Ordained Servant Online
Review Article: No Reformed Theology of Justification?
The Way of Salvation: The Role of Christian Obedience in Justification, by Paul A. Rainbow. Milton Keynes: Paternoster, 2005, xxii + 329 pages, $29.99, paper.
Covenant, Justification, and Pastoral Ministry: Essays by the Faculty of Westminster Seminary California, ed. by R. Scott Clark. Phillipsburg, NJ: P;amp;R, 2006, xii + 465 pages, $24.99, paper.
Two books circulating in the ongoing justification controversy prompt sober consideration of matters that strike at the heart of our identity as a Reformed denomination. The first is The Way of Salvation: The Role of Christian Obedience in Justification by Paul A. Rainbow. Put succinctly, Rainbow critiques "the Reformers" for going too far in eliminating works entirely from the picture of justification. He proposes instead a more "round" doctrine of justification, one he develops from the vantage point of the "New Perspective(s) on Paul" (NPP) and related recent biblical and theological studies.
The second volume is Covenant, Justification, and Pastoral Ministry: Essays by the Faculty of Westminster Seminary California, edited by R. Scott Clark (henceforth CJPM). The fruit of a Seminary conference held in 2003, CJPM addresses the justification controversy as it has developed within conservative Reformed and Presbyterian communions in the USA. CJPM is a loaded canon pointed in the direction of the NPP, the "Federal Vision" (FV), and various individuals ("Reformed revisionists") understood to sympathize in some way with these programs or movements. As the product of a Reformed confessional seminary, the criticism is marshaled in this case from the perspective of the Reformed confessional tradition and, thus, from a perspective sympathetic to the idea of justification sola fide.
To the extent these proposals (NPP, FV, etc.) are handled accurately, CJPM is helpful. However, for all the concerns I share with the contributors, I am not entirely confident their opponents will recognize themselves in the portrait CJPM paints; a problem I regret to note is present in more than a few places. We may not agree with Norman Shepherd's theology, but when one writer asks—on the basis of the chapter titles (!) of Shepherd's Call of Grace—if Shepherd is "implying that given the reality of the covenant there is no need for the message of justification by faith" (Jones, 319, n. 13), we have cause for concern about our standards for scholarship.
Similarly, while I agree that the doctrine of the imputation of the active obedience of Christ is an offshoot of theological inquiry and polemic in the mid-sixteenth century, I am significantly less confident than Clark (230–31) in identifying the idea in Calvin, even "seminally" (231, n. 6), before his final revision of his Institutes in 1559/1560. Also in Clark's essay the important distinctions between imputation, Christ's active obedience, and the imputation of Christ's active obedience are often ambiguous. They are used synonymously so that evidence in a given writer of imputation or even of the necessity of Christ's "active" obedience, e.g., in Calvin, is assumed to stand as evidence of the full doctrine (cf. the citations in Clark, 229–65). In this discussion it is important to be clear that one can hold theoretically to imputation and to the necessity of Christ's active obedience without holding to the imputation of Christ's active obedience as belonging to the meritorious ground of justification. I write, I should add, as one who does hold to the "full" doctrine.
Other matters in CJPM, like understandings of "sola fide" and many exegetical arguments, are problematic and certainly merit analysis, though the limits inherent to a double review article prevent me from doing so here.
There are a few notable high points in the volume, however. For instance, the importance of the category of "merit" is properly upheld throughout; O. Palmer Robertson's definition of "covenant" (Estelle, 97) as well as the rejection by Robertson, Robert Letham, Cornelius Plantinga, and others of the pactum salutis are appropriately criticized (Estelle, 97; Clark & VanDrunen, 177–79); and the covenant of creation/life/works is ably defended (Estelle, 89–136).
Because the readership of Ordained Servant is much more likely to encounter CJPM than Rainbow's Way of Salvation, I will give more attention to the former. And because CJPM depends heavily on historical argument, this will be reflected in this review as well. However, I hope it will soon become clear why I include discussion of Rainbow's book at all.
