How We Got Here: The Roots Of The Current Controversy Over Justification

Editor’s Note: The following is the complete chapter as it appeared in R. Scott Clark, ed., Covenant, Justification, and Pastoral Ministry: Essays by the Faculty of Westminster Seminary California (Phillipsburg: P&R Publishing, 2007), 3–24. In 2021, the publisher returned the publication rights to the copyright holder and the chapter is presented here as a service to the public by the Heidelberg Reformation Association. The material is copyrighted. All Rights Reserved. You are welcome to link to this chapter but you are not entitled to reproduce it in any way without permission of the copyright holder.


Presently there is open disagreement within Reformed and Presbyterian churches over the most basic elements of the doctrine of justification. Some are arguing (implicitly and explicitly) that the doctrine of justification contained in the Reformed confessions and catechisms (i.e., symbols) is either inadequate or incorrect.

Some of these revisionists draw upon the work of E. P. Sanders, James Dunn, and N. T. Wright on Second Temple Judaism and Paul’s view of the law. Others synthesize threads in covenant theology developed in the Netherlands by Klaas Schilder (1890–1952) and S. G. DeGraaf (1889–1955) and in North America by John Murray (1898–1975) and Norman Shepherd.1

1. For an introduction to Schilder’s life and work, see J. Geertsma, ed., Always Obedient: Essays on the Teachings of Dr. Klaas Schilder (Phillipsburg, NJ: P&R, 1995). For Shepherd’s cov-


The Reformed Confessions: A Line of Demarcation

As “Our Testimony on Justification” shows (see the appendix), the teaching of the Reformed symbols is unambiguous on the doctrine of justification. No matter which view of confessional subscription one holds (e.g., system, strict, or good faith), one must agree that the doctrine of justification taught in the Reformed confessions is of the essence of the symbols such that rejection of justification sola gratia, sola fide (historically understood) constitutes a deviation from Reformed dogma. As a matter of integrity, then, all who subscribe the Westminster Standards or the Three Forms of Unity (as faculty members, we subscribe both) are obligated to uphold and defend the doctrine they contain. The doctrine of justification was, after all, the material principle of the Reformation, and the Reformed symbols were written, published, and adopted as public, ecclesiastically sanctioned summaries of those Reformation doctrines.2

To be sure, one may hold one view or another of Second Temple Judaism. Such questions are academic, important background studies for the understanding of Scripture, but without necessary effect upon the doctrine of justification. The same is not necessarily true, however, for every claim concerning covenant nomism and related contentions about the relations of faith to obedience in the act of justification. To conclude that in justification faith justifies because it obeys or that Christ did not perform vicarious active obedience or that Paul’s doctrine of justification was not primarily about right standing before God has the most serious implications for the historic (and confessional) doctrine of justification. In this case, the question is no longer merely academic, but necessarily ecclesiastical as well.

enant theology and doctrine of justification, see Norman Shepherd, The Call of Grace: How the Covenant Illumines Salvation and Evangelism (Phillipsburg, NJ: P&R, 2000); idem, “Justification by Faith Alone,” Reformation and Revival 11 (2002): 75–90; idem, “Justification by Faith in Pauline Theology” and “Justification by Works in Reformed Theology,” in Backbone of the Bible: Covenant in Contemporary Perspective (ed. P. Andrew Sandlin; Nacogdoches, TX: Covenant Media, 2004), 85–120. For Murray’s covenant theology, see John Murray, The Covenant of Grace: A Biblico-Theological Study (London: Tyndale, 1953); idem, Collected Writings of John Murray (Edinburgh: Banner of Truth, 1976–82), 4.216–40.

2. W. Robert Godfrey, “Westminster, Justification, and the Reformed Confessions,” in The Pattern of Sound Words: Systematic Theology at the Westminster Seminaries: Essays in Honor of Robert B. Strimple (ed. David VanDrunen; Phillipsburg, NJ: P&R, 2004), 140–43, makes a helpful distinction between the Reformed symbols as ecclesiastical documents and systematic theology.


It is not the function of a seminary faculty to do the work of church courts and assemblies. Ministers who serve in academia have, however, a moral obligation to apply their studies to the life of and for the benefit of the churches. This volume, therefore, seeks to help remedy the confusion by addressing the doctrine of justification from every department of theology: exegetical, historical, systematic, and pastoral. One book will not likely settle all questions, but we hope that it will advance the discussion toward a happy resolution.

Defining “Reformed”

There is, at present, confusion about what constitutes the Reformed doctrine of justification. This is because two sides use the same adjective, “Reformed,” to describe incompatible views. One side tends to argue that genuinely Reformed doctrine teaches one covenant before and after the fall, the imputation of Jesus’s passive obedience only, and faith that justifies because it obeys.3 The other side, in contrast, holds that the Reformed doctrine denies those very things. Without equivocating, both sides cannot be correct.

It is the purpose of this book to explain and defend—first from Scripture but also from Reformed history, theology, and practice—the doctrine of justification as expressed in the Reformed confessions. The monocovenantal theology described above, with its denial of the law/gospel distinction and the imputation of Christ’s active obedience, cannot be squared with Scripture, the confessions, or Reformed theology. The denial of the law/gospel distinction, the imputation of Christ’s active obedience, and the simplicity of faith in justification are not part of Reformed soteriology as defined by the confessions. If this claim is true—that there is within the churches a movement seeking to inculcate in them anticonfessional doctrines of justifica-

3. Godfrey (ibid., 138–39) argues that the rise of a distinctively Reformed approach to biblical theology (e.g., Geerhardus Vos), to pastoral counseling (e.g., Jay Adams), and to apologetics (e.g., Cornelius Van Til) may have given the impression that there should also be a distinctively Reformed doctrine of justification.


tion and covenant theology—it is well to consider how such a state of affairs has come to pass.

