Colossians 2:14: responding to “The Law of Moses was nailed to the cross of Christ.”

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POSTED 27 OCTOBER, 2017

Pastor: Colossians 2:14: The Law of Moses was nailed to the cross of Christ.

“[H]aving canceled out the certificate of debt consisting of decrees against us, which was hostile to us; and He has taken it out of the way, having nailed it to the cross.”

reproduced from The New Testament Validates Torah MAXIMUM EDITION

2:14 Making the Colossian Believers alive—bringing them to redemption via the work of His Son—God has done something very important on their behalf (Colossians 2:13).[1] As the ESV renders Colossians 2:14, He “cancel[ed] the record of debt that stood against us with its legal demands. This he set aside, nailing it to the cross.” What is this “certificate of debt,” and what are the “decrees against us, which were hostile to us” (NASU)? All readers of Paul’s letter can agree that Colossians 2:14 represents a damning indictment against people that needed to be dealt with via the sacrifice of Yeshua. But as we Messianics are quite abundantly aware, it is Colossians 2:14 that is commonly used to assert that “the Law of Moses has been nailed to the cross.” However, with the Greek nomos or “law” noticeably absent from this verse, what is Paul really communicating? Furthermore, how do we stay away from non-literal or extrapolated renderings of to kath’ hēmōn cheirographon tois dogmasin? This is literally rendered as “the handwriting in the ordinances that is against us” (YLT).

There are three main views of what “the certificate of debt” represents, which one is likely to encounter in studying Colossians:

  1. The debt or penalties incurred from human sin toward God, condemning people without a permanent sacrifice
  2. Some kind of a book or record in Heaven that kept a roll of condemned people
  3. The Law of Moses, which if not kept perfectly, condemns all people who break it

Traditional views of Colossians 2:14 dating back to the Protestant Reformation often associated the certificate of debt as either the record of human sin, or the guilt of human sin incurred before God.[2] Another common view of Colossians 2:14, similar to this, sees this certificate of debt as the pronouncement of condemnation that hung over Yeshua as He was dying on the cross (Matthew 27:37; Mark 15:26; Luke 23:38; John 19:19). Both would fit within the scope of what is seen in the lexical definition of cheirographon: “a hand-written document, specif. a certificate of indebtedness, account, record of debts” (BDAG).[3]

One suggestion among some interpreters is that the “certificate of debt” is somehow similar to a Jewish apocalyptic view in which a book recording all of one’s evil deeds was to be remitted. The existence of this book is derived principally from passages seen in the Tanach. Moses appeals to God after the Israelites worshipped the golden calf, “But now, if You will, forgive their sin—and if not, please blot me out from Your book which You have written!” and is told by the LORD, “Whoever has sinned against Me, I will blot him out of My book” (Exodus 32:32, 33). The Psalmist indicates how sinners should “be blotted out of the book of life and may they not be recorded with the righteous” (Psalm 69:28). And Daniel prophesies how in the end, “everyone who is found written in the book, will be rescued” (Daniel 12:1). Furthermore in the Book of Revelation, Yeshua promises those in Sardis, “He who overcomes will thus be clothed in white garments; and I will not erase his name from the book of life” (Revelation 3:5). So, the “certificate of debt” includes a record of human sin that has now been erased or blotted out (Grk. exaleiphō)[4] by the sacrifice of Yeshua at Golgotha (Calvary).

The most common view of the “certificate of debt” that one will find today among lay readers of Colossians is that it represents the Law of Moses nailed to the cross of Yeshua. It proposes that the Torah as cheirographon was a note of indebtedness that required cancellation. Sometimes, scholars who argue for this view provide external evidence from Jewish literature to support this proposal. Testament of Job 11:9-12 from the Pseudepigrapha is one reference to be considered:

“Sometimes they would succeed in business and give to the poor. But at other times, they would be robbed. And they would come and entreat me saying, ‘We beg you, be patient with us. Let us find how we might be able to repay you.’ Without delay, I would bring before them the note and read it granting cancellation as the crowning feature and saying, ‘Since I trusted you for the benefit of the poor, I will take nothing back from you.’ Nor would I take anything from my debtor.”[5]

Today’s Messianic Believers are of the conviction that God’s Torah is still relevant Instruction for His people. While many contemporary Christians have concluded that Colossians 2:14 relates to the Law of Moses being nailed to the cross, it is important for us to survey a wide array of interpreters’ opinions. Many are not, in fact, convinced that the Law in its totality was nailed to the cross. The chart below has summarized some of the various views present:

