Covenant Theology Under Attack
Meredith G. Kline
[A modified version
of Professor Kline's article was originally published in the February, 1994 issue of New
Horizons, the denominational magazine of the Orthodox Presbyterian
Church. What follows is the unexpurgated text.]
Recounted in the lore about the founding of
our movement is the stirring testimony of the dying Machen in
a telegram sent to John Murray: "I'm so thankful for active
obedience of Christ. No hope without it."
The active obedience of Jesus is his fulfilling
the demands of the covenant probation. By the passive obedience
of his atoning sacrifice he secures for us the forgiveness of
sins. But he does more than clear the slate and reinstate us
in Adam's original condition, still facing probation and able
to fail. Jesus, the second Adam, accomplishes the probationary
assignment of overcoming the devil, and by performing this one
decisive act of righteousness he earns for us God's promised reward.
By this achievement of active obedience he merits for us a position
beyond probation, secure forever in God's love and the prospect
of God's eternal home.
This grand truth is a fruit of covenant theology.
It grows out of the soil of the Reformed doctrine of federal
representation, which is based on the biblical teaching about
the two Adams whose responses under covenant probation are imputed
to those they represent. Thus, God imputes to those whom Christ
represents the righteousness of the victory of his active obedience
in his probationary battle against Satan. Here was Machen's strong
comfort in death. He knew that the meritorious work performed
by his Savior had been reckoned to his account as if he had performed
it. God must certainly bestow on him the glorious heavenly reward,
for Jesus had earned it for him and God's name is just.
Fuller versus Machen's Hope
Opposition to the covenant theology that affords
the believer such a confident hope in Christ is the main burden
of Daniel P. Fuller's latest book, The Unity of the Bible
(Zondervan, 1992),  as it was of his Gospel and Law: Contrast
or Continuum? (Eerdmans, 1980). The earlier book answered
the question posed in its title with a vehement "Continuum
- no contrast!" The contrast Fuller rejects is that between
grace and the works principle which classic covenant theology
asserts was present in the Law (the old covenant), governing Israel's
retention of the kingdom in Canaan. This tenet of covenant theology
is in agreement with the emphatic teaching of the apostle Paul.
 Covenant theologians fully recognize that the eternal
salvation of the elect is by God's grace alone, solely on the
basis of Christ's merit. That is true from the Fall to the Consummation,
not excluding the Mosaic economy. Accordingly, the old covenant
is subsumed under the Covenant of Grace. But classic covenant
theology also recognizes that at another level, that of the typological
kingdom, the works principle was simultaneously operating under
the old covenant. 
Fuller's refusal to acknowledge a works/grace
contrast between the Mosaic covenant and gospel administrations
(preeminently, the new covenant) is part of his broader insistence
that divine-human relationship never entails a works principle.
Human merit is an essential ingredient in the concept of works
and Fuller denies the very possibility of human merit anywhere
in history, even before the Fall. He repudiates covenant theology
not only in its recognition of a works principle in the Law but
in its identification of God's original covenant with Adam as
a covenant of works. Fuller claims there is a continuum of divine
"grace" throughout all God's dealings with man, pre-Fall
as well as redemptive.
Because the theology Fuller promotes is in
effect an assault on the foundations of the gospel and because
its influence is insidious, infiltrating even our own theological
community, it is important that we all acquaint ourselves with
its distinctive ideas and favorite arguments. Hopefully our consideration
of the issue (intricate though it is) will at the same time serve
to sharpen our understanding of God's justice and grace and to
enliven our appreciation of our Lord's active obedience. 
The Eclipse of Divine Justice
Our focus here will not be on Fuller's mishandling
of the Law but on the fallacies of his notions about the pre-Fall
covenant. As covenant theology recognizes, there is a big difference
(not a continuum) between the pre-Fall covenant and the subsequent
Covenant of Grace. In the former, Adam does not receive the kingdom
blessings (but rather a curse) if he forfeits God's favor by disobedience.
Under the gospel, on the contrary, we do receive those blessings
in spite of our having forfeited them by sin.
