Westminster Theological Journal 55 (1993) 113-35.

Copyright © 1993 by Westminster Theological Seminary, cited with permission.

PAUL'S VIEW OF THE LAW IN ROMANS 10:4-5

THOMAS R. SCHREINER

I. Introduction

TWO difficult verses for understanding Paul's view of the law are Rom
10:4-5. Rom 10:4, for example, has often been used to posit an absolute
discontinuity between law and gospel since Paul says here that "Christ is
the end [te<loj] of the law." Others, however, claim that to read such
discontinuity into the verse is unwarranted, and they argue that Paul is
asserting that "Christ is the goal of the law." In this latter view, faith in
Christ is the goal to which the law points, and there is a fundamental
harmony between the gospel and the OT law. Although Rom 10:5 has not
been as significant in the history of interpretation as Rom 10:4, the meaning
of this verse has been the subject of increasing debate in recent years. Since
these two verses are important for determining Paul's stance toward the OT
law, it is my goal to examine various interpretations of Rom 10:4-5 and to
defend the interpretation which is the most credible.

II. Christ is the End of the Law: Rom 10:4

The interpretation of te<loj ga>r no<mou Xristo<j is a well-known battle-

ground in Pauline studies,1 and we cannot in this article examine in suf-
ficient detail a verse which has been of such controversy. Nevertheless,
various interpretations of the verse will be described and critiqued,2 and I
will attempt to defend my own view.

1. The Law Is Abolished

One of the dominant views in NT scholarship, especially in Lutheran
circles, is that Christ is the end of the law in the sense that the OT law is
1
For the history of interpretation see R. Badenas, Christ the End of the Law: Romans 10:4 in
Pauline Perspective (JSNTSup 10; Sheffield: JSOT, 1985) 7-37; J. A. Nestingen, Christ the End
of the Law: Romans 10:4 as an Historical Exegetical-Theological Problem (Ph.D. dissertation,
University of Toronto, 1984).
2
It should be noted that some of the scholars fit into more than one of the categories listed
below, indicating that there is some fluidity between some of the interpretations. The most
notable contrast is between those who translate te<loj as "goal" and those who translate it
as "end."
113
114 WESTMINSTER THEOLOGICAL JOURNAL

now abolished for the believer.3 Christians are no longer under the law (cf.
Rom 6:14-15; Gal 5:18), and thus the Mosaic law is not binding for the
believer. Even the moral law of the OT is abolished since the whole law has
passed away (cf. Gal 5:3), and no distinctions between various parts of the
law can be supported either from Jewish literature or Paul.
This interpretation is difficult to tackle in a brief space because it intro-
duces the thorny issue of how the Testaments relate to one another. The
major defect of this view is that other statements in Romans (2:26; 8:4;
13:8-10; cf. also 1 Cor 7:19; Gal 5:14) indicate that Paul expected believers
to obey the moral norms of the Mosaic law. For example, in Rom 13:8-10
Paul lists some specific commands from the OT, and makes it clear that he
expects believers to fulfill them. If some of the moral norms of the OT law
are still binding on believers, then it is difficult to see how Christ can be the
absolute end of the law.4

2. Messianic Age Ends Age of Law

A view related to the above one is that Paul believed that the era of law
has come to an end with the arrival of the Messianic era. When Rom 10:4
says that "Christ is the end of the law," the point is that Christ inaugurated
the Messianic age, and since the Messianic age has begun the law is no
longer in force. This view is often defended by showing that it was a com-
mon Jewish conception that the law would be abolished with the onset of
the Messianic epoch.5
3
H. Raisanen, Paul and the Law (Philadelphia: Fortress, 1983) 54-55; E. Kasemann, Com-
mentary on Romans (Grand Rapids: Eerdmans, 1980) 282-83; W. Schmithals, Der Romerbrief
Ein Kommentar (Gutersloh: Gerd Mohn, 1988) 370; W C. Linss, "Exegesis of telos in Romans
10:4," BR 33 (1988) 6, 10-11; F Hahn, "Das Gesetzesverstandnis im Romer- and Galaterbrief,"
ZNW 57 (1976) 50; S. Westerholm, Israel's Law and the Church's Faith: Paul and His Recent
Interpreters (Grand Rapids: Eerdmans, 1988) 130; C. K. Barrett, "Romans 9:30-10:21: Fall and
Responsibility in Israel," Essays on Paul (Philadelphia: Westminster, 1982) 147; H. Schlier, Der
Romerbrief (HTKNT; Freiburg: Herder, 1977) 311; O. Michel, Der Brief an die Romer (MeyerK;
Gottingen: Vandenhoeck & Ruprecht, 1966) 255; G. Delling, "te<loj," TDNT 8.56; R.
Aldrich, "Has the Mosaic Law Been Abolished?" BSac 116 (1959) 322-35; A. van Dulmen,
Die Theologie des Gesetzes bei Paulus (SBM 5; Stuttgart: Katholisches Bibelwerk, 1968) 126.
4
Of course, all of these verses in Romans could be interpreted in another way. For a more
detailed defense of the ongoing validity of the law see T. R. Schreiner, "The Abolition and
Fulfillment of the Law in Paul," JSNT 35 (1989) 47-74; K. N. Snodgrass, "Spheres of Influ-
ence: A Possible Solution to the Problem of Paul and the Law," JSNT 32 (1988) 96, 99, 105-7.
5
J. A. Fitzmyer, "Paul and the Law," A Companion to Paul: Readings in Pauline Theology (ed.
M. J. Taylor; New York: Alba, 1975) 75, previously published in The Jurist 27 (1967) 18-36;
H. J. Schoeps, Paul: The Theology of the Apostle in the Light of Jewish Religious History (Phila-
delphia: Westminster, 1961) 171-75; A. Schweitzer, The Mysticism of St. Paul the Apostle (Lon-
don: A. C. Black, 1931) 191-192; van Dulmen, Die Theologie des Gesetzes, 126. For a careful
evaluation of the evidence see W. D. Davies, Torah in the Messianic Age/or the Age to Come
(Philadelphia: SBL, 1952).
 PAUL'S VIEW OF THE LAW 115

The fatal defect in this theory is the weakness of the alleged Jewish
evidence.6 Adequate proof is lacking in rabbinic literature that the law
would in fact be abrogated during the Messianic age. Moreover, even if
such a theory could be defended in rabbinic literature, there is no clear
evidence in Paul for such a theory. Neither Rom 10:4 nor any text from
anywhere else in Paul (e.g., Galatians 3) says that the law has come to an
end now that the Messianic era has arrived. Finally, even if one were to say
that Rom 10:4 and Galatians 3 do teach that the law has ended now that
the Messianic age has been inaugurated, then the same objection we noted
for the first view would apply, viz., Paul could not have taught that the law
has ceased to have any binding authority on believers since he cites moral
norms from the law as authoritative for the church.

3. Law Has Ended as a Way of Salvation

Other scholars claim with a closely related theory that the law has come
to an end as a way of salvation.7 Righteousness in the OT era was via the
law, but now that Christ has come right standing with God is no longer
based on the law. There is some ambiguity regarding what scholars mean
when they say that salvation was by law in the Mosaic era, but now that
Christ has come salvation is only through him. Presumably some are merely
saying that although salvation in the OT was still by faith, such faith
involved offering sacrifices and the performance of other commandments in
the OT law. Now that Christ has come sacrifices and other prescriptions of
the law are no longer necessary. The sacrifice of Christ has replaced the OT
cultus. The idea that the sacrifice of Christ has replaced OT sacrifices is
surely in accord with Pauline theology, but it is hardly evident that Paul
is proclaiming the end of the OT law and sacrificial system in this sense in
Rom 10:4. No discussion on the atoning work of Christ is to be found here.
We shall argue below that there is a better way to explain the flow of
thought in Rom 10:3-5.
Other scholars who see the law as coming to an end as a way of salvation
seem to be suggesting that there are two different ways of salvation, one
6
Cf. P. Schafer, "Die Torah der messianischen Zeit," ZNW 65 (1974) 27-42; E. Bammel,
"No<moj Xristou?," SE III (TU, 88 [1964]) 120-23.
7
P. Althaus, Der Brief an die Romer (NTD; Gottingen: Vandenhoeck & Ruprecht, 1959) 108;
H. W. Schmidt, Der Brief des Paulus an die Romer (THKNT; Berlin: Evangelische
Verlagsanstalt, 1963) 175; R. Mohrlang, Matthew and Paul: A Comparison of Ethical
Perspectives (SNTSMS 48; Cambridge: Cambridge University Press, 1984) 27; J. Reumann,
"Righteousness" in the New Testament (Philadelphia: Fortress, 1982) 88; R. N. Longenecker,
Paul: Apostle of Liberty (Grand Rapids: Baker, 1964) 144-47; G. E. Ladd, A Theology of the New
Testament (Grand Rapids: Eerdmans, 1974) 502-3; E. G. Gulin, "The Positive Meaning of the
Law According to Paul," LQ 10 (1958) 116; Delling, TDNT 8.56; A. Nygren, Commentary on
Romans (Philadelphia: Fortress, 1949) 379-80; J. Munck, Christ and Israel: An Interpretation of
Rom. 9-11 (Philadelphia: Fortress, 1967) 84; van Dulmen, Die Theologie des Gesetzes, 126.
116 WESTMINSTER THEOLOGICAL JOURNAL

based on the law and one based on the gospel.8 If this is what some scholars
have in mind, then this is not a convincing solution. Paul appeals to both
Abraham and David (Rom 4:1-8) to teach that salvation has always been
by faith, and that there is not a distinct way of salvation in the OT More-
over, Rom 9:31-32 demonstrate that Paul does not criticize the Jews for
pursuing the law. The problem is the way they pursued the law, i.e. "not from
faith but as from works."

