Which Covenant Theology?

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), 197–227. 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.

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Introduction

Covenant theology seems to be all the rage these days. According to E. P. Sanders, the “pattern of religion” known as Second Temple Judaism can be described as “covenantal nomism.”1 N. T. Wright’s Climax of the Covenant captures his own summary of the New Testament (especially Paul), and Norman Shepherd and his followers advocate a covenantal approach that stands over against both a medieval theology of merit and a Lutheran doctrine of justification.2 A small but vocal group in our own circles even calls its position the “federal-vision” theology, despite frequently sweeping denunciations of the classic


1. All references to E. P. Sanders are to his Paul and Palestinian Judaism (Minneapolis: Fortress, 1977).

2. See also N. T. Wright, What Saint Paul Really Said: Was Paul of Tarsus the Real Founder of Christianity? (Grand Rapids: Eerdmans, 1996), 117: “First, it [justification] is covenant language—not in the sense of that word made famous through some sixteenth- and seventeenth- century discussions, but in the first-century Jewish sense.” Typically, Wright dismisses a long-established view with a considerable consensus as something other than “the first-century Jewish [i.e., biblical] sense,” without any argumentation. We are to simply accept that he has a direct access to the Bible that apparently our predecessors and we ourselves do not have.

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federal theology that dominated Reformed instruction all the way to Louis Berkhof’s Systematic Theology.

Not only Second Temple Judaism but all of these somewhat diverse challenges to the evangelical doctrine of justification may be accurately described as “covenantal nomism.” This pattern of religion is united by three principal theses: (1) our personal obedience is a condition of justification, but that this does not mean that justification is strictly merited; (2) there is no qualitative distinction between law and gospel or a covenant of works and a covenant of grace; and (3) we “get in by grace, but stay in by obedience” (Sanders)—that is, a final justification by works.3 While we cannot do justice to the various aspects of this argument, it will hopefully become clearer that Paul, the Reformers, and the federal theology that forms the warp and woof of the Reformed system stand on one side, while the revised covenant theologies espoused by the new perspective on Paul, Norman Shepherd, and the federal vision—despite their differences—reflect together something very similar to the covenantal nomism that the Reformation repudiated. If true, this would be important because it would mean that the Reformers were at least close to getting it right when they compared the Galatian heresy to medieval theology and, further, that the only reason that such historical confusion over law and gospel is less objectionable to many today is that a similar confusion is widely accepted within our ranks.

Is Obedience a Condition of Justification?

Sanders argues that the Jews of Paul’s day did not believe in merit, strictly speaking, and so were not trying to justify themselves by legalistic works. Yet, his own magisterial study shows just how crucial was the concept of merit. Since, however, for Sanders “merit” can mean


3. There is considerable debate over Sanders’s method (“types of religion”) and his tendency (especially in Wright’s view) to be too interested in soteriology: in other words, he is still asking Protestant questions of Jewish texts. Here I am less interested in taking a stand in this debate, which is beyond my competence, than in using Sanders’s typology as a marker for the broad similarities that unite the otherwise different movements described here. For a more extensive discussion of some of these issues, see Michael S. Horton, Justification and Participation: A Covenant Soteriology (Louisville: Westminster John Knox, forthcoming).

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only strict merit (i.e., an exact quid pro quo), he tries (unsuccessfully) to exonerate Second Temple Judaism from that charge. The mere presence of references to God’s grace and provisions for forgiveness leads Sanders to conclude that Judaism was far from the medieval theology targeted by the Reformers. However, as we will see, Rome was no less committed to a halfhearted works-righteousness that far fell short of a full-blown Pelagianism.

Thus, part of the difficulty that we encounter in all of the versions of covenantal nomism surveyed here is the remarkably poor scholarship in treating the Reformers and their successors. Despite Sanders and his diverse students having made the Reformation views part of their thesis (viz., the Reformers missed Paul’s point), not a single representative of the new perspective on Paul demonstrates any scholarly familiarity with primary or secondary sources in the field.

The presence of forgiveness, divine assistance, grace, and repentance as a means of restoration after sin makes Second Temple Judaism nothing like medieval Rome, we are told. One will find this thesis persuasive, however, only if one misunderstands the latter as a purely Pelagian works-righteousness. Rome, too, affirmed the need for forgiveness and grace, with its own provisions for sin through sacrifices and penance. Furthermore, the Reformers never argued that Paul’s opponents had no place for grace, forgiveness, and sacrifice. Rather, they were convinced that, like the medieval church, the Jewish believers in Galatia had confused law and gospel, grace and works, promise and conditionality, Abraham and Sinai.4

Both forms of covenantal nomism, ancient and medieval, certainly did hold to the necessity of our own meritorious obedience in some sense as a condition of justification. Even Sanders concedes this much concerning Second Temple Judaism. The difference is one’s theological perspective: for Paul and the Reformers, this position—whatever we want to call it—amounted to works-righteousness. Justification is either by works or by grace, but it cannot be by both. A debilitating habit of the representatives considered here, from Sanders to Wright, Shepherd, and the federal vision, is the pretense to be simply


4. See, e.g., the commentaries of Luther (his second commentary) and Calvin on Galatians, although this is part of their running polemic through their writings more generally.

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reading the text, while others are “doing theology.” Everyone in this debate, however, is working with biases that shape their exegetical labors. Sanders is semi-Pelagian; that comes across quite clearly in his dogmatic pronouncements. If one believes that semi-Pelagianism avoids works-righteousness and is therefore acceptable as a religion of grace, one will hardly challenge as works-righteousness a position that admits some notion of grace. If, on the other hand, one maintains that Scripture prohibits this semi-Pelagianism as a distortion of the gospel, then a religion need not be fully Pelagian in order to qualify as works-righteousness. Though I have no difficulty assigning the label semi-Pelagian to Sanders, I am not at all making a sweeping judgment about everyone else I will be considering. Those, however, who depend on Sanders’s thesis—even if they are not themselves semi-Pelagian—should recognize the theological assumptions that make that thesis plausible. Sanders’s so-called discoveries are hardly new, except to the generations of biblical scholars who have heard distorted versions of Reformation theology only secondhand or thirdhand and assumed a crude view of Judaism as “law without grace,” which the Reformers were too well informed to have adopted.5

Monocovenantalism (one covenant simultaneously evangelical and legal in its basis) simply collapses the Abrahamic promise and the Sinaitic law. What results is covenantal nomism. Even after—indeed especially after—reading Montefiore’s and Sanders’s descriptions of Second Temple Judaism, the contrast with Paul’s preaching could not be greater. Paul does not believe that Judaism had no place for God’s grace or provisions for forgiveness, but he emphatically declares that the earthly Jerusalem is in bondage to works-righteousness just the same and that the law cannot bring about peace with God, even with the assistance of the Spirit, grace, and provisions in case of transgression (Gal 4). If our obedience in any respect is a condition of our justification, we are condemned—since the law does not exonerate hearers but only doers of the law (Rom 2:13; Gal 3:10–11). Monocovenantalism old and new attempts to combine merit and grace, and the result is that both concepts are weakened. The place traditionally


5. Admittedly, this is a sweeping claim, the defense of which is beyond the scope of this essay. It receives some treatment in Horton, Justification and Participation.

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given in Reformed theology to Christ’s full and meritorious obedience as our representative is eclipsed or even denied, while our own obedience (however weak) is seen as a condition of justification. Thus, both the justice of God in upholding his righteous law and his mercy in satisfying its conditions himself are eclipsed—or, better, both his justice and his mercy are relativized by each other instead of being held together simultaneously in their integrity. The end product is a relaxed law and a demanding gospel.

