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Published online by Cambridge University Press: 08 September 2022
In the ongoing discussions of Gal 3.10–14, interpreters have underappreciated the connection between Paul's argument in 3.10 and his use of Ps 143.2 in 2.16. This article argues that Paul bases his denial of justification by works in 2.16 on the confession of humanity's universal sinfulness in Ps 143.2. Given the rhetorical function of 2.15–21 as well as the close verbal and logical ties between 2.16 and 3.10, it contends the same thought underlies Paul's charge in 3.10 that those of works are under a curse. On this basis, the article assesses various interpretations of Gal 3.10.
1 Unless otherwise noted, all Scripture translations are the author's.
2 This view has an ancient and distinguished pedigree, including Justin Martyr, Dial. 95; John Chrysostom, Hom. Gal. on 3.10; Aquinas, Thomas, Commentary on Saint Paul's Epistle to the Galatians (trans. Larcher, F. R.; Aquinas Scripture Series 1; Albany, NY: Magi, 1966) 80Google Scholar; Luther, M., Lectures on Galatians, 1535, Chapters 1–4 (Luther's Works 26; Saint Louis, MI: Concordia, 1963) 254Google Scholar; Calvin, J., Commentaries on the Epistles of Paul to the Galatians and Ephesians (trans. Pringle, W.; Edinburgh: Calvin Translation Society, 1854) 89Google Scholar. Modern advocates include Lietzmann, H., An die Galater (HNT 10; Tübingen: Mohr (Paul Siebeck), 1932 3) 19Google Scholar; Lightfoot, J. B., Epistle of St. Paul to the Galatians (Grand Rapids: Zondervan, 1957) 137Google Scholar; Oepke, A., Der Brief des Paulus an die Galater (THKNT 9; Grand Rapids: Evangelische Verlagsanstalt, 1964 3) 72Google Scholar; Schreiner, T. R., ‘Is Perfect Obedience to the Law Possible? A Re-Examination of Galatians 3:10’, JETS 27 (1984) 159–60Google Scholar; Das, A. A., Paul, the Law, and the Covenant (Grand Rapids, MI: Baker Academic, 2001) 145–70Google Scholar; Kim, S., Paul and the New Perspective: Second Thoughts on the Origin of Paul's Gospel (Grand Rapids: Eerdmans, 2002) 141Google Scholar; Westerholm, S., Perspectives Old and New on Paul: The ‘Lutheran’ Paul and his Critics (Grand Rapids: Eerdmans, 2004) 375 n. 66Google Scholar; Moo, D. J., Galatians (BECNT; Grand Rapids: Baker Academic, 2013) 202–3Google Scholar; Keener, C. S., Galatians: A Commentary (Grand Rapids: Baker Academic, 2019) 235Google Scholar.
3 As estimated by Keener, Galatians, 235.
4 D. P. Fuller, ‘Paul and “the Works of the Law”’, WTJ 38 (1975) 28–42, at 34–5; E. P. Sanders, Paul, the Law, and the Jewish People (Philadelphia: Fortress, 1983) 29; N. T. Wright, The Climax of the Covenant: Christ and the Law in Pauline Theology (Minneapolis: Fortress, 1992) 145; J. D. G. Dunn, The Epistle to the Galatians (BNTC; Peabody, MA: Hendrickson, 1993) 171; N. H. Young, ‘Who's Cursed – and Why? (Galatians 3:10–14)’, JBL 117 (1998) 28–42, at 83; T. G. Gombis, ‘The “Transgressor” and the “Curse of the Law”: The Logic of Paul's Argument in Galatians 2–3’, NTS 53 (2007) 81–93, at 83; J. N. Aletti, ‘L'argumentation de Ga 3,10–14, une fois encore. Difficultés et propositions’, Bib 92 (2011) 182–203, at 187; B. R. Trick, Abrahamic Descent, Testamentary Adoption, and the Law in Galatians: Differentiating Abraham's Sons, Seed, and Children of Promise (NovTSup 169; Leiden: Brill, 2016) 83; E. McCaulley, Sharing in the Son's Inheritance: Davidic Messianism and Paul's Worldwide Interpretation of the Abrahamic Land Promise in Galatians (LNTS 608; London: T&T Clark, 2019) 116.
5 H. D. Betz, Galatians: A Commentary on Paul's Letter to the Churches in Galatia (Hermeneia; Philadelphia: Fortress, 1979) 145 n. 71; C. D. Stanley, ‘“Under a Curse”: A Fresh Reading of Galatians 3.10–14’, NTS 36 (1990) 481–511, at 482; Wright, Climax, 145; J. M. Scott, ‘“For as Many as are of Works of the Law are under a Curse” (Galatians 3.10)’, Paul and the Scriptures of Israel (ed. C. A. Evans and J. A. Sanders; JSNTSup 83; Sheffield: JSOT Press, 1993) 187–221, at 188; R. J. Morales, The Spirit and the Restoration of Israel: New Exodus and New Creation Motifs in Galatians (WUNT ii/282; Tübingen: Mohr Siebeck, 2010) 88; Aletti, ‘L'argumentation’, 187. The objection from Phil 3.6 received impetus from the well-known essay by K. Stendahl, ‘The Apostle Paul and the Introspective Conscience of the West’, HTR 56 (1963) 199–215, who found in Phil 3.6 evidence of Paul's ‘robust conscience’ (200), although he still held that Paul taught the impossibility of keeping the law in Gal 3.10–12 (202).