4. Christ Is the End of the Ceremonial Law

It has also been claimed that Christ is the end of only part of the law, viz.,
the ceremonial law.9 However, it is not at all clear in this context that Paul
is referring to only part of the law, nor does this view explain adequately
why righteousness is now available since the ceremonial law has been set
aside. Is salvation by law more easily attainable with the moral law in force?

5. The Exclusivity of the Law Is Set Aside

Some claim that the point here is that Christ is the end of the exclu-
siveness of the law. Now salvation is also available to the Gentiles, and the
Jews of Paul's day have wrongly limited it to themselves.10 There is little
doubt that Paul focuses on the inclusion of the Gentiles in Romans 9-11 (cf.
9:24-26; 10:11-13, 19-20; 11:11-22). But this is not the central theme of
Romans 9-11. In these chapters God's faithfulness with respect to his prom-
ises for the Jewish people (cf. Rom 9:6) is the theme.11 Moreover, the specific
problem in Rom 9:30-10:3, I have argued elsewhere, cannot be limited to
the nationalism of the Jews.12 Practices which separated Jews from Gentiles,
such as circumcision, Sabbath, and food laws, are not even mentioned in
this section of the letter. It seems that the most natural way of reading Rom
9:32 and 10:3 is to see the Jews faulted for attempting to be righteous on the
basis of their works, and these works cannot be limited to part of the law.
Thus, a critique of works-righteousness in a broad sense is evident in this
8
A number of scholars in the first category listed above may be of this persuasion as well.
The lack of precision in the way this view has been expressed makes it difficult in some cases
to delineate specifically what some scholars have in mind when they say the law has come to
an end as a way of salvation.
9
So, e.g., C. Haufe, "Die Stellung des Paulus zum Gesetz," TLZ 91 (1966) 171-78.
10
M. A. Getty, "An Apocalyptic Perspective on Rom 10:4," HBT 4-5 (1982-83) 97, 100;
id., "Paul and the Salvation of Israel: A Perspective on Romans 9-11," CBQ 50 (1988) 466-67;
F. Refoule, "Romains X,4. Encore Une Fois," RevBib 91 (1984) 339; J. D. G. Dunn, Romans
(WBC; Dallas: Word, 1988) 2:598; F. Watson, Paul, Judaism and the Gentiles: A Sociological
Approach (SNTSMS 56; Cambridge: Cambridge University Press, 1986) 165; van Dulmen, Die
Theologie des Gesetzes, 127.
11
So also B. L. Martin, Christ and the Law in Paul (NovTSup 62; Leiden: Brill, 1989) 133.
12
See "Israel's Failure to Attain Righteousness in Romans 9:30-10:3," TrinJ 12 (1991)
209-20.
 PAUL'S VIEW OF THE LAW 117

text. And even though Paul proclaims the inclusion of Gentiles in Romans
9-11, the Jews are not specifically reproved for being too exclusive in Rom
9:30-10:8. Instead, they are censured for failing to obey the law and for
legalism.13

6. Christ Is the Goal of the Law

An increasingly popular interpretation, which was also prominent, if not

dominant, in the history of the church,14 is the conception that Christ is the
goal of the law.15 A more extended critique will be given of this interpre-
tation in view of its increasing popularity and its historical significance.
Robert Badenas' claim that te<loj must be translated teleologically in
Rom 10:4 is debatable,16 for—whatever one makes of the term outside the
NT—in the Pauline corpus and the rest of the NT the semantic range of
the word is used more commonly with a temporal rather than a teleological
meaning. Curiously even Badenas' own summary of Pauline usage could be
interpreted to support such a conclusion:17 (1) twice the word means
"fully" or "completely" (2 Cor 1:13; 1 Thess 2:16); (2) three times it
13
Similarly, F. Mailer's view ("’Christus [ist] des Gesetzes Ende zur Gerechtigkeit fur
jeden, der glaubt,’ [Rom 10:4]," in Paulus—Apostat oder Apostel? [ed. M. Barth et al.; Regens-
burg: F. Pustet, 1977] 31-44]) that Paul is speaking of the end of the law only for the Gentiles
but not the Jews is not persuasive. Paul indicts the Jews in these verses because they were
attempting to establish their own righteousness (Rom 10:3), not because they were imposing
the law on the Gentiles. For an effective refutation of Mufner see Schmithals, Romerbrief, 370.
14
See the historical surveys of Badenas and Nestingen cited in n. 1 above.
15
D. P. Fuller, Gospel and Law: Contrast or Continuum? (Grand Rapids: Eerdmans, 1980)
84-85; C. T. Rhyne, Faith Establishes the Law (SBLDS 55; Chico: Scholars, 1981) 103-4; id.,
"Nomos Dikaiosynes and the Meaning of Romans 10:4," CBQ 47 (1985) 492-93; L. Gaston, "For
All the Believers: The Inclusion of Gentiles as the Ultimate Goal of Torah in Romans," Paul
and Torah (Vancouver: University of British Columbia Press, 1987) 130; C. E. B. Cranfield, A
Critical and Exegetical Commentary on the Epistle to the Romans (ICC; Edinburgh: T. & T
Clark, 1975, 1979) 2.519-20; B. Reicke, "Paulus caber das Gesetz," TZ 41 (1985) 247-49; F.
Fluckiger, "Christus des Gesetzes te<loj," TZ 11 (1955) 153-54; P W. Meyer, "Romans 10:4 and
the ‘End’ of the Law," The Divine Helmsmen: Studies on God's Control of Human Events,
Presented to Lou H. Silberman (ed. J. L. Crenshaw & S. Sandmel; New York: Ktav, 1980) 65-66,
68; W. S. Campbell, "Christ the End of the Law: Romans 10:4," Studia Biblica 1978: III. Papers
on Paul and Other New Testament Authors. Sixth International Congress on Biblical Studies (ed.
E. A. Livingstone; JSNTSup 3; Sheffield: JSOT Press, 1980) 74-77; G. E. Howard; "Christ the
End of the Law: The Meaning of Romans 10:4ff," JBL 88 (1969) 333; J. Ziesler, Paul's Letter to
the Romans(Philadelphia: Trinity Press International, 1989) 257-58; Badenas, Christ the End,
114-17; W. C. Kaiser, Jr., "Leviticus 18:5 and Paul: Do This and You shall Live (Eternally?)"
JETS 14 (1971) 26; J. E. Toews, The Law in Paul's Letter to the Romans (Ph.D. dissertation,
Northwestern University, 1977) 220-42; G. N. Davies, Faith and Obedience in Romans: A Study
in Romans 1-4 (JSNTSup 39; Sheffield: JSOT, 1990) 1187-89; R. Bring, "Paul and the Old
Testament: A Study of the Ideas of Election, Faith, and Law in Paul, with Special Reference to
Rom. 9:30-10:13," ST 25 (1971) 45-46; Snodgrass, "Spheres of Influence," 107.
16
See his word study in Christ the End, 38-80. Against Badenas, see Dunn, Romans 2.589.
17
Badenas, Christ the End, 78-79. We omit the use of te<loj in Rom 13:7 since it refers to
the paying of taxes.
118 WESTMINSTER THEOLOGICAL JOURNAL