Lost: One Grammar and Several Categories

The long conflict between orthodoxy and modernity has left the corpus reformatum with some serious wounds. One of those wounds was the reimagination of our identity. Rather than identifying ourselves as Reformed and defining Reformed by the symbols, over time we identified ourselves as conservatives and came to regard our Reformed identity as just a subset of a broader antimodern reaction. Consequently, we have gradually tended to abandon our grammar (ways of speaking) and our categories (ways of thinking) so that now, when they are reintroduced, they appear to some as novelties.

For example, doctrines such as the covenant of works and its relations to the covenant of grace, the pactum salutis, and justification suffered the same fate. In this period, respected theologians and their students were able to reject the covenant of works, despite its prominence in the Westminster Confession of Faith, without ecclesiastical consequence.4 The same sorts of cause-and-effect relations are evident in the current debate over justification. The concerns, vocabulary, convictions, and categories of the Reformed confessions are not dominating the thinking and language of much of the Reformed world. If they were, the state of the question would be different. Instead, a significant number of pastors and theologians are teaching a doctrine of justification obviously at variance with the Reformed confessions. It is not difficult to imagine the uproar if those same people had rejected the confessional doctrine of Scripture, instead of the doctrine of justification.

The Plausibility of Error

These revisions of the doctrine of justification have found a certain degree of plausibility because the context in which we decide what is

4. John Murray took exception to many places in the Westminster Standards, most notably WCF 7.2 and 25.1–3. For a list of his published exceptions, see James E. Urish, “A Peaceable Plea about Subscription: Toward Avoiding Future Divisions,” in The Practice of Confessional Subscription (ed. David W. Hall; 2nd ed.; Oak Ridge, TN: Covenant Foundation, 2001), 220–21.


credible changed markedly in the twentieth century. The subordination of confessional Reformed and Presbyterian interests in favor of those of broadly conservative Christianity changed what sociologist Peter Berger describes as “plausibility structures,” that is, that context in which we decide what is credible.5

Part of this shift in plausibility structures occurred when we adopted the categories liberal and conservative as our primary way of evaluating doctrine and practice. From the point of view of historic Reformed orthodoxy, this turn has not been altogether happy. In business, when a large corporation moves to acquire a useful but smaller company, the latter can remain independent and risk being crushed by the competition, or it can seek the relative safety of merging with a friendlier, but equally large corporation. The danger of such a merger is that the small company may lose its identity. Confessional Reformed Christianity survived the takeover attempt by liberalism, but in order to survive we became a subsidiary of modern American evangelicalism. As J. Gresham Machen and Cornelius Van Til feared, what began as a temporary, strategic alliance became a permanent relation.6

It might be objected that Reformed Christians are evangelicals and that it is not a matter of whether they will be a subset of evangelicalism, but how. The response is that it depends on the notoriously difficult definition of evangelical as it describes American Protestants since 1720. There are three competing interpretations of the nature of contemporary evangelicalism. The first and dominant view is that American evangelicalism is defined by its relations to the sixteenth-century Protestants and Reformed orthodoxy as it came to expression in old Princeton. Arguing this case in his well-researched and highly influential books, George F. Marsden interprets the rise of early-twentieth-century fundamentalism in relation to old Princeton and the

5. Peter Berger, A Rumor of Angels: Modern Society and the Rediscovery of the Supernatural (Garden City, NY: Doubleday, 1969), 42–57. One need not accept Berger’s premise that society is a purely human product to recognize the validity of his observations about the situatedness of human knowledge and that human beings form and maintain their views in conversation with others. Michael Polanyi observes the role of authority in learning in Science, Faith, and Society (Chicago: University of Chicago Press, 1946).

6. On Machen’s ambivalence toward fundamentalism, see D. G. Hart, Defending the Faith: J. Gresham Machen and the Crisis of Conservative Protestantism in Modern America (Grand Rapids: Baker, 1994). See Van Til’s criticism of evangelicalism in “The New Evangelicalism” (syllabus, Westminster Theological Seminary, Philadelphia, 1960).


rise of neo-evangelicalism (post-1946) relative to old Westminster. Donald Dayton describes this as the “Presbyterian paradigm.” For his part, Marsden argues that his interpretation is more complex than Dayton allows and that his view is complementary to Dayton’s.7 This approach is associated with the Institute for the Study of American Evangelicalism and may be seen in the work of Mark Noll and many others.

A second view, advocated by Dayton, is that American evangelicalism is rooted in the sixteenth-century Anabaptist movement and has been more Methodist or Pentecostal than classically Protestant. He argues that American evangelicalism is normed by the revivals of the eighteenth and (especially) the nineteenth centuries. He contends that Marsden’s “paradigm” (in the sense that Thomas Kuhn uses the word) unfairly omits the socially radical and theologically deviant (from the Reformed point of view) Wesleyan and Pentecostal (i.e., pietist) mainstream of evangelicalism. In this view, Princeton and Westminster are on the margins of evangelicalism. Dayton calls this a “Pentecostal paradigm” for interpreting American evangelicalism.8

The final and perhaps most provocative approach is that of D. G. Hart, who argues that there is no such thing as “evangelicalism.” It was a convention, an artificial construct that scholars only recently created and that defies definition.9 Ironically, the Pentecostal Dayton may

7. See George F. Marsden, The Evangelical Mind and the New School Presbyterian Experience (New Haven: Yale University Press, 1970); idem, Fundamentalism and American Culture: The Shaping of Twentieth-Century Evangelicalism, 1870–1925 (Oxford: Oxford University Press, 1980); idem, ed., Evangelicalism and Modern America (Grand Rapids: Eerdmans, 1984); idem, Reforming Fundamentalism: Fuller Seminary and the New Evangelicalism (Grand Rapids: Eerdmans, 1987).