The Pan-confessional Thesis
So we have two very different books standing, it would seem, on two opposite sides of the controversy. But I want to suggest this is only apparently true. In fact these books share at least two key features: (1) they assume the existence of a pan-confessional theology of justification; and (2) in their analyses of this pan-confessional theology they consistently frame it in classically Lutheran, not Reformed, terms, for the purpose either of criticism (Way of Salvation) or of defense (CJPM).
What is "pan–confessionalism"? Speaking generally, the pan–confessional phenomenon is an effort to offer a theological response to problems or proposals from the perspective of what two or more confessional traditions hold in common, accenting areas of agreement and minimizing (and sometimes denying) areas of disagreement. It is an effort to retrieve the importance of confessions of faith in contemporary, low–church evangelicalism, but it typically shows little sensitivity to the fuller theological systems of which the various confessional documents are expressions. Instead, this relationship between theological system and confessional document is effectively reversed.
We have an early indication of Rainbow's pan-confessional approach in his preface where he states, "The bits on the Reformation emphasize what Luther, Melanchthon and Calvin taught in common about justification. They do not explore how the understanding of each developed over time, nor do they highlight individual accents" (vii). Rainbow, then, will assess and criticize "the Reformation" or the "Luthero-Reformed tradition" (42) on sola fide and good works by engaging it pan-confessionally.
However, what for Rainbow is a matter of pragmatics is for CJPM a matter of principle, even theological conviction. Professor Robert Godfrey, who focuses on Calvin, puts it unequivocally, stating:
It is important to underscore that the Reformation speaks with one voice on this point. Luther and Reformed theologians are agreed about justification and about faith alone. The contention that the Reformed somehow have a distinctive doctrine of justification is simply false and can be articulated and defended only by those who do not understand either Lutheran or Reformed theologies ... The Reformed do not have a theology of justification or of faith alone different from that of the Lutherans, but there is a common Reformation theology, a common Reformation doctrine here, that the Lutheran and Reformed uphold together. (268–69)
This conviction that there is no difference between Reformed and Lutheran theologies of justification is the dominant thread that runs straight through CJPM. For this reason the terms "Reformed," "Reformation(al)," and "Protestant" are consistently treated as synonyms. So important is this conviction that it forms part of the Seminary's "Testimony on Justification," included as an Appendix. Here those who teach "that Lutherans and Calvinists have different doctrines of justification" are called "covenant moralists" who are "contrary to the Reformed confessions and/or historic Reformed conviction" (432). Elsewhere David VanDrunen calls "highly questionable" (50) the concern to distinguish carefully the Lutheran and Reformed views on the relationship between justification and sanctification. The contributors also seem concerned to shield the Heidelberg Catechism from the opinion, which I happen to share, that for historical reasons it reflects at points distinctly Lutheran theological influences (e.g., Horton, 218–19). Yet Clark rightly recognizes that the Belgic Confession and the Heidelberg Catechism both emerge from the backdrop of intra-Lutheran debates over justification in the mid-1560s (13–14), but this does not inform his analysis.
Before offering analysis, we need to appreciate that this is an astonishing series of assertions, particularly coming from historians (as several of the contributors are). Not only does this conviction misinterpret the history of Reformed theology, particularly the thought of Calvin who is the chief representative of the "Reformed" view in CJPM, it also ignores what classical and contemporary Lutheran theologians have had to say on the matter. I think particularly of the pointed arguments by the Lutheran luminaries Quenstedt and Pieper that the Reformed cannot teach justification sola fide consistently because of their teaching on union with Christ and faith. In contrast with Reformed theology, Lutheranism holds that union with Christ is the fruit and effect of justification. With a view to what I note below with respect to Calvin and Osiander, it is significant that Pieper also points to Reformed Christology (as expressed in the non-ubiquitarian model of the Supper) as the root of alleged Reformed confusion on justification.