denotes "the eschatological end" (1 Cor 1:8; 10:11; 15:24); (3) twice "final
destiny" (2 Cor 11:15; Phil 3:19); and (4) five times it is teleological (Rom
6:21-22; 10:4; 2 Cor 3:13; 1 Tim 1:5). It should be observed that the first
three categories above match the semantic range of "end" more than they
do "goal." It cannot be denied that the range of te<loj is dynamic, and thus
it does not always refer to a temporal end. But Badenas' claim that the
translation "goal" is lexically required in Rom 10:4 is at least debatable
even from his own presentation of the evidence.
What is even more significant is that, contrary to Badenas, 1 Tim 1:5
seems to be the only clear example of the word te<loj meaning "goal" in
the Pauline corpus. The other four examples Badenas lists are all disputed.
The two uses of te<loj in Rom 6:21-22 should be translated as "outcome,"
or "result," not "goal." The words "outcome" or "result" signify an
inevitable result, while "goal" suggests an intended purpose.18 Paul says of
evil deeds that "the end [te<loj] of those things is death" (v. 21). Con-
versely, "the end [te<loj]" of sanctification "is eternal life" (v. 22). Surely
the "goal" of wickedness is not "death"! When Paul speaks of the te<loj
of wickedness, he is referring to the "result," "consequence," or "out-
come" of evil behavior. The parallelism of the verses indicates that the word
te<loj should be construed similarly in v. 22.19
Contrary to Badenas, the meaning of te<loj in 2 Cor 3:13 is most likely
"end" not "goal."20 This is suggested by the participle katargoume<nou,
which modifies te<loj in v. 13. The verb katarge<w in this context refers to
the passing away or cessation of the old covenant (cf. 2 Cor 3:7, 11). 21 2 Cor
3:11 makes this particularly clear. The covenant which is "passing away"
(katargou<menon) is contrasted with one that is "remaining" (me<non). One
cannot separate in 2 Corinthians 3 the end of the splendor on Moses' face (v. 13)
from the passing away of the old covenant (v. 11), for Paul uses the cessation of
glory on Moses' face as an illustration of the passing away of the old covenant. 22
Nonetheless, Badenas' claim that te<loj means "goal" in 2 Cor 3:13 is
still a possibility. To interpret te<loj as goal, however, probably reads too
18
All results, of course, may be construed as the intended purpose of God. One needs to
be careful, though, of defining terms on the basis of this truism.
19
Interestingly Badenas himself (Christ the End, 74) links Rom 6:21-22 with 2 Cor 11:15 and
Phil 3:19 earlier, but then he places Rom 6:21-22 in a different category in his conclusions (pp.
78-79).
20
Badenas, Christ the End, 75.
21
L. L. Belleville (Reflections of Clog: Paul's Polemical Use of the Moses-Doxa Tradition in 2
Corinthians 3.1-18 [JSNTSup 52; Sheffield: JSOT, 1991] 204-5) argues that the word katarge<w
means "fading." But support for this definition is not strong. The evidence points to katarge<w
meaning "to bring to an end," "nullify," and "abrogate." Rightly R. B. Hays, Echoes of
Scripture in the Letters of Paul (New Haven: Yale University Press, 1989) 134-35; O. Hofius,
"Gesetz and Evangelium nach 2. Korinther 3," in Paulusstudien (WUNT 51; Tubingen: Mohr,
1989) 96-99.
22
Badenas' comments (Christ the End, 75) on this text are quite murky so that it is difficult
to understand his interpretation.
 PAUL'S VIEW OF THE LAW 119

much into the word in this context. Linguistically, it is preferable to see

redundancy at work here. Paul uses the redundant expression "the end of
what is passing away" to drive home his point.23 What is particularly
instructive is to note that in 2 Cor 3:13 there is a prepositional construction
(ei]j to> te<loj). In every other passage in the NT where there is a preposition
before the word te<loj, it never means "goal" or even "outcome" or "re-
sult." In fact, in seven of these texts the temporal meaning is clearly
present.24 The temporal meaning is quite possibly present in four other
texts with a prepositional phrase,25 and once again the meaning "goal" is
not possible in these texts. The prepositional phrase ei]j to> te<loj in 2 Cor
3:13, therefore, most probably means "to the end."
The above discussion does not prove that te<loj refers to a temporal end
in Rom 10:4, but it does show that the theory that it often means "goal"
in Paul cannot be sustained. In fact, the meaning "goal" is indisputably
present in only one text in the Pauline corpus (1 Tim 1:5), while the tem-
poral meaning is quite common.26 Both interpretations are possible given
the use of the word, but the way Paul usually utilizes the term causes one
to expect the meaning "end."27 Thus, the meaning "end" seems preferable
linguistically to "goal" unless there are compelling contextual reasons for
preferring "goal."28 I will try to show later that such contextual reasons are
not present.
It is also argued by some that the racing imagery of Rom 9:30-33 suggests
that "goal" is the most appropriate translation of te<loj.29 Belief in Christ
23
For some helpful comments on redundancy see M. Silva, Biblical Words and Their Meaning:
An Introduction to Lexical Semantics (Grand Rapids: Zondervan, 1983) 153-55.
24
Matt 10:22; 24:13; Mark 13:13; 1 Cor 1:8; Heb 3:14; 6:11; Rev 2:26.
25
Luke 18:5; John 13:1; 2 Cor 1:13; 1 Thess 2:16. The use of the preposition with the plural
te<lh (1 Cor 10:11) is not included here since the meaning of the word in the singular is what
is being investigated.
26
I have already presented evidence which shows that in prepositional phrases the tem-
poral meaning predominates. The temporal meaning for te<loj is also clearly present in
contexts in which it is not the object of the preposition. Cf. Matt 24:6, 14; Mark 3:26; 13:7;
Luke 1:33; 21:9; 1 Cor 15:24; Heb 7:3; 1 Pet 4:7; Rev 21:6; 22:13. A temporal meaning is
probably present in Matt 26:58. On the other hand, the only NT texts besides 1 Tim 1:5 which
could mean "goal"—as I read the evidence—are 1 Pet 1:9 and Luke 22:37.
27
Hofius ("2. Korinther 3," 110--11) shows that Badenas' observations on the grammatical
character of Rom 10:4 are not accurate. In particular, Badenas thinks he has found exact
parallels between Rom 10:4 and other texts in the NT and Greek literature. Hofius points out
that he fails to see that te<loj in Rom 10:4 is a predicate nominative, while in these other
texts—which he sees as grammatically parallel— te<loj; is a subject nominative.
28
The arguments against te<loj meaning "goal" also apply to those who see te<loj as
referring to "summation," "completion," or "fulfillment" here. For this latter interpretation
see K. Barth, Church Dogmatics 2/2 (Edinburgh: T. & T Clark, 1957) 244-45; P. von der
Osten-Sacken, Romer 8 als Beispiel paulinischer Soteriologie (FRLANT 112; Gottingen:
Vandenhoeck & Ruprecht, 1975) 254-55. Badenas (Christ the End, 36-37) also points out the
weaknesses of te<loj meaning "summation," "completion," or "fulfillment."
29
Badenas, Christ the End, 114-15; Gaston, "The Inclusion of Gentiles," 130; Fluckiger,
"Christus des Gesetzes te<loj," 154; Campbell, "Romans 10:4," 76.
120 WESTMINSTER THEOLOGICAL JOURNAL

is the appropriate goal, say these scholars, of pursuing the law in faith. This
suggestion is flawed because it ignores the immediate context of 10:4, and
jumps back to 9:30-33. In 10:1-3 Paul has ceased to use the racing imagery
of 9:30-33 where he speaks of Israel pursuing righteousness, and thus it is
inappropriate to import that imagery from 9:30-33 into the specific context
of 10:1-4.30
Final arguments put forward in favor of "goal" are the larger context of
Romans 9-11 and the general Pauline theology of law.31 In this regard it is
said by these scholars that the very thesis of Romans 9-11 is found in 9:6
where Paul says that God's word has not failed with respect to Israel. How
could Paul say this if he were asserting that Christ is the end of the law?
Moreover, Paul's overall view of the law is one that suggests continuity be-
tween law and gospel, not contrast.32
Even though we agree with the general thesis of the above statements,
these are not telling arguments for the meaning "goal" in Rom 10:4. Both
of these arguments appear to be directed against those who see an absolute
discontinuity between the law and gospel.33 But Rom. 10:4, if te<loj is
translated as "end," need not, and as we shall argue below, should not be
construed as a global and overarching statement on the relationship be-
tween gospel and law. In other words, one can still translate te<loj as "end"
in this specific context and hold to a positive view of the law in Paul. Thus,
the general theological objections posed by those who espouse the trans-
lation "goal" are not decisive.

7. Christ Is the End and Goal of the Law

Others think that both options are a possibility here, arguing that "goal"
and "end" combined together communicate the meaning of te<loj in Rom
10:4.34 Such a solution is unlikely, for there is no other text in Paul in which
te<loj; combines the meanings "end" and "goal." Heikki Raisanen suggests
that this solution is due to the inability of the interpreter to determine
30
So also Raisanen, Paul and the Law, 54.
31
Cf. here Badenas, Christ the End, 117-18.
32
On this point see Fuller, Gospel and Law.
33
It should be said that there is some discontinuity between the old era and new era in Paul
(cf. Gal 3:15-4:7; 2 Cor 3:4-18).
34
E.g., M. A. Seifrid, "Paul's Approach to the Old Testament in Romans 10:6-8," TrinJ
6 (1985) 7-8; E. J. Schnabel, Law and Wisdom from Ben Sira to Paul: A Tradition Historical
Enquiry into the Relation of Law, Wisdom and Ethics (WUNT 2.16; Tubingen: Mohr, 1985) 91;
F. J. Leenhardt, The Epistle to the Romans (London: Lutterworth, 1961) 266; U. Wilckens, Der
Brief an die Romer (EKKNT; Neukirchen: Neukirchener Verlag, 1978-82) 3.222-23; A. J.
Bandstra, The Law and the Elements of the World: An Exegetical Study in Aspects of Paul's
Teaching (Grand Rapids: Eerdmans, 1964) 105-6; Ladd, Theology, 502-3; F. F Bruce, The
Epistle
of Paul to the Romans (TNTC; Grand Rapids: Eerdmans, 1963) 203; J. C. Beker, Paul the
Apostle: The Triumph of God in Life and Thought (Philadelphia: Fortress, 1980) 91, 106-7; C. K.
Barrett, A Commentary on the Epistle to the Romans (HNTC; New York: Harper & Row, 1957)
197-98.
 PAUL'S VIEW OF THE LAW 121

which meaning is most convincing.35 As noted previously the weight of the

lexical evidence favors a temporal idea, and the comparative rarity of the
meaning "goal" weakens this interpretation.

