The Possibility of Perfect Obedience: Paul and An Implied Premise in Galatians 3:10 and 5:3
by Michael Cranford

This article originally appeared in Novum Testamentum 36 (1994): 242-258.

That Paul believed that the law demanded perfect obedience of its Jewish adherents, and that such obedience was, due to human inability, never forthcoming, are suppositions underlying centuries of traditional scholarship in its interpretation of Romans and Galatians. This human inability to perform all the stipulations of the law is offered as the reason why works of law cannot save. Consequently, these assumptions bring content to the expression "works of law" (Gal 2:16; 3:10; Rom 3:20, 28). "Works of law" refers to obedience to the law offered to merit salvation, an obedience which Paul sets over against faith, understood as a trust in God which does not involve human effort and therefore does not run aground on human inability. That Paul's argument as a whole, throughout Galatians and Romans, rests on his belief that the law demanded perfect obedience is an assumption under the traditional view of such importance that it cannot be overstated. While this thought of perfect obedience is never actually expressed in Romans, it is assumed as a critical tenet underlying chaps. 1-3, with their pronouncement of universal human sinfulness.¹

E. P. Sanders has noted that this assumption, if it is truly Paul's, amounts to an almost total break with the Judaism of his time. In Palestinian Judaism, the requirement to obey the law is a consequence of election and not a condition for it, kept perfectly or otherwise.² And with the exception of 4 Ezra, the law is never considered to demand perfect obedience.

All the rabbis whose views are known to us took the position that all the law must be accepted. This was not only a Shammaite position. No rabbi took the position that obedience must be perfect. . . Even in Qumran, where perfection of way was stressed, allowance was made for transgression and atonement. The requirement of virtually perfect obedience in 4 Ezra makes the work stand out as unique in Jewish literature of the period—and that requirement is entirely unattested before 70 C.E.³

This becomes a problem in our assessment of Paul when we realize that any significant departure from the Jewish view would make his line of argumentation unconvincing. And if this assumption of perfect obedience is, in fact, an implication which Paul never actually expresses, an argument founded on it could prove to be unintelligible to readers following the Jewish mindset. Moore wonders

How a Jew of Paul's antecedents could ignore, and by implication deny, the great prophetic doctrine of repentance, which, individualized and interiorized, was a cardinal doctrine of Judaism, namely, that God, out of love, freely forgives the sincerely penitent sinner and restores him to his favor—that seems from the Jewish point of view inexplicable.⁴

The rhetorical plausibility of Paul's argument, if indeed he holds to a requirement of perfect obedience, is further jeopardized by his statements elsewhere which imply that some people—and even he himself—can and do fulfill the requirements of the law (Phil 3:6; Rom 2:13-14). These considerations mandate a closer examination of what Paul actually says in Gal 3:10, 5:3 and Phil 3:6, to determine if he does assume a requirement of perfect obedience, and the validity of this assumption used either as a foundation for interpreting Paul's argument elsewhere (e.g., Romans 1-3) or as evidence that his rhetoric is strained and artificial.⁵

Galatians 3:10 and the Curse of the Law

Since it is generally agreed that Paul never comes closer to expressing the idea that the law demands perfect obedience than in Gal 3:10, our investigation of the matter necessarily begins there. As many commentators have noted, Gal 3:10 itself contains an apparent tension: Paul warns that those who depend on works of law are under a curse (v. 10a), since everyone who does not perform the law in its entirety is cursed (v. 10b, citing Deut 27:26). If it is assumed that "works of law" refers to the performance of the law, then Paul's proof-text in the last part of the verse does not explain why the mere effort to keep the law leads to a curse. What brings the curse is paradoxically both what is done (i.e., works of law, v. 10a) and what is not done (i.e., all the law, v. 10b). The tension has traditionally been resolved by the addition of an unstated premise, which amounts to a claim that no one can keep the whole law.⁶ The argument is then constructed as a simple syllogism:

(1) All who do not keep the law perfectly are cursed (Deut 27:26, cited in Gal 3:10b).
 (2) No one can keep the law perfectly (implied premise).
 (3) Therefore, all who rely on the works of the law are under a curse (Gal 3:10a).

In addition to relieving the tension in 3:10, the addition of an implied premise furthers the Reformation categories of faith and good works as competing soteriological paradigms. Some scholars have argued that what brings a curse in 3:10 is not a failure to do all the law, but rather the attempt to do any of it. The curse is not incurred by partial obedience, but rather by legalism, since any effort to merit salvation (whether the law is kept perfectly or not) is sinful by its very nature.⁷ A major advantage of this view is that it removes the need for a second, implied premise. Unfortunately, it runs aground on the text Paul uses to support his position; Deut 27:26 does not denounce legalism, but rather actual transgressions of the law's commands.⁸

Supporting arguments for the existence of the implied premise, when they are forthcoming at all,⁹ tend to assume three basic forms. First, this interpretation is set forth on the grounds of its sensibility. Schreiner notes that premise 2 is an obvious implication, given premises 1 and 3. In fact, without the assumption of the implied premise, the citation of Deut 27:26 would be meaningless. "But it is most sensible to claim that Paul cited Deut 27:26 because he assumed that no one could obey the law (cf. Rom 3:9-20)."¹⁰

