishops must know the first one (Protos or Primus) among them. On this basis, Schmemann Dragas: The Autocephaly ofthe OCA 187 ‘Went on to state that this canon must be viewed in reference to the Holy Trinity itself, which does not have any form of | subordination in its structure." In this sense, the role of the primus is not to ensure a Church's jurisdictional position, but is to ensure unity for all. In other words, he argued that “autocephaly is precisely the right to elect and to consecrate bishops within a given region,” while the “second level of “primacy” is that of wider geographical area." ‘Response to Argument 1 ‘Trempelas counters the above by going to the very core of ‘whether the term “jurisdiction” was applicable to the ear- ly notion of a local church. He begins, in agreement with Schmemann, that the “local church is free and protected within her own limits,” but differentiates his position by add- ing that “no other bishop has the right to assume the ofice of celebrant without the permission of the local bishop.”®” ‘A clear example ofthis can be seen in ancient church his- tory where St. Polycarp had to consult with the Bishop of ‘Rome in order to celebrate the Eucharist in his territory. This ‘begs the question on whether this action of “es “receiving from” did indeed show jurisdictional authority. ‘Trempelas, seeing his former example as self-explanatory, clearly believed it did, and was therefore enough to show thatthe notion of jurisdiction had always existed among the churches. Having said that, Trempelas does concede thatthe ‘actual term “jurisdiction” did not appear in the early local church per se, but felt that this was mainly due toa broth- erly and spiritual understanding that each church had to one nother. Ths led him to conclude that a leader's supervision Was a matter of concer, and not ofhonor at that time, which ‘meant that the notion of jurisdiction was alway’ applicable, ven if it was not always audible To prove his point, he gave a number of examples in support ofthis etai: 1 James presided over the fist Apostolic Couneil be- 188, GOTR 61:3-42016 a LE att een sree Se a at = 1 etnies folane ie Ort ree infact eer cen tart een oe Seen cae wit his in nnd, e then timed to Shmemann's er ee et i of oh Set eet es Se ten ee teow ree ty Saal ire ee ere aa enna cite See wee i en Te ict ee Sec nn ee Dragas: The Autocephaly ofthe OCA 189 cannot do anything without the consent of all Trempelas| furthermore claimed thatthe canonist Balsamon maintained thatthe First bishop is understood as the head of a certain province without whom the bishops within that province cannot deal with common church concerns.”" He therefore believed that Schmemann could not understand the nuanc- es of this canon because he was ignorant of the Greek lan- ‘guage. In that sense, he confused the role ofthe Head bishop and his provincial bishops with the mystery and roe of the Holy Trinity in the Godhead that displays an order without subordination, In his view, Trempelas concluded that the purpose of this canon i intended to be an admonition to the bishops to be of one mind end united in the bond of love, rather than being interpreted as giving a description of the Holy Trinity.” Argument 2: Original & Imperial Layer In his second conclusion, Sehmemann analyzed the rela- tionship between the Church and the Byzantine Empire ar- ‘guing that the Church formed an alliance with the Empire in order to create a “Christian Universe.” This allianes, in tum, led to the formation ofa close relationship between the Orthodox Church and the Byzantine Empire, which allowed itto mold certain “imperial” traits into the substance of the Church itself It was indeed these very imperial traits that became a part of the Orthodox Church, although they were inessence purely historical and therefore temporal. The tem= porality ofthese traits therefore made them secondary to