COLOSSIANS 2:14 AND VIEWS OF THE TORAH OF MOSES

FAVORABLE, OR AT LEAST NEUTRAL, TOWARD THE TORAH OF MOSES

NEGATIVE TOWARD THE TORAH OF MOSES

Paul dwells on God’s method of forgiveness. He uses the metaphor of a bond…a ‘statement of indebtedness’ which had to be signed by the debtor as an acknowledgment of his debt. The debt was impossible to pay. Moreover it was backed by legal demands, since every trespass is a violation of the law of God….Paul imagines God taking the statement of debts and nailing it to the cross of Christ.[6]
Donald Guthrie
Legalism is wrong because believers are dead to the Law in Christ. He fulfilled its demands in His life and by His death, and Christians are in Him.[7]
Norman Geisler
The image in 2:14 is of a legal document which lists the charges against us: its cancellation is emphasized—it has been erased, set aside, and nailed to Christ’s cross. The last phrase suggests that Paul might be thinking of the accusation nailed to the cross (Mark 15:26 and pars.). With Christ’s death and resurrection, the power of the charges against us has been nullified (cf. Gal 3:13-14).[8]
Morna D. Hooker
The Jews had contracted to obey the law, and in their case the penalty for breach of this contract meant death (Deut 27:14-26; 30:15-20). Paul assumes that the Gentiles were committed, through their consciences, to a similar obligation, to the moral law in as much as they understood it (cf. Rom 2:14, 15). Since the obligation had not been discharged by either group the “bond” remained against us ([kath’ hēmōn]).[9]
Peter T. O’Brien
The metaphor is probably adapted to the earlier Jewish idea of a heavenly book of the living…as developed in apocalyptic circles into that of books whereas deeds of good and evil were recorded with a view to the final judgment…This is most obviously the background of thought here, with [kath’ hēmōn] (“against us”) confirming that the document in question was one of condemnation, that is, presumably the record of their “transgressions”….[W]e should note that it is not the law which is thought of as thus destroyed, but rather its particular condemnation ([cheirographon]) of transgressions, absorbed in the sacrificial death of the Christ (cf. Rom. 8:3).[10]
James D.G. Dunn
It would be in keeping with the ironic tone we find at various points in this chapter that Paul should refer to the Mosaic Law as a mere IOU note, or perhaps as a book which does nothing but keep a tally of one’s sins….The Mosaic Torah did not, we should note, stand over against Jews and Gentiles…In Paul’s view, it shut up the Jews under sin and shut out the Gentiles from the hope and promise of membership in God’s people.[11]
N.T. Wright
To sum up, the great principle asserted in v.14 is the destruction of the law in and by the cross of Christ. The law, however, is viewed in a certain character (i.e., as a bond of indebtedness or as an instrument of condemnation, something that “stood opposed to us”).[12]
Curtis Vaughan
In causing him to be nailed to the cross, God (the subject of the verb) has provided for the full cancellation of the debt of obedience that we had incurred. Christ took upon himself the penalty that we were under because of our disobedience, and his death fully satisfied God’s necessary demand for due punishment of that disobedience.[13]
Douglas J. Moo
V. 14 says Christ’s death wiped out the IOU (a record of debts owed written by the hand of the debtor; cf. Phlm 19; Testament of Job 11.11) which stood against believers. While cheirograph is used of a receipt in Tob[it] 5.3 and 9.5, it is not found elsewhere in the NT. Here it seems to be a reference to the heavenly book of deeds in which a record of one’s wrongdoings is kept. In fact in Apocalypse of Zephaniah 3.6-9; 7.1-8 the same word is used for that book (cf. Apocalypse of Paul 17; Rev. 5.1-5; 20.12).[14]
Ben Witherington III

In reviewing the above opinions, it may surprise you to see that some of the theologians that we would think to be very anti-Torah in their approach to Colossians 2:14, are actually those who rightfully recognize that the principle issue is God dealing with human sin. Disturbing to me, those who would classify as being a bit more conservative in their theology, are the ones who immediately jump into claiming that the Torah is precisely what was nailed to the cross. And, one of the most conservative of all the voices, Curtis Vaughan, has a statement that is especially noted: “the great principle asserted in v.14 is the destruction of the law in and by the cross of Christ.”[15] This is most worrisome because it goes against Yeshua’s own word, “Do not think that I came to destroy the Law or the Prophets” (Matthew 5:17, NKJV).