Shepherd and others within our circles share the view of advocates of the new perspective on Paul that merit—a crucial category in Reformation theology (particularly with respect to Christ’s)—is an idea we can live without. Not surprisingly, the crucial doctrine of the imputation of Christ’s active obedience—indeed, imputation of Christ’s righteousness at all—is denied. (Interestingly, even Wright is unwilling to go quite that far: he does not deny imputation; he just does not see it as the point of λογίζομαι in Paul.)6

Reformed theology simply failed to eliminate merit from its medieval vocabulary, we are told. Typical of the caricatures, federal-vision advocate Richard Lusk summarizes the classic Reformed position:

In other words, Jesus is the successful Pelagian, the One Guy in the history of the world who succeeded in pulling off the works righteousness plan. Jesus covered our demerits by dying on the cross and provides all the merits we need by keeping the legal terms of the covenant of works perfectly. Those merits are then imputed to us by faith alone. . . . Such is the view of bicovenantal federalism.7

Aside from Calvin and the Reformed orthodox repeatedly distinguishing between human ability before and after the fall and aside from Pelagianism being the view that after the fall we can obey God perfectly apart from grace, Lusk here seems to have trouble accepting the very notion that Christ’s representative work included his life of obedience. Lusk affirms Jesus’s sinlessness, substitutionary


6. Wright, What Saint Paul Really Said, 123.

7. Rich Lusk, “A Response to ‘the Biblical Plan of Salvation,’” in The Auburn Avenue Theology, Pros and Cons: Debating the Federal Vision (ed. E. Calvin Beisner; Fort Lauderdale, FL: Knox Theological Seminary, 2004), 137.

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atonement, and “the infinite value of his obedience,” but denies that his own obedience is in any way a meritorious feat that is then imputed to us.8

In the bicovenantal system of classic Reformed theology, says Lusk (correctly), “Jesus is regarded as a dutiful servant who has to earn favor.”9 (There is a prominent messianic-Servant theme in the Old Testament, is there not?) He appeals to Philippians 2:9, of all texts, to say that “Paul writes the Father graced him with such a name as a gift.”10 That passage, however, actually says that “Christ became obedient even to death, even the death of the cross. Therefore [on the basis of that obedience] God also has highly exalted him and given him the name above every name.”

The covenant of works, Christ’s meritorious obedience, and imputation stand or fall together in Reformed theology, Lusk rightly recognizes:

Those who advocate a meritorious covenant of works put a great deal of weight on the so-called “active obedience” of Christ. I remember hearing sermons in which I was told “Jesus’ thirty-three years of law-keeping are your righteousness. They were credited to you! He kept the law, the covenant of works, on your behalf!” . . . But the notion of his thirty-three years of Torah-keeping being imputed to me is problematic. After all, as a Gentile, I was never under Torah and therefore never under obligation to keep many of the commands Jesus performed. . . . God’s righteousness is his own righteousness, not something imputed or infused. . . . Paul is not identifying the gospel with the doctrine of imputed righteousness.11

Yet, again there is a contradiction: “He was raised up on the basis of his flawless obedience to the Father,” Lusk says.12 But “on the basis of” means “ground.” Lusk does not even refer to this flawless obedience as a means, but as the ground, yet he has told us that the ground was grace. What is the difference between saying that Jesus


8. Ibid., 137–38.

9. Ibid., 137.

10. Ibid.

11. Ibid., 141 (emphasis original).

12. Ibid., 142.

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was raised because he had merited everlasting life by his obedience and saying that he was raised on the basis of his flawless obedience to the Father? If his flawless obedience is the basis, then, it is clearly a matter of deserts. Whatever it means to say that Christ was raised on the basis of his flawless obedience, it surely cannot be grace; “otherwise grace is no longer grace” (Rom 11:6). The inevitable tendency of Lusk’s argument is to diminish the uniqueness of Christ’s justification by personal, loving, faithful, devoted, filial obedience to his Father and to view Christ simply as the first Christian—one who in some vague sense “deserved” to be rewarded with salvation, but in no sense meriting it. As we will see, this amounts not to the end of the category of merit but a shift from condign (strict) to congruent (graciously accepted) merit.

Lusk himself says, again contradicting his statements above, “Christ ‘deserved’ to be rewarded after he suffered and died, not because of some abstract justice (or ‘merit’), but because the Father had freely promised him such (cf. Isaiah 53:10–11; Philippians 2:9).”13 Although he puts it in scare quotes, even Lusk concedes some notion of Christ’s “deserving” to be rewarded. And who says that it is “because of some abstract justice” as opposed to “the Father’s promise”? Certainly not Reformed theology, according to which Jesus, like Adam, was promised the consummation on the condition of his successful completion of the probation.

Such sweeping contrasts between “abstract justice” and relational categories—applied to the character of God, the atonement, justification, and future destinies—have a long but quite unhelpful career in the history of modern theology. Lusk never clarifies what he means by “abstract,” so the assumption is simply that it describes the position that Christ actually fulfilled a covenant of works. That there really are abstract theories of atonement and justification out there I do not doubt. I am familiar with popular presentations in which the atonement and justification are treated as impersonal transactions. We do need to reflect more on the covenantal context of these truths. For example, we are repeatedly reminded in the epistles of the words reported first in the Psalter: “I desire obedience and not sacrifice.” The


13. Ibid., 147.

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imputation of Christ’s active obedience is the ground upon which the Father can receive from his human servant (representatively in Jesus Christ) the full love, loyalty, and obedience in which he delights and his law requires, so that he can receive as “sons” those who “in Christ” are as yet in themselves sinful. It is about relationship after all: adoption, filial devotion—and the restoration of sinners to God in such a way that in Christ even their feeble and sin-stained works can be nevertheless acceptable to the Father precisely because they are merely a response to and in no way condition of that acceptance. So much for abstract justice. Further, Lusk’s claim that Gentiles were never under Torah is refuted by Paul’s argument in Romans 1–3, that “all the world” is swept into Israel, condemned by the law, whether written on the conscience (Gentiles) or on tablets (Jews).

With the covenant of works and the concept of strict merit denied, the imputation of Christ’s perfect obedience to God’s covenant law is no longer a relevant category. According to Lusk, “This justification requires no transfer or imputation of anything.”14 We also encounter another false choice: either imputation or union with Christ.15 Citing Calvin and Richard Gaffin, Lusk says that believers are righteous by virtue of their union with Christ.16 Protestantism, however, avoided the false choice between imputation or union, making imputed righteousness the legal ground of the union.17

At this point Lusk appeals to Shepherd’s contrast between a merit principle and a covenantal approach.18 Yet like the new perspective on Paul, Lusk (and Shepherd) ignores not only that the Reformed held to the principle of merit (Christ’s) within a thoroughly covenantal theology, but also fails to recognize that Rome had a covenantal paradigm—very much like the covenantal nomism already described.

Identified especially with the school of nominalism, the slogan of this medieval covenant theology was this: “God will not deny his grace to those who do what lies within them.”19 Strictly speaking,


14. Ibid., 142.

15. Ibid., 142–43.

16. Ibid., 143.

17. See Horton, Justification and Participation, for an elaboration of this theme.

18. Ibid., 144.

19. See Heiko Oberman, Forerunners of the Reformation: The Shape of Late Medieval Thought Illustrated by Key Documents (Philadelphia: Fortress, 1966), 123–74. For a fuller treat-

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no one merits salvation (condign merit). Rather, God accepts the imperfect obedience of those who belong to the church as if it were satisfactory for final justification (congruent merit). Although no one is strictly meritorious of final justification, God has instituted a covenant in which cooperation with infused grace will be accepted in place of perfect fulfillment of the law. Grace was provided through the sacraments, just as it had been through the sacrifices of the old covenant. As faith became formed by love—in other words, as faith became obedience—it became justifying. The “new law,” as the New Testament was called, is a kinder, gentler form of conditionality than is the old covenant. Jesus is a new Moses, but a milder one (evidently, the Sermon on the Mount, with its far more demanding interpretation of Torah, was not determinative). Similarly, the Arminians on the Continent and neonomians (such as Richard Baxter) in England sought a rapprochement with Rome on justification by saying that faith—construed as obedience—was the only work substituting for full obedience. The law now relaxed, one could be justified simply by having the beginnings of holiness. It was a “kinder, gentler” justification by works.