8. Ceasing to Use the Law to Establish One's Righteousness

I would like to suggest that Paul is speaking experientially in this text, so

that his point is that Christ is the end of using the law to establish one's own
righteousness.36 Those who believe in Christ cease using the law as a means
of establishing their own righteousness, for believers see that righteousness
comes through believing in Christ, and it cannot be attained by obeying the
law.
The logical relationship between vv. 3-4 is the primary support for this
view. The assertion that "Christ is the end of the law" is not merely an
abstract theological proposition which Paul suddenly inserts into the dis-
cussion. Instead, a ga<r joins 10:3-4, indicating that v. 4 is intimately wed-
ded to v. 3. One of the crucial issues, then, is how the relationship between
vv. 3 and 4 should be explained.
Before the connection between the two verses can be adequately ex-
plained, a word needs to be said about v. 3 itself. "The Jews did not subject
themselves to the righteousness of God, being ignorant about the right-
eousness of God and seeking to establish their own." I have argued else-
where that the fault of the Jews in v. 3 cannot be limited to nationalistic
righteousness, as if Paul were saying that the sole problem of the Jews is that
they excluded the Gentiles from participation in covenantal blessing.37 The
main proposition in v. 3 is that the Jews "have not subjected themselves to
the righteousness of God." I understand this to mean that the Jews have not
submitted themselves to the divine activity of God by which he declares
those who trust in him to be righteous. The two participles (a]gnoou?ntej
and zhtou?ntej in v. 3 are causal, in that they explain why the Jews did not
submit themselves to the saving righteousness of God. The reasons given are
because they were ignorant of God's righteousness and because they were
trying to establish their own righteousness. Now these two reasons should
35
Paul and the Law, 53.
36
Longenecker, Apostle of Liberty, 152-53; S. K. Williams, "The ‘Righteousness of God’ in
Romans," JBL 99 (1980) 284; H. Hubner, Law in Paul's Thought (Edinburgh: T. & T. Clark,
1984) 138; R. Bultmann, "Christ the End of the Law," in Essays Philosophical and Theological
(London: SCM, 1955) 36-66, esp. p. 54; L. Morris, The Epistle to the Romans (Grand Rapids:
Eerdmans, 1988) 380-81; J. Murray, The Epistle to the Romans (NICNT; Grand Rapids: Eerd-
mans, 1959-65) 49-50; U. Luz, Das Geschichtsverstandnis des Paulus (BEvT 49; Munich:
Kaiser, 1968) 139-45, 156-58; Nygren, Romans, 389; W. Gutbrod, "no<moj," TDNT 4.1075. A
similar view is held by Martin (Christ and the Law, 144). He says that Christ is the end of the
enslavement, condemnation, and death which the law brings. It should be said here that
agreement with Bultmann's position on this specific text does not necessitate an existentialist
interpretation of Paul.
37
See n. 12 above.
122 WESTMINSTER THEOLOGICAL JOURNAL

not be sharply distinguished since those who are ignorant of God's saving
righteousness, the gift of his grace, and his glory will inevitably try to
establish their own righteousness and godliness as a way to merit his
approval.38
I conclude that Paul is countering here a form of works-righteousness in
which the Jews thought that they could attain right standing with God by
their works. This is the most natural way of understanding the statement
that "they were seeking to establish their own righteousness." A parallel
verse in the near context, Rom 9:32, informs the reader that Israel failed to
attain righteousness via the law because they sought to attain righteousness
"as from works" instead of by faith. Since e@rga in Paul refers to "works"
in a general sense and cannot with warrant be limited to only part of the
law, and since there is no mention of matters like circumcision, food laws,
or Sabbath in the context, it is fair to conclude that Paul is saying that some
Jews thought they could obtain righteousness by doing what the law says.
This short excursus on the meaning of v. 3 brings us back to the impor-
tant question of the relationship between the two verses. Paul's charge
against the Jews in v. 3 is that they did not submit themselves to God's
saving righteousness because they were seeking to establish their own
righteousness. What is the connection when Paul then says, "For Christ is the end
of the law with reference to righteousness for everyone who believes"? Sam
Williams rightly observes that there is an implied proposition linking vv.
3-4.39 The implied proposition, says Williams, is that the Jews were wrong
in not subjecting themselves to God's righteousness. Another possibility is
that the implied proposition is that those who have believed in Christ have
submitted to God's righteousness. Which of these two is correct is not that
crucial since in either case it is clear in the context that the Jews should have
submitted to God's righteousness, and this submission would be expressed
by believing in Christ. Verse 4 then provides the reason why the Jews should
have subjected themselves to God's righteousness, viz., that Christ brings
to an end the attempt to establish one's own righteousness. The close con-
nection between vv. 3-4 demonstrates that Paul is not making some global
theological statement on the relationship between gospel and law in v. 4.
He is responding to the specific problem raised in v. 3 of people wrongly
using the law to establish their own righteousness. In v. 4 Paul points out
that those who believe in Christ cease using the law as a means of estab-
lishing their own righteousness.
Such an interpretation understands ei]j as an adverbial preposition of
general reference, not as introducing a result or purpose clause.40 Mark
Seifrid's grammatical analysis shows that sic in such constructions often
signifies result, but even his study shows that there are exceptions, and thus
38
Cf. Cranfield, Romans 2.515.
39
Williams, "The Righteousness of God," 283-84.
40
So Longenecker, Apostle of Liberty, 152-53.
 PAUL'S VIEW OF THE LAW 123
the key issue here is the existing context.41 The whole focus of the context
is on Jews who wrongly use the law to establish their own righteousness.
Verse 4 makes an experiential statement regarding this state of affairs which
we paraphrase as follows: Christ is the end of using the law to establish one's
own righteousness for those who believe.
Some lodge a complaint against the exegesis we suggest on the grounds
that ei]j dikaiosu<nhn is closer to Xristo<j than it is to te<loj ga>r no<mou.42
But the latter phrase is moved up front for emphasis, and Seifrid rightly
argues that ei]j dikaiosu<nhn is not related to all that precedes but only to
the predicate nominative te<loj no<mou.43
The words panti> t&? pisteu<onti support the idea that Paul is not making
a global statement on the relationship between gospel and law. Christ is not
the end of using the law for righteousness for all people. Verse 3 demon-
strates that some Jews wrongly try to use the law for their own righteous-
ness. Thus, v. 4 only claims that those who believe, who trust in Christ for
their righteousness, cease trying to use the law to establish their own
righteousness.
Verses 5-8 provide a ground for v. 4 as the ga<r in v. 5 indicates.44 But
how do vv. 5-8 function as a ground for v. 4? I understand v. 5 as follows:
The one who performs the righteousness of the law will live if he observes
it. Implied in this verse is the idea that no one can keep the law, and thus
righteousness is not available through the attempt to keep the law. Vv. 6-8
teach that Christ has done what is impossible for people to accomplish.
Righteousness does not come by doing the law, for no one can perform it
perfectly; righteousness comes by trusting in Christ. Thus, vv. 5-8 ground
v. 4 in that they confirm that believing in Christ brings to an end any
attempt to gain righteousness by the law. Verse 5 plays an important role
in that it shows that the attempt to gain righteousness by law is futile since
no one can obey what the law demands.
Before summarizing where we have gone, a false conclusion which could
be drawn from v. 4 should be addressed. Paul is not suggesting here that
before Christ came every Jew used the law to establish his or her own
righteousness, but now that he has come one should be saved by trusting
Christ. Paul explicitly teaches that Abraham (Rom 4:1-5; Gal 3:6-9) and
David (Rom 4:6-8) were saved by faith and not by works. We think Paul
mentions Christ in v. 4 because now that the fullness of time has come (Gal
4:4) the specific way in which one manifests reliance upon God and his
promises is by trusting the God who sent his Son to atone for sins (cf. Rom
3:21-26).
41
Seifrid, "Romans 10:6-8," 9 n. 29.
42
Cranfield, Romans, 2:519-20 n. 2; E. P. Sanders, Paul, the Law, and the Jewish People
(Philadelphia: Fortress, 1983) 61 n. 114; Badenas, Christ the End, 116.
43
Seifrid, "Romans 10:6-8," 9 n. 30. In light of Seifrid's study Raisanen's contention (Paul
and the Law, 55 n. 59) that such an understanding is linguistically impossible is unconvincing.
44
So also Rhyne, Faith Establishes, 111; A. Lindemann, "Die Gerechtigkeit aus dem Gesetz:
Erwagungen zur Auslegung and zur Textgeschichte von Romer 10:5," ZNW 73 (1982) 239.
124 WESTMINSTER THEOLOGICAL JOURNAL

In summary, it seems to me that the main problem with most interpre-

tations of Rom 10:4 is that scholars are trying to support their whole under-
standing of the relationship between the law and the gospel on the basis of
this text. Accordingly, great battles are fought over whether Christ is the
goal or end of the law. The issues in this theological dispute are utterly
crucial, and they need further discussion. But my thesis in this article is that
Paul has something more modest in view in Rom 10:4. The particular
problem he is countering is the human tendency to misuse the law to
establish one's own righteousness. The purpose of the text is not to provide
a programmatic statement on the relationship between gospel and law
Paul is responding to a specific problem, the use of the law to establish one's
own righteousness. It is not surprising, then, that Rom 10:4 would contain
an experiential statement, for Paul is reacting to an experiential problem.
Such an attempt to establish one's own righteousness is of great conse-
quence for Paul since those who do so have failed to submit themselves to
God's saving righteousness. They should have submitted to God's righteous-
ness since belief in Christ is the end of using the law to establish one's own
righteousness for all who believe. Paul is not, therefore, giving a weighty
theological pronouncement here on the relationship between the Testa-
ments. He is simply saying that those who believe in Christ will no longer
use the law to establish their own righteousness. They have submitted
themselves to the righteousness of God by trusting Christ for their salvation
(cf. Rom 10:6-8).
III. The Interpretation of Rom 10:5
We have gotten ahead of ourselves since the interpretation of v. 5 is itself
quite controversial.45 The interpretation of v. 4 is coupled with one's inter-
pretation of v. 5. We shall analyze and critique three major interpretations,
and then defend our own.