the Church since these worldly characteristics could be changed, ‘much lke the world did. On the other hand, the primary traits of Orthodoxy were not of this world as it receives instruc- tion from above, which was essentially unchangeable and unreliant on historical development. This can be seen in the fact thatthe Church during its early years was otherworldly, especially sine it had been denied legal status or jurisdic 190 GOTR 61:34 2016 lived in.” This changed, however, under the Byzantine Empire, whose acceptance of it enabled it to adopt certain imperial traits that led to many structural and artificial jurisdictional developments. For example: 1. The Patriarchate of Constantinople was given pri- macy over the East, even though the Patriarchates of Alexandria and Antioch opposed this. 2, ‘The Christian emperor (Basileus) could convoke ecu- rmenical synods, nominate bishops, change territorial boundaries, and grant privileges tothe Church, 3. The patriarch in due time took on the role of an em- peror, whilst his bishops became his subordinate like civil governors or delegates. 4, The jurisdiction of the ecumenical patriarchate beeame an imperial jurisdiction, which rendered it secondary and artificial to its ue otherworldly nature. Response to Argument 2 “Trempelas begins his counterargument by first respond- ing to Schmemann's notion of the “imperial” layer of the ‘Church by making the following points: 1. Schmemann acknowledges that the imperial layer had not destroyed the original or the previous (essential) layer of the Church's canonical tradition. 2, ‘The jurisdictional layer may have been different from the original layer, but it was nevertheless justified and necessary within the sphere ofits application. 3. Both the imperial and the jurisdictional layers must not bbe confused with the original layer tht i stil opera- tives rather, they must be viewed within the context of their development with one another asa hand-by-hand operation. ‘Trempelas then proceeds to the argument on the role of the Emperor in order to clarify this matter. He first looks to the historical account of Eusebius of Caesarea who reported Dragas: The Autocephaly ofthe OCA 191 that Emperor Constantine proclaimed himself as a bishop of those who are outside the Church as @ companion of the bishops. This proclamation, however, did not mean that he vasa bishop within the church per se, since Constantine was reported to have said tha, “You are bishops whose jurisdic tion is within the Chureh: 1 am also a bishop, ordained by God to oversee those outside the Church.” In other words, the Emperor acknowledged that he was not a member of the “jurisdictional” administration ofthe Church, but rather that be was a pat of the Church, while not superseding it, within the context of their relation to the State. In this sense, the Emperor's ultimste authority lay only in the temporal realm, even though his sovereignty was also granted to him from God. His role as a temporal authority was to accomplish the ax Romana, which was to ensure peace to ll Romans and uphold is role of protector of the Church. This was the rea- son he summoned, attended and supported the Ecumenical Synods, which rightly led him to be called “priest” and “archpries."” Having said that, the emperor could bestow honors, titles and distinctions on people or even to episcopal sees, but only the Church itself could make an official ruling on per- manent Church affairs. There were times, however, when Orthodox rulers tried to circumvent the Church by using. their power, but the Church was the one to ultimately de- cide what would happen to it. This is why the emperors of the iconoclastic period (727-843) did not succeed to impose ‘upon the Church their theological approach to the spzitual ‘meaning of the icons. A case in point could be seen when the fourteenth-century prince of Serbia, Stefan Dusan, uni laterally convened his own territorial synod for the elevation ‘ofa patriarchate only in the presence of the Archbishops of ‘Tymovo and Ochrid. This action led to a schism between Constantinople and Serbia since the latter had not attained universal agreement from the other Church juis . 