While Shepherd and the federal-vision proponents oppose the category of merit in principle, they do insist that faith and obedience (or faith as obedience) are the instruments of final justification, which amounts to the congruent merit advocated by late medieval theology. While our confessions affirm that the faith that justifies is a living, active, and obedient faith, they universally insist that faith is justifying only in its act of resting in Christ’s merits. In the words of John Murray, “It is this resting, confiding, entrusting quality of faith that makes it appropriate to and indeed exhibitive of the nature of justification. . . . Faith terminates upon Christ and his righteousness and it makes mention of his righteousness only. . . . This is both the stumbling block and the irresistible appeal of the gospel.”20

It is impossible to read Sanders’s description of Second Temple Judaism and Heiko Oberman’s description of late medieval nominal-


ment, see idem, The Harvest of Medieval Theology: Gabriel Biel and Late Medieval Nominalism (Durham, NC: Labyrinth, 1983), esp. 167–220.

20. John Murray, Principles of Conduct: Aspects of Biblical Ethics (1957; repr. Grand Rapids: Eerdmans, 1991), 217.

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ism and not recognize striking similarities. This covenantal nomism is the official position of post-Tridentine Rome, as the most recent Catechism of the Catholic Church illustrates:

With regard to God, there is no strict right to any merit on the part of man. Between God and us there is an immeasurable inequality, for we have received everything from him, our Creator. The merit of man before God in the Christian life arises from the fact that God has freely chosen to associate man with the work of his grace. The fatherly action of God is first on his own initiative, and then follows man’s free acting through his collaboration, so that the merit of good works is to be attributed in the first place to the grace of God, then to the faithful.21

This is not a new position, however; it has been the long-standing Counter-Reformation interpretation: neither fully Pauline nor fully Pelagian.

Lusk confidently declares that Calvin “clearly repudiated the notion that Christ merited God’s favor in any strict sense,” citing Alister McGrath.22 Both Lusk and McGrath, however, are wrong. Of course, Calvin did deny that our works were meritorious, but Calvin speaks clearly of Christ’s meritorious obedience, without which (says the Reformer) there could have been no salvation: “By his obedience, however, Christ truly acquired and merited grace for us with the Father. Many passages of Scripture surely and firmly attest this.” In fact, he adds: “I take it to be a commonplace that if Christ made satisfaction for our sins, if he paid the penalty owed by us, if he appeased God by his obedience . . . then he acquired salvation for us by his righ-


21. Catechism of the Catholic Church (2nd ed.; Rome: Libreria Editrice Vaticana, 1997), 486 §§2007–8.

22. Lusk, “Response to ‘the Biblical Plan of Salvation.’” All of Lusk’s confident assertions are not only based on secondary research, but on dated research that does not take into account the massive contradiction of the discontinuity thesis (i.e., the assertion that Calvin and the Calvinists did not see things eye to eye). See especially Richard Muller, The Unaccommodated Calvin (Oxford: Oxford University Press, 2000); idem, After Calvin: Studies in the Development of a Theological Tradition (Oxford: Oxford University Press, 2003). The work of Lyle Bierma, Carl Trueman, Joel Beeke, and R. Scott Clark represent a significant reevaluation of the unfounded assumptions of discontinuity between Calvin and the Reformed tradition, while a fresh wave of first-rate scholars has emerged within European universities greatly substantiating Muller’s “continuity” thesis: namely, Irena Backus, Willem Van Asselt, and Anton Vos, among others.

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teousness, which is tantamount to deserving it. . . . Hence it is absurd to set Christ’s merit against God’s mercy” (Institutes 2.17.3, 1, emphasis added). Christ’s meritorious obedience is the basis upon which God can justly show mercy to sinners.

Merit is the category for Christ’s saving work that one finds in the Reformed and Presbyterian confessions. Not only is it found in the more fully developed federal theology of the Westminster Divines, it is just as clearly articulated in the Belgic Confession 22–24, which refer repeatedly to Christ’s having merited our salvation. And according to Heidelberg Catechism 17, Christ came to “earn for us and restore to us righteousness and life.”

The Canons of Dort rejected those “who teach that Christ, by the satisfaction which he gave, did not certainly merit for anyone salvation itself and the faith by which this satisfaction of Christ is effectively applied to salvation, but only acquired for the Father the authority or plenary will to relate in a new way with men and to impose such new conditions as he chose. . . . For they have too low an opinion of the death of Christ, do not at all acknowledge the foremost fruit or benefit which it brings forth, and summon back from hell the Pelagian error” (Rejection of Errors 2.3, emphasis added). Ironically, Lusk and his colleagues accuse the Reformation appeal to Christ’s meritorious obedience of being “Pelagian,” while Dort refers this charge to its denial. Rejection of Errors 2.4 is especially pertinent in its rejection of those

who teach that what is involved in the new covenant of grace which God the Father made with men through the intervening of Christ’s death is not that we are justified before God and saved through faith, insofar as it accepts Christ’s merit, but rather that God, having withdrawn his demand for perfect obedience to the law, counts faith itself, and the imperfect obedience of faith, as perfect obedience to the law, and graciously looks upon these as worthy of the reward of eternal life. . . . And along with the ungodly Socinus, they introduce a new and foreign justification of man before God, against the consensus of the whole church.

Christ not only merited our salvation in a congruent sense—that is, in the sense that God graciously accepted his work as satisfactory—

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but also in the condign sense: he actually fulfilled the obedience that God required of us all in Adam.

Lusk claims that the teaching of Christ’s active obedience and the covenant of works was never heard of in the church until the federal theologians. As early as the second century, however, Irenaeus distinguishes between a covenant of law and a covenant of promise, identifying the former with the first arrangement with Adam as well as the Sinai covenant, while linking the latter to the protevangelium, Abraham, and the new covenant in Christ.23 John of Damascus makes a similar statement.24 And Augustine says: “The first covenant was this, unto Adam: ‘Whensoever thou eatest thereof thou shalt die the death,’” which is why all his children “are breakers of God’s covenant made with Adam in paradise.”25 In fact, Augustine elaborates this point in considerable detail in these two passages, contrasting the creation covenant with the covenant of grace as we find it in the promise to Abraham. To be sure, federal theology represents a refinement and greater elaboration, but not a new idea. More importantly, these distinctions between promise and law, the Abrahamic and Sinaitic covenants, faith and works, are explicit in the Old and New Testaments.

Finally, says Lusk, the covenant of works and its category of Christ’s meritorious obedience leads inevitably to antinomianism—a charge with which Paul was not unacquainted. In a sweeping indictment of the entire Reformed tradition (including the Puritans who framed the Westminster Standards), Lusk writes:


23. Irenaeus, Against Heresies 4.25; 5.16.3; 4.13.1; 4.15.1; 4.16.3 (ANF 1.24–26, 554); cf. Ligon Duncan, “The Covenant Idea in Irenaeus of Lyons” (paper presented at the North American Patristics Society annual meeting, May 29, 1997); Everett Ferguson, “The Covenant Idea in the Second Century,” in Texts and Testaments: Critical Essays on the Bible and the Early Church Fathers (ed. W. E. March; San Antonio: Trinity University Press, 1980), 135–62.

24. John of Damascus, An Exact Exposition of the Orthodox Faith 2.30 (NPNF2 9.43).

25. Augustine, City of God (trans. Henry Bettenson; ed. David Knowles; New York: Penguin, 1972), 688–89 §16.28; cf. Augustine, On Christian Doctrine 3.33 (NPNF1 2.569). Augustine commends the hermeneutical rules of Tichonius: “The third rule relates to the promises and the law, and may be designated in other terms as relating to the spirit and the letter, which is the name I made use of when writing a book on this subject. It may be also named, of grace and the law. This, however, seems to me to be a great question in itself, rather than a rule to be applied to the solution of other questions. It was the want of clear views on this question that originated, or at least greatly aggravated, the Pelagian heresy. And the efforts of Tichonius to clear up this point were good, but not complete. For, in discussing the question about faith and works, he said that works were given us by God as the reward of faith, but that faith itself was so far our own that it did not come to us from God.”

