Mr. Shepherd rejects not only the term ‘covenant of works’ but the possibility of any merit or reward attaching to the obedience of Adam in the creation covenant. He holds that faithful obedience is the condition of all covenants in contrast to the distinction made in the Westminster Confession.”

…By rejecting the distinction between the covenant of works and the covenant of grace as defined in the Westminster Standards, and by failing to take account in the structure of the ‘covenantal dynamic’ of Christ’s fulfillment of the covenant by his active obedience as well as by his satisfaction of its curse, Mr. Shepherd develops a uniform concept of covenantal faithfulness for Adam, for Israel, and for the New Covenant people. The danger is that both the distinctiveness of the covenant of grace and of the new covenant fullness of the covenant of grace will be lost from view and that obedience as the way of salvation will swallow up the distinct and primary function of faith. Obedience is nurtured by faith in Christ and flourishes precisely as we trust wholly in him.

—The Board of Trustees of Westminster Seminary (Philadelphia) “Reason and Specifications Supporting the Action of the Board of Trustees in Removing Professor Shepherd,” (February 26, 1982), 15.