1. Radical Discontinuity between Law and Gospel

Most scholars see a marked contrast between v. 5 and vv. 6-8, although
there are still debates regarding what v. 5 is specifically saying. Some claim
that the only point in v. 5 is that no one can obey the law sufficiently,46 while
others argue that Paul is only critiquing legalism.47 We should examine
45
The varying textual readings in 10:5 are quite complicated. For a defense of the reading
in Nestle-Aland26 see Lindemann, "Romer 10:5," 231-37; B. M. Metzger, TCGNT 524-25.
46 So, e.g., Martin, Christ and the Law, 137; Westerholm, Israel's Law, 129; F. Thielman, From
Plight to Solution: A Jewish Framework for Understanding Paul's View of the Law in Galatians
andRomans (NovTSup 61; Leiden: Brill, 1989) 113-14; van Dulmen, Die Theologie des
Gesetzes, 127.
47
E.g., Rhyne, Faith Establishes, 104-6; id., "Romans 10:4," 494-95; Kasemann, Romans:
285; Schmithals, Romerbrief, 371-72; G. Klein, "Sundenverstandnis and theologia crucis bei
Paulus," in Theologia Crucis—Signum Crucis: Festschrift fur Erich Dinkier zum 70. Geburtstag
(ed.
 PAUL'S VIEW OF THE LAW 125

briefly the arguments of those who see Paul as only opposing legalism in this
text, for such a tradition of interpretation has been enormously influential,
especially in Lutheran circles. It is asserted that the very attempt to gain
salvation by law is sinful whether it can be obeyed or not. Walter Schmi-
thals represents this view when he says that Paul rejects law righteousness
"weil der Versuch, aus dem Gesetz zu leben, als solcher fluchwurdig ist." 48
Some scholars also perceive a radical discontinuity between the "spirit"
and the "letter" in vv. 5-8. They assert that Paul in this context uses the
OT texts cited in vv. 6-8 against the OT text quoted in v. 5, for part of the
OT consists of "letter," while other portions are informed by the "spirit."49
The "letter," according to this view, is found in the citation of Lev 18:5 in
10:5, while the "spirit" is revealed in the citations in vv. 6-8. Such a
distinction between the "letter" and the "spirit" is supported respectively
by the use of gra<fei in v. 5 and le<gei in vv. 6-8.
Contrary to the above interpretation Paul does not say that anyone who
performs the law will die. Instead, v. 5 explicitly says that the person who
performs the law will live (o[ poih<saj au]ta> a@nqrwpoj zh<setai e]n au]toi?j)
by obeying it. There is no warrant for concluding that doing the law leads to
death when Paul says precisely the opposite, viz., that doing the law leads
to life. Contrary to Schmithals, Paul's statement in v. 5 only makes sense
if it is assumed that no one can perfectly obey the law. The attempt to gain
righteousness by law is excluded precisely because no one has the ability to
put into effect what the law demands. Schmithals is correct in claiming that
Paul is opposing an attempt to be righteous by works in this text. But the
reason Paul sees this attempt as folly is because sinners can never obey the
law perfectly and thus are fools if they think they can put God in their debt
by their good works.
To see a distinction between "letter" and "spirit" on the basis of gra<fei
and le<gei in vv. 5-8 is also unwarranted.50 This can be shown from Romans
9-11 alone. He uses the verb gra<fw in five other texts (Rom 9:13, 33; 10:15;
11:8, 26) in order to introduce OT citations. In all of these texts the OT is
cited to confirm an argument that Paul has just made. There is no indi-
cation at all that he considers such OT citations to be "letter" rather than
"spirit." Moreover, the noun grafh< is employed in three passages (Rom
9:17; 10:11; 11:2) to introduce three OT texts. Once again it is clear that
Paul is using these texts in support of his argument. We can conclude
C. Andresen and G. Klein; Tubingen: Mohr, 1979) 279-80; Lindemann, "Romer 10:5,"
243-46; Schlier, Romerbrief, 311; Schmidt, Romer, 175.
48
Schmithals, Romerbrief, 371. See also other scholars listed to the previous note.
49
So Kasemann, Romans, 286; Schmithals, Romerbrief 375; Klein, "Sundenverstandnis,"
279; Schlier, Romerbrief, 311; Michel, Romer, 256.
50
So Lindemann, Romer 10:5," 240; Badenas, Christ the End, 122-24; Toews, The Law in
Romans, 256-57; Wilckens, Romer 3.226; Refoule, "Romains X,4," 330.
126 WESTMINSTER THEOLOGICAL JOURNAL

therefore that there is no evidence from the introductory formulas used in

Romans 9-11 that Paul is distinguishing between "letter" and "spirit"
when citing the OT.51

2. Jesus Christ Is the Obedient One

Some scholars, who see Paul as saying that Christ is the goal of the law
in v. 4, understand v. 5 as referring to the perfect obedience of Jesus
Christ.52 He is the a@nqrwpoj in v. 5 who has performed all that the law
says.53 The major difficulty with this interpretation is that it is hard to see
in the generalizing noun a@nqrwpoj a specific reference to Jesus Christ.54
Andrew Bandstra's attempt to locate a parallel in Phil 2:7-11 seems par-
ticularly strained,55 for the two passages are in remarkably different con-
texts, and the passages differ significantly with respect to the words used.
Bandstra's decision to focus on Phil 2:7-11 as a parallel text is all the more
surprising since a much closer parallel in wording and theme is evident
between Rom 10:5 and Phil 3:9, and this latter parallel would yield quite
a different interpretation as we shall see.

3. The Obedience of Faith

Other scholars who see Christ as the goal of the law in v. 4 maintain that
v. 5 is referring to an obedience of the law which springs from faith.56 The
doing of the law in v. 5, then, is not a works-righteousness, but it is the result
of trusting in God. In this interpretation there is no contrast between v. 5
51
For the OT citations which are introduced with le<gw see Rom 9:15, 17, 25; 10:6, 8, 11,
16, 19, 20, 21; 11:2, 4, 9.
52
Barth, Church Dogmatics 2/2.245; Cranfield, Romans 2.521-22; Reicke, "Paulus uber das
Gesetz," 249-50; Bandstra, Elements of the World, 104; Campbell, "Romans 10:4," 77-78; R.
Bring, Christus and das Gesetz: Die Bedeutung des Gesetzes des alten Testaments each Paulus
and sein Glauben an Luther (Leiden: Brill, 1969) 36, 44-55; id., "Paul and the Old Testament,"
49-50.
53
For this significance of a@nqrwpoj see Bandstra (Elements of the World, 104). Reicke ("Paul-
us uber das Gesetz," 250) sees support for this in the aorist participle poih<saj signifying once
for all action. He reads too much significance into the aorist participle, which is used to
designate undefined action. For a careful analysis of the aorist tense see F. Stagg, "The Abused
Aorist," JBL 91 (1972) 222-31.
54
It is interesting to note, therefore, that some scholars think a@nqrwpoj is used to stress the
inclusion of all people, both Jew and Gentile (so Howard, "Romans 10:4," 334; Toews, The
Law in Romans, 269, 283; Badenas, Christ the End, 121; Davies, Faith and Obedience, 198).
This later view also seems to be an overinterpretation. The term a@nqrwpoj is a generalizing
noun which refers to all people, but there is no particular emphasis on the inclusion of the
Gentiles in the use of the word in this context.
55
Bandstra, The Elements of the World, 103-4. Against the link with Phil 2:7-11 see Refoule,
"Romains X,4," 345; Seifrid, "Romans 10:6-8," 14.
56
Fuller, Gospel and Law, 85-88; Gaston, "The Inclusion of Gentiles," 130; Howard, "Ro-
mans 10:4," 335-37; Badenas, Christ the End, 118-25; Kaiser, "Leviticus 18:5 and Paul," 27;
Toews, The Law in Romans, 243-83; Davies, Faith and Obedience, 189-200.
 PAUL'S VIEW OF THE LAW 127

