As ENS notes, the defenders of Title IV claimed their February 2011 response to our original critique “conclusively establishes the constitutionality” of Title IV. General Convention must have reached a different conclusion. In any event, we invite all concerned about Title IV to read our replies to their defense of Title IV before accepting the characterization that its constitutionality has been established: “Title IV Unmasked: Reply to Our Critics” (February 2011) and “Title IV and the Constitution” (March 2011). The latter in particular is a comprehensive review of the constitutional provisions for clergy discipline from 1789 to the present. Our own conviction after undertaking this work: “The conclusion that the 2009 Title IV revision is unconstitutional cannot reasonably be denied.” Our critics never answered these papers.