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Talk about obedience is always suspect because it smells of merit. . . . The entire federalist theological construction creates massive dichotomies that make it virtually impossible to tie together faith and works, justification and Christian growth, grace and new obedience, and so on, in any organic, covenantal whole. . . . Sanctification comes to fit only very awkwardly into our theological system and the pressures towards (theoretical, if not practical) antinomianism become greater and greater.26

A typical argument used by Paul’s opponents (and by the medieval church) was that justification on the basis of an alien righteousness, simply received and not acquired by oneself—even with God’s help— would lead inexorably to license. Lusk too assumes that if one accepts the traditional Reformed position one would simply be antinomian. To deduce is one thing, but to actually make the sweeping historical claim that the Westminster Divines (i.e., the Puritans) were afraid to talk about obedience, “Christian growth, grace and new obedience, and so on, in any organic, covenantal whole” goes beyond any criticism leveled even by the tradition’s staunchest opponents.27

Aside from the obvious historical inaccuracies in such sweeping denunciations of Reformed theology, the most pressing problem with this challenge is that when Christ’s fulfillment of meritorious obedience of the covenant of works/law on our behalf is categorically denied, it is not that the concept of merit disappears, but only the term. “Thus, in Christ, our faith-wrought good works have value before God, but not merit,” Lusk says.28 Just what is that “value” that is not “merit”? And is that “value” in reference to justification? According to Rome, the category of “final justification” answers that question. Although believers “get in by grace”—even grace alone, through a regenerative baptism—they are justified on the last day according to their works. Not only do federal-vision advocates such as Lusk endorse something close to baptismal regeneration (emphasizing that this is by grace alone), we find in these writers comments such as the following from Lusk:


26. Lusk, “Response to ‘the Biblical Plan of Salvation,’” 145.

27. Ibid.

28. Ibid., 146.

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Biblically, judgment according to works comes at the end of history, not the beginning. Only after we have had time to mature into fruit bearers does God give a full evaluation of our covenant fidelity. Judgment according to works is eschatological, not protological. But the proponents of the covenant of works put this mature judgment at the beginning! The New Covenant sacramental system reveals this basic progression [toward a judgment according to works at the end]. God, not man, makes the water used in baptism. The one baptized has no works to offer. He is completely passive. But due to the Lord’s Supper man must “make” bread and wine out of the raw materials of creation. The elements of the Supper represent human labor and are offered to God as a sacrifice of praise and thanks. Man is active in eating and drinking at the table, and God judges us according to our “works” therein (cf. 1 Corinthians 11:17ff.). So baptism, as the sacrament of initiation, grants initial justification apart from works. But the Supper, as the sacrament of nourishment and maturation, includes an evaluation of our works.29

This is a classic statement of the unfortunate consensus at the Council of Trent. And in some important respects, once different sacraments are substituted, it fits Sanders’s definition of covenantal nomism in Second Temple Judaism. The notion of two justifications—one by grace, the other by works—distinguishes all these forms of covenant nomism from biblical faith.

Critics of the Reformation doctrine like to quote Paul’s reference to “the obedience of faith” (Rom 1:5) as if this were a proof-text for justification by faithfulness.30 Yet this is not a new insight but an old error. The Canons of Dort condemn the view that “the imperfect obedience of faith” is “a condition of salvation” or “worthy of the reward of eternal life. For by this pernicious error the good pleasure of God and the merit of Christ are robbed of their effectiveness and people are drawn away, by unprofitable inquiries, from the truth of


29. Ibid.

30. Paul is not suggesting that faith justifies because it is obedience, but is simply treating “obedience” at least in reference to faith (and therefore justification) as believing in Christ. If critics are willing to limit their definition of obedience (in reference to justifying faith) as Paul does here, and as Jesus does in John 6:29, we would have no quibble. But, in fact, their “obedience of faith” is actually a “faith of obedience.”

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undeserved justification and the simplicity of Scripture” (Rejection of Errors 1.3).

Related to the question of merit is the argument that Paul’s polemics against works are not as sweeping as the Reformers assumed. Since the Reformers did not have Sanders, Dunn, and Wright at hand, they could not have known that “works of the law” referred to circumcision and dietary laws—that is, ethnic badges, rather than to any and all works. Yet once more, when we read the Reformers, we soon encounter the same debates. For example, Calvin says of Galatians 2:15: “[Others] hold that this [i.e., works of the law] does not refer to moral works. The context, however, shows clearly that the moral law is also comprehended in these words, for almost everything that Paul adds relates to the moral rather than the ceremonial law.”31 The new perspective on Paul unwittingly repeats the medieval arguments as if they were fresh exegetical discoveries, and the federal vision demonstrates no greater familiarity with the sources that they assume to have gotten Paul so badly wrong.

Is There a Qualitative Distinction between Law and Gospel?

Monocovenantalism is a common distinctive of the various forms of covenantal nomism we are describing. Yet, as already noted, biblical scholarship is increasingly aware of the differences between conditional and unconditional covenants in Scripture. Even such a seminal architect of the new perspective on Paul as James Dunn recognizes this: “The more obvious line of reasoning is that Paul was so remembered [as chief heretic of Judaism] because he was in fact the one who brought the tension between law and gospel (already present in Jesus’s own ministry—Mark 7:1–23; Matt 15:1–20) to its sharpest and indeed antithetical expression.”32 Dunn acknowledges a law/gospel antithesis in Paul.33 Similarly, even Wright makes a distinction between


31. John Calvin, Commentaries on the Epistles to the Galatians and Ephesians (trans. William Pringle; Grand Rapids: Eerdmans, 1948), 37–39.

32. James D. G. Dunn, Jesus, Paul, and the Law: Studies in Mark and Galatians (London: SPCK/Louisville: Westminster, 1990), 93.

33. Ibid., 95.

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commands and promises.34 In fact, although he would not wish to be seen aiding and abetting a confessional dogmatic system, throughout Climax of the Covenant Wright repeatedly strengthens the exegetical case for the Mosaic theocracy as a law-covenant distinguished from the Abrahamic promise-covenant.35 On Romans 7:7–12, Wright states the argument: “The law is not sin, but its arrival, in Sinai as in Eden, was sin’s opportunity to kill its recipients.”36 Many of these representatives of the new perspective on Paul are far more careful in their exegesis and often less radical in their repudiation of Reformation theology than those of the federal vision.

Yet on the subject of election in Galatians 3, Wright’s view seems to be that Paul modified the single Jewish doctrine of election and covenant.37 Classic federal theology has generally held that two covenants are in view (as Paul says explicitly): national (Sinai) and individual-global (Abrahamic). This is already an Old Testament concept that Paul simply draws out and expands. They are not just two successive covenants, but two covenants that coexist side by side. In fact, even Jesuit Old Testament scholar Dennis J. McCarthy complains that the failure to recognize and distinguish unconditional and conditional covenants in the Old Testament leads to enormous exegetical confusion.38

The problem with Paul’s opponents was precisely that they were monocovenantalists (covenantal nomists, just as Sanders describes the position) and confused the blessings of Abraham with the Mosaic covenant described in Deuteronomy 27–30, failing to realize that in this way they were under only covenant curses rather than blessings. Wright even says that “the temporary status of the Torah has given way to the permanent creation, in Christ, of a worldwide people


34. Wright, What Saint Paul Really Said, 23.

35. Paul’s point, then, is that Israel as a nation has failed to keep Torah and is thus as a nation under its curse, so that Torah can hardly be the means of returning after exile and retaining membership and becoming a blessing to the world. This can happen (Gal 3:10–14) only when Israel becomes “the means of blessing the world in accordance with the promise to Abraham”; N. T. Wright, The Climax of the Covenant: Christ and the Law in Pauline Theology (Minneapolis: Fortress, 1992), 146.

