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Paul, the Law and Eschatological Justification: Three Views of Romans 2:13

One of the most important and most hotly debated exegetical and biblical-theological issues in our day is that concerning the words of Paul in Romans 2:13, "The doers of the Law shall be justified" (οι ποιηται νομου δικαιωθησονται). What does the Apostle Paul mean by this statement? Is it a perfect obedience that Paul has in view? Is he merely taking up the Jewish mindset concerning the Law and a supposed standing before God on the basis of having that Law? Does this verse teach that a man or woman will be shown (evidenced) to have been justified in accord with their life of good works on Judgment Day? Or, is it a statement about a general obedience that forms the basis of our standing before God on Judgment Day? A survey of the differing views will help us navigate through these questions. There are essentially three positions on the meaning of this verse: (1) The hypothetical view; (2) the eschatological justification (in accord with our works) view; and (3) the eschatological justification (on the basis of our works) view. If we misinterpret this verse we may, in the words of Richard Gaffin, "undermine or eclipse, whether or not intentionally, the full graciousness of justification according to Paul."

The Hypothetical View

The view adopted by the majority of older Reformed theologians and commentators is that which has been commonly called "the hypothetical view." This interpretation is supported by a contextual consideration of the argument of Romans 1:18-3:20. Seeing the flow of these chapters as one coherent argument from plight to solution, proponents of "the hypothetical view" suggest that Paul is arguing from the logical implication of his opponents' position. That Paul is addressing unbelieving Jews (and it is widely debated who exactly the apostle is addressing in 2:1ff) is the underlying conclusion of proponents of "the hypothetical view." Accordingly, the Jews of Paul's day presumed that they are accepted by God on the basis of their possession of the Law and their supposed doing the deeds required by the Law. The problem was, as the apostle explains in both ch. 2 and ch. 3, that no one (i.e. Jew or Gentile) has done the Law. This is the very reason why another source of righteousness (i.e. the imputed righteousness of Christ by faith alone) must be provided (Rom. 3:20-30).

In Romans 1:18-5:21, the apostle moves from a general statement of the extreme depravity of all men to a specific address to unbelieving Jews about their own depravity (2:1-3:9) to the solution provided in the imputed righteousness of Christ (3:20-5:21). The crux of Paul's argument rests on the fact that the unbelieving Jews, who had the Law of God, thought that having the Law of God somehow put them in a right relationship with God. They were then looking at the Gentiles with judgmental distain. When Paul comes to his statement in 2:13, he insist that if righteousness--and, therefore, a right standing with God--came through the Law, it would not be the hearers of the law that would arrive at such a right standing, but the doers of the Law who would obtain it. Underlying Paul's statement about doers of the law being justified is Paul's theology of the demands of the Law. In the words of the Westminster Larger Catechism, "The moral law is the declaration of the will of God to mankind, directing and binding everyone to personal, perfect, and perpetual conformity and obedience thereunto..." (LC 93) and "the law is perfect, and binds everyone to full conformity in the whole man unto the righteousness thereof, and unto entire obedience forever; so as to require the utmost perfection of every duty, and to forbid the least degree of every sin" (LC. 99). (1)

John Calvin, in his commentary on Romans, explained what is commonly called "the hypothetical view" when he wrote:

For the hearers of the law, etc. This anticipates an objection which the Jews might have adduced. As they had heard that the law was the rule of righteousness, (Deuteronomy 4:1) they gloried in the mere knowledge of it: to obviate this mistake, he declares that the hearing of the law or any knowledge of it is of no such consequence, that any one should on that account lay claim to righteousness, but that works must be produced, according to this saying, 'He who will do these shall live in them.' The import then of this verse is the following, 'That if righteousness be sought from the law, the law must be fulfilled; for the righteousness of the law consists in the perfection of works.' They who pervert this passage for the purpose of building up justification by works, deserve most fully to be laughed at even by children. It is therefore improper and beyond what is needful, to introduce here a long discussion on the subject, with the view of exposing so futile a sophistry: for the Apostle only urges here on the Jews what he had mentioned, the decision of the law,  "That by the law they could not be justified, except they fulfilled the law, that if they transgressed it, a curse was instantly pronounced on them." Now we do not deny but that perfect righteousness is prescribed in the law: but as all are convicted of transgression, we say that another righteousness must be sought. Still more, we can prove from this passage that no one is justified by works; for if they alone are justified by the law who fulfill the law, it follows that no one is justified; for no one can be found who can boast of having fulfilled the law. (2)
John Murray, in his commentary on Romans, also defended "the hypothetical view" in his explanation of the words of Romans 2:13:

This verse is directly connected with the two clauses immediately preceding and supports or confirms the proposition that the law will be the instrument of the condemnation pronounced upon those who have sinned under it. The emphasis in verse 13 falls upon the difference between “hearers of the law” and “doers of the law.” The mere possession of the law does not insure favorable judgment on God’s part. The law is the standard of judgment but it is the law as demanding conformity. The apostle is undoubtedly guarding against that perversion so characteristic of the Jew that the possession of God’s special revelation and of the corresponding privileges would afford immunity from the rigour of the judgment applied to others not thus favored. He speaks of “the hearers of the law” because it was by hearing the Scriptures read that the mass of the people of Israel became acquainted with them and in that sense could be said to have the law (cf. Luke 4:16; John 12:34; Acts 15:21; 2 Cor. 3:14; James 1:22). It is quite unnecessary to find in this verse any doctrine of justification by works in conflict with the teaching of this epistle in later chapters. Whether any will be actually justified by works either in this life or at the final judgment is beside the apostle’s interest and design at this juncture. The burden of this verse is that not the hearers or mere possessors of the law will be justified before God but that in terms of the law the criterion is doing, not hearing. The apostle’s appeal to this principle serves that purpose truly and effectively, and there is no need to import questions that are not relevant to the universe of discourse.

This is the first occasion that the word “justify” is used in this epistle. Although it is not used here with reference to the justification which is the grand theme of the epistle, the forensic meaning of the term is evident even in this case. “Shall be justified” is synonymous with “just before God” and the latter refers to standing or status in the sight of God. To justify, therefore, would be the action whereby men would be recognized as just before God or the action whereby men are given the status of being just in God’s sight. (3)

Because of the density of his language, Murray has sometimes been misunderstood to have denied "the hypothetical view." For instance, Richard Gaffin makes the following statement on the basis of his reading of Murray:
The hypothetical reading of verses 5-13, or at least 5-11, is beset with a substantial difficulty. The future judgment in view here, including the principle role of works involved, is no different from the descriptions or allusions that we find in a number of places elsewhere in Scripture...If Romans 2:5ff are not interpreted hypothetically, then the perceived problem of conflict of biblical teaching on justification by faith simply defaults to these and other like passages and they will also have to be interpreted hypothetically on their positive side. But consideration of them will show, as John Murray put it bluntly, "the impossibility of such a procedure." The broader biblical outcome suggests that the positive outcome in view in Romans 2:5 ff., at least in verses 5-11, if not verses12-13 as well, is best seen as describing what will be true of Christians at the final judgment. (4)
This is both interesting and important given the fact that Murray, in his comments on Rom. 2:13, supplied a footnote that seems to reflect that he adopted "the hypothetical view;" and, that he disavowed an interpretation that supports some form of eschatological justification (at least, on the basis of  "faith and its fruit"). He wrote:
Philippi’s statement is worthy of quotation: “Whether or not there are such perfect ποιηταὶ τοῦ νόμου the apostle does not say in this passage, but only opposes the true standard to the false standard of the Jews, that ἀκροαταὶ τοῦ νόμου are just before God. The entire reasoning of the Roman epistle tends to this conclusion, that no man is by nature such a ποιητὴς τοῦ νόμου, or can be” (ad loc.). cf. also Godet, ad loc. although one cannot subscribe to his view of two justifications, “the one initial, founded exclusively on faith, the other final, founded on faith and its fruits.” (5)
Related to this view of Rom. 2:13 is the theology of Romans 4 and the relationship between Abraham and justification. When Paul goes to defend the doctrine of justification by faith alone, he sets Abraham out as the model (Rom. 4:1ff). Interestingly, he contrasts two instruments of justification: faith and works. It has not frequently been pointed out how the relationship between Abraham and the Law factors into this discussion. If Abraham is the model of a justified believer, and if there is such a thing as an eschatological justification that is related to doing the Law, then why wasn't the Law given until 400 years after Abraham. Sinclair Ferguson unpacks this wonderful point--and it's relationship to the theological meaning of Paul's use of the phrase, "the works of the Law"--in his 2005 lecture on the New Perspective. Proponents of "the hypothetical view" have a strong exegetical defense of their position due to the fact that everywhere else the word νομου or its variant forms is used in relationship to δικαιοι in the epistle it is always to suggest that no one is justified by doing the Law because no one has done the law.