Also to be noted is that while Ben Witherington III correctly acknowledges how the issue in Colossians 2:14 is human wrongdoings—and in this way he can be considered to be “neutral” toward the Torah—he later argues that the debt canceled is not a record of sins, but rather is actually the agreement to follow (or even obey?) God’s commandments. Rather than concluding that the “certificate of debt” composes the penalties incurred from disobeying God, his conclusion is “that believers need not keep paying a debt to those sorts of records of sin or indebtedness or to such laws and rules that say they still owe something.”[16] So, looking at this from one angle, the righteous principles of the Ten Commandments would just be viewed as parts of a bill to be paid, and obedience to them is no longer required now that the Messiah has been crucified. Has this approach helped a modern Christendom with all of the moral and ethical controversies it faces? Note how when people are told that they no longer have to be concerned with keeping any of God’s commandments, they often never take the time to study or examine what they have to say.

Andrew T. Lincoln’s view also cannot go without mentioning. In his estimation, “to argue that what is in view is not the law per se but only the law in its condemnatory function is to have read too fine a distinction into the verse.” This he has to say to recognize that there have been many throughout Christian history considering Colossians 2:14 to only speak of condemnation upon sinners, a debt that has been incurred. Perhaps this was caused by human disobedience to the Torah, but the Torah itself as intended by God was not the cause (i.e., Deuteronomy 4:1; 5:33; 8:1; et. al.). In contrast to this, Lincoln concludes, “The document itself is said to be opposed to humanity and, when one brings into play the ascetic regulations mentioned later, the clear implication is that it is condemnatory of humans because of their body of flesh.”[17] But why would the Torah be opposed to people if God gave it for the benefit of people? It is only opposed to people when they violate it—not when they follow it! So, Lincoln is correct when claiming that the Torah condemns people because of their uncircumcised body of flesh (Colossians 2:11), or their sin nature, but is incorrect when claiming that the Torah as a whole was just given to condemn. And, the promise of the New Covenant is God writing the Torah onto the hearts of His people (Jeremiah 31:31-34; Ezekiel 36:16-36) needs to be seriously considered here.

Douglas J. Moo, interestingly enough, points out that the view of “certificate of debt” being the Torah in totality, has some problems. He says “that the word [cheirographon] may refer to the Mosaic law, viewed by Paul as a record of human obligation that has not been met…fits a bit awkwardly with the basic sense of the word, since, of course, an IOU is written not by the one to whom the obligation is due (God, the author of the law), but by the one who is in debt (human beings).”[18] The Lord did not give His people the Torah as a record of what they had done, but rather what they should do to live properly: “All these blessings will come upon you and overtake you if you obey the Lord your God” (Deuteronomy 28:2). Severe violation of His Instruction incurred penalties, and so those penalties—which were backed up by certain stipulations that required capital punishment—needed to be dealt with.

The Apostle Paul asserts that this “certificate of debt” was cheirographon tois dogmasin. This is invariably rendered as “the bond which stood against us with its legal demands” (RSV), “the record that stood against us with its legal demands” (NRSV), or “the charge of our legal indebtedness” (TNIV). James D.G. Dunn notes the crucial clause here to be the “unarticulated dative, [tois dogmasin],” which “leaves the precise relationship obscure.”[19] Many interpreters of Colossians 2:14 immediately connect dogmasin to its parallel usage in Ephesians 2:15,[20] where by Yeshua’s sacrifice He has abolished ton nomon tōn entolōn en dogmasin. They incorrectly assume this to be the termination of the Mosaic Torah, which supposedly divided Jews and non-Jews from each other and had to be removed, and similarly in Colossians 2:14 conclude that the “certificate of debt” was backed up by the Torah and that all of the Torah was nailed to the cross.[21]