36. Ibid., 197.

37. Ibid., 171.

38. Dennis J. McCarthy, Old Testament Covenant: A Survey of Current Opinions (Atlanta: John Knox, 1972), 5.

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characterized by faith. This people is the single family promised to Abraham. We may compare Romans 8.3f.: what the law could not do, being weak because of human sinfulness, God has done in Christ and by the Spirit.”39 Then Wright returns to the false dilemma that seems to result from his abiding commitment to Dunn’s “membership identity” thesis.40 This, again, is based on his restrictive view that “the law” has reference to only Israel’s Torah—and only the ceremonial aspects at that—which is, as we have seen, an argument that the Reformers also encountered.41

The Reformers, however, spoke of νόμος (Torah) in both a wide and a narrow sense: law as a principle of works-righteousness and law as God’s specific commandments to Israel. They did not maintain that law and gospel are antithetical in principle, whether understood in terms of the old and new covenants or in terms of commands and promises, which are after all present in both covenants. When, however, it comes to the principle by which sinners are to appear before a holy God in his righteous judgment, says Calvin, we must heed the gospel and not the law, “forgetting all law righteousness. . . . If consciences wish to attain any certainty in this matter [of justification], they ought to give no place to the law.” The law still guides believers in the way of holiness: “But where consciences are worried how to render God favorable, what they will reply, and with what assurance they will stand should they be called to his judgment, there we are not to reckon what the law requires, but Christ alone, who surpasses all perfection of the law, must be set forth as righteousness” (Institutes 3.19.2). Romans 10:5–6 drives this point home, Calvin says: “Do you not see how he [Paul] makes this the distinction between law and gospel . . . ? This is an important passage, and one that can extricate us from many difficulties if we understand that that righteousness which is given us through the gospel has been freed of all conditions of the law. . . . The gospel promises are free and dependent solely upon God’s mercy, while the promises of the law depend upon the condition of works” (Institutes 3.11.17).


39. Wright, Climax of the Covenant, 172.

40. Ibid., 173.

41. Ibid., 182.

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Remarkably, given the recurring polemics, Wright goes so far as to conclude: “The Lutheran wants to maintain the sharp antithesis between law and gospel; so does Paul, but within the context of a single plan of God, and with no suggestion that the Torah itself is a bad thing.”42 Further, “the Lutheran view is not without its merit; it simply needs setting in a wider context,” namely, seeing the relation as “contained within the sense of climax, of ‘goal.’ When I reach my goal I stop traveling; not because my journey was a silly idea but because it was a good idea now fully worked out.”43

This is less radical, of course, than denying the law/gospel distinction altogether, as many even in our circles are now doing. Yet, even this fails to recognize that the Reformers regularly referred to law and gospel in precisely these two ways, which may be fairly described in terms (albeit anachronistically) of the historia salutis and the ordo salutis. Calvin also speaks of “the law” in both senses: redemptive-historical (old covenant) and as a principle of works.44 The Reformers assert both with great hermeneutical sophistication and nuance, while covenantal nomism simply collapses the latter into the former. A thorough treatment of Paul’s understanding of the law in these broader and narrower senses is provided by Stephen Westerholm, among others.45


42. Ibid., 241.

43. Ibid., 244.

44. For more on this, see my “Calvin and the Law-Gospel Hermeneutic,” Pro ecclesia 6 (1997): 27–42.

45. Stephen Westerholm, Perspectives Old and New on Paul: The “Lutheran” Paul and His Critics (Grand Rapids: Eerdmans, 2004), 105–20. For example, regarding the question as to whether “works of the law” is restricted to ethnic distinctives: “That Paul could use ‘law’ and ‘works of law’ interchangeably [Rom 3:28] makes it highly unlikely that, with the latter phrase, he has in mind only a few specific statutes or, indeed, a distortion of the law. . . . But the only commandments of the law mentioned by Paul before his reference to ‘works of the law’ in Rom 3:20 are taken from the Decalogue (2:21–22), and do not refer to Jewish ‘identity markers’” (118). “The ‘works of the law’ which do not justify are the demands of the law that are not met, not those observed for the wrong reasons by Jews. If in Rom 2 the Jews are condemned for not fulfilling the works of the law, that can hardly fit circumcision, dietary laws, etc., which they did in fact keep scrupulously. That Paul supports his rejection of the ‘works of the law’ in Rom 3:20, 28 by showing that Abraham was justified by faith, not works (4:1–5), is positively fatal to Dunn’s proposal, as it was to that of Gaston. For the ‘works’ by which Abraham could conceivably have been justified, and of which he might have boasted (4:2), were certainly not observances of the peculiarly Jewish parts of the Mosaic code. Paul is here demonstrating that the broad category of ‘works’ cannot be a factor in salvation in order to exclude the subcategory, ‘works of law.’ Not particular works which set Jews apart, but works in general—anything ‘done’

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Neither Paul nor the Reformers thought that the law was itself the problem, contrary to the position of Hans Dieter Betz, Rudolf Bultmann, and others against whom the new perspective on Paul is reacting, as if their negative view of the law as law was that of the Reformers.46 According to Paul, the law is good, but we are not (Rom 7:12). This is why “law”—any imperative—cannot bring life. If any law could have, then Torah surely would have done it (Gal 3:21). Justification and new life depend on a divine indicative, and not just any such indicative, but God’s deed in Christ as offered in the covenant of grace. In fact, Paul’s own use of the phrase principle of law versus principle of faith (as in Rom 3:27 and 9:30–32) is not inimical lexically to substituting the term covenant, where principle (νόμος) is used to refer to a regime, order, or economy. Steve Schlissel, however, simply rejects the validity of such a distinction:

God has peppered his Word with a lot of “or-elses,” so many that no one could miss them. But while the or-elses couldn’t be missed, they could be mis-assigned, as if they belonged to the Law and not to the Gospel. This is a false division, of course. It is a division, however, famously rejected by Calvinists! . . . Of course Christ has become a new Moses!47

At this point, the federal-vision writers are simply confused. On one hand, they repeatedly reject Reformed bicovenantalism (works and grace), realizing that it rests on the law/gospel distinction. Yet, by calling it “Lutheran” they think that they can create a new “Reformed” doctrine out of whole cloth. John Frame similarly exaggerates the


that might deserve a recompense (μισθός, 4:4) or justify pride (καύχημα, v. 2)—are meant, and that in contrast with the ‘faith’ of one who ‘does not work’ but benefits by divine grace without any consideration of personal merit” (119). While Paul’s law does not include Jesus’s commands but is restricted to the Mosaic law, Luther’s “contrast between ‘law’ and ‘gospel,’ though never explicit in the epistles, does not distort Paul’s point” (122).

46. Hans Dieter Betz, Galatians (Hermeneia; Minneapolis: Fortress, 1979), 145–46. For an excellent treatment of Paul’s use of the phrase, see C. E. B. Cranfield, “‘The Works of the Law’ in the Epistle to the Romans,” Journal for the Study of the New Testament 43 (1991): 325–86; cf. Douglas Moo, “‘Law,’ ‘Works of the Law,’ and Legalism in Paul,” Westminster Theological Journal 45 (1983): 94–97.

47. Steve M. Schlissel, “A New Way of Seeing?” in The Auburn Avenue Theology, Pros and Cons: Debating the Federal Vision (ed. E. Calvin Beisner; Fort Lauderdale, FL: Knox Theological Seminary, 2004), 23.