The Eschatological Justification (in accord with works) View

In recent years, it has become commonplace to find theologians speaking of an "eschatological justification" when discussing Romans 2:13. This phrase--by itself--carries with it a world of baggage due to the ambiguous way in which it has often been used. The view is founded on a biblical-theological construct that positions the soteriological blessings of Christ in the already/not-yet framework of the two comings of Christ and the relationship of Rom. 2:13 within the context of 2:3-11. Accordingly, proponents suggests that just as there is an already and a not-yet to the saving blessings of regeneration, adoption and sanctification, so too is there an already and a not-yet to the saving blessing of justification. Because Romans 2:6-7 seem to clearly teach that the good works of believers, and the evil works of unbelievers, will stand as evidence on judgment day, some have sought to import the same meaning into the words of Rom. 2:13. (6)

As has already been noted above,  Richard Gaffin is an outspoken proponent of the eschatological justification according to works view. He explains what he means by according to works when he writes:

For Christians, future judgment according to works does not operate according to a different principle than their already having been justified by faith. The difference is that the final judgment will be the open manifestation of that present justification, their being "openly acquitted" as we have seen. And, in that future judgment, their obedience, their works are not the ground or basis. Nor are they co-instrumental, a coordinate instrument for appropriating divine approbation as they supplement faith. Rather, they are the essential and manifest criterion of that faith, the integral "fruits and evidences of a lively faith." Appropriating the language of the Westminster Confession of Faith, 16:2. It is not for nothing, I take it, and not to be dismissed as an overly fine exegesis to observe, that in Romans 2:6 Paul writes "according (κατα) to works," not "on account of, because of (δια)," expressing the ground, nor "by (εκ) works," expressing the instrument. (7)

To be fair, Gaffin seems to back away from Romans 2:13 in the bulk of his discussion and focuses, rather, on Rom. 2:3-10 in his explanation of eschatological justification according to works. However, after an extensive explanation of judgment according to works, Gaffin writes:

The perennial question at issue in verses 5-11, or if verses 12-13 are included, is whether on their positive side they have in view a scenario that is actual or one that is unrealized and true only in principle. That is, on the one side, is Paul describing Christians and the actual outcome of the final judgment for them or, alternatively, is he speaking hypothetically? The former reading, it seems to me, is almost certainly right. (8)

Gaffin draws a sharp distinction between a judgment according to works and on the basis of works. In fact, he goes to great length to explain the significance of the difference. He writes:

Within the larger context of Paul's teaching as a whole, then, the question is unavoidable. How are we to relate this future judgment according to works, as spelled out in this passage and others, to his clear and emphatic teaching elsewhere that justification, as already pronounced eschatological judgment, is a present reality, received by faith alone and on the sole basis of the imputed righteousness of God revealed in Christ?

