The censure by rebuke is the least of the disciplinary actions Spahr faced.
The ruling by the six-member Permanent Judicial Commission of the Redwoods Presbytery of the Presbyterian Church USA came after a three-day trial in Napa at which 10 couples testified.
Prosecutor JoAn Blackstone sought a public rebuke against Spahr, 68, of San Francisco and an ordained minister for 36 years. Her attorney Scott Clark argued for an acquittal.
Rev. Beverly Brewster, a member of Spahr's defense team, said the commission could have acquitted Spahr or found her guilty and imposed disciplinary actions ranging from a rebuke to revocation of her ordination, the most serious disciplinary action.
Spahr also could have been ordered to undergo supervised rehabilitation or a temporary suspension of her ministerial duties, Brewster said.
Spahr performed the wedding ceremonies in 2008 when gay marriages were legal in California. The legality of gay marriages in California is still before the state courts.
Citing Spahr's June 20, 2008 marriage of two women, the complaint stated, "officers of the Presbyterian Church USA authorized to perform marriages shall not state, imply, or represent that a same sex ceremony is a marriage. Under W-4.9001, a same sex ceremony is not and cannot be a marriage."
Regarding the other marriages, the complaint charged Spahr with persisting "in a pattern or practice of disobedience" by representing "no fewer than 15 such additional ceremonies were marriages of persons of the same sex."
Spahr also was charged with violating her ordination vows and failing to further the peace, unity and purity of the church.
The Permanent Judicial Commission of the Presbytery of the Redwoods ruled in 2006 after a trial in Santa Rosa that Spahr did not commit an offense when she married two lesbian couples, one in Rochester, N.Y. and another in Guerneville in 2005.
The Permanent Judicial Commission of the Synod of the Pacific then ordered the Permanent Judicial Commission of the Redwoods Presbytery to rebuke Spahr for conducting the ceremonies.
The church's Permanent Judicial Commission of the General Assembly in Louisville, Ky., the church's highest court, then reversed the action by the Permanent Judicial Commission of the Synod of the Pacific.