8. See Donald W. Dayton, Discovering an Evangelical Heritage (New York: Harper & Row, 1976); idem, “The Limits of Evangelicalism: The Pentecostal Tradition” and “Some Doubts about the Usefulness of the Category ‘Evangelical,’” in The Variety of American Evangelicalism (ed. Donald W. Dayton and Robert K. Johnston; Downers Grove, IL: InterVarsity, 1991). Dayton and Marsden (and others) have engaged in a long-running debate about the roots and nature of modern evangelicalism. See George Marsden, “Demythologizing Evangelicalism: A Review of Donald W. Dayton’s Discovering an Evangelical Heritage,” Christian Scholar’s Review 7 (1977): 203–11; and Christian Scholar’s Review 23 (1993): 12–89, which features essays and responses by Marsden, Dayton, and comments by several evangelical observers.

9. See D. G. Hart, Deconstructing Evangelicalism: Conservative Protestantism in the Age of Billy Graham (Grand Rapids: Baker, 2004); idem, The Lost Soul of American Protestantism (Lanham: Rowman & Littlefield, 2002); idem, That Old-Time Religion in Modern America: Evangelical Protestantism in the Twentieth Century (Chicago: Dee, 2002).


agree with the Presbyterian iconoclast Hart, for Dayton also signaled his dissatisfaction with the term evangelical as an adjective in 1991.

To have real meaning, evangelicalism as a universal must have particulars, but it is exceedingly difficult to find those particulars, and even when some are nominated, there are multiple filters for determining which are included. If one uses recognized institutions as a barometer (e.g., Evangelical Theological Society, Christianity Today, Fuller Seminary) and measures contemporary evangelical theology by something like Reformed orthodoxy, then one will likely agree with the criticisms of evangelicalism (as being in a sort of Babylonian captivity) made by David Wells.10 Given that the original evangelicals were certainly the sixteenth- and seventeenth-century Protestants, who routinely described themselves as evangelicals, Wells has a point.

When Reformed folk call themselves evangelicals they are thinking of the sixteenth and seventeenth centuries, but almost no one today who might be included under the adjective evangelical defines the word according to sixteenth- and seventeenth-century usage. The “Protestant paradigm” is not holding. According to the Institute for the Study of American Evangelicalism there are about 100,000,000 American evangelicals.11 By contrast, there are no more than 700,000 confessional Reformed Christians in the United States. If, for the sake of discussion, we include this group under rubric of evangelicalism and if more than 99% of American evangelicals do not define themselves by the Reformed Confessions or the convictions of sixteenth- and seventeenth-century Protestantism, then perhaps “evangelical” is no longer a useful adjective to describe those who are confessionally Reformed.

Reformed Christianity defines itself by doctrine and practice. Obviously, given the variety of evangelical theological and ecclesiastical possibilities, neither doctrine nor practice defines evangelicalism. Rather, religious experience defines evangelicalism. What unites evangelicals across ecclesiastical and theological boundaries is their common quest for the immediate (literally “without instruments”) experience or

10. See David F. Wells, No Place for Truth (Grand Rapids: Eerdmans, 1993); and idem, God in the Wasteland (Grand Rapids: Eerdmans, 1994).

11. “Defining Evangelicalism,” .html#How%20Many.


knowledge of God. By contrast, what animates Reformed Christianity is not the immediate experience of God, but his glory, which he achieves through the means of grace (HC 65 [Schaff 3.328]). Reformed Christianity is organized around mediation: the mediation of revelation in God’s covenants and chiefly through the mediator of the covenant of grace—Jesus Christ the Word. Reformed Christianity is nothing if not doctrinal and churchly. To the degree we are defined by our theology and practice, we are not evangelicals, as defined above.12

As a member of the conservative evangelical corporation, the Reformed functioned as defenders of Christian theism and the reliability of Scripture, but conservative evangelicalism did not care for our doctrinal peculiarities, namely our Creator/creature distinction (and our definition of theology that followed), our doctrines of God, man, Christ, salvation, and eschatology. This antipathy was especially strong for our doctrines of the church and sacraments.13 Consequently, over the course of the war with modernity, the Reformed came to identify themselves not by their confessional doctrine and practice, but by those conservative virtues valued by our evangelical patrons.

Tertullian asked famously in the third century, “What has Athens to do with Jerusalem?” We might also ask: What have Reformed and Presbyterian Christians to do with a movement encompassing proponents of plenary inerrancy and limited inerrancy, classical and open theism, divine omniscience and middle knowledge, creedal and social Trinitarianism, Protestants, Roman Catholics, and Eastern Orthodox, those who use the sacraments and those who reject their use?

Therefore, Reformed and Presbyterian folk do better to distinguish between those who are confessional and those who are nonconfes-

12. At root, part of this debate is the question of who “owns” evangelicalism, that is, who belongs to it properly and who does not. This is a question of politics, not theology. With this problem in view, Michael Horton proposes that evangelicalism be regarded as a sort of village green or commons where Christians from a variety of traditions may meet for conversation, owned by no one in particular. In his response to Horton, Roger Olson rejects the “commons” metaphor in favor of the “big tent.” The reaction of Olson and others to the proposal to dissolve the evangelical corporation suggests that, at some level, they realize they’re suzerainty and are reluctant to release Reformed confessionalists from their vassalage. See the Horton-Olson dialogue in “Reflection: Is Evangelicalism Reformed or Wesleyan? Reopening the Marsden-Dayton Debate,” Christian Scholar’s Review 31 (2001): 131–68.