192 GOTR 61:3-4 2016 The schism lasted for @ few decades and was only healed ‘when the ecumenical patriarch accepted the Serbian retrac- tion. This clearly showed that only the Church in its entirety could each a consensus on administrative and jurisdiction ‘matters. Trempelas’s final argument is designed to show the juris- dictional importance ofthe role ofthe early patriarchate. He begins with the use of the following canons 1, Apostolic Canon 1 orders that « bishop should be con- secrated by two or three bishops. 2. Canon 4 of the First Ecumenical Council declares that 4 bishop must be appointed by all the bishops of the ‘province, with the exception of difficulties of traveling. ‘But in every province the ratification of what is done should be left to the Metropolitan.” 3, Canon 6 of the First Ecumenical Council states that “if any one isto be made bishop without the consent of the ‘Metropolitan, the great synod had declared that such a ‘man ought not be a bishop." These canons, Trempelas concludes, clearly indicate that by the fourth century, there was an obvious practice of primacy ofhonor and a division of provinces or ecclesiastical regions. Besides, “both powers, that is, the authority of consecration, and the authority of jurisdiction, are inseparable within the same plenitudo potestatis of al bishops." In a reference 10 the sixth canon, he explains thatthe term “exousla” high- lights the existing practice of acknowledging the authority of the established Patriarchates over many other metropol- tan provinces. The second canon of the Second Ecumenical Council gave the bishops the right to ordain other bishops only within their jurisdiction, The third canon, in turn, ree- ‘ognized the bishop of Constantinople as having the prerogs- tive of honor afer the bishop of Rome. The jurisdictional ‘power of the bishop within his province led tothe formation ofthe Pentarchy of patriarchates. This was established in or- Dragas: The Autocephaly ofthe OCA 193 der to cons the Aran heresy, which had over popusted cern at of the OrhodoxZeamene Ths Pearcy a Towed th patch of each jurisdiction to pstess he same Driv of oy igh he as vse nt Order of primacy (enoiy), Hene, Tempel argues tt Sehmenans socal “impel” theo hs no bass and concludes tht "his sper Mteation urition of the five patiarchal tones was an exceptional aur ex pressed canonically though te Syod ofeach ee and sot {a peaonl urieton ofthe invdnal shops of hese patitchal hones" ‘Tu AUTOCEPHALY OF THE OCA ToDaY ‘The ase ofthe tocophay of the OCA has il nt been resolved il this day. The Eeumenial Pata the vst majority ofthe Oniodorsfoepalou Caches conte to ret and merely view the OCA es an at tonomods Matoplia of fhe Risen Orbotox disper Whats more, te OCA continues f be sxeined by an sen Orhodoy by mat being blo prpat nan of Ill Pan Onboor event ot Commies as an ea a= scan Orns Chr aie came mane raf be Assembly of Conca Otadox Bishop of he United States of America, wich seceded the now dfn Standing Cotes ofthe Caonl Orodox Bishops the Amecas (SCOBA)." ently, ths new Asem of Bishops lang SCODA before cived forte oa par what the OCA could not une fo unital he “x. tonic” Bishops of the daspor under one Ansan our Gi, much ike an Ameria Hay Synod n doing 0 he ‘Assembly was able o pomoteslosrsdninsttve tes among the sacs, tishenciraged ursitionl nity ind evi el te seve analy tb 194 GOTR61:3-42016 ‘The OCA, on the other hand, was only able to add three “ethnic” jurisdictions (an Albanian, Bulgarian, and Romanian) end a Mexican exarchate under its jurisdiction, ‘which was a far ery from its intial rally to unite the various ‘American Orthodox jurisdictions under itself! The addition, of ethnic jurisdictions, however, was not without contro- versy, as it was usually done in protest and under dubious circumstances. The Albanian Jurisdiction ‘The Albanian immigrants began to arrive in the United States in the beginning of the twentieth century, and intial ly organized their parishes under the aegis of the Russian ‘Metropolia (now OCA) since Constantinople didnot recy ‘ize an Albanian jurisdiction nor the use of the Albanian an- juage in its churches. One ofthe key central figures for the push for ecclesiastical independence was a man by the name of Theofan S. Nol. He, in tur, would play an integral parti the hisiory ofthe Albanian nation asa politician, and as the founder and hierarch of the Albanian Orthodox Church. He ‘was ordained tothe priesthood by Russian Archbishop Platon fon the March 18, 1908, and performed the frst Orthodox lit- ‘gy in the Albanian language four days later. He was then pul in charge of the Albanian Orthodox Mission in America, And was later elevated tothe rank of archimandrite” ‘The Albanian parishes became independent from the Metropolia in the wake of the 1917 Bolshevik Revolution, and Fr. Noli continued his governance in America until he found an opening to return to Albania to expand his work in his native land, Once there, he unilaterally declared auto- ccephaly for the Church in Albania in 1922 and was conse~ crated tothe rank of Bishop in Korehe Cathedral in Albania, fone yetr later The Patriarchate of Constantinople initially rejected this decree as uncanonical, but was willing to al- Tow the use of the Albanian language and grant a form of Dragas: The Autocephaly ofthe OCA 195 autonomy to ease the tensions in 1929, An agreement was eventually struck aftr a formal apology was given to the ecumenical patriarch, who, in turn, granted autocephaly to the Albanian Chureh on April 12, 1937." ‘After World War I, the rise of Communism in Albania ere ated a suspension of communication between the American parishes and their mother Church. Inthe midst ofthis, Bishop Noli had returned to the United States in 1932 to administer the twelve American parishes (mostly in New England) after briefly serving as Albanian prime minister eight years pri- cr?” The turmoil in Albania led some American Albanians to request help from Patriarch Athenagoras of Constantinople, who then sent Bishop Mark Lipa (of Albanian descent) 10 organize the Albanian parishes in 1949-1950. It appears that there was some administrative strain between Bishop ‘Noli and Bishop Lipa, in which the majority of the parishes ‘were aligned with the former and a smaller number with the latter." Nevertheless, Bishop Lipa created the Albanian Orthodox Diocese of America in 1951 out of the former Albanian Mission, and then went on to become one of the founding signers on behalf of the diocese for the Standing Conference of Canonical Orthodox Bishops in America, which was founded in 1960 forthe Formation of pan-Ortho- 4dox cooperation in the county.” In 1965, the rit between the two groups grew larger fol~ lowing the controversial consecration of Fr. Stephen Lasko to the rank of bishop by the Albanian Holy Synod shortly after the death of Bishop Noli. There was an attempt at ree~ onciliation during 1966-1967, but to no avail. It certainly ‘di not help thatthe now Bishop Lasko, formerly ordained to the priesthood by Bishop Noli, had received ously laid jurisdictional claim over the Albanian American Diocese." The situation became more desperate for Bishop 196 GOTR 61:3-42016 Lasko after the Albanian Communist regime proclaimed it- self an atheist state and began a policy of religious perse- cution to all religions in 1967. No longer maintaining any canonical connection to its mother Church, Bishop Lasko petitioned the OCA for the reception of his Diocese in 1970, He and his Diocese were