A second point of support is found in Paul's use of pasin in v. 10b. The fact that the MT does not have a word corresponding to pasin in Deut 27:26 is taken as evidence that Paul worked from the LXX for the very purpose of adding an emphasis which the MT was lacking; namely, that the curse was incumbent on those who failed to observe all the law.¹¹ Sanders has disputed this point by claiming that Paul's selection of Deut 27:26 is rooted in purely terminological concerns which render the occurrence of pasin here incidental.¹² Deut 27:26 is the only place in the LXX where the terms "law" and "curse" occur together, and the expediency of demonstrating their association superseded his consideration of other occurring terms (like pasin) and even his attention to the passage's meaning in its original context. In fact, Sanders argues that the key to determining what the proof-text actually means is found in what Paul says about the text, over against the meaning of the proof-text itself.¹³ By placing these in unresolved tension, Sanders provides for his interpretation in a way that makes inconsistency a recurring component in Paul's style.

What Sanders overlooks is that any mishandling of the text on Paul's part would provide his opponents the opportunity to discount his use of the text and therefore the argument on which it rests. It is all the more unlikely that Paul would overlook the significance of pasin when its inclusion places the first and last parts of 3:10 in direct conflict. The actual meaning of Deut 27:26 should not, for this reason, be treated as inconsequential in determining how Paul is using it in Gal 3:10. Sanders is also guilty of ignoring Gal 5:3 and 5:14, where similar terminology suggests that Paul's inclusion of pasin in 3:10 had significance, even if we allow that it was not his overriding motive for selecting Deut 27:26.¹⁴

A third point of support for the inclusion of the implied premise is that it is a natural development in Paul's supposed line of thought. Paul's earlier argument (3:7-9), demonstrating that justification is by faith, is strengthened in vv. 10-12 by an argument against justification by legal works.¹⁵ This development supposes that Paul is concerned with the question of how an individual procures salvation, with the possible alternatives being mere human effort (i.e., obeying the law) and faith (i.e., believing, understood as something other than obedience). Paul argues for the latter by offering the figure of Abraham in vv. 7-9 as a prototype for Christian faith.¹⁶ Abraham is the example of how an individual becomes justified by faith. Abraham believed and did not work, and was consequently justified. The Christian who believes and does not work can have similar expectations.

In support of this, Paul argues beginning in 3:10 that an individual who relies on legal works will not only not be saved, but will in fact be cursed—a curse whose remedy is only realized through faith in Christ (3:13). Paul then sets faith and works in antithesis as two competing ways of receiving eternal life (vv. 11-12), with the clarification that these paths to salvation are completely distinct, inasmuch as the law involves doing, and is therefore by definition not of faith, which does not involve doing (inferred from v. 12).¹⁷ The fact that Lev 18:5, quoted in v. 12, promises life to those who practice the law must be seen as a principle which is never realized for the reason already mentioned—no one practices the law well enough to live by it.¹⁸ The implied premise in 3:10 is therefore found consistent with the traditional view's assessment of the entire pericope.

The traditional view, and its support for the inclusion of the implied premise in Gal 3:10, runs aground on several points, however, leaving us with a reading that not only breaks from the common Jewish understanding regarding obedience to the law, but also fails to intuitively account for what Paul does say. For example, Schreiner offers the following appeal in support of the sensibility of reading the implied premise:

For example, if I say, "All fairy-tale characters are fictitious," and then remark that "Cinderella is fictitious," it is logical to accept the implied proposition that "Cinderella is a fairy-tale character." Of course, there are situations in which a character can be fictitious without the genre of the story being a fairy tale. But if I make the above statements consecutively, the implied proposition is so obvious that it goes without saying. We think the evidence supports a similar use of an implied proposition in Gal 3:10.¹⁹

Of course, Schreiner loads his example by selecting a proper name (i.e., "Cinderella") which is immediately recognizable as a fairy-tale character, and therefore forces the implied proposition before it is even suggested. A different example, without using a forced premise, but which otherwise maintains the same structure as Schreiner's argument, is as follows. "All bachelors are men. Tom is a man." What should be obvious is that it is not logical to accept the implied proposition "Tom is a bachelor."²⁰ In fact, to derive that from the previous two statements is a formal fallacy. While it might be true that Tom is a bachelor, it might just as well be totally false. Schreiner does not rest his point here, of course, but builds on this example by stating that Paul's use of Deut 27:26 in the last part of 3:10 commends the inclusion of the premise as the simplest reading.²¹ If it can be demonstrated that it is not the simplest reading, however, and that a competing reading explains the inclusion of Deut 27:26 without the need for the implied premise at all, then Schreiner's primary support for his interpretation is removed.