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Lutheran view of the law/gospel relation in the name of a Reformed covenantalism. “Reformed” seems to be defined by Frame’s own idiosyncratic view rather than by that tradition’s typical way of speaking about this issue, since he says: “The view that I oppose, which sharply separates the two messages [of law and gospel], comes mainly out of Lutheran theology, though similar statements can be found in Calvin and in other Reformed writers. . . . I believe that we should stand with the Scriptures against this tradition.”48 This, of course, puts Frame at odds with classic Reformed theology, whose covenant of works/covenant of grace scheme is a redemptive-historical elaboration of the law/gospel distinction.49 This claim, however, places him at odds even with such modern representatives as Murray, who writes concerning the distinction between law and gospel: “In the degree to which error is entertained on this point, in the same degree is our conception of the gospel perverted. . . . What was the question that aroused the apostle to such passionate zeal and holy indignation, indignation that has its kinship with the imprecatory utterances of the Old Testament? In a word it was the relation of law and gospel.”50

This was also Shepherd’s argument in the controversy at Westminster Seminary: we need a distinctly Reformed (covenantal) doctrine of justification, not the so-called Lutheran one found in the Reformed confessions!51 Whatever results from a “non-Lutheran Reformed” doctrine of justification, however, cannot be called Reformed. Schlissel claims that “Paul’s point, therefore, was not to prove justification by faith, but rather to prove justification for Gentiles. . . . Obedience and faith are the same thing, biblically speaking.”52 Again the federal vision asks us to make a false choice: either a faith divorced from obedience or a faith that is obedience, the same false choice demanded by the Counter-Reformation and by Paul’s antagonists. In Rome’s construction, faith itself is mere assent to church teaching. (This, by the way,


48. John Frame, “Law and Gospel,” Chalcedon Report (Jan. 4, 2002): 1, 7 (emphasis added).

49. See Michael Horton, “Law, Gospel, and Covenant,” Westminster Theological Journal 64 (2002): 279–88.

50. Murray, Principles of Conduct, 181.

51. See, e.g., the more recent argument (or assertion) by Norman Shepherd, “Justification by Faith Alone,” Reformation and Revival 11 (2002): 81.

52. Schlissel, “A New Way of Seeing?” 26 (emphasis added).

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seems virtually indistinguishable from Wright’s definition of faith.)53 Therefore, in order for faith to be “fully formed” it must become a work: fides formata caritate (faith formed by love). So too for the federal vision: not only does genuine faith yield obedience, but faith justifies a person only insofar as it is obedience. This is nothing more than a repristination of the covenantal nomism that Paul, the Reformers, and our confessions condemn.

Further, all of these challenges ignore the careful way in which mainstream Reformed theology has dealt with the obvious conditionality in Scripture, including Paul. This tradition has never said that there are no conditions in the covenant—or even in justification. Rather, it argued that the condition of justification is faith and that the conditions of salvation as a whole process are many: lifelong repentance and faith, sanctification, and glorification. This theology, however, emphasized that these conditions are fulfilled by the gifts that come to us through union with Christ. Thus, God promises to give faith and perseverance, justification and sanctification, throughout the course of our life, all the while distinguishing justification from the process of inner renewal. Furthermore, even the law that accused us now appears to us as a delight. Luther writes: the law “no longer terrifies us with death and hell but has become our kind friend and companion.” Christ has turned the prison into a palace. “He did not destroy and abrogate the Law; but He so changed our heart . . . and made the Law so lovely to it that the heart now delights and rejoices in nothing more than the Law. It would not willingly see one tittle of it fall away.”54 Thus, even the law depends on the gospel for its efficacy. The distinction between law and gospel, works and faith, and the covenant of works and covenant of grace does not, at least in Reformed theology, imply an absolute antithesis except at the point of how one is accepted by


53. Furthermore, as Wright sees the matter, faith is defined not as trust in the person and work of Christ, but as assent to Paul’s redefinition of Jewish monotheism. Paul is arguing for “justification by belief, i.e., covenant membership demarcated by that which is believed.” He recognizes that this amounts to “my redefinition of what ‘justification’ thus actually means” (Climax of the Covenant, 2–3). How does this not represent the Roman Catholic view of faith as mere assent to church teaching?

54. See Luthers Werke Kritische Gesamtausgabe (ed. J. K. F. Knaake, G. Kawerau, et al.; Weimar: Böhlau, 1883–), 101, 1.459; and Ewald M. Plass, What Luther Says (St. Louis: Concordia, 1956), 2.766.

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God. To distinguish the respective nature and role of command and promise is not to
denigrate, much less repudiate, either.

The new covenant is a covenant of promise or gospel—that is, of what God will do for us—not only the promise to forgive all sins but to give a new heart (Jer 31:30–31). Yet God’s gift of new obedience can in no way serve as a second instrument of justification, nor can faith be defined as obedience (faith formed by love) in the act of justifying sinners. Certainly not on every point, but where justification is concerned, faith and works are absolutely antithetical (Rom 3:20–28; 4:4–5, 13–17; 10:1–13; 11:6; Gal 2:16–21; 3:2–14, 21–4:31; Eph 2:8–9; 2 Tim 1:9).

Summarizing Wright almost verbatim, Schlissel asserts:

The lenses through which the Letters of Paul must be read are not those supplied by systematic theology, abstract or otherwise. They must be the lenses provided by the Story, by Scripture itself. “Justification” in Galatians and Romans deals with the status of Gentiles. . . . Legal justification, far from being “the heart of the Gospel,” let alone identical with it, is hardly ever in view when Paul speaks of justification. Paul’s concern is the status of the Gentiles as Israelites indeed, through faith, not through ritual circumcision or the various identity markers uniquely connected with it.55

Commenting on Luke 10:25–37, Schlissel writes: “It is effrontery, an insult, to suggest that Jesus’s answer, ‘Do this and you will live,’ was anything other than plain truth. . . . It was Christ teaching that obedience to the law was something very do-able and that such obedience, which includes repentance and faith, does save.”56 Yet Schlissel so overstates his case that not even Wright would concur. The federal vision is so reactionary in its rejection of the so-called Lutheran paradigm that its own systematic-theological prejudices render responsible exegesis of Jesus as well as of Paul an impossible quest. As for the Reformed confessions, Christopher Hutchinson rightly


55. Schlissel, “A New Way of Seeing?” 33.

56. Cited by Christopher Hutchinson, “A Reply to ‘A New Way of Seeing?’” in The Auburn Avenue Theology, Pros and Cons: Debating the Federal Vision (ed. E. Calvin Beisner; Fort Lauderdale, FL: Knox Theological Seminary, 2004), 53, quoting Steve Schlissel’s comments in Christian Renewal (April 28, 2003): 11.

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concludes: “The assertion that the law-gospel formula is a ‘Lutheran’ scheme is discredited just three questions into the 1563 Heidelberg Catechism: ‘Q. 3. How do you come to know your misery? A. The law of God tells me.’”57 Ursinus’s own opening arguments in his commentary on the Heidelberg Catechism—“the law and the gospel as the two parts of the Word of God”—serve only to confirm this point.58

Lusk seems to be a little more open to exegetical nuance than Schlissel, who sees no significant discontinuity between the old and new covenants. There is some need to distinguish the Mosaic and Abrahamic covenants, says Lusk.59 Yet “the fundamental requirement of the Mosaic covenant was not any different from the basic requirements of the Abrahamic or Christic covenants: the obedience of faith.” Further, “the law did not require perfect obedience,” and “the sacrificial system clearly offered a remedy for sin.” Thus, “the law was a pre-Christian revelation of the gospel.” Lusk then cites passages from Paul and Hebrews, indicating what we have called the redemptive-historical use of law and gospel, but as if this were the only use these apostolic writers made of those categories and as if there were no contrast at all.60 So the sweep from Moses to Christ is continuum, never contrast.61

We are surely better served with the more nuanced claim that Paul employs both a redemptive-historical and a principled (dogmatic) strategy (1) reflecting law and gospel as a continuum of promise/type leading to fulfillment (infancy to adulthood) and (2) reflecting contrasting means of justification. Just as the Reformed view does not pose a false choice between justification and sanctification or between the historia salutis and the ordo salutis, it offers a far richer and broader way of accounting for the diversity of the biblical material. This diversity should not be exchanged for the reductionism that results from the imposition of any a priori dogmatic scheme. Paul’s (or Jeremiah’s)


57. Hutchinson, “Reply to ‘A New Way of Seeing?’” 57.

58. Zacharias Ursinus, Commentary on the Heidelberg Catechism (1852; 2nd ed.; repr. Phillipsburg, NJ: P&R, 1985), 1.

59. Lusk, “Response to ‘the Biblical Plan of Salvation,’” 127.

60. Ibid., 128.

61. Ibid., 129.

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statements about the differences between the Abrahamic covenant of promise and the Mosaic covenant of law is simply lost in the fog of a one-sided emphasis on redemptive-historical progress of a single covenant. At the end of the day, Christ is simply a new Moses.