Grace is of
course the term we use for the principle operative in the gospel
that was missing from the pre-Fall covenant. Properly defined,
grace is not merely the bestowal of unmerited blessings but God's
blessing of man in spite of his demerits, in spite of his
forfeiture of divine blessings. Clearly, we ought not apply this
term grace to the pre-Fall situation, for neither the bestowal
of blessings on Adam in the very process of creation nor the proposal
to grant him additional blessings contemplated him as in a guilty
state of demerit. Yet this is what Fuller and company are driven
to do as they try to create the illusion of a continuum between
the pre-Fall and the redemptive covenants. Only by this double-talk
of using the term grace (obviously in a different sense)
for the pre-Fall covenant can they becloud the big, plain contrast
that actually exists between the two covenants (cf. Rom. 4:4).
Not grace but simple justice was the governing
principle in the pre-Fall covenant; hence it is traditionally
called the Covenant of Works. God is just and his justice is
present in all he does. That is true of gospel administrations
too, for the foundation of the gift of grace is Christ's satisfaction
of divine justice. If you are looking for an element of continuity
running through pre-Fall and redemptive covenants (without obliterating
the contrast between them), there it is - not grace, but justice.
In keeping with the nature of God's covenant with Adam as one
of simple justice, covenant theology holds that Adam's obedience
in the probation would have been the performing of a meritorious
deed by which he earned the covenanted blessings.
By what reasoning does Fuller disallow the
possibility of meritorious human deeds and thus reject the doctrine
of a covenant of works? One argument is that man cannot add to
God's glory since he is already all-glorious; we cannot enrich
God since everything already belongs to him. Do we not read that
even when a man has done all that God requires of him, he is still
an unprofitable servant, that he has done no more than his duty?
The statement of Jesus appealed to (Luke 17:10)
does indeed indicate that we can never do something extra beyond
our covenantal obligations, as a sort of favor for which God should
be grateful. But this does not mean that human works of obedience
are of no merit. Though we cannot add to God's glory, Scripture
instructs us that God has created us for the very purpose of glorifying
him. We do so when we reflect back to him his glory, when our
godlike righteousness mirrors back his likeness. Such righteousness
God esteems as worthy of his approbation. And that which earns
the favor of God earns the blessing in which that favor expresses
itself. It is meritorious. It deserves the reward God grants
according to his good pleasure. Just as disobedience earns a
display of God's negative justice in the form of his curse, so
obedience earns a manifestation of God's positive justice in the
form of his blessing (cf. Rom. 2:6-10; Ps. 62:12; Prov. 24:12).
This is simple justice.
At this juncture, advocates of the Fuller approach
adduce a second argument to justify their use of the term grace
rather than works for the pre-Fall covenant. They say
that even if it be granted that Adam's obedience would have earned
something, the reward to be bestowed so far exceeded the value
of his act of service that we cannot speak here of simple justice.
We must speak of "grace."
We have already criticized the duplicity of
using the term grace in the covenant with Adam in a sense
totally different from the meaning it has in the gospel. Now
we will focus on the denial of the simple justice of the pre-Fall
arrangement. For one thing, the alleged disparity in value between
Adam's obedience and God's blessing is debatable. It could be
argued that insofar as man's faithful act of obedience glorifies
God and gives pleasure to God, it is of infinite
value. But the point we really want to make is that the presence
or absence of justice is not determined by quantitative comparison
of the value of the act of obedience and the consequent reward.
All such considerations are irrelevant.
One way to show this is to note the theological
trouble we get into if we let the factor of relative values be
the judge of justice. For example, in the case of the eternal
intratrinitarian covenant we would end up accusing the Father
of injustice towards the Son. For the value of the Son's atonement
payment was sufficient for all mankind, yet the Father gives him
the elect only, not all. We can avoid blasphemous charges against
the Father only if we recognize that God's justice must be defined
and judged in terms of what he stipulates in his covenants. Thus,
the specific commitment of the Father in the eternal covenant
was to give the Son the elect as the reward of his obedience,
and that is precisely what the Son receives, not one missing.