I would counter the traditional reading by suggesting that "works of law" in 3:10a refers to something other than (in fact, something significantly less than) complete obedience to the law, but offered as sufficient in and of itself.²² Deut 27:26 denounces works of law, then, not because no one can keep the law perfectly, but because "works of law" is, at best, partial obedience, and is in fact accompanied by actual disobedience.²³ The absence of any mention in this context (or in Romans 1-3, as it turns out) of perfect obedience is not because it was so obvious to Paul and his readers that it could be assumed, but rather because it was completely irrelevant to his argument. That fact that it never shows up at any point in Galatians or Romans, and that a Jewish mindset would never presuppose it, argues that it is not the simplest way to read Gal 3:10.

With this alternative reading we can then account for the occurrence of pasin without needing to assume that Paul is concerned with whether or not anyone can keep the law perfectly. Paul's use of the term enhances the idea that works of law do not constitute real obedience to the law, in that they are accompanied by actual disobedience. Using Deut 27:26 to argue for perfect obedience is problematic in its own right, since the passage did not have such a comprehensive reference in its original context, and Paul's opponents would have to be obtuse not to recognize this.²⁴ They would be forced to agree, however, that the law pronounces a curse on those who transgress its principal ordinances.²⁵

A close examination of Paul's line of thought in Galatians 3 as a whole brings the inclusion of the implied premise into even greater doubt. Paul's earlier argument (3:1-9) is directed at showing that the Galatians are sons of Abraham on the basis of faith (v. 7) and therefore not on the basis of works of law (vv. 2, 5). The question giving rise to the discussion here is not, "How do I, as an individual, become saved?" but rather, "What is the basis for Gentiles to be considered sons of Abraham?"²⁶ Bruce states that

The Galatian Christians had apparently been told by the agitators how necessary it was for them to be true sons of Abraham, and therefore to be circumcised, as Abraham was. . . It is not circumcision that makes a man a son of Abraham in the sense that matters most, but faith. The antithesis between ek pisteos (ex akoes pisteos) and ex ergon nomou which is implicit in vv 2, 5, 11, is implied here [in v. 7]; and circumcision is an ergon nomou.²⁷

The issue of sonship is a question regarding group membership, and what the identifying characteristic is of the group to be identified with Abraham. Abraham is therefore not offered as an example for how one should believe and be saved, as the prototype for Christian faith, but rather as the reason why faithful Gentiles are God's children and, by implication, why those who are "of works of law" are not (i.e., those who are circumcised and are not "of faith," though Paul makes no effort to draw faithful Jews, like himself, into the argument). That individual pursuit of salvation is not Paul's primary concern can be seen from the earliest stages of his argument. Howard notes that the question of how the Galatians received the Spirit in v. 2

...concerns the activity of God, not that of the Galatians. It is to be expected, then, that the answer will concern the activity of God as well. The answer comes in vs. 6: ‘Just as Abraham believed God and it was reckoned (elogisthe) to him for righteousness.' It would be incorrect to understand this answer to mean that as the Galatians believed so Abraham believed.²⁸

Gen 15:6 is quoted not with the prescription to believe like father Abraham, but as the reason why those who are "of faith" are his children (v. 7). In fact, the faith of the Galatians is assumed in Paul's argument, not prescribed, as we would expect if Abraham was being offered to show how an individual becomes saved. Abraham's sons are identified by their faith, and it is this group (those who are "of faith") who will be blessed, and because it is by faith it is a blessing available to Gentiles (who, if they were "of works" by accepting circumcision, would technically be Jews).

When we come to v. 10, this same line of thought is continued. Not only are those who are "of faith" blessed with Abraham (v. 9), but those who are "of works of law" are cursed. This second group, which is excluded from sonship, is seen as a soteriologically distinct entity from those in v.9. This group is characterized by works of law instead of real obedience, and their disobedience confirms that they are not among the faithful who are blessed with Abraham. Consequently, they are cursed.²⁹ The question of perfect obedience is an issue of an individual's response to the Torah, and has no real significance with regard to the characteristics which identify those who are blessed and those who are cursed.

In confirmation of this, Paul's argument does not go on to support a claim of perfect obedience by showing that every individual has sinned, as one might expect in the traditional view, but to argue that the characteristics of the two groups just mentioned are distinct. The thought, supposed by his opponents, is that those who are "of faith" and those who are "of works of law" are the same group, and so Paul undercuts any objection to 3:10 on these grounds. He does so by citing a point of agreement; namely, that the basis for life is faith, and he supports this in v. 11 by quoting Hab 2:4.³⁰ This is "evident," according to Paul, and the implication (also found in 2:16) is that his Jewish Christian opponents would not deny that God's people are identified by their faith. The real issue is whether those who are "of faith" are not also to be identified with those who are "of works of law" (i.e., the circumcised), such that the boundaries of the two groups are coterminous.³¹

They cannot be, however, because those who are "in the law" are not justified (implied, on that basis), and this explains why those who are "of works of law" (3:10a) are cursed. The expressions hosoi ex ergon nomou and en nomo have the same referent, and are group identifiers.³² This explanation for why those who are "of works of law" are not justified clearly removes any need to argue for a failure to obey the law perfectly. If God justifies those with faith and not those without it, it makes the whole question of perfect obedience irrelevant.³³ Schreiner struggles with this point, wondering "why the law is excluded as a way of salvation. It seems that Paul is merely dogmatically asserting the correctness of his position."³⁴ But Paul can do this as long as he is asserting a principle that his opponents would agree with, and I have already pointed out that Paul indicates this very thing in v. 11. The debate in Galatians 3 is not over how an individual becomes saved, but what the sons of Abraham look like. Paul asserts that they look like people with faith, without respect to works of law.

