"Why, the justices [of Iowa] asked in conclusion, do statutes and civil law protect the secret of the confession? This is based, they answered, on “the idea that the human being does sometimes have need of a place of penitence and confession and spiritual discipline. When any person enters that secret chamber, [the law] closes the door upon him, and civil authority turns away its ear. The privilege of the statute purports to be applicable to every Christian denomination, of whatever polity. Under the polity of the Presbyterian denomination, this privilege cannot be applicable to it unless it be true that the ruling elders are ‘ministers of the Gospel,’” when sitting collectively as a committee."
Iowa

January 1, 1970