and vv. 6-8; both texts speak of the obedience that comes from faith. The
following arguments are presented to support such an interpretation.
The conjunction de< in v. 6 is usually translated adversatively as "but."
Those who defend the theory that there is continuity between vv. 5-6 claim
that such a translation is unwarranted. The conjunction de< often means
"and," and the context, it is claimed, favors this latter interpretation.57
Thus, v. 5 and vv. 6-8 do not refer to two different ways of righteousness
but one way of righteousness, for the obedience that springs from faith (vv.
6-8) naturally leads to a doing of the law (v. 5).
Verse 5 cannot stand in contrast with vv. 6-8, according to those who
defend this interpretation, because Paul would never use the OT against
itself.58 That is, in v. 5 Lev 18:5 is cited, and in vv. 6-8 Paul alludes to Deut
9:4; 30:12-14 (and perhaps Ps 107:26). We can assume, these scholars af-
firm, that Paul wanted to convince the Jews of the credibility of his stance
regarding the OT law. But if Paul uses the OT texts alluded to in vv. 6-8
against the citation of the OT in v. 5, then no Jew would be persuaded of
his argument, for the Jews believed that there was a fundamental harmony
in OT Scripture. No argument which pitted OT scripture against OT
scripture would carry the day with Jews who valued the OT. Moreover,
Paul himself regularly appeals to the OT as authoritative, and thus it is
difficult to conceive of him as denigrating part of OT revelation.
Those who see a harmony between the doing of the law and the righteous-
ness of faith argue that the OT contexts of the two texts are quite similar.
Lev 18:5 does not teach that Israel should obey the law in order to earn
salvation.59 Instead, as with the rest of the OT, this verse teaches that obe-
dience to the law would be the expression, the intended result of God's
saving work. The obedience demanded here refers to maintaining life in the
covenant, not acquiring life by good works. And since sacrifice could be
offered for sins committed, there is no thought in Leviticus of obeying the
law perfectly in order to gain salvation. Furthermore, an analysis of Deut
30:12-14 makes it clear that Moses speaks of doing the law. Deut 30:12-14
says three times that the law should be observed. These scholars conclude,
then, that the obedience of Lev 18:5 cannot be separated from the obedi-
ence of Deut 30:12-14.60 Both describe the obedience that springs from
faith. There is no contrast between the two texts in the OT nor in Paul.
57
Fuller, Gospel and Law, 67; Badenas, Christ the End, 123; Toews, The Law in Romans, 252-
53; Davies, Faith and Obedience, 190-91; Fluckiger, "Christus des Gesetzes te<loj," 155.
58
Fuller, Gospel and Law, 67-69; Badenas, Christ the End, 123; Davies, Faith and Obedience,
194; Fluckiger, "Christus des Gesetzes te<loj," 155. Badenas (121) and Toews (The Law in
Romans, 244-45) ask how the Jews could be wrong in pursuing righteousness by works if that is
what the law in fact teaches.
59
So Kaiser, "Leviticus 18:5 and Paul," 19-28; Howard, "Romans 10:4," 334; Toews, The
Law in Romans, 244-45, 253, 264-70; Davies, Faith and Obedience, 192-93.
60
Fuller, Gospel and Law, 85-86.
128 WESTMINSTER THEOLOGICAL JOURNAL

4. The Nature of the Contrast between Rom 10:4-5

Despite some impressive arguments for continuity between Rom 10:5 and
10:6-8, it is much more likely that the relationship between these verses is
adversative rather than continuative. In the course of arguing for the view
that there is a contrast between v. 5 and vv. 6-8 I shall respond to the
arguments given in support of continuity between v. 5 and vv. 6-8.
Those who opt for continuity between v. 5 and vv. 6-8 rightly remark
that de< can be adversative or continuative. An exegetical judgment must be
made on the basis of the immediate context rather than the use of this
conjunction. The following arguments indicate that the context supports an
adversative relationship between 10:5 and 10:6-8.
The doing of the commandments of the law in Rom 10:5 (o[ poih<saj
au]ta<) is equivalent to the establishing of one's own righteousness in 10:3. In
both verses Paul counters the idea that one can obtain righteousness
through works. The parallel between vv. 3 and 5 is strengthened by the
particular wording employed. Verse 3 says the Jews "did not subject them-
selves to the righteousness of God" because they "were ignorant of the
righteousness of God." The genitive qeou? which is used twice with the word
dikaiosu<nh in v. 3 is a genitive of source. It is a righteousness which comes
from God as a gift. In v. 5 the righteousness is not from God. It is "righ-
teousness which is from the law" (th>n dikaiosu<nhn th>n e]k tou? no<mou), and
it is based on "doing" (o[ poih<saj). The link between vv. 3 and 5 is as
follows: because the Jews did not know that righteousness was God's gift (v.
3), they tried to gain their own righteousness based on keeping the law (v. 5).
In order to sunder the connection between vv. 3 and 5, it is claimed that
the verses are not parallel because the word no<moj is lacking in v. 3.61 This
objection is hardly persuasive, for the righteousness which the Jews tried to
establish (10:3) was based on the law. Rom 9:31-32 demonstrates that Israel
tried to attain righteousness by pursuing the law with a works mentality.
The pursuit of the law "as from works" is synonymous with "seeking to
establish their own righteousness" in Rom 10:3.62 The connection between
vv. 3 and 4 also shows that the attempt to establish one's own righteousness
in v. 3 is related to the law. The verses are connected with a ga<r, and v. 4
says that "Christ is the end of the law with reference to righteousness for
everyone who believes." Whatever one makes of the specific meaning of v.
4, the correlation between "law'' and "righteousness" in the verse shows
that the attempt to establish one's own righteousness in v. 3 is based on
the law.
The argument presented above regarding the connection between Rom
10:3-4 can be expanded further. Even if we accept for the sake of argument
the meaning "goal" for te<loj in 10:4, there is still the implication that the
61
Davies, Faith and Obedience, 195-96.
62
Fuller (Gospel and Law, 71-79), who does not agree with our interpretation of Rom 10:5-8,
nevertheless rightly sees the parallel between Rom 9:31-32 and 10:3.
 PAUL'S VIEW OF THE LAW 129

false righteousness of the Jews in 10:3 is based on the law. Let me explain
how this is so. Verse 3 says that the Jews did not submit themselves to God's
righteousness because they tried to establish their own. Verse 4 provides the
reason why (ga<r) they should have submitted themselves to God's righteous-
ness. Let us assume that Paul is saying that they should have submitted to
God's righteousness and forsaken their own because Christ is the "goal" of
the law. The connection between vv. 3-4, then, would indicate that the
Jews tried to pursue their own righteousness because they misread the true
goal or intention of the law. But if they failed to obtain righteousness be-
cause they did not see the goal of the law, then it follows that their own
righteousness in 10:3 was based on a misunderstanding of the law. My point,
then, is that even if we accept the view that te<loj means "goal" in v. 4,
the false righteousness of the Jews in v. 3 is still based on the law. It follows,
therefore, that both v. 3 and v. 5 describe righteousness by law, and if v. 3
refers to works-righteousness, then so does v. 5.
An adversative relationship between vv. 5 and 6-8 is also supported by
the antithesis between doing and believing which permeates the text in Rom
9:30-10:13. Israel did not attain righteousness through the law because it
was pursued "as from works" (9:32). Israel had a zeal for God (10:2) which
was manifested in the establishment of their own righteousness (10:3).
These texts seem parallel to the idea of gaining righteousness by doing
(10:5). But Paul stresses again and again in this text that the way to obtain
righteousness is not by doing but by believing (Rom 9:30, 32-33; 10:4, 6, 8,
9, 10, 11). Nowhere in this context does Paul speak of a doing of the law
which stems from faith, although he does speak positively of obeying the law
elsewhere (Rom 8:4; 13:8-10; cf. Gal 5:14). To see a fulfillment of the law
which is grounded in faith in 10:5 sits awkwardly in the context of Rom
9:30-10:8, for the remaining verses posit an antithesis between doing and
believing.
The close parallel between Phil 3:9 (mh> e@xwn e]mh>n dikaiosu<nhn
th>n e]k
no<mou a]lla> th>n dia> pi<stewj) and Rom 10:5 (th>n dikaiosu<nhn th>n e]k
tou?
no<mou) is powerful evidence supporting the idea that Rom 10:5 describes
works-righteousness.63 The wording of the two texts is almost exactly the
same (dikaiosu<nhn th>n e]k no<mou, Phil 3:9; th>n dikaiosu<nhn th>n e]k
no<mou, Rom 10:5). All scholars agree that Phil 3:9 speaks negatively of
"righteousness from law." It is extremely unlikely that the same phrase in
Rom 10:5 is being used positively. This interpretation is strengthened by the
fact that in both Phil 3:2-11 and Rom 9:30-10:8 Paul is responding to
Jewish opponents who insisted that Gentiles must observe the OT law to be
saved.64 The subject under discussion in Philippians 3 and Romans 10 is,
therefore, the same. Paul contends that faith in Christ is what is necessary
63
So also Rhyne, Faith Establishes, 105; Lindemann, "Romer 10:5," 239 n. 29.
64
For a defense of the view that the opponents in Philippians 3 were Judaizers see P. T.
O'Brien, The Epistle to the Philippians (NIGTC; Grand Rapids: Eerdmans, 1991) 26-35.
130 WESTMINSTER THEOLOGICAL JOURNAL

