1837 General Assembly, the Old School majority successfully passed resolutions removing all judicatories found under the Plan from the Presbyterian Church. In total, three synods in New York and one synod in Ohio along with 28 presbyteries, 509 ministers, and 60 thousand church members (one-fifth of the PCUSA's membership) were excluded from the church. New School leaders reacted by meeting in Auburn, New York, and issuing the Auburn Declaration, a 16-point defense of their Calvinist orthodoxy. When the General Assembly met in May 1838 at Philadelphia, the New School commissioners attempted to be seated but were forced to leave and convene their own General Assembly elsewhere in the city. The Old School and New School factions had finally split into two separate churches that were about equal in size. Both churches, however, claimed to be the Presbyterian Church in the USA. The Supreme Court of Pennsylvania decided that the Old School body was the legal successor of the undivided PCUSA. Slavery dispute and Civil War division The Synod of Philadelphia and New York had expressed moderate abolitionist sentiments in 1787 when it recommended that all its members "use the most prudent measures consistent with the interests and state of civil society, in the countries where they live, to procure eventually the final abolition of slavery in America". At the same time, Presbyterians in the South were content to reinforce the status quo in their religious teaching, such as in "The Negro Catechism" written by North Carolina Presbyterian minister Henry Pattillo. In Pattillo's catechism, slaves were taught that their roles in life had been ordained by God. In 1795, the General Assembly ruled that slaveholding was not grounds for excommunication but also expressed support for the eventual abolition of slavery. Later, the General Assembly called slavery "a gross violation of the most precious and sacred rights of human nature; as utterly inconsistent with the law of God". Nevertheless, in 1818, George Bourne, an abolitionist and Presbyterian minister serving in Virginia, was defrocked by his Southern presbytery in retaliation for his strong criticisms of Christian slaveholders. The General Assembly was increasingly reluctant to address the issue, preferring to take a moderate stance in the debate, but by the 1830s, tensions over slavery were increasing at the same time the church was dividing over the Old School–New School Controversy. The conflict between Old School and New School factions merged with the slavery controversy.