Paul continues in v. 12 by stating, "And the law is not of faith, but ‘he who does these things shall live by them.'" The first point, that the law is not of faith, is a summary of what Paul has been asserting all along—that the two boundaries are not coterminous, and that those who are "of works of law" are not the same as those who are "of faith." Paul then cites Lev 18:5, and this is commonly assumed to be a proof for the claim that the law is not of faith, in direct contrast to Hab 2:4, cited in v. 11b. The law is not of faith because it involves doing.³⁵ This dichotomy between believing and obedience, and treating faith in an intangible, spiritualized fashion, would never be convincing to Paul's opponents, however, and it is a contrast which is never explained either here or in Romans (cf. Rom 1:5). As Schoeps states, the OT concept of faith

...never admits a spiritualized interpretation, but always connotes trust in the sense of fidelity. For scripture knows only one alternative as regards man's position in face of God, His covenant and His law: namely, fidelity or infidelity. Faith means obedience towards God. The modern conceptual antithesis: faith or doubt, is as little known in scripture as the Pauline antithesis faith or works.³⁶

Consequently, the Jews would never view Lev 18:5 as contradicting Hab 2:4, since obeying the law would have been seen as an integral part of a life of faith.³⁷ Stanley admits that there is no inherent reason why these verses would have to be understood as opposites, and even acknowledges that the contrast between faith and obedience assumed here "will of course be convincing only to the reader who already holds that . . . ‘faith' and ‘doing' are fundamentally incompatible: the basic premise is simply taken for granted here, never argued."³⁸

If we do not assume that Paul is rejecting lawkeeping on the grounds of human inability, however, then there is no reason to see Lev 18:5 as indicating a second path to salvation that is never realized due to universal sin. Instead of seeing Lev 18:5 as a proof for the fact that the law is not of faith, it can be viewed in contrast to this assertion, and offered as a valid, positive principle.³⁹ Stanley notes that the all' preceding the citation of Lev 18:5 prepares the reader for a contrast, but claims that the actual nature of the contrast is only apparent in light of the earlier citation of Hab 2:4.⁴⁰ I would argue that the contrast is not between the citations, but between the law viewed negatively as an identifier of Jewish ethnicity (v. 12a) and viewed positively as a standard of obedience (v. 12b).⁴¹ Paul states in v. 12 that, while law and faith mark out different groups, those who will live (by faith) actually obey the law. This point runs parallel to Hab 2:4, and denounces those who are "of the law" on the same grounds as 3:10—they disobey the Torah.

Galatians 5:3 and the Obligation to Keep the Whole Law

In Gal 5:3, Paul tells the Galatians that everyone who submits to circumcision is under obligation to keep the whole law. The traditional view sees this as a secondary proof that Paul believed the law could not be kept perfectly. Paul is arguing that to undergo circumcision is to embark on a secondary road to salvation, and one which must necessarily result in failure because no one can keep the whole law.⁴² Again, the explicit statement that it is impossible to keep the whole law is missing from Paul's argument, but Schreiner claims that it is implied, and "makes more sense" to read it in to the text than to exclude it.⁴³ In light of Schreiner's view, it is unfortunate that Paul has again left the most salient point of his argument unexpressed. If 5:3 is a threat that gains rhetorical force because obeying the whole law is impossible, then why doesn't Paul say this? If true, it would strengthen an otherwise obscure point. But Paul's statement in 5:3 is cogent without any implied premise regarding perfect obedience, if we assume that the opposing view is arguing that circumcision is sufficient, in and of itself.

That this is the case is suggested at various points in the letter. Paul's opponents had undoubtedly urged circumcision as a primary basis for identification with Abraham (who, after all, did not have the "whole" law), and therefore urged separation from other Gentiles.⁴⁴ Sanders suggests that they had adopted a policy of gradualism,⁴⁵ but it is easy to see how the cultic ordinances would have been stressed over other points of law in the debate over Gentile membership in the covenant (cf. 2:12-14). Paul argues that circumcision cannot be divorced from obedience to the law, though his opponents were clearly advocating circumcision while not keeping the law (6:13), and this ends up being denounced in 5:3 just as in 3:10. In fact, 3:10 and 5:3 make the very same point: circumcision is less than (and therefore not equivalent to) obeying the law, though it was being offered as sufficient in and of itself.