The challenge, with this interpretation, is recognizing that in Ephesians 2:15 dogma likely pertains to “a formal statement concerning rules or regulations that are to be observed” (BDAG), or an opinion,[22] meaning man-made ordinances that were responsible for erecting the dividing wall seen in the Jerusalem Temple (Josephus Antiquities 15.417; Jewish War 5.194). Anyone who was not a Jew or a proselyte was prohibited from entering the inner court of the sanctuary on threat of death. Paul uses this analogy to describe how via His sacrifice, Yeshua has nullified “the religious Law of commandments in dogmas” (PME), anything that would pass itself off as “Torah” or “commandments,” and be inappropriately used—just as the dividing wall—to keep others unnecessarily separated from God’s people. (This would notably include things like 1QS 1.9-11, where the Qumran community actually said it was justified to hate outsiders.) So, if the dogma seen in Ephesians 2:15 is what caused people in the Temple complex to be separated out on threat of death, are we at all unjustified to conclude that the dogma referred to in Colossians 2:14 are those things which would similarly require death? Could earlier generations of Protestants indeed be right in concluding that the condemnation and/or record of sin is the whole issue of what was nailed to the cross in Colossians 2:14?

The two classical definitions of dogma we have to consider are “that which seems to one, an opinion, dogma,” and “a public decree, ordinance” (LS).[23] It is not inappropriate for us to consider how in Colossians 2:14, Paul first could have used dogma (as public decree, ordinance) to describe the condemning aspects of the Torah that have been erased via the shed blood of the Lord. Later in composing Ephesians, dogma (as opinion) could have been used to describe condemning injunctions passing themselves off as Torah, keeping people separated from God’s purpose, but were by no means Biblical law.[24] The dogma that separated the nations in the Temple complex carried with it the threat of death, just as the dogma that composed the “certificate of debt” are what ultimately nailed Yeshua to the cross on our behalf. In approaching dogma this way—with dogma representing something that incurs execution—we eliminate any significant interpretational problems that exist between Yeshua’s claim about His work of fulfilling, not abolishing the Torah (Matthew 5:17-19). We can appropriately uphold the foundational principle of how in nailing the Torah’s condemnation to the cross of Yeshua, “I [the Lord], even I, am the one who wipes out your transgressions for My own sake, and I will not remember your sins” (Isaiah 43:25).

Dunn actually holds to dogmasin being halachic rulings that are later condemned in vs. 16, 21-22. He believes this to be valid because the verb rendered “submit[ting]…to decrees,” is dogmatizō.[25] Here, we can see how a record of human sin was nailed to the cross of Yeshua, whereas the Colossian errorists were being “dogmatized.” They were in error because they did not have to physically abase themselves, as Yeshua had already undergone the most extreme pain imaginable in death.

Dispensationalists, the one group of conservative Christians that Messianics will probably encounter or have to interact with most frequently, must especially argue that the Mosaic Law was nailed to the cross (as opposed to just the record or condemnation of sin). According to them, the Age of Law is now over, and the Age of Grace/Church Age has been inaugurated. When Yeshua said “it is finished” in John 19:30, the Torah came to an end—as opposed to complete reconciliation being made available between God and humanity.[26]

What does the work of Yeshua as depicted in Colossians 2:14, with something nailed to the cross, describe for us? Is it the Torah of Moses in its entirety? Or, is it the condemnation upon sinners that He has taken away for us, receiving upon Himself the death that is required of us all? Please consider how of all animal sacrifices specified in the Torah, there is no sacrifice available for intentional sins. Roger Bullard accurately summarizes how, “By forgiving our sins…God erased the record of those sins. What happened on the cross…abolished it and freed us from the grasp of the angelic beings”[27] (Colossians 2:8). The record of sin has been abolished! For this we should all rise in great praise! With the record of sin nailed to Yeshua’s execution-stake and the penalties now remitted, all people have to do is acknowledge this, confessing their sins, and asking the Lord for forgiveness and reconciliation. The Torah has not been abolished, but the capital penalties that stand over those who break it (making unredeemed sinners “under the Law”) have now been paid in full.

I do not disagree with Vaughan when he comments, “The bond…has been removed permanently, that is, removed so that its claims against us can never again alienate us from God.”[28] Sadly, though, Vaughan has to define the bond as “the Mosaic law,”[29] and not simply as the condemnation decreed upon sinners as defined by the Law.

The significance of Yeshua suffering and dying is to highlight to the Colossians, in Lincoln’s words, that they do not need to feel “a sense of guilt” where “some are undergoing rigorous ascetic requirements.”[30] Where various people in Colossae may think that they need to suffer more in order to access the Heavenly realm, by His sacrifice Yeshua has removed those things which have condemned human sin. Yeshua has already suffered the required physical pain that they are trying to inflict upon themselves, and Believers need not seek such pain. As is seen throughout Paul’s own ministry experiences, suffering and persecution will just come as one accomplishes God’s work—and no one has to seek it!