Now, to be sure, there is continuity or common ground between the classic Reformed and Lutheran statements on justification. Comparing the Formula of Concord with the great Reformed confessions highlights an important harmony that should not be minimized. However, this common ground is, we must appreciate, limited to the constituent features of the doctrine as they are expressed in its most simplified form, i.e., in confessional definitions. It does not include the relationship justification bears to sanctification, union with Christ, or other important ideas with which a theology of justification is concerned. While it is useful in this definitional sense to speak of a Reformation consensus on justification, if we move beyond this into the theology of justification, we inevitably obscure the real, systemic theological differences between these two Reformation traditions. Furthermore, those wishing to cite witnesses to the contrary need to be discerning: does the statement have in view this definitional agreement or properly theological agreement? In CJPM there is no indication of this simple but crucial distinction (cf. Godfrey, 268).
Allow me to explain my concern briefly. The Reformed tradition began as an objection to the emerging Lutheran consensus on the nature and mode of eucharistic union with Christ. In the 1540s and 1550s especially, Calvin, as the leading voice of a broader Reformed representation, inveighed frequently and passionately against Lutheran ideas on Christ and the Supper. The ubiquitarianism of his opponents especially concerned him, as it required a departure from Chalcedonian orthodoxy on the person of Christ and a minimization of the ministry of Christ's Spirit. At the heart of the rise of what we call the "Reformed" theological tradition, then, was a conviction regarding union with Christ, fleshed out in the context of christological-eucharistic controversy.
This eucharistic controversy was largely contemporaneous with several justification controversies within Lutheranism, one of which revolved around an aberrant and widely-rejected theologian, Andreas Osiander. Calvin was asked to weigh in on the debate, not least because Calvin's opponents associated Calvin with Osiander on account of some nominal similarities. Calvin did offer a brief response early on, but then provided a large and masterful refutation of Osiander as part of his 1559 revision of his Institutes (in III.xi.5–12). But Osiander had died years earlier, in 1552. Why then does Calvin reply at such length in 1559? The text of his refutation reveals that the object of his critique—on justification, it should be remembered—was in fact not Osiander at all. Instead, Calvin used the deceased Osiander as a foil to continue his running critique of Lutheran ubiquitarianism. He does so by suggesting Osiander's unorthodox theology of union with Christ (in relation to justification) is only an outgrowth of his Lutheran Christology and eucharistic theology—theology which is not unique to Osiander but held in common by Calvin's Lutheran counterparts.
Upon examination (and I do encourage the reader to work carefully through Calvin's refutation) one finds that Calvin attacks Lutheran Christology and sacramentology as the cause of Osiander's unorthodox theology of justification. In short, Calvin argues that "Osiandrianism" rests upon the presupposition of the Lutheran Christology and sacramentology. Not only does it rest upon this presupposition, however. Calvin evidently perceives in Osiander's aberrant doctrine of justification the inevitable soteriological implications of a consistently-held Lutheran Christology and sacramentology. Indeed, as I have argued extensively elsewhere, Calvin's pattern of expression and argument suggests it is this crucial subtext of Calvin's response that is in fact the principal point of his entire refutation. For Calvin, Osiander is the only consistent Lutheran. As far as Calvin is concerned, then, the theology of justification in Lutheran thought, in terms of its christological-pneumatological framework, is significantly different from the consensus of Reformed theologians.
In light of considerations like these (and others could be noted), I suggest that a careful examination of the evidence confirms that language of "the Protestant (or Reformation) theology of justification" is an unhelpful and theologically misleading categorization. Indeed the evidence in the texts of the period suggests that (1) beyond the few decades that span Luther's "turn" and Calvin's 1559 refutation of Osiander, and (2) with a view to the theological (especially in terms of the Christology of union with Christ) and hermeneutical features of the emerging Lutheran and Reformed traditions, there is in fact no such thing as a "Reformational" or pan-confessional theology of justification.