Why then did Paul say in Galatians that the Mosaic covenant could not annul the Abrahamic? Why would that question even arise unless there was some contrast and tension? Whatever differences there might be between the Abrahamic and Mosaic covenants, they do not seem to be a matter of principle, says Lusk: “Or to put it another way, the New Covenant is just the Old Covenant in mature, glorified form.”62 Does this characterization, however, come close to the contrasts that are drawn by Paul and the writer to the Hebrews or John 1:17? Actually, “law and gospel actually perform the same (rather than contradictory) functions . . . [and] are simply two phases in the same redemptive program.”63 Once again, this simply does not accord with the facts, with respect to either Luther or Paul. And because this distinction is confused in the new perspective on Paul and federal vision, there is no longer any acknowledgement of even a difference between imperatives and indicatives. The law does not equal condemnation, says Lusk:

The flip side, though, is that the gospel is not a pure unconditional message of grace and blessing, as the law/gospel dichotomy seems to imply. The gospel can condemn every bit as much as the law. . . . Thus, whether or not a particular piece of God’s revelation is comforting (“gospel”) or condemning (“law”) depends on the state of the person’s heart to which it comes.64

To be sure, we must recognize that there certainly is an existential aspect: the sinful tendency of human nature to “suppress the truth in unrighteousness” will lead unbelievers to turn even the gospel into law, but should the hermeneutic of unbelief be normative? Ironically, having correctly rejected Bultmann’s existentialist hermeneutics, the new perspective on Paul and some of its federal-vision supporters


62. Ibid., 130.

63. Ibid., 131.

64. Ibid., 131–32.

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inadvertently return to something like it at just this point. Is there really no such thing as indicative and imperative moods encoded into the text? Does it all depend on reader response? The systematic-theological grid seems to impose itself over even obvious rules of Greek grammar.

Is Final Justification by Works?

Again, this position is identical to the covenant theology of the late middle ages. Unlike the strict justice of the old covenant, the new covenant reflects a relaxation in God’s demands. As the new perspective on Paul and federal-vision advocates have told us, God’s law is very “do-able” (Schlissel). It is easy: get in by grace, stay in by cooperating with God’s grace—doing whatever lies within you. If this is the view of new perspective on Paul and federal vision, then it is the height of arrogance to criticize the medieval church for its version of covenantal nomism. According to the Council of Trent, one “got in” by baptism, which could hardly be regarded as a human work of the infant. This is the “first justification,” but one’s subsequent status (“second justification”) depended on cooperation with infused grace. “Final justification” referred to the last judgment, which involves a divine weighing of good works against transgressions. Ironically, even the term final justification is employed by Wright, and a final justification by works is endorsed by the new perspective on Paul, Shepherd, and the federal vision.65

With Paul, the Reformers challenged this entire paradigm by insisting that one not only gets in but stays in by grace alone. They realized that the law, which we could not fulfill, nevertheless had to be fulfilled. Clearly, this involves some notion of merit: either Christ’s or our own personal obedience. Paul’s contrast between “the righteousness that is by the law” and “the righteousness that is by faith” (Rom 10:5–6) is


65. Wright, What Saint Paul Really Said, 126: “It is strange, above all, that the first mention of justification in Romans is a mention of justification by works—apparently with Paul’s approval (2:13: ‘It is not the hearers of the law who will be justified before God, but the doers of the law who will be justified’). The right way to understand this, I believe, is to see that Paul is talking about the final justification.” It is interesting to see that Wright does have a place for talking about how one is actually justified before God after all.

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also that of the Reformers, as is the apostle’s criticism of Judaism as a energetic zeal without the knowledge of God’s justifying righteousness in Christ alone (10:2–4). The traditional Protestant interpretation does not deny that Paul has in mind the boundary markers that separate Jews from Gentiles, but it recognizes that he also speaks more broadly of works-righteousness.66

Of course, there is a final vindication of God’s elect on judgment day, but the point of the doctrine of justification is to say that this eschatological verdict has already been rendered in the present. There are not two verdicts: one dependent on Christ’s obedience, the other on ours—getting in by grace, staying in by obedience. Like Paul’s critics, the Reformers’ opponents, “being ignorant of God’s righteousness, and seeking to establish their own righteousness, [have] not submitted to the righteousness of God. For Christ is the end of the law for righteousness to everyone who believes” (10:3–4). “This only I want to learn from you,” Paul demands of the Galatians:

Did you receive the Spirit by the works of the law, or by the hearing of faith? Are you so foolish? Having begun in the Spirit [getting in by grace], are you now being made perfect by the flesh [staying in by obedience]? . . .

For as many as are of the works of the law are under the curse; for it is written, “Cursed is everyone who does not continue in all things which are written in the book of the law, to do them.” But that no one is justified by the law in the sight of God is evident, for “the just shall live by faith.” Yet the law is not of faith, but “the man who does them shall live by them.” Christ has redeemed us from the curse of the law, having become a curse for us. (Gal 3:2–3, 10–12)

Those who seek to be justified by works, even congruently, with the assistance of grace, are not children of Abraham (the father of faith). In fact, they are slaves, not sons, heirs of Hagar the slave rather than


66. That election is of grace, for example, is illustrated in Jacob’s being chosen “before the twins were born and had done [anything] either good or bad—in order that God’s purpose of election might continue, not because of works but because of his call” (Rom 9:11). Clearly, it is works of any kind that Paul has in mind here, as also in 11:6: “But if it is by grace, it is no longer on the basis of works; otherwise grace would no longer be grace.” With reference to election and justification, grace and works are not only distinguished but completely antithetical.

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of Sarah the free woman. Or, to change the metaphor, Paul says that the Jerusalem below is in bondage, while the Jerusalem above is free. There are two covenants, says Paul, not one: a covenant of law (Sinai) and a covenant of promise (Abraham and his Seed) (4:21–31).

All of this is consistent with the prophets, especially Jeremiah 31, where God reissues the unilateral promise that the new covenant “will not be like the covenant I made with their fathers” at Sinai, “my covenant that they broke, though I was a husband to them, says the LORD” (31:32). Paul does not invent the gospel; he is simply reminding them that the covenant of promise (Abrahamic) cannot be annulled by the later covenant at Sinai (Gal 3:15–18). Evidently, Paul thought that his opponents had collapsed the Abrahamic covenant of promise, which was unconditional and global, into the covenant at Sinai, which was conditional and limited to the nation. This confusion of law covenants and promissory covenants creates a single covenantal nomism. The new perspective on Paul gets the second half of Paul’s polemic: the Abrahamic covenant is global rather than restricted to the nation, but misses the first half upon which the second is predicated, namely, that the Abrahamic covenant is global precisely inasmuch as it is determined by the work of Christ and not by Israel’s fidelity to the conditions of national status and possession of the land.