13. According to Marsden’s Reforming Fundamentalism, Fuller Seminary was founded as a West Coast version of Westminster Seminary, without the ecclesiastical connections to the separating Presbyterians and the Reformed view of the sacraments.


sional.14 By the former, I mean those who are defined by Scripture as understood by the historic Protestant confessions and catechisms.15 According to this category, there are Lutheran confessionalists, Reformed confessionalists, and perhaps others. In the nonconfessional category, one finds liberals, that is, those who identify with modern autonomy, and conservatives, who are more traditional. What unifies liberals and conservatives is their relative autonomy to historic symbols of the Reformed and Lutheran churches. Confessionalists, on the other hand, define themselves, their theology, their piety, and their practice according to public, ecclesiastically sanctioned symbolic documents.

Because the Reformed and Presbyterians have used the wrong categories to identify themselves, errors in the doctrine of justification have become more plausible than they might otherwise be. If we examined doctrinal issues through confessional lenses, then, revisions to central doctrines would be less plausible. When, however, we filter doctrine through the categories conservative or liberal, the definition changes. In the modern period, rather than standing for a full-bodied theology, piety, and practice, the word Reformed has come to mean predestinarian. With such minimalist doctrinal boundaries, we were ill prepared to anticipate and refute errors that were not obviously liberal or that presented themselves as being consistent with a minimalist boundary marker such as divine sovereignty.

A Preliminary Proposal

Great changes frequently go unnoticed when they happen. The true nature of such changes becomes evident only after the fact. For example, by rights, had the papacy been as powerful in the sixteenth century as it was in the thirteenth century, it seems incredible that Luther would have survived to challenge the existing order in the way

14. See Hart, Lost Soul of American Protestantism.

15. The Roman communion does not appear to be a strictly confessional body inasmuch as, since Vatican II at least, she is quite latitudinarian on doctrine and practice. It is not necessary to adhere strictly to the magisterial doctrine as embodied in the conciliar pronouncements or the Catechism of the Catholic Church to be regarded as a faithful Roman Catholic. What is essential is to remain in submission to the Roman see. In a similar way, though Anglicans confess the Thirty-Nine Articles, it is not essential to hold them to be regarded as a faithful Anglican or Episcopalian.


he did. In fact, few were conscious of the weakness of the papacy in the sixteenth century, but it was weak and the Reformation survived. More recently, the true weakness of Soviet-bloc communism was made manifest only by the refusal of certain nations and peoples to submit to Moscow. In a similar way, modernity has been mortally wounded, and the need for the broad evangelical coalition has passed. It is time for Reformed Christianity to move out of the evangelical “big tent” and back into our own churches and to take up our own confessions again and recover our own grammar, theology, and piety.

I propose that instead of reading Scripture through the eyes of various contemporary reconstructions of the Reformed faith—for example, the federal vision or covenant nomism—Reformed and Presbyterian Christians do better to read the Scriptures with the visible institutional church as expressed, publicly and authoritatively, in the Reformed and Presbyterian standards.

Protestant Controversies over Justification

Another part of the explanation for the existence of the current crisis over justification is that it is part of a recurring pattern. Almost from the moment Luther first proclaimed the doctrine of justification on the basis of the finished work of Christ for sinners, imputed to sinners and received through faith alone, it came under attack. The first critics were defending of the prevailing medieval doctrine of justification on the joint basis of gracious acceptance of our best efforts (meritum de congruo) and Spirit-wrought sanctity (meritum de condigno) through gratia infusa, with which, of course, the sinner must cooperate for final justification. Luther’s doctrine of justification, complained Trent (session 6, chapter 7), is nothing more than a legal fiction. According to the Roman critics of the Reformation, God can declare us “righteous” only if we are actually, intrinsically righteous.16

Rome was not the only critic of the Protestant doctrine of justification. Andreas Osiander (1498–1552) argued that the forensic doctrine of justification could not be correct. God could not declare sinners

16. H. Denzinger, Enchiridion symbolorum (30th ed.; Barcelona: Herder, 1955), §§799– 800.,/p>


to be just. They must be intrinsically just; that is, it must be that God actually transforms them by the infusion of the divine nature, with Christ himself, and on that basis declares them to be just.17 Calvin wrote at great length against this argument (Institutes 3.11).

A controversy developed in 1535 over the role of good works in salvation. In a revision of his Commonplaces Melanchthon proposed that good works are “necessary” for salvation.18 He reasoned that if good works necessarily follow salvation, they must be necessary to it. Melanchthon denied that sinners merit justification by good works, but he seems to have made them an efficient cause of justification, at least for a time. Luther reacted by affirming the first part of the proposition but rejecting Melanchthon’s conclusion as a non sequitur.

The controversy simmered until the Leipzig Interim (1548), when the qualifier sola was omitted from the article on justification.19 Concerned about antinomianism, Georg Major (1502–74) defended the article in 1551 by arguing that one cannot be saved without good works.20 In 1553 he modified his formula by saying that good works are necessary ad retinendam salutem (to retain salvation). Melanchthon sided with Major in that year, saying that “new obedience is necessary for salvation.”21 Major argued that he was addressing salvation as a broader concept, not the narrower concept of justification, but his critics saw him confusing justification and sanctification.22 The controversy continued through 1550s and quieted only on Major’s death.23

It is against the backdrop of this long-running crisis that the doctrine of justification in the Belgic Confession (1561) and the Heidelberg

17. R. Seeberg, Textbook of the History of Doctrines (trans. Charles E. Hay; Philadelphia: Lutheran Publication Society, 1904), 2.369–74.

18. F. Bente, Historical Introductions to the Symbolical Books of the Evangelical Lutheran Church (St. Louis: Concordia, 1922), 112–24; C. G. Bretschneider, ed., Corpus reformatorum (Berlin: Schwetschke, 1834–1941), 21.421, 775.

19. The text of the article is in Robert Kolb and James A. Nestingen, eds., Sources and Contexts of the Book of Concord (Minneapolis: Fortress, 2001), 184–89.