But the difficulty with the pan-confessional thesis goes well beyond historical confusion. A friend once pointed out astutely that B. B. Warfield, in his Plan of Salvation, takes particular pains to distinguish carefully the Reformed theological tradition not only from Roman Catholicism but also from every form of "less consistent Calvinism." Cornelius Van Til too recognized the importance of this point, applying his concern for antithesis in much the same way. It was Van Til who rightly stressed that "In Calvinism more than in any other form of Protestantism the message of Christianity is clearly presented as a challenge to the wisdom of the world." As Orthodox Presbyterians in their line, it seems to me that, while appreciating what we have in common with other branches of the Church, we need to relate this fundamental commitment to Reformed theology as a system to pan-confessional proposals that work to move us back behind the rise and development of Reformed theology in the 1540s and 1550s to some form of more generic "Reformational" theology.
Conditional Language and Law-gospel
Our attention turns now to a cluster of problematic assertions that results from adopting the pan-confessional thesis. I can only draw attention to them here. It is best to understand these assertions as flowing out of the pan-confessional thesis inasmuch as pan-confessionalism consistently defaults to Lutheran, not Reformed, theology, and, in my view, it does so unmistakably when this cluster of issues is in view.
Rainbow is convinced the problem of conditional language (i.e., places in Holy Scripture where eternal life or salvation is predicated in some sense on obedience, suffering with Christ, or perseverance) sinks the doctrine of justification sola fide. "My thesis in a nutshell," he states,
is that, though the Reformers had Paul on their side in decrying merit before conversion and rightly emphasized that God freely imputes righteousness to a believing sinner apart from prior moral efforts, nevertheless they were wrong to exclude 'evangelical obedience' ... from having a secondary role in the way of salvation which we tread thereafter ... While faith is the ultimate condition for both events [i.e., present and final justification], deeds are proximately conditional in their own right for the culminating event. (xvi)
Rainbow continues, "Sola fide has become not only a norm which governs exegetical and theological decisions, but a subconscious pre-understanding by which we sift what we will allow ourselves even to see on the sacred page" (xviii).
In my view the law-gospel discussions in CJPM confirm that Rainbow's concern is not unwarranted. Rainbow fails to appreciate, however, that Calvin, at least, has no difficulty understanding "evangelical obedience" as having a "a secondary role in the way of salvation," seeing as this is precisely how he explains the role of good works in the believer's path to salvation.
For instance, explaining the conditional language in Romans 2, Calvin states: "The meaning, therefore, is that the Lord will give eternal life to those who strive to attain immortality by endeavoring to do good works." In a parallel passage in the 1539 Institutes, he states more fully that God "leads them into possession of [eternal life] through the pursuit of good works in order to fulfill his own work in them according to the order that he has laid down ..." Through this pursuit of good works, says Calvin, one is "prepared to receive the crown of immortality." While they form no part of the ground of justification and are not its instrument, good works are still necessary to, and thus a condition of, the end of our salvation: eternal life. Moreover, throughout his many discussions of this topic Calvin makes clear this necessity is not grounded in justification but in the reality of union with Christ. Rainbow wishes to press the importance of conditional language on the shoulders of Protestant defenders of sola fide, but for this very reason he should have attended to what Calvin says on the subject.
And Calvin's understanding of the place of good works is hardly unique. Francis Turretin, for instance, answers the question, "Are good works necessary to salvation?" with "We affirm" and proceeds to explain how this necessity (and causality) is and is not to be understood. In the course of his explanation he states that good works are "required as the means and way for possessing salvation." He then distinguishes the Reformed view (hence the "we affirm") from "various Lutheran theologians" and notes that "although works may be said to contribute nothing to the acquisition of our salvation, still they should be considered necessary to the obtainment of it, so that no one can be saved without them" (emphasis mine).
In contrast with this clearly conditional, saving place for good works, Clark argues that they are "merely evidence of sanctity and nothing more" (252–3; emphasis is Clark's, who uses Trent as his source and then confuses matters by writing "sanctity" while Trent stated "justification"). I cannot see how such an understanding squares with the testimony of Scripture or the Reformed tradition. Indeed, when one identifies the "Law" category of a law-gospel scheme with "a specific grammatical mood—the imperative" (Clark, 332, n.2; cf. 355)—one is unable to do full justice to the multitude of imperatives in the New Testament that are clearly "Gospel," i.e., that commend (imperatively) obedience in some form as a condition for eternal life and a blessing of the Spirit. For this reason, exegesis of conditional language in the Scriptures is the context within which one must explore the law-gospel question in order to avoid equivocation. In other words, it is not simply the terms (who would deny that Reformed writers have taught Law and Gospel?) but this filter-like hermeneutical-theological function of law-gospel which many writers have rightly identified more with the Lutheran than the Reformed tradition.