Judged by the stipulated terms of their covenant, there was no
injustice but rather perfect justice. By the same token there
was no grace in the Father's reward to the Son. It was a case
of simple justice. The Son earned that reward. It was a covenant
of works and the obedience of the Son (passive and active) was
What is true in the covenant arrangement with
the second Adam will also have been true in the covenant with
the first Adam, for the first was a type of the second (Rom. 5:14)
precisely with respect to his role as a federal head in the divine
government. Accordingly, the pre-Fall covenant was also a covenant
of works and there too Adam would have fully deserved the blessings
promised in the covenant, had he obediently performed the duty
stipulated in the covenant. Great as the blessings were to which
the good Lord committed himself, the granting of them would not
have involved a gram of grace. Judged by the stipulated terms
of the covenant, they would have been merited by simple justice.
The Employer Metaphor
Instructive for the concept of justice is the
parable of the workers in the vineyard (Matt. 20:1-16). In particular,
it illustrates the point that in administering a work contract,
the amount of the stipulated wages is irrelevant to the question
of justice. Those who worked the full day challenge the owner
of the vineyard when they discover that the same pay they received
was given to others who labored fewer hours. But they were rebuffed
by the reminder that their employer had dealt with them exactly
as their work covenant prescribed. To honor the covenant commitment
was justice. Similarly, the higher rate of pay received by the
others did not transform that transaction into one of "grace."
It too was a payment of what was "right" (v. 4). It
was simple justice, no more, nothing other than justice.
This parable is also of interest in connection
with another favorite contention of Fuller. He claims that to
speak of a works principle in God-man relationship is to liken
God to an employer. And that is blasphemous, he says, because
an employer is a "client lord," one who has needs which
compel him to hire employees, who earn wages from him for meeting
A couple of things by way of rebuttal. The
rewarding of obedience is not something done only in an employer-employee
relationship. It takes place in the parent-child relationship
too, among others. When the parent promises the child a reward
for doing some chore, that is tantamount to a covenant of works,
and it is a matter of simple justice that the obedient child receive
the covenanted reward.  So the doctrine of the Covenant of
Works is not necessarily founded on the metaphor of God as an
employer. The covenant-keeping parent is another option. The
king conferring a royal grant on a loyal subject would be another.
But actually there is no need to refrain from
likening God to an employer. This metaphor which Fuller abominates
was used by Jesus himself in the parable of the vineyard workers
(and other parables). As the example of Jesus' parable demonstrates,
metaphors must not be pressed too far and, more specifically,
used of the employer metaphor for God does not imply that God,
like human employers, is a needy client lord dependent on his
employees' services. What we can properly gather from that parable
with its employer metaphor is that the God-man relationship is
governed by the principle of divine justice, including its positive
expression in God's granting covenanted rewards for the performance
of stipulated duties.  The propriety of the Covenant
of Works doctrine is thereby confirmed.
Subversion of the Gospel
The ultimate refutation of Fuller's theology
is that it undermines the gospel of grace. All the arguments
employed by Fuller and sympathizers to prove that Adam could not
do anything meritorious would apply equally to the case of Jesus,
the second Adam. Thus, the Father was already all-glorious before
the Son undertook his messianic mission, and their covenanting
with one another took place, of course, within a father-son relationship.
Moreover, the parallel which Scripture tells us exists between
the two Adams would require the conclusion that if the first Adam
could not earn anything, neither could the second. But, if the
obedience of Jesus has no meritorious value, the foundation of
the gospel is gone. If Jesus' passive obedience has no merit,
there has been no satisfaction made for our sins. If Jesus' active
obedience has no merit, there is no righteous accomplishment to
be imputed to us. There is then no justification-glorification
for us to receive as a gift of grace by faith alone.
There are only two consistent choices open
to Fuller. He can carry through the logic of his present position
by declaring the work of Jesus to be without merit and thus abandon
the gospel in any recognizably biblical-Reformational form. Or
he can affirm Christ's merit and the gospel - but then he must
first recant his attack on the Covenant of Works.
The actual teaching of those in the Fuller
school is an inconsistent mixture. They want to affirm the atonement
accomplished through Jesus' passive obedience (thereby accepting
the idea of negative, punitive justice), but they fail totally
in their handling of his active obedience. There is simply no
room in their system for a divine justice functioning positively
in reward of obedience, no room for an accomplishment of righteousness
by anybody that might be imputed to somebody else. The resultant
tendency is to confuse justification and sanctification in a new
legalism, in which the role of good works, which was not permitted
entrance through the front door, now sneaks in the back door.
What Christ could not do is left for us to do, somehow.