20. Seeberg, History of Doctrines, 2.364. See also Robert Kolb, “Georg Major as Controver- sialist: Polemics in the Late Reformation,” Church History 45 (1976): 455–68; idem, Nikolaus von Amsdorf (1483–1565): Popular Polemics in the Preservation of Luther’s Legacy (Nieuwkoop: DeGraaf, 1978), 123–71.

21. Seeberg, History of Doctrines, 2.366–67.

22. Kolb, “Georg Major,” 460–61; idem, Nikolaus von Amsdorf, 133. Von Amsdorf equated salvation and justification and did not recognize Major’s distinction.

23. Major repudiated these formulations in 1570.


Catechism (1563) must be interpreted.24 They sided unequivocally with Luther, against Major and Osiander. The only basis for our justification is Christ’s obedience to the law imputed to us and received through faith alone. Belgic Confession24 even went so far as to remind the Reformed that, though it is impossible that a Christian should not produce the fruits of sanctity, nevertheless, that sanctity is “of no account” toward justification. Indeed, we are justified “even before we do good works” (Schaff 3.411). The Heidelberg Catechism explicitly excluded sanctity as any part of the ground or instrument of justification, teaching instead, that sanctification is the only and always the result of justification (see 21, 56, 60).25

The first great threat to the doctrine of justification in the early seventeenth century came from Jacobus Arminius (ca. 1560–1609). Though it is often considered that the Synod of Dort was solely concerned with protecting the doctrine of predestination, in the minds of the orthodox the doctrine of justification was just as much in jeopardy.26 It seemed to the orthodox that Arminius redefined justifying faith so that it changed both the ground and instrument of justification (see chapter 8 below).

Against the Socinian and Arminian revisions of the doctrine of justification, the Westminster Divines reasserted the classical Protestant doctrine of justification. The Westminster Standards categorically repudiated any notion that one is justified on any other basis than the imputation of the “perfect obedience and sacrifice” (WCF 8.5) or the “obedience and satisfaction of Christ” (11.1). Faith justifies not

24. Zacharias Ursinus, the primary author of the Heidelberg Catechism, was Melanchthon’s student for seven years and was a witness to this controversy.

25. In reading the Heidelberg Catechism, it is crucial to remember that its doctrine of justification is in the second part of the catechism, not the third, where the doctrine of the Christian life is contained. It is wrong to appeal to HC 87, “Can they, then, be saved who do not turn to God from their unthankful, impenitent life?” as proof that the catechism teaches justification by or through sanctity. This question is addressing the logical necessity of sanctity as a result of justification and distinguishing between salvation (including justification and sanctification) and the narrower concept of justification. For the catechism to make our dying to self and living to Christ the instrument of justification would contradict flatly the teaching of HC 21 and HC 60. This was Ursinus’s interpretation of HC 86–87; see Zacharias Ursinus, The Commentary of Dr. Zacharias Ursinus on the Heidelberg Catechism (trans. G. W. Williard; 1852; repr. Phillipsburg, NJ: Presbyterian & Reformed, 1985), 464–67.

26. See W. R. Godfrey, “Tensions within International Calvinism: The Debate on the Atonement at the Synod of Dort, 1618–1619” (PhD diss., Stanford University, 1974), 40–43.


because it is obeying, but because it is “receiving and resting on Christ and his righteousness” (11.2).

Richard Baxter (1615–91) sponsored the second crisis in the doctrine of justification.27 His 1649 Aphorisms on justification taught quite clearly that faith justifies because it obeys.28 The orthodox (e.g., WLC 70–73) had been explicit that only Christ’s obedience is the ground and that in the act of justification faith’s only virtue is that it trusts Christ’s finished work. Baxter’s revision of the doctrine of justification prompted sharp responses from John Owen (1616–83), whose 1677 treatise On the Doctrine of Justification by Faith was, in effect, an extended repudiation of Baxter.29

The issues fueling the neonomian controversy of the seventeenth century reemerged in the first quarter of the eighteenth century when the Scottish church was convulsed by a complicated debate between two groups, one tending toward neonomianism and the other, who identified with the 1645 Marrow of Modern Divinity, known as the “Marrow men.” James Buchanan argues that the doctrine of justifi-

27. For a more positive assessment of Baxter’s doctrine of justification, see J. I. Packer, The Redemption and Restoration of Man in the Thought of Richard Baxter: A Study in Puritan Theology (Studies in Evangelical History and Thought; Carlisle, UK: Paternoster, 2003), 237–65; and Hans Boersma, A Hot Peppercorn: Richard Baxter’s Doctrine of Justification in Its Seventeenth-Century Context of Controversy (Zoettermeer: Uitgeverij Boekcentrum, 1993). C. F. Allison, The Rise of Moralism: The Proclamation of the Gospel from Hooker to Baxter (London: SPCK, 1966), offers a critical assessment. Boersma agrees largely with Packer and seeks to refute Allison’s view that Baxter’s doctrine of justification is virtually identical to that of the Council of Trent. Packer (261) says that Baxter adapted Hugo Grotius’s legal views to argue a “political” view of the law. In this scheme, the demands of the law change under Christ. This view of the law has a long medieval pedigree and was categorically rejected by the Reformation (see chapter 12 below). Carl Trueman notes the need for interpreters of Baxter’s theology to account for its medieval roots; see “A Small Step toward Rationalism: The Impact of the Metaphysics of Tommaso Campanella on the Theology of Richard Baxter,” in Protestant Scholasticism: Essays in Reassessment (ed. Carl R. Trueman and R. S. Clark; Carlisle, UK: Paternoster, 1999), 185n13; idem, The Claims of Truth: John Owen’s Trinitarian Theology (Carlisle, UK: Paternoster, 1998), 200–205. Boersma concedes (167) that Baxter made evangelical obedience “a secondary part of the condition of the continuation of justification.” He also says that Baxter’s denial that faith receives Christ’s righteousness directly made room for human fulfillment of the conditions of the covenant by the “peppercorn” of evangelical obedience for justification (255). We are declared righteous partly because we are intrinsically righteous (281). Our works are “a condition of continued and consummate justification” (301). Even according to Boersma’s sympathetic analysis of Baxter, there is enough evidence to sustain Allison’s judgment.