Justification and Sanctification in Relationship
This brings us to a related problem, this time only with a view to CJPM. Despite the clear witness in the texts of the tradition, especially but far from exclusively in Calvin (see especially his commentary on 1 Cor. 1:30), that justification, sanctification, and any other graces of salvation are distinct, inseparable, and simultaneously bestowed aspects of union with Christ, the contributors to CJPM argue otherwise, and do so with evident passion. They prefer instead the classical Lutheran construct in which sanctification flows from justification, and to identify the Reformed tradition wholly with it.
For example, Clark insists that, in excluding sanctity from the ground or instrument of justification, the Heidelberg Catechism teaches instead "that sanctification is the only and always the result of justification, (sic)" referring to questions 21, 56, and 60. For VanDrunen, those who teach a view other than the allegedly "Reformed teaching on justifying faith and the obedience that flows from it ...," i.e., that "... obedience ... inevitably flows from justifying faith ...," belong to a class of "Reformed Revisionists" (49). Indeed, according to VanDrunen, "the Reformation has always taught that sanctification is a fruit of justifying faith" (50). He claims that attacks on our (Westminster) confessional doctrine of justification involve a "denial that good works are to be seen entirely as the fruits of justifying faith" (50). The impression is clear that the only alternative to confusion on the meritorious grounds and instrumentality in justification is to speak of obedience in classically Lutheran terms. Indeed Clark frames the Reformation in just this way: "Before the Reformation," he writes, "we were said to be justified to the extent that we were sanctified. In the Reformation that pattern was reversed: sanctification was made the result of justification" (21). Compare VanDrunen's identical way of framing the relationship (30), Godfrey's similar discussion of justification and "its fruit in holiness" (280), and Jones on justification as the "launchpad for sanctification" (296), as further examples of a persistent theme.
Moreover, union with Christ, crucial to a proper understanding of this relationship, largely recedes from view in CJPM. In an essay devoted entirely to the relationship of justification and sanctification, Hywel R. Jones (285–306) is preoccupied with their distinction and says nothing at all about the place of union with Christ, something which is at least puzzling. Instead he works exclusively with the existential facet of their relationship: "The realization that one is pardoned and accepted by God on the basis of Christ's righteousness, without any works of one's own, motivates and supports one in doing the will of God—as nothing else does or can do" (287, emphasis Jones; cf. Johnson, 418–19). I am not aware of anyone who would deny this, and speaking in this way of "motivation" is surely appropriate. But we must not confuse the existential—what can be described in terms of my experience of grace—with the theological, as Jones, Godfrey (270, on Calvin), and others in CJPM seem to do.
Now, it needs to be mentioned that the problem here is not merely historical but the inevitable neglect of the theological benefit of Reformed theology on this point. Put most concisely, appreciating the biblical truth that sanctification does not result from justification, but is an aspect, like justification, of our union with Christ, alone safeguards the doctrine of justification against the Roman Catholic error. If we argue, with CJPM, that justification is the cause of sanctification, then we attribute to justification a generative, transformational quality (in that sanctification is generated or produced by justification) and thus, ironically in view of the driving concern in CJPM, compromise the purely forensic character of justification, its nature as a declarative act rather than the beginning of a work. This is the liability of the Lutheran model, but it is a liability that is entirely avoided in the Reformed model according to which justification and sanctification come to us as distinct, inseparable, simultaneous benefits of union with Christ, rather than one coming from the other (cf. WLC 69). CJPM urges a model which could have been pulled directly from the Formula of Concord. The Reformed model, however, best reflects the Apostle Paul's own as it is expressed, for instance, in 1 Corinthians 1:30.