Schreiner argues that Paul rejects circumcision in 5:3 because it obligates one to keep the law, and he interprets "keeping the whole law" as something negative.⁴⁶ But Paul makes no value judgment on keeping the whole law, and it is difficult to see how he might do so when he speaks of it positively in the near context (5:14), albeit in a different sense. Paul's point that circumcision should be connected to keeping the whole law simply emphasizes the failure of his opponents to do so and the meaninglessness of a sign (or work) that is not accompanied by faithful obedience (5:6; 6:15; cf. Rom 2:25). Nothing in 5:3 suggests that keeping the whole law is impossible or undesirable.

Philippians 3:6 and Paul's Blamelessness Under the Law

Phil 3:6 deserves some brief attention, since it is occasionally cited as evidence that Paul believed that perfect obedience to the law was, in principle, a possibility.⁴⁷ Paul remarks that, if anyone else has a mind to put confidence in the flesh, he does far more (3:4), and then enumerates certain objective facts about his standing as a Jew, concluding with the claim that, with regard to the righteousness which is in the law, he was blameless (3:6). While most commentators agree that Paul is saying he successfully kept the law,⁴⁸ they qualify his statement here by arguing that it reflects an earlier, Pharisaic attitude which underwent revision following his conversion.⁴⁹ These commentators base this assumption on what Paul says elsewhere about universal sin (Romans 2-3); Paul cannot actually be stating that he kept the law in Phil 3:6, because elsewhere he argues that everyone sins. This begs the very question under consideration, however. Whether or not Paul thought perfect obedience was possible should inform our understanding of Romans 1-3, not be derived from it.

Paul's statement in Phil 3:6 has the rhetorical force of counteracting the claims of his opponents, called here the "mutilation" (katatome), as opposed to the Philippians, who (along with Paul) are designated the circumcision (3:2-3). Paul's statement in 3:6, as with the other claims in vv. 5-6, loses this force if it reflects anything other than an objective fact. Paul views his observance of the law from his current perspective in precisely the same manner that he views his circumcision. The significance of such obedience, and Paul's view of the ongoing role of the law, may have undergone change, but Paul's view of his obedience to the law has not, and this should not be set at odds with his statements in Romans 1-3 and 7:7-9.

The most likely explanation is that Paul views keeping the law in connection with the law's own provision for sin. Offering atoning sacrifices to cover transgression is part of keeping the whole law, and has the effect of restoring a transgressor to the state of complete obedience. As Howard states,

The Levitical system of sacrifices provided a means whereby man, when he sinned, could obtain forgiveness. In fact observance of the law to a large degree involved the offering of sacrifices for the atonement of sins. To keep the law then was, among other things, to find cultic forgiveness for breaking the law.⁵⁰

Schreiner allows that Paul's statement in Phil 3:6 probably means that he offered sacrifices to cover his sin, but then the very offering would be an acknowledgement of sin,⁵¹ with the implication that sin (atoned for or not) invalidates perfect obedience to the law. If Schreiner is not willing to allow that keeping the whole law includes lapses which are provided for by making atonement for sins, then he is probably correct to assert that Paul did not believe that perfect obedience to the law is possible, since the sacrificial system does imply the inevitability of lapses. But by the same token, Paul indicates in Gal 5:14 (cf. 6:2) that the law can be fulfilled by Christians, and this "whole" fulfillment must allow for occasional sins as well. In Paul's thinking, keeping the whole law must include a provision for sins, or else no one could ever fulfill the law, either before or after the Christ event. And if it is possible after, in light of human sin, then why not before? To state that Paul's view of the efficacy of OT sacrifices has changed, and that he has broken with the OT view regarding atonement,⁵² is to assume a point which Paul never develops. And while I am ready to allow that Paul may actually have believed this, the fact that it is never expressed is proof that the question of perfect obedience is never at issue in his writings.

Conclusion

The question of whether or not Paul believed that perfect obedience to the law was possible cannot be answered with complete certainty. Paul clearly understood that the human condition involved sin, and that faith in Christ was the solution to humanity's plight. But that perfect obedience to the law was impossible because of that plight is a thought Paul never expresses, and which turns out to be irrelevant in light of what Paul does say. To see Paul as grounding his whole argument in Galatians and Romans on the impossibility of keeping the law threatens to jeopardize the cogency of his rhetoric. By ignoring the validity of the sacrificial system as an integral component of the law, and by treating faith as something other than—and even inconsistent with—obedience to the law, Paul's argument, if intelligible to his opponents at all, would be easily refuted. While this state of affairs cannot be excluded in principle, and while the existence of an implied premise in Gal 3:10 and 5:3 is not impossible, we are not forced to such an unintuitive extreme. If works of law are viewed as something other than obedience to the law—something which identify those who are disobedient to the law and therefore excluded from the covenant blessings—then no implication regarding perfect obedience need be assumed. Such a claim would be readily understood by a Jewish listener, who would at least agree that those who are not God's people are disobedient to the law, faithless, and under a curse. Paul's argument in Galatians 3 simply proves that it is not the Galatian Gentiles who fall into such a category, since they are "of faith." Rather, it is Paul's disobedient opponents who are cursed, together with all who are "of works of law." That the Galatians should not undertake to be identified by works of law is clearly entailed.