for righteousness, not observance of the law. Since these two texts deal with
the same subject and possess almost identical wording, we conclude that
they do not bear radically different meanings. In both verses Paul is ex-
cluding righteousness by works and affirming faith in Christ as the way of
salvation.
It should also be emphasized that nowhere does Paul speak positively of
"righteousness which comes from the law" (th>n dikaiosu<nhn th>n e]k tou?
no<mou, Rom 10:5; cf. Phil 3:9). The point we are making here is that the
Greek formulation e]k tou? no<mou suggests that the law is the "source" of
righteousness. Paul, as we have noted previously, speaks positively else-
where of believers keeping the law. But nowhere does he ever say that
righteousness comes "from" the law.65 He insists again and again that
righteousness comes from God and is his gift. Thus, he uses the phrase
dikaiosu<nh qeou? (Rom 1:17; 3:5, 21, 22; Rom 10:32; 2 Cor 5:21; Phil 3:9)
as a genitive of source on numerous occasions to underscore the truth that
righteousness is a gift of God.66 Righteousness cannot come "from" the law
because the law incites people to sin (Rom 5:20; 7:5, 7-13). Those who see
Rom 10:5 as a positive description of keeping the law do not appreciate
sufficiently the differences between what Paul says in Rom 10:5 and other
texts in which he speaks affirmatively of keeping the law. The notion that
righteousness "comes from" the law is contrary to the heart of Pauline
theology.
The other correlation between Phil 3:9 and Rom 9:30-10:8--which
should not be missed—is the contrast between the righteousness which
comes from the law and the righteousness which is on the basis of faith.
Israel failed to attain righteousness because they did not seek it "by faith
but as from works" (Rom 9:32). Gentiles obtained "righteousness by faith"
(Rom 9:30; cf. 9:33). It is the one who "believes" (t&? pisteu<onti) who stops
using the law to establish his own righteousness (Rom 10:4). The "right-
eousness which comes from the law" (Rom 10:5) is contrasted with "the
righteousness by faith" (h[ e]k pi<stewj dikaiosu<nh, Rom 10:6). Phil 3:9
supports the claim that there is a contrast between the "righteousness
which comes from the law" and "righteousness by faith" in Rom 10:5-6.
In Philippians Paul goes a step beyond merely saying that his own "righteous-
ness" was not "from the law." He also affirms that he obtained the right-
eousness which is a gift from God on the basis of faith (th>n e]k qeou?
dikaiosu<nhn e]pi> t^? pi<stei). Phil 3:9, then, not only shares the same word-
ing as Rom 10:5 regarding "righteousness which is from the law." Paul also
65
Fuller (Gospel and Law, 86) and Davies (Faith and Obedience, 196-97) contend that Rom 10:5
should be distinguished from Phil 3:9 because the former passage does not speak of "one's own
righteousness" as the latter does. It is unwarranted, though, to demand that every element of
Phil 3:9 be reproduced in Rom 10:5.
66
The meaning of dikaiosu<nh in Paul is intensely debated, and the amount of literature
is enormous. The most satisfying solution has been suggested by D. Moo, Romans 1-8 (Wycliffe
Exegetical Commentary; Chicago: Moody, 1991) 65-70, 75-86.
 PAUL'S VIEW OF THE LAW 131

goes on to contrast his own righteousness with "the righteousness of God on

the basis of faith." Since Phil 3:9 and Rom 10:5-6 share the same wording
both regarding "righteousness from law" and "righteousness on the basis
of faith," we have good evidence that both texts should be interpreted
similarly. The parallel between Phil 3:9 and Rom 10:5 cannot be dis-
counted merely by saying that the former text is personal and autobio-
graphical, while the latter refers to a corporate reality.67 This observation
is correct, of course, but materially the texts still deal with the same issue.
Paul in Philippians 3 is using his previous experience as an example to
illustrate the false path into which the false teachers are trying to lure the
Philippians.68 Paul's personal experience was a corporate experience for the
opponents in Philippians! So too, what was a problem for Israel corporately
(Romans 9-10) plagued Paul personally (Philippians 3). The difference
between Romans 9-10 and Philippians 3 is that Paul is speaking of many
people in Romans who had the same problem which he formerly had
according to Philippians.
Neither is it compelling to say that in Rom 10:5 the word "law" is not
used to describe a false righteousness as it is in Philippians.69 It is already
clear from Rom 9:32 that the law if it is pursued "as from works" can be
misused so as to establish one's own righteousness. The Jews thought they
were righteous precisely because of their obedience to the law. This fits
nicely with Rom 10:5 where the one who does the law expects to gain
righteousness from the doing of the commandments. The object of the
participle poih<saj; in v. 5 is the word au]ta<, and au]ta< indisputably refers
to the commandments in the OT law. It follows, then, that even though the
word "law" is not specifically present in v. 5, the concept is materially
present, for it is the commandments of the law which people would "do."
Paul does not censure the actual doing of the commandments. What he
is suggesting is that no one keeps the law sufficiently. The reason he does not
elaborate on human inability to keep the law in v. 5 is that this is old ground
in Romans which has already been covered (1:18-3:20). What is astonish-
ing to Paul is that people who fail to obey the law still think they can gain
life by observing the commandments. Thus, Paul reminds the church that
perfect obedience, which is impossible, is needed to be right before God.
Supporting the idea that Paul is speaking negatively of works-
righteousness in Rom 10:5 is his citation of Lev 18:5 in Gal 3:12.70 Most
commentators concur that in Gal 3:12 Paul quotes Lev 18:5 to contrast the
law and faith.71 He says, "But the law is not of faith, but the one who does
67
Cf. C. Muller, Gottes Gerechtigkeit and Gottes Volk: Eine Untersuchung zu Romer 9-11
(FRLANT 86; Gottingen: Vandenhoeck & Ruprecht, 1964) 73-74.
68
Schmidt (Romer, 174) rightly observes that Paul once was what the Judaizers now are.
69
So Fuller, Gospel and Law, 86..
70
So Rhyne, Faith Establishes, 105.
71
For representative examples see H. D. Betz, Galatians (Hermeneia; Philadelphia: Fortress,
1979) 147-48; F F. Bruce, The Epistle to the Galatians (NIGTC; Grand Rapids: Eerdmans, 1982)
132 WESTMINSTER THEOLOGICAL JOURNAL

them [the commandments of the law] shall live by them." It is improbable

that Paul is using Lev 18:5 in a different way in Rom 10:5 and Gal 3:12, for
both texts treat the same theme, i.e., whether or not righteousness is avail-
able by the law. Gal 3:12 also contains the same contrast between the law
and faith which we are contending is present in Rom 10:5-6. The burden
of proof is clearly on those who think Paul cites Lev 18:5 in two completely
different ways.
Feeling the sting of this argument, a few scholars have suggested that
Paul describes the keeping of the law positively in Gal 3:12 as well.72 This
suggestion is completely improbable given the situation in the Galatian
churches and the structure of the argument in the letter. The Galatians
were under attack from opponents who insisted that they submit to circum-
cision to be part of the people of God (Gal 5:2-6; 6:12-13). The heart of the
letter (Gal 2:15-5:12) contains a response to these opponents. Paul labors
to prove that justification does not come by "works of law" (2:16; 3:2, 5, 10),
that the attempt to obtain righteousness by law leads to a curse (3:10), that
the law is not a source of life (3:21), and that people who are "under law"
are actually under the sway of sin (3:23, 25; 4:3, 8-10, 21-25). It is im-
plausible in the course of this argument that Paul would positively insert
the proposition that one who keeps the law will obtain life (Gal 3:12). Such
a statement would have played into the hands of the Judaizers, for it was
they who were demanding adherence to the law for salvation. I am not
denying that Paul affirms keeping the law at the end of Galatians (cf. 5:14),
but he only does this after he clears up the problems raised by the Judaizers.
Daniel Fuller agrees that Paul uses Lev 18:5 in a negative sense in Gal
3:12. He tries to defend the idea, however, that the OT citation has a
different meaning in Rom 10:5.73 In support of this he notes that no in-
troductory formula is employed in Gal 3:12, while in Rom 10:5 Paul in-
troduces the citation by saying "Moses writes." The reference to Moses
signals, says Fuller, that in Rom 10:5 Paul is citing Lev 18:5 in accord with
its intended meaning in its OT context. Fuller's stimulating proposal
should be rejected. Omitting the introductory formula in Gal 3:12 is no
indication that Paul is inserting the legalistic interpretation of the verse by
the Judaizers. There is no introductory formula in Gal 3:11 either, and yet
there is no doubt that Paul considers the OT citation from Hab 2:4 to be
authoritative. If anything the inclusion of Moses in Rom 10:5 betrays the
fact that there is a contrast between 10:5 and 10:6-8, for elsewhere Paul
contrasts the new age with the era of law inaugurated under Moses (2 Cor
163; E. DeW. Burton, A Critical and Exegetical Commentary on the Epistle to the Galatians
(ICC; Edinburgh: T. & T. Clark, 1921) 167; R. Y. K. Fung, The Epistle to the Galatians (NICNT;
Grand Rapids: Eerdmans, 1988) 145-46. The specific nature of the contrast will not be
investigated in detail here. See my "’Works of Law’ in Paul," NovT 33 (1991) 239-240.
72 Davies, Faith and Obedience, 196; Toews, The Law in Romans, 279-82; Bring, Christer und
Gesetz, 62; cf. also Cranfield, Romans 2.522 n. 2; Reicke, "Paulus uber das Gesetz," 250.
73
Fuller, Gospel and Law, 88, 98-99.
 PAUL'S VIEW OF THE LAW 133