Assessment and Conclusion
For both books the first step in the wrong direction was the adoption of the pan-confessional thesis. This approach precludes appreciating the distinct and rich theological model that Reformed theology alone commends.
In saying this, we need to stress again the important agreement that exists in the classical Lutheran and Reformed definitions of justification. Moving beyond these definitional features, however, we move beyond meaningful talk of a "Reformational" doctrine to two distinct theological frameworks for justification which have important systemic and hermeneutical differences. Moreover, if we choose to continue to speak and think pan-confessionally, then we evidently see "the theology of justification" as something more restricted in scope and depth than we should. Most importantly, we risk obscuring and ultimately leaving behind the christological-pneumatological structures of Reformed thought that are the theological rationale for its existence in the first place.
I hasten to add that, with respect to the thrust of CJPM, it is not in question whether or not theologians in the Reformed tradition have used the kind of language or held the kind of theology that the contributors do. I have no difficulty agreeing that this is the case. But this is not the same as arguing that those who disagree with the pan-confessional, sanctification-from-justification, law-gospel schematic are not "Reformed." I am aware of no extant evidence that requires our sympathy with such a suggestion. Rather, given our ecclesiastical context, church officers in the OPC especially need to be aware that the way commended forcefully in CJPM is not the only way to wrestle with NPP and FV issues.
In short, I can commend neither Way of Salvation nor CJPM as guides to a Reformed perspective on the various justification controversies of our day. Rather, I would alert my fellow OPC officers to the challenge to the integrity of the Reformed theological tradition that these publications represent. Furthermore, careful work on justification from the perspective of a more nuanced and informed grasp of Reformed theology is not only desirable but needed. I would encourage our teachers to take up this work, and to do so with the richness of the Reformed theological system in view.
 In what is among the more helpful essays in CJPM, Steven M. Baugh alone seems to recognize an area of dissonance between Lutheran and Reformed traditions, noting "confessional Reformed and Lutherans are fundamentally agreed on the essence of justification as consisting of the forgiveness of sins and the imputation of Christ's righteousness as a gift by grace through faith alone, but ... the Reformed wing of Protestantism has from very early on expressed this in distinctive ways through biblical notions of the covenant mediation of Christ" (138).
 E.g., Francis Pieper, Christian Dogmatics (4 vols; St. Louis, MO: Concordia Publishing House, 1950-1957), vol. 3, p. 436.
John Theodore Mueller, Christian Dogmatics (St. Louis, MO: Concordia Publishing House, 1934), 320; Johannes A. Quenstedt, Theologia Didactico-Polemica sive Systema Theologicum ... in quatuor partes distributum (1696; repr. Leipzig, 1715), III, p. 621; Heinrich Schmid, The Doctrinal Theology of the Evangelical Lutheran Church, 3rd ed., trans. Charles A. Hay and Henry E. Jacobs (Minneapolis, MN: Augsburg Publishing House, 1889), sect. 47:481.
 Pieper, Christian Dogmatics, vol. 2, p. 196.
 I discuss this in "Imputation and the Christology of Union with Christ: Calvin, Osiander, and the Contemporary Quest for a Reformed Model," Westminster Theological Journal 68 (2006): 219-51, but much more fully in Chapter 5 of Life in Christ: Union with Christ and Twofold Grace in Calvin's Theology (Studies in Christian History and Thought; Milton Keynes: Paternoster, forthcoming). Because my points regarding the Institutes require an appreciation of the polemical backdrop to Calvin's points and a range of cited examples that I cannot include here, I strongly encourage the reader to refer to the "Imputation" article and to Life in Christ, once it is available, for documentation and fuller discussion of many of the issues raised here and elsewhere in this review.
 Cornelius Van Til, The Case for Calvinism (1963; repr. Phillipsburg, N.J.: P&R, 1979), 106.
 Here again one can find a fuller, focused discussion of these matters in Life in Christ.