NOTES

1. See, for example, F. F. Bruce, The Epistle of Paul to the Romans (TNTC; London: Tyndale Press, 1985) 86; C. E. B. Cranfield, A Critical and Exegetical Commentary on the Epistle to the Romans (ICC; Edinburgh: T. & T. Clark, 1975) 198; Douglas J. Moo, Romans (WEC; Chicago: Moody Press, 1991) 144, 164, 210-
11; Matthew Black, Romans (NCBC; Grand Rapids: Wm. B. Eerdmans Pub. Co., 1973) 46. Moo notes that "while it is true that the requirement of perfect obedience is not explicitly set out in Romans 1-3, it is clear that Paul regards everyone as necessarily failing to match up to the standard necessary to secure justification. . . That this standard is perfection is not stated in so many words, but is a not unreasonable assumption" (Romans, 177). Moo's exegesis of chaps. 1-3, and ultimately his treatment of Romans as a whole, is founded on this assumption.

2. E. P. Sanders,Paul and Palestinian Judaism (Minneapolis: Fortress Press, 1977). See esp. Sanders's conclusions on pp. 420-22. Space precludes any discussion of Jewish soteriology here, or a weighing of recent attempts to allow for Sanders's research while still arguing for some measure of synergism in Palestinian Judaism.

3. E. P. Sanders,Paul, the Law, and the Jewish People (Minneapolis: Fortress Press, 1983) 28. See also Paul and Palestinian Judaism, 137-40; "On the Question of Fulfilling the Law in Paul and Rabbinic Judaism," Donum Gentilicum: New Testament Studies in Honour of D. Daube (ed. E. Bammel, C. K. Barrett and W. D. Davies; Oxford: Clarendon Press, 1978) 103-126, esp. 122-23. Richard N. Longenecker admits that while the view that the law requires perfect obedience is not a common one in Jewish thought (Galatians [WBC; Dallas: Word Books, 1990] 118), he argues elsewhere that neither is it foreign (Paul, Apostle of Liberty [New York: Harper & Row, 1964] 41-42). His examples, at best, show that all the law should be accepted, and that the attempt to obey it should be made, but they do not demonstrate that perfect obedience is required, or that perfect lawkeeping is impossible. In fact, the warnings in Jewish literature which he cites must (by their prescriptive nature) assume that the law can be kept.

4. G. F. Moore,Judaism in the First Centuries of the Christian Era (Cambridge, Mass.: Harvard University Press, 1930) III.150 n. 209. See also A. D. Nock, St. Paul (New York: Harper, 1938) 29-30. Hübner ascribes this view to Paul's Pharisaic background (Hans Hübner, "Gal 3,10 und die Herkunft des Paulus," KD 19 [1973] 215-31), but this is unconvincing in light of Sanders's research.

5. Along these lines see Heikki Räisänen, "Paul's Theological Difficulties with the Law," Studia Biblica III (ed. E. A. Livingstone; Sheffield: Sheffield Press, 1980) 309.

6. See Thomas R. Schreiner, "Paul and Perfect Obedience to the Law: An Evaluation of E. P. Sanders," WTJ 47 (1985) 247; "Is Perfect Obedience to the Law Possible? A Re-examination of Gal 3:10," JETS 27 (1984) 151; Ernest De Witt Burton, A Critical and Exegetical Commentary on the Epistle to the Galatians (ICC; Edinburgh: T. & T. Clark, 1921) 164; Longenecker, Galatians, 118; H. J. Schoeps, Paul: The Theology of the Apostle in the Light of Jewish Religious History (Philadelphia: Westminster Press, 1961) 175-77; Franz Mussner, Der Galaterbrief (TKNT; Freiburg: Herder, 1974) 224-26; Ronald Y. Fung, The Epistle to the Galatians (NICNT; Grand Rapids: Wm. B. Eerdmans Pub. Co., 1988) 142; Brendan Byrne, ‘Sons of God' - ‘Seed of Abraham' (AnBib 83; Rome: Biblical Institute Press, 1979) 151-52.

7. Daniel P. Fuller, "Paul and ‘The Works of the Law,'" WTJ 38 (1975) 30-33, following Ragnar Bring, Commentary on Galatians (Philadelphia: Muhlenberg Press, 1961) 121-24.

8. Schreiner, "Is Perfect Obedience to the Law Possible?" 156. While Schreiner identifies legalism as the root problem engendering Paul's discourse in this passage, he denies that it is the specific issue being addressed in 3:10. What brings the curse is not a legalistic attitude with regard to earning salvation, but imperfect obedience of the law.

9. Many commentators assume this reading without supporting it exegetically, and typically cite earlier works as if they are decisive, all the while admitting that Paul never actually says that no one keeps the whole law. E.g., Räisänen, who states that "the majority of interpreters assume that Paul is thinking here of the impossibility of fulfilling the Torah, although he does not say this in so many words. All those who stick to the law are accursed, because they all transgress it. No doubt this interpretation is correct" (Heikki Räisänen, Paul and the Law [Philadelphia: Fortress Press, 1983] 94).