It is important to assert once again that the new perspective on Paul is often to be faulted not in what it affirms, but in what it denies. Covenant theology, whether covenantal nomism or the Reformed variety, is inherently communal.67 It resists reduction to “me and my personal relationship with God”—or to the question, “How can I be saved?” There is no doubt that a one-sided interest in the ordo salutis and individual salvation has threatened to eclipse the historia salutis and the cosmic horizon. Reformed theology has been urging balance


67. We should note Wright’s alteration of Sanders’s thesis: “At this point the categories of ‘getting in’ and ‘staying in,’ made popular by E. P. Sanders, seem to need more nuances: ‘getting back in,’ for instance, or ‘staying in when it looked as though one had been ejected’” (What Saint Paul Really Said, 155). There is all this continuity: “But Paul is not simply offering another form of ‘covenantal nomism.’ The covenant is now the renewed covenant; and the badge of membership is faith” (156). The majority of Israelites, Paul laments, are headed toward the curse of AD 70, but many (“Israel in principle”) is entering into the restoration promised in the prophets through Messiah (156n61, in discussing 1 Thess 2). Concerning Sanders’s thesis, Wright adds: “I do not myself believe such a refutation can or will be offered; serious modifications are required, but I regard his basic point as established” (20).

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in this area long before the appearance of Wright’s work. At the same time, Reformed covenant theology resists the opposite reduction to the question of covenant membership.68 The gospel is not “a description of how people get saved,” Wright insists, but is rather “the return of Israel from exile.”69 Again, we do not doubt that this redemptive-historical (biblical-theological) aspect is crucial, nor has it been lacking in Reformed covenant theology, but does this narrow definition exclude equally important elements in the prophets: forgiveness of sins, reconciliation with God, a new heart, adoption, the resurrection of individual bodies, all of which were both issues of individual salvation and the fulfillment of God’s promise to restore Israel? Jesus spoke of the publican returning “to his house justified rather than” the Pharisee (Luke 18:14). “What must I do to be saved?” was clearly a question that Jesus and the apostles were asked, and answered, in the New Testament. Since not only Paul but Jesus says, “None of you keeps the law” (John 7:19), this especially becomes a paramount personal crisis. Even if revivalism has sacrificed ecclesiology to the quest for personal salvation, “How can I be saved?” is not the question of Luther’s tortured subjectivity, but is asked and answered in the Gospels (Matt 19:25) and Acts (2:40; 16:30). In fact, says Paul, “This is a faithful saying and worthy of all acceptance, that Christ Jesus came into the world to save sinners, of whom I am chief” (1 Tim 1:15).

The Gentile mission would hardly have made sense if the gospel were simply the announcement of Israel’s return from exile. And the Jewish mission would not have had any better success with


68. Heikki Räisänen, Paul and the Law (2nd ed.; Tübingen: Mohr, 1987), 147. Räisänen points out, however, that this thesis itself is unraveling, especially with the appearance of M. A. Elliott’s The Survivors of Israel: A Reconsideration of Pre-Christian Judaism (Grand Rapids: Eerdmans, 2000): “This fresh and thorough study of pre-Christian Jewish literature effectively repudiates the notion of ‘nationalistic election theology’ in Judaism, i.e., ‘covenantal nomism’ in Sanders’ terms, and convincingly demonstrates ‘a highly individualistic and conditional view of covenant.’ . . . Thus the work deprives the New Perspective School of its basis in Judaism and so makes its proposed revolution in Pauline studies abortive.” Whether this overstates Elliott’s achievement, my approach is able to give place to the new perspective’s emphasis on a national election theology and, with it, a covenantal nomism. It distinguishes, however, between this (Sinaitic covenant) and the earlier (Abrahamic) covenant. This distinction, anchored so explicitly in the text (especially in Gal 3), allows us to account for both strands of exegetical data: a covenant of works and a covenant of grace.

69. Wright, What Saint Paul Really Said, 43 (emphasis original).

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the “good news” reduced to the imperative to relax the entrance requirements.

So what happens if Paul’s polemics against “works of the law” refers only to ethnic markers? Do we not end up with salvation by works, just not these particular works unique to Jewish identity? Schlissel and others actually go further than Wright in refusing any distinction between the principles of command and promise or between old and new covenants. Jesus is a new Moses; all discontinuity is eclipsed, even though the very announcement is that this new covenant “will not be like the covenant I made with [their] fathers” at Sinai. Included in a list of proof-texts for Schlissel’s systematic-theological proposition that the gospel is full of conditions is Deuteronomy 28:

If you fully obey the LORD your God and carefully follow all his commands I give you today, the LORD your God will set you high above all the nations on earth. All these blessings will come upon you and accompany you if you obey the LORD your God. . . .

However, if you do not obey the LORD your God and do not carefully follow all his commands and decrees I am giving you today, all these curses will come upon you and overtake you. (28:12, 15 NIV)

Once more, however, we see that the question is not systematic theology versus the Bible, but careful systematic theology versus careless systematic theology. We have already affirmed conditionality. We do not deny it. There is even obvious conditionality in the new covenant, although conditions function differently: they are means of administering the covenant, not of election or justification, whose only ground is Christ’s person and work, the latter received through faith alone. Schlissel thinks that the law expressed in Deuteronomy is easy to fulfill, whereas even Moses realizes its impossibility due to Israel’s sin (Deut 7–9). So we appeal to Paul by way of response:

For as many as are of the works of the law are under the curse; for it is written [in Deut 27:26, just cited by Schlissel as pertaining to believers], “Cursed is everyone who does not continue in all things which are written in the book of the law, to do them.” But that no one is justified by the law in the sight of God is evident, for “the just

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shall live by faith.” Yet the law is not of faith, but “the man who does them shall live by them.” Christ has redeemed us from the curse of the law, having become a curse for us (for it is written, “Cursed is everyone who hangs on a tree”), that the blessing of Abraham might come upon the Gentiles, in Christ Jesus, that we might receive the promise of the Spirit through faith. . . .

Tell me, you who desire to be under the law, do you not hear the law? (Gal 3:10–14; 4:21)

Schlissel believes that the law as well as the gospel makes alive, but Paul maintains, “For if there had been a law given which could have given life, truly righteousness would have been by the law” (Gal 3:21). If the Sinai covenant’s conditions are for everlasting rest, as Schlissel suggests, then we are still under its curse. There are not two justifications, one based on Christ’s righteousness and another based on our own. A final justification based on our own works, even those works done in faith, would reverse the verdict pronounced in our present justification.

Conclusion

These challenges of covenantal nomism represent both a threat and an opportunity. Seyoon Kim says that the new perspective on Paul is attempting to overturn the entire “Reformation interpretation of Paul’s gospel.”70 Yet Kim also points up the important contributions of this debate: “It appears that further work is needed to clarify the relationship between the covenantal and forensic dimensions of justification.”71 This is precisely where the classic Reformed version of covenant theology makes a contribution that has often been overlooked on both sides in these related debates. Union with Christ in the covenant of grace is the context within which justification makes sense and is given both its cosmic-eschatological and individual horizon. In this covenant theology, the historia salutis and ordo salutis come together, as do justification and sanctification, the church and the individual.


70. Seyoon Kim, Paul and the New Perspective: Second Thoughts on the Origin of Paul’s Gospel (Grand Rapids: Eerdmans, 2002), xiv.

71. Ibid., 83.

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Union with Christ is not an alternative to the Reformation doctrine of justification, but its proper horizon.

The new perspective on Paul raises a host of important themes and makes some important contributions to our understanding of Paul and Israel. Furthermore, even the federal-vision circle is right to encourage us to appreciate more fully an objectivity to the covenant and its sacraments that has been severely weakened by revivalism. The cure, however, may be worse than the disease. That we must be always reforming according to God’s word is not to be denied, but what we find in our classic Reformed resources is far more reflective of the whole counsel of God than the reactionary tendencies of our day. If we are to recover a genuinely Reformed covenant theology, it will require patient exegesis, not reactionary and dismissive polemics that derive from false dilemmas, reductionism, and caricatures. Clearly, we all have a lot more work to do, but at least we can rejoice in that the most decisive work, namely, the perfect fulfillment of the law, has already been done for us.

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Note: A special thanks to Courtney Litts for her efforts in helping us to get this chapter formatted to publish here.


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