It is perfectly legitimate to recognize how the “certificate of debt” that has been paid by Yeshua’s sacrifice, is the condemnation and record of human sin. The power of this condemnation was found in various “decrees against us,” the stated death penalties for high crimes as specified in the Torah. It is not at all incorrect to recognize that by His death and shed blood, our relationship to the Torah has certainly been changed, but that does not mean that the Torah is to be thrown by the wayside and never studied or meditated upon (Psalm 119:15, 27). The Torah remains relevant instruction that is to be upheld and taught as a standard of God’s righteousness and holiness (Romans 3:31), but the problem of a permanent sacrifice for sin has now been taken care of (Hebrews 10:11-12).

With this in mind, though, I have still encountered people in today’s Messianic movement who would argue for a kind of theonomy.[31] They think that the death penalty decreed upon sinners for various crimes in the Torah should still be enacted—even with Yeshua’s sacrifice permanently atoning for the human sin problem. This would mean, at least in principle, that if one were to discover adulterers or homosexuals in the assembly, they should be tried and executed. This does make many, most especially myself, feel very uncomfortable. In 1 Corinthians 5, rather than demanding that the sexually immoral be executed for their sins, the Apostle Paul rules that they be excommunicated from the assembly. This is not because there was no proper Jewish court for them to be condemned by, but as he states it, their sin will get the better of them and they will die as a consequence if they fail to repent (1 Corinthians 5:5). Paul knew the gravity of the cross, and would never promote stoning people as a method of handling sins after the resurrection—since he himself was responsible for errantly stoning or overseeing the deaths of many Jewish Believers (Acts 7:58; Galatians 1:13; 1 Corinthians 15:9) prior to encountering the Lord on the Damascus Road!

History is replete with post-crucifixion examples of where various societies and religious movements have tried to, albeit unsuccessfully, enact capital punishment for every high crime specified in the Torah. There is perhaps no worse example of this then the complicated record of the English Reformation, where Catholic and Protestant monarchs alike would try those of the other side as heretics, believing them to be in violation of God’s Law, and burning many at the stake. About the only significant exception for executing a criminal would be for murder, the death penalty for murderers being a Creation ordinance (cf. Genesis 9:6). And even that has to be done very, very carefully.[32]

Even with the Torah’s death penalty upon sinners now remitted via the sacrifice of Yeshua, this does not at all mean that it is unimportant to know those sins in the Torah that prescribe the death penalty. While all of our collective human sin is what nailed the Lord to the tree, it is those very specific sins that carry capital punishment which ultimately condemned Him. When we review the weekly Torah portions and examine those regulations, which if violated caused ancient persons to be stoned or hanged until dead, we should stop for a moment and recognize that the Messiah came so that those penalties would not need to be enacted any more (cf. Romans 10:4, Grk.). They have all been wiped away by His suffering for us. With final redemption now available, we need to remember how “the kindness of God leads you to repentance” (Romans 2:4). If we should ever suffer for Him, it should only come as we serve Him and are possibly persecuted—not that we have to suffer as He did to attain eternal life.


NOTES

[1] This entry has been adapted from the commentary Colossians and Philemon for the Practical Messianic.

[2] For one example, see John Wesley, Explanatory Notes Upon the New Testament, reprint (Peterborough, UK: Epworth Press, 2000), 747 says: “This was not properly our sins themselves (they were the debt), but their guilt and cry before God.”

Many Protestant churches today hold services on Good Friday where people can write their sins or transgressions on small pieces of paper, and then actually nail them to a cross in the sanctuary, representative of how the record of human sin has been taken care of by Jesus’ sacrifice. This concurs with Colossians 2:14 representing the condemnation upon human sin.

[3] BDAG, 1083.

[4] In a classical context, the verb exaleiphō means “to wipe out, obliterate,” or “metaph., like Lat. delere, to wipe out, destroy utterly” (LS, 269).

[5] R.P. Spittler, trans., “Testament of Job,” in The Old Testament Pseudepigrapha, Vol 1, 844.