10. Schreiner, "Is Perfect Obedience to the Law Possible?" 156; see also "Paul and Perfect Obedience," 257. Similarly, Albrecht Oepke notes that the implied premise is unstated for the very reason that it is obvious to Paul (Der Brief des Paulus an die Galater [THK; Berlin: Evangelische Verlagsanstalt, 3, 1973] 105). See again Moo (Romans, 177), who moves from the reasonableness of the assumption to its certainty with remarkable alacrity.

11. Fung, Galatians, 141; Schreiner, "Paul and Perfect Obedience," 256 n. 15; Longenecker,Galatians, 117. Hans Dieter Betz notes that Paul's quote does not fully correspond to either the LXX or the MT (Galatians [Hermeneia; Philadelphia: Fortress Press, 1979] 144-45), and so the precise reason why Paul used the particular variation of Deut 27:26 found here should be seen as speculative at best.

12. Sanders,Paul, the Law, and the Jewish People, 21.

13. Ibid., 215. This has led Sanders to a similar position with regard to Romans 2, where Paul is thought to draw on material as a result of rhetorical necessity, even though such material contains elements which are not only irrelevant but even inconsistent with his argument elsewhere (pp. 129-32).

14. Hübner finds 3:10 and 5:14 in delicate balance, stating that one cannot fulfill the law quantitatively (all the law, 3:10) simply because the law contains stipulations which must be qualitatively fulfilled (the whole law, 5:14), and these approaches to doing the law are mutually exclusive (Hans Hübner, Law in Paul's Thought [Edinburgh: T. & T. Clark, 1984] 41).

15. Fung, Galatians, 141.

16. Longenecker, Galatians, 113; Betz, Galatians, 143. Fung stresses the identical quality of Abraham's and the Christian's faith to further this point: "If it be asked how Abraham's one act of trusting God's promise to him can be cited in support of the Christian way of ‘hearing with faith' the message of Christ, the answer would seem to lie in the consideration that that one act was part of Abraham's commitment of his whole self to God, and that the faith which justifies is similarly total self-commitment to God" (Galatians, 136).

17. Longenecker states that "Paul sees Lev 18:5 as devoid of the principle of faith" (Galatians, 121).

18. Schreiner, "Paul and Perfect Obedience," 258.

19. Schreiner, "Is Perfect Obedience to the Law Possible?" 156.

20. By "not logical" I mean that such a move does not follow the rules of valid inference. It is possible that Schreiner could have a different understanding of "logical" which allows for invalid inferences, however.

21. Schreiner, "Is Perfect Obedience to the Law Possible?" 156.

22. On this point I am in complete agreement with James Dunn, who states that "to be of the works of the law is not the same as fulfilling the law, is less than what the law requires, and so falls under the law's own curse" (James D. G. Dunn, "Works of the Law and the Curse of the Law," Jesus, Paul and the Law [Louisville: Westminster/John Knox Press, 1990] 226).

23. That works of law should be seen as referring to circumcision, at least, is an assumption defended at length by Dunn ("Works of the Law," 219-25) and assumed by more traditional commentators as well (e.g., F. F. Bruce, The Epistle to the Galatians [NIGTC; Grand Rapids: Wm. B. Eerdmans Pub. Co., 1982] 155). The fact that Paul's opponents relied on circumcision to the exclusion of obeying the law is confirmed in 6:12-13, and it is precisely this thought which underlies Paul's thinking in Galatians 3, as well as Rom 2:21-27.

24. F. F. Bruce notes that Paul generalizes Deut 27:26 in Gal 3:10 and moves away from the more specific injunctions of the dodecalogue (Galatians, 158). Such an assumption presupposes that Paul wants to argue that perfect obedience of the whole law is impossible, however, since otherwise Paul's opponents could counter that they at least escaped the curse of Deut 27:26 by keeping the dodecalogue (reminiscent of the rich ruler in Luke 18:20-21)—unless, of course, those who are "of works of law" have compromised the dodecalogue, which would make Paul's use of the text accurate and his argument stunningly poignant, without any need to argue for or against perfect obedience.

25. This is precisely Paul's point in Rom 2:21-25, with regard to the decalogue. Paul there accuses the Jews of stealing (cf. Exod 20:15), adultery (20:14), idolatry (20:4-6), and, indirectly, blasphemy (20:7).

26. Contra Stanley, who states that vv. 2-14 are "designed to offer a definitive response to the question asked in v. 2: ‘Did you receive the Spirit on the basis of works of Torah, or by hearing with faith?'" (Christopher D. Stanley, "‘Under a Curse': A Fresh Reading of Galatians 3.10-14," NTS 36 [1990] 494). What Stanley overlooks is that this question needs no proof; it is a simple challenge to the readers' experience. The real controversy is sonship (here, with regard to Abraham, and later, with regard to God), and the question in v. 2 assumes a response that need not be argued for and which, having been brought to the readers' attention, lends support to the developing argument regarding sonship.