With an eye to a long and somewhat complicated discussion that we are not able to survey here in any detail, the answer to this relational question does not lie in the direction of distinguishing two different justifications. This view has variant forms: one present, by faith and one future, by works, the former based on Christ's work, the latter based on our obedience, even if seen as Spirit-empowered; or, yet again, present justification based on faith in anticipation of future justification on the basis of a life time of faithfulness. All such views undermine or eclipse, whether or not intentionally, the full graciousness of justification according to Paul. (9)

Here, Gaffin is taking on a yet another interpretation of Romans 2:13--namely, a future justification on the basis of works. According to the footnote he supplies in the paragraph above, He specifically has N.T. Wright in view. Note the warning he raises at the end of the second paragraph above.

The Eschatological Justification (on the basis of works) View

Readers of this post who are familiar with the language of eschatological justification will know that a sharp distinction is drawn between eschatological justification in accord with our works and on the basis of our works. It is, in a reductionistic sense, the difference between Protestantism and Roman Catholicism. While biblical-theological nuances seem to distance an adoption of the latter view in such writings as E.P. Sander, James Dunn and N.T. Wright, it lands proponents of the New Perspective(s) on Paul in the same functional place as Rome.  

In his commentary on Romans, Wright comes out and plainly insists that Romans 2:13 teaches that "Justification, at the last, will be on the basis of performance." (10) In What Saint Paul Really Said, Wright states that he believes that "present justification declares, on the basis of faith, what future justification will affirm publicly... on the basis of the entire life." (11) In recent discussions, Wright has been challenged as to his use of the phrase on the basis of. At times he seems to make the phrases in accord with and on the basis of synonymous--though they clearly are not in their historic, linguistic and philosophical usages. (12) Certain defenders of Wright have even insisted that he is simply saying what Gaffin and Ridderbos have said about an eschatological justification in accord with works. However, as Douglas Moo has recently pointed out, Wright continues to use the specific language of "on the basis of" in his latest book, Paul and the Faithfulness of God

Most surprisingly, G.K. Beale, in his massive New Testament Biblical Theologysupports a doctrine of eschatological justification on the basis of works--taught in Romans 2:13--when he writes:

These verses [i.e. Romans 2:3-10] focus not only on the time of final judgment but also on the time of reward for those who "do good" (vv. 7, 10). Verse 6 ("who will render to each person according to his deeds") seems best interpreted in this context to mean that there will be a judicial evaluation of the works of all people; some will be found wanting and be judged, others will be found to have works and not be judged but will receive life. Accordingly, with this preceding context in mind, it seems best to understand Paul's statement in verse 13 , "the doers of the Law will be justified," to refer to the final judgment when those who have faith in Christ and possess good works, though not perfect, will be "justified" or "vindicated" on the basis of those works. This idea of judgment by works, though without the language of "justification/vindication," is also reflected later in Rom. 14:10, 12. (13)

Concluding Thoughts

Of course, a litany of other pertinent exegetical and biblical-theological considerations factor into this discussion (e.g. a fuller treatment of Romans 2:6-7, the already/not-yet structure of Paul's theology, a consideration of those passages that do teach that there will be a judgment according to works, the doctrine of rewards, etc.). While we do not have time to consider them, or the more nuanced sub-categories of these three overarching positions (14), this post is merely meant to serve as a basic introduction to the three main interpretive approaches to this verse. So what are we to make of these three attempts to interpret Romans 2:13?

While it has lost traction in recent years, "the hypothetical view" offers, in my opinion, the strongest defense of the overall context of Romans 1:18-3:20. It would seem a contradiction of seismic proportion for Paul to say in 2:13, "doers of the Law will be justified," and in 3:20, "Now, apart from the Law the righteousness of God is revealed...," unless he is explaining in 2:13 what it would take for a man to be justified if that justification were through the Law. This view fits most naturally in the flow of Paul's argument, which, it seems to me, is why the Reformers and Puritans--almost unanimously--opted for it.