accepted into the OCA one year later, on October 14, 1971, and he was given the ttle bishop of Boston of the Albanian Archdiocese." Bishop Lipa, on the other hand, stayed under the canonical protection of the ‘ecumenical patriarchate of Constantinople and afiited his diocese with the Greek Orthodox Archdiocese in America, ‘Today, the primates have changed, but the situation remains the seme, The Bulgarian Jurisdiction ‘The Bulgarians came to North America in the beginning, of the twentieth century, and mainly formed communities in the midwestern United States. Although some Russian sourees have claimed that the Bulgarians were initially un- der their jurisdiction, the Bulgarians claimed otherwise, stat- ing that their Church was always under their Mother Church in Bulgaria This bond, however, was greatly stained after the Communist takeover of Bulgaria in 1946, shorly after the Bulgarian Mission was made into a diocese from its Holy ‘Synod in 1937. The bishop at the time, Andrey, cut the cese’s administrative ties, whilst maintaining spiritual tis, from its Mother Church in fear that the Communist inflta- tion in the Holy Synod would use its influence to conduct forms of espionage in its Church structures abroad.” In the 1960s, the now Metropolitan Andrey sought to re establish its administrative ties with the Bulgarian Church in the midst of a power struggle between him and a new See adn Tegal Quartet 5, 121971 6S Sar aconhat, 42-43. Os : rs iol Quarter 8908 ° also Russian Autocephaly, 44. 7 Pe Se See Mldimir® Theological 15,n05. 1-2 ee ological Qurtry 18, nos. -2(1971: 71-80, “ia 76 Bi, 21971) 63-70. (a97):67. ee 206 GOTR61:3-42016 “bid, 78. ii, 79-80. ‘id 20, nb, 49-54, bid, 4 said 31 This statement is somewhat bios asthe sin was neither ‘amen, nor dd he conduct misonary work inthe United States dar ‘AW ime tis more corectto say hat be was Russian at who trachea in Resin etry onthe Americon continent until twas serfs ne United Stats of Ameren in 1867. Fora bie histor on he ‘Rlskanmision. ee FitzGerald, The Orhodos Church 21. Ae Vdinir’s Theologica! Quortry 15,008 1-2(1971: 80-51 bi, 32-54 2p, 53-84 Fr, Schmemann also expands pon his ation of Lo- eal Church, ae hall see ler in his arte, “Meaning Storm,” footnote ‘SpaGerl The Othodar Church, 106. ~rOnly Msc nd ot te Patriarchate of Constantinople recognized thesnccepbalous sists of he Churches of Georgia and Czzchoslowakia welt Moreover the Church of Czechoslovakia became own 5 ‘hevOnhodon Church ofthe Czech Lands and Slovakia afer the sept faton ofthe two republics in 1983. - ee Russian Aulocphaly, 48-67. See aso K. T War's comment i “putcepaly Criss: Deadlock between Constantinople and Masco” ee eches Review 3 (1971): 314 trast be add, howeves tht ‘ioc Trempelun wrote hse some ofthese Charches have changed ‘eke poition. MgereThe Church of Greece a Russian Awtocepaly, 35. tia id, 58 ‘nbd, $9: This argument is based on canon 28 of he Fourth Essen al Counclwhich states the ecumenical paiarch bas jurisdiction over St Spararan Tends" Bossom, however, dspues thi stain tha he ‘usb nds wereony part ofthe Ecamene of the Byzantine Epis mid roy id, 65-66 ‘AlevnderSchmemann, “A Meaning! Sto” Fotote 1. Shesaaltcs N. Trempels, The Auacephaly ofthe Metopalia in Amer veartnns and ed. Georges Bebi, Robert G Stephanopoules and N:M. ‘ie (rocine, MA: Holy Cross Theological School Pes, 1773) Schema, "A Meaningful Stor" 7. Dragas: The Autocephaly ofthe OCA 207 “Semen AMening Srm & “ti Never des esa at he try of prot teach natn ot nly bund wa spies eye feted er jdt rome duce he Mera, 32-3 “ioe hit “i 35.6, a 38 ce 2Sthnemam, "A Metin Sim? 9 *Schnan, A Meng St ta "8 Se Pe, 0 Ge ata Mapp ‘ir aetna. Succ totter sneer fhe Pepentoy Cnn f he ‘rbconing ru an x Coa Sec hp onenpeupoy a moe smaion teved Deter 310. Rati points ab ei te ote rpms cc ye sss psn ot espn ame opi, Pie es Aare SSNs tt Oe 19 Skee yp" St era Tg” fom Sant