28. Richard Baxter, Aphorismes of Justification, with Their Explication Annexed (London, 1649), thesis 74.

29. John Owen, The Works of John Owen (ed. W. H. Goold; repr. Edinburgh: Banner of Truth, 1967), vol. 5.


cation was not directly involved in the controversy, since both sides formally affirmed Westminster Confession of Faith 11, but certainly questions touching the nature of justification were not far removed from the debate.30 Chief among the Marrow men was Thomas Boston (1677–1732), who defended the Marrow doctrine of justification by grace alone, through faith alone, and from it a strong doctrine of assurance of faith resting in the promises of the gospel.31 The Marrow men were opposed by a majority in the Scottish Kirk, who attacked the Marrow and its supporters as antinomian and even Amyraldian.

The Oxford Movement (1833–45), led by John Henry Newman (1801–90), challenged the Protestant doctrine of justification in the Church of England. In his 1838 lectures on justification, Newman caricatured Luther and ignored the places where Hooker agreed with confessional Protestants in order to make his case for a distinctively Anglican doctrine of justification.32 Newman’s position, however, was an untenable halfway house to Rome, which even he found unsatisfactory.

In the twentieth century, the foundation of the confessional doctrine of justification, that is, the Protestant distinction between law and gospel, was eroded severely by Karl Barth’s “inversion” of law and gospel into grace and law (see chapter 12 below). The effects of this revision reverberated throughout mainline and evangelical Christianity in Europe and in North America.

Thus, one might say that the current controversy arrived more or less on schedule in 1974. There is no need to rehearse the history here, as O. Palmer Robertson and W. Robert Godfrey (both participants) have recently recounted it.33 What matters here is that in 1981 the board of

30. James Buchanan, The Doctrine of Justification (1867; repr. Edinburgh: Banner of Truth, 1997), 184.

31. See, e.g., Thomas Boston, Human Nature in Its Fourfold State (1720; repr. Edinburgh: Banner of Truth, 1964), 284–92; The Marrow of Modern Divinity . . . with Notes by Thomas Boston (1726; repr. Seoul: Westminster Publishing House, [1991]). See also David C. Lachman, The Marrow Controversy, 1718–1723: An Historical and Theological Analysis (Edinburgh: Rutherford, 1988); and Philip Graham Ryken, Thomas Boston as Preacher of the Fourfold State (Rutherford Studies in Historical Theology; Edinburgh: Rutherford, 1999), 42–56.

32. Alister McGrath, “The Emergence of the Anglican Tradition on Justification, 1600–1700,” Churchman 98 (1984): 28–43. See also Allison, Rise of Moralism.

33. O. Palmer Robertson, The Current Justification Controversy (Unicoi, TN: Trinity Foundation, 2003); Godfrey, “Westminster, Justification,” 136–40.


Westminster Theological Seminary found that one of their systematic theologians, Norman Shepherd, was unable to “communicate with unmistakable clarity the doctrine of justification by sovereign grace alone through faith alone on the grounds of Christ’s righteousness alone.”34 They also found that “Mr. Shepherd has not been able to satisfy the Board and considerable portions of the Seminary constituency that the structure of his views and his distinctive formulations clearly present the affirmations by which our Standards guard the relation and place of faith and works with respect to salvation.”35

The board had ample reason for making this judgment. According to board documents, in his 1974 class syllabus Shepherd taught that “justification presupposes faith; faith is not the ground of justification; faith is the instrument of justification. justification presupposes good works; good works are not the ground of justification; good works are the instrument of justification.”36 In a 1975 informal faculty meeting, he “questioned making justification by faith alone a touchstone of orthodoxy, since, as he argued, what can be said of faith can also be said of good works; neither can be the ground of justification, both can be instrument.”37

In his defense, Shepherd argued in 1976 that “faith coupled with obedience to Christ is what is called for in order to salvation and therefore in order to justification.” “Thus, faith and new obedience are in order to justification and salvation.”38 Shepherd continued to defend his views and sustained serious criticism. In 1980 the faculty and board approved a statement on justification for which Shepherd voted and with which he said he agreed. The board was troubled, nonetheless by his 1981 Sandy Cove lectures and concluded that

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

34. “Reason and Specifications Supporting the Action of the Board of Trustees in Removing Professor Shepherd” (Westminster Theological Seminary, February 26, 1982), 2.

35. Ibid., 3.

36. Ibid.

37. Ibid.

38. Ibid., 15.


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.39

Shepherd’s critics continue to find in his more recent writings the very same ambiguities, problems, and errors that led to his dismissal.40

In the history of theology, there is a short list of those who have concluded, with Shepherd, in favor of a “a uniform concept of covenantal faithfulness for Adam, for Israel, and for the New Covenant people.” The traditional adjective for such a view is Pelagianism.41 The board reached the same conclusions about Shepherd’s soteriology that Wilhelmus à Brakel reached concerning the Arminians, who denied the covenant of works:

Whoever errs here or denies the existence of the covenant of works will not understand the covenant of grace, and will readily err concerning the mediatorship of the Lord Jesus. Such a person will very readily deny that Christ by His active obedience has merited a right to eternal life for the elect. This is to be observed with several parties who, because they err concerning the covenant of grace, also deny the covenant of works. Conversely, whoever denies the covenant of works, must rightly be suspected to be in error concerning the covenant of grace as well.42

What à Brakel understood—and what we must relearn—is that what is at stake in these distinctions is not some idiosyncratic cov-

39. Ibid. In my judgment, the board suffered a failure of nerve that should not be repeated today, after Shepherd has clearly repudiated the imputation of Christ’s active obedience and renewed his siege on the gospel of justification sola fide, sola gratia, solo Christo.