27. Bruce, Galatians, 155.

28. George Howard,Paul: Crisis in Galatia (2nd ed.; SNTSMS 35; Cambridge: Cambridge University Press, 1990) 55.

29. With Wright, I agree that Paul is associating the curse with ethnic Israel as a whole, marked out by works of law (N. T. Wright, The Climax of the Covenant: Christ and the Law in Pauline Theology [Minneapolis: Fortress Press, 1991] 145-47), though I would be hesitant to claim, as he does, that the disobedience occasioning Paul's use of Deut 27:26 is purely related to Israel as a nation, and has no reference at all to Paul's opponents. Note that my understanding of the curse, which I would associate with exclusion from covenant blessings (3:14; cf. Rom 9:3), breaks with Dunn's, who presses the issue of Jewish nationalism too far, in my opinion, in attempting to explicate the curse as "a wrong understanding of the law" ("Works of the Law," 229).

30. Hays sees Hab 2:4 as messianic, with Christ as the representative figure with whom the Gentiles participate to receive the blessing (Richard B. Hays, The Faith of Jesus Christ: An Investigation of the Narrative Substructure of Galatians 3:1-4:11 [SBLDS 56; Chico: Scholars Press, 1983] 150-57, 208-209).

31. This would have been a basic assumption for a Jew of Paul's time (Dunn, "Works of the Law," 228). For further discussion regarding Paul's distinction between sociological and soteriological boundaries, see Michael Cranford, "Election and Ethnicity: Paul's View of Israel in Romans 9.1-13," forthcoming in JSNT.

32. Dunn, "Works of the Law," 221-22. The fact that Paul moves from an apparently narrower definition (i.e., works of law) to a broader one (i.e., in law) simply shows that the law in its social function (marking out who is and is not part of Israel) is envisaged in broader terms than a few ritual observances in the law (like circumcision), though when the law was kept in this regard it certainly meant that some parts were observed to the neglect of others (Gal 6:13).

33. Thus Sanders,Paul, the Law, and the Jewish People, 26-27; Hays, Faith of Jesus, 207. Bruce also makes this observation, but it does not factor into his conclusions regarding the passage as a whole (Galatians, 161).

34. Schreiner, "Paul and Perfect Obedience," 259.

35. Stanley, "Under a Curse," 502; Longenecker, Galatians, 120; Fung,Galatians, 145.

36. Schoeps,Paul, 202.

37. Nils Dahl, "Contradictions in Scripture," Studies in Paul: Theology for the Early Christian Mission (Minneapolis: Augsburg Publishing House, 1977) 159-77. Walter Kaiser argues that the principle of life offered in Lev 18:5 is not at odds with the NT doctrine of faith, and should not be understood as failing due to human inability (Walter C. Jr. Kaiser, "Leviticus 18:5 and Paul: Do This and You Shall Live (Eternally?)," JETS 14 [1971] 19-28).

38. Stanley, "Under a Curse," 504.

39. Similarly, Lloyd Gaston notes that the all' prevents us from viewing v. 12b as a proof-text for v. 12a, with the consequence that Lev 18:5 is cited by Paul here positively, rather than in contrast to Hab 2:4 ("Paul and the Law in Galatians 2 and 3," Paul and the Torah [Vancouver: University of British Columbia Press, 1987] 74).

40. Stanley, "Under a Curse," 503.

41. It is no surprise that these are the same alternating uses of the law drawn together in Rom 3:20.

42. Fung, Galatians, 222-23; Bruce, Galatians, 230-31.

43. Schreiner, "Paul and Perfect Obedience," 266-68.

44. Longenecker, Galatians, 227.

45. Sanders,Paul, the Law, and the Jewish People, 29; see also Bruce, Galatians, 229-30.

46. Schreiner, "Paul and Perfect Obedience," 264.

47. Cf. Betz,Galatians, 145 n. 71.

48. Hawthorne notes that Paul's use of "righteousness" refers to conformity to external rules which are considered to be God's requirements. Paul, in his obedience to the law, omitted nothing that was required of him (Gerald F. Hawthorne, Philippians [WBC; Waco: Word Books, 1983] 135; see also Moisés Silva, Philippians [WEC; Chicago: Moody Press, 1988] 175-76).

49. Thus, Marvin R. Vincent, A Critical and Exegetical Commentary on the Epistles to the Philippians and to Philemon (ICC; Edinburgh: T. & T. Clark, 1897) 98-99; Ralph P. Martin, The Epistle of Paul to the Philippians (TNTC; Grand Rapids: Wm. B. Eerdmans Pub. Co., 1987) 147; Peter T. O'Brien, The Epistle to the Philippians (NIGTC; Grand Rapids: Wm. B. Eerdmans Pub. Co., 1991) 380.

50. Howard,Paul: Crisis in Galatia, 53.

51. Schreiner, "Paul and Perfect Obedience," 261.

52. Thus Schreiner, "Is Perfect Obedience to the Law Possible?" 159.