 John Calvin, The Epistles of Paul the Apostle to the Romans and to the Thessalonians, trans. Ross Mackenzie, Calvin's New Testament Commentaries, vol. 8, ed. David W. Torrance and T. F. Torrance (Grand Rapids, MI: Eerdmans, 1960), 44. Italics mine.
 John Calvin, Institutes of the Christian Religion, ed. John T. McNeill; trans. Ford Lewis Battles, Library of Christian Classics 20-21 (Philadelphia, PA: Westminster Press, 1960), III.xviii.1. Italics mine.
 I discuss this union with Christ-good works-eternal life complex at length in Chapter 3 of Life in Christ, particularly with a view to Calvin's handling of conditional language in his Romans commentary. I contrast Calvin's approach with Melanchthon's, among others.
 There is evidence Rainbow is not interested in a careful reading of Calvin, however. He introduces one of Calvin's most sophisticated and nuanced statements about what sola fide does and does not mean with "Hear Calvin squirm" (xxi).
 Francis Turretin, Institutes of Elenctic Theology, trans. George Musgrave Giger; ed. James T. Dennison, Jr., 3 vols. (Phillipsburg, N.J.: P&R, 1994), vol. 2, pp. 702-3 (topic 17, quest. 3).
 Peter Lillback's The Binding of God: Calvin's Role in the Development of Covenant Theology, Texts and Studies in Reformation and Post-Reformation Thought (Grand Rapids, MI: Baker, 2001), is a helpful study that is sensitive to this functional, rather than merely nominal, part of the Law-Gospel picture. Rather than dismissing Lillback's work, Clark (340) would have been well advised to examine its many citations with this distinction in view.
 Neither HC 21 ("What is true faith?"), 56 ("What believest thou concerning 'the forgiveness of sins'?"), nor 60 ("How art thou righteous before God?") teaches that sanctification is the result of justification, as Clark insists. Only Ursinus's comments on Q&A 21 could be cited in support of such an idea, but his comments on the HC are of course not to be confused with the Catechism itself. All the same, this is not to exclude the evidence, clear in my view, of distinctly Lutheran influences within the Catechism, something also rejected in Clark's essay but outside the scope of this review. See, on the actually quite limited extent of the Catechism's self-conscious Reformed identity, Lyle D. Bierma, "The Sources and Theological Orientation of the Heidelberg Catechism," in An Introduction to the Heidelberg Catechism: Sources, History, and Theology, ed. Lyle D. Bierma et al., Texts and Studies in Reformation and Post-Reformation Thought (Grand Rapids, MI: Baker, 2005), 75-102, esp. the conclusions on p. 102.
 The reader will notice that, unlike Clark, VanDrunen, in each of these citations, speaks in a more nuanced manner not of sanctification as the result of justification per se but of "justifying faith." If by this choice of expression VanDrunen intends only that faith (whether justifying, adopting, or with a view to any benefit that faith-union with Christ brings) yields sanctification, then this is certainly acceptable. I am unsure VanDrunen intends subtly to distinguish his view from Clark's, however.
 Lane G. Tipton's essay on union with Christ and justification in K. Scott Oliphint, ed., Justified in Christ: God's Plan for Us in Justification (Fern, Ross-shire: Mentor, 2007), pp. 23-49, discusses this point in a compelling fashion that reflects a nuanced grasp of the best of the Reformed tradition on this question.
 See, e.g., The Book of Concord: The Confessions of the Evangelical Lutheran Church, ed. Robert Kolb and Timothy J. Wengert (Minneapolis, MN: Fortress Press, 2000), p. 569.
 Since working through Way of Salvation and CJPM I have come across Justified in Christ: God's Plan for Us in Justification, noted earlier. The essay in this volume by Peter Lillback is an example of a more nuanced handling of the Reformed-Lutheran question coming from one within confessional presbyterianism.
Mark A. Garcia is a minister in the Presbytery of the South and regular supply at Immanuel Orthodox Presbyterian Church in Oakdale, Pennsylvania. Ordained Servant, October 2007.