The irony of all this is that a position that
asserts a continuum of "grace" everywhere ends up with
no genuine gospel grace anywhere. An approach that starts out
by claiming that a works principle operates nowhere ends up with
a kind of works principle everywhere. What this amounts to is
a retreat from the Reformation and a return to Rome.
Fuller and Machen's Heirs
The assault on classic covenant theology of
which Fuller has become a vociferous spokesman is being endorsed
by some prominent leaders within even the broadly Reformed wing
of evangelicalism. And the sad fact is that this theology, which
undermines the biblical truths that provided Machen with his dying
comfort, has had its aiders and abettors within the very movement
that Machen founded. Strangely, it was the one who received Machen's
deathbed telegram who opened the door a considerable crack for
the views inimical to the doctrine of the active obedience of
John Murray's exegetical study of Romans 5
was supportive of the classic doctrine of imputation, but this
was undercut by the recasting of covenant theology he undertook
in the Covenant of Grace (Tyndale Press, 1953).  Murray
did at least affirm the possibility of meritorious human work,
with obedience receiving a just reward, but he limited this to
a situation where the reward would perfectly balance the value
of the work. (For Murray that meant an obedient Adam must remain
in his original state without advancement.) This qualification
restricted the possibility to a theoretical moment at the beginning
before the covenant was superimposed on this primal state of nature,
since on Murray's (mistaken) definition of covenant, "grace"
came with covenant, and that spelled the end of any momentary
hypothetical administration of simple justice.
The door left ajar by Murray was thrown wide
open to Fuller's theology by Murray's successor. Norman Shepherd
rightly rejected Murray's notion of a state of nature. (Such
a pre-covenant situation never existed; the world was created
a covenantal order from the outset.) However, this meant that
for Shepherd, who adopted Murray's equation of covenant and "grace,"
there was no place at all left for a covenant of works or meritorious
human obedience or simple justice. Though the ensuing controversy
over Shepherd's views led to his departure, his teaching was not
officially renounced by ecclesiastical or seminary arms of our
movement, and key elements of the Fuller-Shepherd theology continue
to be advocated among us. 
The current intensification of the Fuller crusade
awakens anew our concern over the sympathy for his views that
has continued to smolder within the Machen movement for more than
a decade after the Shepherd case. The church must be alerted
against the encroachment of this radical renunciation of the Reformation,
this subtle surrender to Rome. May Machen's heirs not let go
of their commitment to covenant theology but continue to cherish
it, and in particular its precious doctrine of the righteousness
secured for us by the active obedience of Christ. As Machen said:
No hope without it!
 Fuller is a professor at Fuller
Theological Seminary. The present article began as a review of
his The Unity of the Bible.
 See, e.g., Acts 13:39; Romans 5:13,
14; 10:5-10; 2 Corinthians 3:6-9; Galatians 3:11-18; 4:21-26;
 So, for example, Charles Hodge,
Systematic Theology (Eerdmans, 1981), 2.375.
 For more detailed exegetical discussion
of passages central to the controversy, see my "Gospel Until
the Law," Journal of the Evangelical Theological Society
34,4 (1991) 433-446 and my Kingdom Prologue (Overland Park,
KS: Two Age Press, 2001). T. David Gordon, a New Testament colleague,
has demonstrated that Romans 9:32, regarded by Fuller as a key
proof text of his thesis, is on the contrary a straightforward
statement of classic covenant theology's view of the Law. See
his "Why Israel Did Not Obtain Torah-Righteousness: A Translation
Note on Rom. 9:32," Westminster Theological Journal
54,1 (1992) 163-166.
 Working with its faulty concept
of justice, Fuller theology alleges that the parent-child relationship
is always characterized by "grace," never by simple
justice. The fact that God's covenants with Adam and Israel involve
a father-son relationship is then urged as an argument against
identifying them as works transactions.
 I am not suggesting that this is
a central point of the parable but simply noting something implicit
in the parable's metaphorical infrastructure.
 Fuller commented on this with approval
in Gospel and Law (pp. 6 and 79, n. 23).
 As the following quote shows, Shepherd
himself still adheres to the Fuller line: "But in the kingdom
of God we don't work for rewards in this sense [as earned]. God
does not relate to us as an employer to an employee." (The
Outlook 42,3  21).