[6] Donald Guthrie, “Colossians,” in D. Guthrie and J.A. Motyer, eds. The New Bible Commentary Revised (Grand Rapids: Eerdmans, 1970), 1147.

[7] Norman M. Geisler, “Colossians,” in BKCNT, 678.

[8] Morna D. Hooker, “Colossians,” in James D.G. Dunn and John W. Rogerson, eds., Eerdmans Commentary on the Bible (Grand Rapids: Eerdmans, 2003), 1408.

Galatians 3:13 speaks how “Messiah redeemed us from the curse of the Law.” This is not to be construed to as to mean that having to obey the Torah is actually some kind of curse. Rather, the curse of the Law is the condemnation decreed upon those who violate it.

[9] Peter T. O’Brien, Word Biblical Commentary: Colossians, Philemon, Vol. 44 (Nashville: Thomas Nelson, 1982), 125.

[10] James D.G. Dunn, New International Greek Testament Commentary: The Epistles to the Colossians and to Philemon (Grand Rapids: Eerdmans, 1996), pp 164, 165, 166.

[11] N.T. Wright, Tyndale New Testament Commentaries: Colossians and Philemon (Grand Rapids: Eerdmans, 1986), pp 112, 113.

[12] Curtis Vaughan, “Colossians,” in EXP, 11:202.

[13] Douglas J. Moo, Pillar New Testament Commentary: The Letters to the Colossians and to Philemon (Grand Rapids: Eerdmans, 2008), pp 211-212.

[14] Witherington, Philemon-Colossians-Ephesians, 158.

[15] Vaughan, in EXP, 11:202.

[16] Witherington, Philemon-Colossians-Ephesians, 158.

[17] Andrew T. Lincoln, “The Letter to the Colossians,” in NIB, 11:625.

[18] Moo, Colossians-Philemon, pp 209-210.

[19] Dunn, Colossians-Philemon, 165.

[20] In Lincoln’s view, though, “The use of the later term in Eph 2:15…cannot be determinative for this earlier usage in Colossians” (in NIB, 11:625).

[21] Cf. Wright, Colossians-Philemon, 114.

[22] BDAG, 254; further stated as “something that is taught as an established tenet or statement of belief, doctrine, dogma.”

[23] LS, 207.

[24] As evidence of how dogma is not always used in reference to Biblical law itself, and can have some wider implications, note how in the Apocrypha an apostate Jew is said to leave all of tōn patriōn dogmatōn or “the ancestral traditions” (3 Maccabees 1:3). Similarly, a brother who is martyred testifies to have been raised on dogmasin or various “teachings” (4 Maccabees 10:2).

[25] Dunn, 165.

[26] Note how the Greek tetelestai can be translated as “It is accomplished!” (CJB/CJSB), or perhaps even “It has been brought to the goal!” (my translation).

[27] Roger Bullard, “The Letter of Paul to the Colossians,” in Walter J. Harrelson, ed., et. al., New Interpreter’s Study Bible, NRSV (Nashville: Abingdon, 2003), 2111.

[28] Vaughan, in EXP, 11:201.

[29] Ibid.

[30] Lincoln, in NIB, 11:629.

[31] D. Thomas Lancaster indicates, “the strict measures of Torah justice—stoning and the like—are not applicable unless one is in the land of Israel under the authority of a duly ordained Torah court of law like the Sanhedrin.” While he admits that a Sanhedrin court in Israel would be able to stone someone, he thankfully says, “As much as we might sometimes like to stone someone, the Torah forbids us from vigilante justice of that sort” (Restoration: Returning the Torah of God to the Disciples of Jesus [Littleton, CO: First Fruits of Zion, 2005], 76), recognizing how only authorized people could do this. But in holding to this opinion, he does overlook the great significance of Yeshua’s sacrifice for the covering of such sin and how these penalties have now largely been remitted. (Furthermore, even with the possibility of a Sanhedrin court reestablished in Israel sometime in the future, it seems unlikely that the Israeli government would give up control of the criminal justice system.)

Perhaps the only exception, this side of Yeshua’s resurrection, would be the death penalty for murder as a Creation ordinance (cf. Genesis 9:5-6)—and even this should be used quite infrequently.

[32] For a further discussion, consult Walter C. Kaiser’s remarks in Wayne G. Strickland, ed., Five Views on Law and Gospel (Grand Rapids: Zondervan, 1996), pp 155-156.