Coup ale west p/ecamgece on ont, La Ch tue, SEEN WV G0 Ne ven 205 S39 ee Deemer 2070, nT, OF Ido Amer 1790-19 Devoe fhe Oo Circ eer Symp SO Anion nd Tr, Amer. =Si Ahoy Aner un The Choro A om Se Apne ean to Dee: persis sgl ope, ta ered Decor 2010; Fak S Met, dia ro ‘tom nthe Une St She (bigon Pe 01) eee ‘cer 1); Torr tr Amer, ed gp 04 sem 208 GOTR 61:3-42016 "See Archbishop Anastasios of Abana, Church of Albania ‘See Bihop lis, "The Albanian Orthodox Church," from the website (fSt Nicholas Albanian Orthodox Chuck: hp:sichoasabanianchi- ‘ergo arthealbnianorthodoxchuch hoa eieved December 2016). See archbishop Anatasin of Albani, Church af bona. ‘See Bishop li, "Albanian Onhodox Chur.” "See Archbishop Anastasios oF Albania Church of bana Bishop ti, “Ani Orthodot Chie and Stephen (Lasko) of Boston, haps: thodonwikorStepen, (Lasko) of Boston (ereved December 2016) See: htp/georgerumballr/les/AdministatowStGrgeWeb-Ad- ‘miAIbATEREyiwe02080 pl, The Constitution of the Albanian Arch tdioeee (rereved December 2016). ‘Thomas E FGerld, Orkodae Church 30-33, 41, 47-48. “See Contin ofthe Blgoron Eastern Orthodax Church Diocese of “America North and South, and dust taken fom the Archival Doe ‘nen ofthe Bulgarian Easter Orbodox Diacse of Amerie, Canada fd Avsalia. See Mito ofthe Bulgarian Church and Law Cours, in Law Journal, ‘November 19,1973 ‘See drofpatoral Encyclical by Bishop Andre, June 1963, taken fom, the archival Documents of the Bulgarian Easier Orthodox Diocese of ‘Ameria, Canada and Australia, p.3. See Mints 2 ofthe Buigrton Eastern Orthodax Church, October 10,1963, iaken fom the Archival Documents of the Bulgarian Eastern Oriteox Diocese of Ameria, Canada and Attala, 3-4 ‘See Western Pemayvania Drocze Honers Archbishop Kyril: & Cont Cate-d Direct Examination of Bishop Kyril ove the Char ef St. Kyril ‘and Hathod, Lorain, Oho, 1983, 74, 8, #2, and, ‘See the Contttion ofthe Bulgarian Eastern Orthod Church Dio- cese af America and Canada, which ea be dowloaded fom the weo= prot hrpevrisdon or/imsge’pd#7010_Amended_Restated_ Constation of te. Bulgarian Diocese pl. "See The Ronanian OthodosArchdlacee Inthe Americas, Staats forthe organization of te Remanian Orthodox Archdiocese in the ‘Americas, 75 Annual Congress of the Clergy & Lay Delegates, July 1, 1996: hep! march ental (ereved December 2016), tnd Terstr, Orthodox Amari, 303-308 ‘Those ordained by the Russians, who were mainly uncdcated ily svt some basi ecclesiastical knowlege, were dane so out of necessity Since the Remanisn Chorch ould not end priests ring the chas of the Fist World Wat. The Romanian Char dd, however, send ned ‘rests onte the war was over, which lee io eon among the ined Dragas: The Auocephaly ofthe OCA 209 104 nied vo tgtretnantered he mabe of pres ht ‘Se. Formas Tr Of, leer ue footie n Cras ae MY sia, rd ain S063 ‘Stam Grea fats Bn Romanos n Cand 71 ‘= Sec The Ramon Qo dco hh merc, Sates ‘ce eran of Remi Once ‘a,c Americ 37-308 ‘9 ‘Tose ils ote casi cis nd be Asef Cates! Onodo np ote Und Sts ot ets ps ‘Sensis onsen eros Ser Thamar peas Yn ony 44 exe De ‘camber 2016). ni ener ceptan Thess, “Te Patho Ace and Bye “Mito gobete we sap Swat 621995) “i 0 Set anemia eriisons ST Sao Oa Chr arian cn they ond re Costco on ld of re Sine" 162, 7016, hp: eexoeucanesevsoly sete ‘seston ponents ated De Ser 200) ‘See te Minutes of the 2009 De, 10-7 IerOnbodos Peps ‘ay Camo an sh inte fh 2018 Cor 1-1 se Shi rn Conrens 5 hen eA “a Domes of he Ootos Cots an scmerel pans (Chambésy, Geneva). ms SSS ete hpi eine ‘December 2016). en "Sethe Mine oft 199,208 21 ier Ordon Poa , 0, orgy Canina he es Ste 200 2013 of be ed Pe Centar PaO Cafe 201 ake fe ti Doe. Seat of the Onaflox Ce fe sn! para (Chon ‘bésy, Geneva), parish (C "te Lys apne io Ye Cong ai of nlite inte Ordos church Visit Ly The lutea! eso he ng nach Lot es Cat & Co 53) 1418 996), 72-73;

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