40. See David VanDrunen, “Justification by Faith in the Theology of Norman Shepherd,” Katekomen 14.1 (2002): 23–26.

41. By this I am not suggesting that Shepherd intended to teach Pelagianism, nor am I saying that Shepherd’s theology is thoroughly Pelagian.

42. Wilhelmus à Brakel, The Christian’s Reasonable Service (1700; trans. Bartel Elshout; repr. Ligioner, PA: Soli Deo Gloria, 1992), 1.355.


enant theology, but the doctrine of justification contained in the Westminster Confession of Faith’s explicit distinction (and arguably the implicit distinction, in the Three Forms of Unity) between the covenant of works as law and the covenant of grace as gospel. Because covenant theology is, as B. B. Warfield says, “architectonic,”43 it is impossible to make a substantial revision to Reformed covenant theology (such as conflating the covenants of grace and works) without necessarily making wholesale changes to Reformed soteriology.

The Work of This Book

The work of this book is to take up the challenge posed by the various forms of covenant nomism. The introductory essay by David VanDrunen is a comprehensive survey of the various movements seeking to revise the doctrine of justification. He summarizes the arguments raised by the critics of orthodoxy and considers some of the common threads linking these lines of criticism. His essay does not refute the various positions surveyed, but alerts the reader to the issues and authors involved in the current controversy and sets the stage for the rest of the volume.

The Exegetical Argument

One of the most persuasive arguments propounded by covenant nomism is its claim to be more biblical than the traditional doctrines of justification, wherein, for example, Luther is said to have read his own experience back into Paul. In the exegetical section, Iain Duguid tests the soundness of the covenant-nomism hypothesis—that justification is a matter of obtaining and retaining status as God’s covenant people—as a description of the Old Testament relations between God and his people and analyzes the crisis that faced God’s people during and after the exile. Can covenantal nomism account for the persistence of God’s relationship with his people after the exile?

43. Benjamin B. Warfield, The Westminster Assembly and Its Work (New York: Oxford University Press, 1931), 56.


Until the modern period, nearly all the Reformed expositors of Scripture found in Scripture a doctrine of the covenant of works (sometimes called covenant of nature, covenant of life, or covenant of law). This doctrine was never received by the Remonstrants or the early critics of Reformed orthodoxy. In the modern period, however, the covenant of works has come under sustained criticism not only from critics but also from many within the Reformed church on the grounds that it is foreign to the theology of Moses and Paul. Bryan Estelle addresses the exegetical and theological questions of its existence and function in the Pentateuch and elsewhere in Scripture. He offers a reassessment of the doctrine based on his exegesis of Genesis 2–3 in the light of recent studies in linguistics and the ancient Near East.

It is a given for many mainline and evangelical New Testament scholars today that Second Temple Judaism has been radically misunderstood until recently and that these misunderstandings have given rise to confusion about the nature of Paul’s covenant theology and doctrine of justification. Steven Baugh challenges the methods and claims of the so-called new perspective(s) by examining and criticizing some of the methods common to proponents of covenant nomism and by testing them and their conclusions against a reading of Romans 5.

The Theological Argument

The doctrine of the pactum salutis was taught widely in Reformed theology until recently. Since the 1950s, it has come under criticism as speculative, rationalist, unbiblical, and even antitrinitarian. David VanDrunen and Scott Clark restate the doctrine, defend it from its contemporary critics, and show its importance to Reformed covenant theology by interacting with its modern critics. They argue the case for the traditional Reformed doctrine of the pactum salutis on exegetical grounds as the best understanding of several biblical passages and on theological grounds as the motive for Christ’s active obedience and a necessary constituent to Reformed covenant theology and a covenantal approach to justification.

Contrary to the frequent assertions of older surveys of the history of theology, Reformed federal or covenant theology did not appear de novo


in the seventeenth century. Rather, it began to appear before the ink of the earliest Protestant theologies was dry. They gathered up threads from across the history of the catholic church and employed them in the service of the Protestant doctrine of justification. Patristic, medieval, and Reformed covenant theologies all take distinct approaches. Michael Horton surveys some of the contemporary competitors to the classic Reformed covenant theology and argues that several of the diverse challenges to the Reformation are properly described as “covenantal nomism” and that they are not very different in substance from what the Reformation repudiated.

Rejected by Rome and rationalist alike, and unlike some other aspects of traditional Reformed theology, the doctrine of the imputation of Christ’s active obedience has enjoyed a privileged status among conservative Reformed and Presbyterian churches. Since the mid-1970s, however, this doctrine has been criticized from within the Reformed movement as part of the proposed revision of the doctrine of justification. The questions raised are not new (e.g., what of Jesus’s obedience is imputed to believers?) but the mixed response is. Chapter 8 explores the question of Jesus’s obedience to the law in the light of the biblical, confessional, and historic doctrine.

The pre-Reformation church taught that only a “formed” faith (fides formata caritate) justifies. In response, Luther asserted sola fide and argued that faith functions as the instrument of justification because it is “formed,” that is, made efficacious by its object, Christ’s obedience for sinners. Robert Godfrey places sola fide in its historical context and addresses how faith functions in the act of justification and how active is our faith in our standing before God. He also responds to those critics who assert that sola fide is not a Reformed doctrine and defends it against some caricatures and misapprehensions.