3:4-18).74 In any case a decisive argument would be needed to defend the

idea that Paul uses Lev 18:5 differently in Gal 3:12 and Rom 10:5. The
similarity of subject matter and theme lead us to the conclusion that Paul
uses Lev 18:5 similarly in Gal 3:12 and Rom 10:5.A major objection to our
view is that such an interpretation means that Paul uses Lev 18:5 contrary
to the intended meaning of that text in the OT, and such a misuse of the
OT would never convince Paul's opponents.75 The best solution to this
difficult problem has been suggested by Moises Silva in an article which
examines Paul's use of Lev 18:5 in Gal 3:12.76 What Silva says about the use
of Lev 18:5 in Gal 3:12 also applies to Rom 10:5. It is not satisfying to
conclude that Paul is only citing the legalistic misinterpretation of Judaizers
in Rom 10:5, but his citation of the OT text is influenced by the scriptural
exegesis of his opponents. Paul's opponents believed that the law itself could
provide life; that it was the source of life. Thus, they pursued the law "as from
works," expecting to secure righteousness through their obedience. Right-
eousness here refers to right standing before God, and the Jewish mistake
was to think that they could establish their own righteousness, i.e., salva-
tion, by their obedience to the law (Rom 10:3). Paul explains in v. 4 that
those who believe in Christ cease using the law as a means of establishing
their own righteousness; they recognize that Christ is the source of life, not
the law. When Paul cites Lev 18:5 in Rom 10:5, his point is that no one can
attain righteousness or eternal life by obeying the law since no one can obey
sufficiently what the law demands.
What Paul is criticizing, then, in Rom 10:5 and indeed in the entire
context of Rom 9:30-10:8 is the attempt to gain right standing with God via
obedience of the law. He is rejecting the idea that the law is a possible source
of life or righteousness, even though the perfect keeping of the law would
bring such righteousness (cf. Gal 3:10-12; Rom 3:19-20). Thus, when Paul
cites Lev 18:5 in v. 5 his citation of that text is influenced by his Jewish
opponents who put forward the verse in order to argue that the law is the
source of righteousness. Paul does not flatly state that their interpretation
is incorrect by explaining Lev 18:5 in context. Instead, he counters their
interpretation by citing Deut 30:12-14.77 Silva notes it is uncommon for NT
74
This point, however, should not be pressed since Paul clearly cites words of Moses as
authoritative elsewhere (Rom 10:19; 1 Cor 9:9). So Seifrid, "Romans 10:6-8," 13.
75
Murray (Romans 2.51) argues that Paul does not use Lev 18:5 in accord with its intended
meaning, but the text is lifted out of context because it aptly describes legalism.
76
M. Silva, "Is the Law Against the Promises? The Significance of Galatians 3:21 for
Covenant Continuity," in Theonomy: A Reformed Critique (ed. W. S. Barker and W. R. Godfrey;
Grand Rapids: Zondervan, 1990) 153-67, esp. 163-66.
77
Of course, Paul's citation of Deut 30:12-14; 9:4 and Ps 107:26 is controversial. For some
insightful comments on the OT texts cited see Thielman, From Plight to Solution, 113-14. There
is a diversity of opinion among scholars regarding the use of the OT texts here. Paul's use of
the OT is seen as arbitrary (C. H. Dodd, The Epistle of Paul to the Romans [MNTC; London:
Hodder & Stoughton, 1932] 166; Schmidt, Romer, 176; M. Black, "The Christological Use of
the Old Testament in the New Testament," NTS 18 [1981] 8-9; Rhyne, "Romans 10:4," 496),
134 WESTMINSTER THEOLOGICAL JOURNAL

writers to call into question the interpretation of opponents by setting forth

an opposing contextual argument of the text in question.78 He goes on to
say, “Jewish literature contemporary to the New Testament shows a similar
hesitation to score points by refuting the opponent's use of Scripture. And
the later rabbinic scholars, as a rule, refuted an argument based on Scrip-
ture by counteracting with a different passage, not by demonstrating faulty
hermeneutics.”79 In other words, Paul cites the OT in Rom 10:6-8 to show
that obeying the law is not the means of obtaining righteousness; rather
Christ has accomplished all that is needed for salvation. The appropriate
human response is a humble faith which accepts what God has done in
Christ.
The interpretation we are proposing does not deny that Paul could use
Lev 18:5 in another context as a way of describing life within the covenant
by the redeemed. What Paul objects to in Rom 9:30-10:8 is the use of the
law as the source of righteousness or life. This interpretation also explains
why the objection that perfect obedience to the law was unnecessary in the
OT is irrelevant.80 Atonement was provided for those within the covenant,
but Paul is opposing those who think they can gain entrance into the
covenant by good works. For those who try to establish their own right-
eousness the provision of sacrifices does not apply because on Paul's terms
they are not yet within the covenant. There are also statements made by
Paul (cf. Gal 2:21; 3:10-13; Rom 3:21-26) which imply that animal sac-
rifices no longer atone; only Christ's sacrifice is truly effective.
as a proverbial use of the wording of the OT so that there is not actually a citation (W. Sanday
and A. C. Headlam, A Critical and Exegetical Commentary on the Epistle to the Romans [ICC;
Edinburgh: T. & T. Clark, 1902] 289; Barrett, "Romans 9:30-10:21," 129; W. D. Davies, Paul
and Rabbinic Judaism: Some Rabbinic Elements in Pauline Theology [London: SPCK, 1948]
153-55; R. N. Longenecker, Biblical Exegesis in the Apostolic Period [Grand Rapids: Eerdmans,
1975] 114, 121-23), as dependent upon wisdom traditions (M. J. Suggs, "The Word is Near You:
Romans 10:6-10 within the Purpose of the Letter," in Christian History and Interpretation:
Studies Presented to John Knox [ed. W. R. Farmer, C. F. D. Moule, and R. R. Neibuhr;
Cambridge: Cambridge University Press, 1967] 299-11; Schnabel, Law and Wisdom, 247-49), as
dependent upon Targumic traditions (S. Lyonnet, "Saint Paul et 1'exegese juive de son temps. A
propos de Rom 10:6-8," in Melanges Bibliques redigees en l'honneur d'Andre Robert [Travaux de
1'Institute Catholique de Paris, IV; Paris: Boud & Gay, 1956] 494-506; M. McNamara, The New
Testament and the Palestinian Targum to the Pentateuch [AnBib 27; 2d printing, with
Supplement containing additions and corrections; Rome: Pontifical Biblical Institute, 1978] 73-
78). For a provocative analysis of the OT citations which argues that Paul appeals directly to the
OT text itself, and that none of the above answers is fully satisfactory, see Seifrid, "Romans 10:6-
8," 17-37. For an extended discussion of the text see also Toews, The Law in Romans, 284-315.
78
Silva, "Is the Law Against the Promises?" 165. For a similar interpretation in some
respects see H. N. Ridderbos, Paul: An Outline of His Theology (Grand Rapids: Eerdmans, 1975)
.155-56.
79
Silva, "Is the Law Against the Promises?" 165.
80
Cf., e.g., G. Howard, Crisis in Galatia: A Study in Early Christian Theology (SNTSMS 35;
Cambridge: Cambridge University Press, 1979) 53.
 PAUL'S VIEW OF THE LAW 135

IV. Conclusion

In conclusion, Rom 10:4 proclaims that Christ is the end of the law in the
sense that he is the end of using the law to establish one's own righteousness.
Thus, those interpreters are mistaken who maintain from this verse that
Christ is the absolute end of the law for the believer. But neither is Paul
asserting that Christ is the goal of the law. The purpose of Rom 10:4 is not
to provide some global statement on the relationship between the Testa-
ments! In the specific context Paul is simply asserting that those who put
their faith in Christ cease to use the law as a means of establishing their own
righteousness. The source of saving righteousness cannot come via law obe-
dience; faith in Christ is the only path to life.
Rom 10:5 fits with such an interpretation of Rom 10:4. Paul in Rom 10:5
is not speaking of the righteousness of Christ, nor is he describing the
obedience of faith. Neither is he suggesting that the very attempt to do the
law is blameworthy. Rather, Paul is saying that righteousness does not come
through the law because the law cannot be obeyed perfectly, and yet people
still vainly try to impress God with their works. The problem, then, is both
a legalism and a failure to obey.81 Paul points out both in Rom 9:32-33 and
10:6-8 that the way to salvation does not lie in doing the law; it is obtained
by believing in Christ. Vv. 6-8 make it plain that Christ has provided all
that is necessary for salvation, and thus the way to obtain salvation is by
believing the gospel which Paul preached.

81
Cf. on this point R. H. Gundry, "Grace, Works, and Staying Saved in Paul," Bib 66
(1985) 18-19; Leenhardt, Romans, 267-70.

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