"The eschatological judgment according to works view," while certainly taught in other places in the New Testament (see Gaffin's treatment of this in his chapter "Eschatology and Justification" in Justified in Christ) nevertheless fails to do justice to the issue of the Law in the central argument of Paul (Rom. 1:18-5:21). If the wider pericope is taken as the guiding theological parameter of Paul's argumentation then it does not make any sense why Paul would speak of a justification by law when his entire premise is that there is a justification apart from the Law in Christ. This is not to say that those who hold to "an eschatological justification according to works" are out of accord with historic Reformed Protestantism. The Westminster Confession of Faith clearly speaks of an "open vindication" of believers on judgment day. Gaffin's defense of a "judgment according to works" is substantiated by other passages, as he so ably argues. Gaffin is clear when he says that good works are merely "the essential and manifest criterion of that faith, the integral 'fruits and evidences of a lively faith.'" I would also suggest that Gaffin et al are correct in their reading of Romans 2:6-7, but that they are mistaken by opting for an "either/or" approach to reading 2:13. Why not rather conclude that Paul is speaking of a future judgment according to good works in 2:6-7 and that he is picking back up on his opposition of the Jewish argument for justification by the Law in 2:13? The context is certainly dynamic enough to include both ideas.

"The eschatological justification on the basis of works view" is the most far removed from the totality of biblical teaching. It is essentially the Roman Catholic cooperationist view of justification packaged in a highly academic, biblical-theological structure. In fact, if we suggest that there is a future justification on the basis of works then we destroy any and all hope of the subjective assurance of believers. At best,  proponents may point someone to the sacraments for some supposed objective assurance while leaving the question of whether I will have enough good works to form the basis of my final justification. This is the exactly the same problem as we find with Rome. It puts men and women in the "never enough quagmire." In fact, Rome's cooperationist approach to justification led Cardinal Bellarmine (Pope Clement VIII’s personal theologian of the Counter-Reformation) to declare that "the greatest of all Protestant heresies is assurance." If we say that we are "justified on the basis of works" then we take away from the perfect and sufficient work of Jesus in His life, death, burial and resurrection. This interpretation makes Jesus a Savior who doesn't make us acceptable to God entirely on the basis of who He is and what He has done. Instead, this view make Jesus a half savior who enables us to cooperate with Him (even if suggested that it is by His Spirit) to gain a right standing with God. In the end, this view would leave room for human boasting on judgment Day. Paul's argument in Romans 4 proves to be an appropriate critique of this view, even as it was of the immediate error he was opposing in the epistle.

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1. For a further exegetical consideration of Paul's theology of the demands of the Law, see Tom Schreiner's two outstanding articles, “Paul and Perfect Obedience to the Law: An Evaluation of the View of E.P. Sanders” and “Is Perfect Obedience to the Law Possible? A Reexamination of Galatians 3:10.” See also Guy Prentiss Waters' "Romans 10:5 and the Covenant of Works"

2. John Calvin Commentary on Romans 

3. John Murray Romans (Grand Rapids: William B. Eerdmans, 1958) vol. 1 on Logos, from his comments on verse 13.

4. Richard Gaffin By Faith, Not By Sight (Paternoster Press, 2006) pp. 96-97; a similar statement is made in Gaffin's article, "Eschatology and Justification," in K. Scott Clark ed. Justified in Christ (Ross-Shire: Christian Focus Publications, 2007) p.

5. Murray Romans n.21 on his comments on 2:13

6. Gaffin has an exceedingly helpful breakdown of this idea in his chapter "Eschatology and Justification" in both By Faith, Not By Sight and in  Justified in Christ.

7. Gaffin By Faith, Not By Sight pp. 98-99

8. Gaffin Justified in Christ p. 16.

9. Ibid., p. 19.

10 N.T. Wright, Romans, NIB 10 (Nashville: Abington, 2003), 440.

11. N.T. Wright, What Saint Paul Really Said (Grand Rapids: Eerdmans, 1997), 129.

12. In fact, in a debate last year between N.T. Wright and James White, Wright downplayed the importance of the distinction. You can find that debate here.

13. G.K. Beale A New Testament Biblical Theology (Grand Rapids: Baker Academic, 2011) p. 518 . I am grateful to my friend Adam Parker for finding this and passing it along.

14. Ibid., p. 517

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