Before the Reformation, we were said to be justified to the extent that we were sanctified. In the Reformation that pattern was reversed: sanctification was made the result of justification. Today there is considerable confusion as to why and how the Christian should strive to be sanctified. Hywel Jones explains from Paul and James how Scripture relates justification and sanctification. Contrary to those who suspect that the traditional Protestant doctrine of justification leads


to immorality, he argues that the doctrine of the Christian life is a vital necessity to sanctity.

The Pastoral Argument

It is one thing to confess the Reformation doctrine of justification, but how should it be practiced? Turning to the life of the church lived institutionally—where theology turns to practice and doxology—Hywel Jones explains the hermeneutical and homiletical implications of sola fide and provides concrete help for pastors seeking to preach the gospel more clearly and winsomely.

Is the law/gospel hermeneutic just one among many, and how does it affect the proclamation of the word? How do many modern practices stand up to the homiletical and liturgical implications of the Reformed law/gospel hermeneutic? Scott Clark argues for the unique structural and hermeneutical function of the confessional law/gospel distinction in preaching.

When Luther inveighed against the “theology of glory,” he was speaking about the twin dangers of rationalism and moralism. Julius Kim illustrates how segments of well-intentioned seventeenth-century English Protestantism succumbed to the theology of glory. He illustrates how it is possible to jettison the Reformation (and Pauline) message of sola gratia, sola fide, precisely because it seems “foolish” and ill suited to motivate Christians to pious living.

The proclamation of the gospel is central to the minister’s calling, but there is more to ministry than preaching. Dennis Johnson explores the implications of the distinction for pastoral ministry beyond the pulpit. In particular, he focuses on the relations between the doctrine of justification and the practice of pastoral counseling and the related questions of assurance and sanctification.

Omissions and Audiences

This volume cannot address all issues entailed by the conservative Reformed appropriation of covenant nomism. There are two sorts of books, the perfect and the finished. This collection of essays is not perfect, but it is finished. Astute readers will notice, for example,


that no essay touches directly the question of the relation between covenant and election.44 Other equally important issues might have been but were not addressed. The concern of this collection of essays is perhaps the central matter of the Christian faith: the righteousness of sinners before a just and holy God.

These essays are not intended to be popular. The faculty held a conference in 2003 in which we presented some of this material in a way that is accessible to Christian laity. Those lectures are available from the Westminster Seminary California. Some of the essays in this collection do arise from that conference, but they have been significantly revised to speak to a more academic audience.

Since the submission of this volume to the publisher early in 2005, several titles have appeared that merit discussion. Unavoidable delays in the publication of this volume, however, prevent us from doing more than acknowledging these titles and alerting the reader to them.45

With these essays we are attempting to join the conversation that began with the work of Krister Stendahl in 1963 and that has received significant impetus from the pens of E. P. Sanders and James Dunn. In turn, their work has been made more accessible by evangelical Anglican scholar N. T. Wright. Parallel to that trajectory has been a movement within confessional Reformed circles, beginning in 1974. This discussion flared up for about seven years, went dormant for twenty years, but has been renewed in the public teaching of Norman Shepherd since 1995. His views have been synthesized by evangelical and Reformed students of the new perspective(s) on Paul and certain threads present in confessional Dutch Reformed theology since before World War II.

44. See R. Scott Clark, “Baptism and the Benefits of Christ: The Double Mode of Communion in the Covenant of Grace,” Confessional Presbyterian 2 (2006): 3–19.

45. Guy Prentiss Waters, The Federal Vision and Covenant Theology (Phillipsburg, NJ: P&R, 2006); Cornel Venema, Getting the Gospel Right (Edinburgh: Banner of Truth, 2006); D. A. Carson, Peter T. O’Brien, and Mark A. Seifrid, eds., Justification and Variegated Nomism, vol. 2: The Paradoxes of Paul (Grand Rapids: Baker, 2004); Jeong Koo Jeon, Covenant Theology and Justification by Faith: The Shepherd Controversy and Its Impacts (Eugene, OR: Wipf & Stock, 2006); Wayne C. Stumme, ed., The Gospel of Justification in Christ: Where Does the Church Stand Today? (Grand Rapids: Eerdmans, 2006); Samuel E. Waldron, Faith, Obedience, and Justification: Current Evangelical Departures from Sola Fide (Reformed Baptist Dissertation Series 1; Palmdale, CA: Reformed Baptist Academic Press, 2006); and Richard Gaffin, By Faith, Not by Sight: Paul and the Order of Salvation (Oakhill School of Theology Series; Carlisle, UK: Paternoster, 2006).


Many years ago, as a university student I heard a lecture on Calvin and Calvinism during which my professor of European history spoke entirely in the past tense, as if Calvinism had died in the St. Bartholomew’s Day massacre in 1572. He seemed genuinely surprised to find that, though we were dead, we yet live. So, we offer these essays with the thought that some readers might find also that Calvinism is not dead, but offers a vital and persuasive alternative to some of the views offered at present.



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  1. If I could put a plug in for Dr. Jeffrey Niehaus’ recent 3 volume work on ‘Righteousness’ here (they are only 10 bucks a piece on Kindle). He exhaustively goes through every use of word righteous/righteousness in the Bible and finds in favor of the Reformers. He exposes the corrupt and and take for granted nature of German liberal academia in this area.

  2. Would love an updated version that could take on the “attempted” nuance of Barclay, who to my mind does not offer a different way (as he intended). I agree with Fesko’s review of “Paul and the Gift.” I find it telling that Roman Catholics flocked to Barclay’s work. Additionally, I find his attempt to use the gift framework to make God univocal to us and this we have to reciprocate his gift of grace-something that is impossible.

  3. Clarifying that last point. I mean, reciprocate to God in the sense that we can give the equivalent of what’s been given to us. I do not deny third use or the necessity of good works as EVIDENCE of justification.


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