6 N. Bonneau, ‘The Logic of Paul's Argument on the Curse of the Law in Galatians 3:10–14’, NovT 39 (1997) 60–80, at 61; W. Reinbold, ‘Gal 3,6–14 und das Problem der Erfüllbarkeit des Gesetzes bei Paulus’, ZNW 91 (2000) 101–6, at 101; R. B. Hays, The Faith of Jesus Christ: The Narrative Substructure of Galatians 3:1–4:11 (Biblical Resource Series; Grand Rapids: Eerdmans, 20022) 178; Stanley, ‘“Under a Curse”’, 482. Similarly, while holding that 3.10 functions as a warning for law-breakers, Aletti, ‘L'argumentation’, 189 says regarding those Scripture calls righteous, ‘L'apôtre doit ainsi aller plus avant et montrer que, même pour ceux-là, l'obéissance aux commandements de la Loi ne saurait faire devenir juste.’
7 Gombis, ‘The “Transgressor”’, 84 n. 9. Similarly, J. D. G. Dunn, ‘Works of the Law and the Curse of the Law (Galatians 3.10–14)’, NTS 31 (1985) 523–42, at 534.
8 Schreiner, ‘Obedience’, 159 n. 30; Kim, Paul and the New Perspective, 141; Moo, Galatians, 204; H. Räisänen, Paul and the Law (Philadelphia: Fortress, 1986) 95–6.
9 E.g. Sanders, Paul, the Law, 27–9; Reinbold, ‘Erfüllbarkeit’, 100–1; Morales, Spirit, 88.
10 The connection between these texts is noted by e.g. D. J. Moo, ‘“Law”, “Works of the Law”, and Legalism in Paul’, WTJ 45 (1983) 73–100, at 97; J. Rohde, Der Brief des Paulus an die Galater (THKNT 9; Leipzig: Evangelische Verlagsanstalt, 1989) 141; Wright, Climax, 155; N. T. Wright, Paul and the Faithfulness of God (Minneapolis: Fortress, 2013) 859 n. 243; Westerholm, Perspectives, 375; J. M. G. Barclay, Paul and the Gift (Grand Rapids: Eerdmans, 2015) 378 n. 72; Keener, Galatians, 190. Fuller consideration is found in F. Thielman, From Plight to Solution: A Jewish Framework to Understanding Paul's View of the Law in Galatians and Romans (NovTSup 61; Brill, 1989) 124–30; M. Bachmann, ‘Zur Argumentation von Galater 3.10–12’, NTS 53 (2007) 524–44, at 532–4 (though he does not discuss Ps 143); J. A. Cowan, ‘The Curse of the Law, the Covenant, and Anthropology in Galatians 3:10–14: An Examination of Paul's Use of Deuteronomy 27:26’, JBL 139 (2020) 211–29, at 228. Cowan rightly observes that the significance of Paul's allusion to Ps 143.2 for the interpretation of Gal 3.10 ‘has rarely been noted’.
11 For a more comprehensive review, see Trick, Abrahamic Descent, 77–90; R. B. Matlock, ‘Helping Paul's Argument Work? The Curse of Galatians 3.10–14’, The Torah in the New Testament: Papers Delivered at the Manchester–Lausanne Seminar of June 2008 (ed. M. Tait and P. Oakes; London: T&T Clark, 2009) 154–79. For discussion of older alternatives, see Schreiner, ‘Obedience’.
12 In addition to these four approaches, some interpreters argue that Paul means to associate the law with the curse without reference to whether or not the law is violated, e.g. Sanders, Paul, the Law, 20–3; M. C. de Boer, Galatians: A Commentary (NTL; Louisville, KY: Westminster John Knox, 2011) 200: ‘Imperfect or incomplete observance of the law does not seem to be the issue for Paul; the problem is the law itself.’ Though differing in some respects, this approach resembles the ‘potential sin’ view described below in that most advocates of the latter view claim that Paul's point does not rest on whether or not the law can be kept. My criticism of the ‘potential sin’ view (see section 4 below), based on Paul's use of Ps 143.2 in Gal 2.16, will also apply to this approach.
13 E.g. Cowan, ‘The Curse of the Law’, 211; Trick, Abrahamic Descent, 82; Moo, Galatians, 158; O. Wischmeyer, ‘Wie kommt Abraham in den Galaterbrief? Überlegungen zu Gal 3,6–29’, Umstrittener Galaterbrief: Studien zur Situierung und Theologie des Paulus-Schreibens (ed. M. Bachmann and B. Kollmann; BThSt 106; Neukirchen-Vluyn: Neukirchener, 2010) 211–29, at 125–6.
14 Stanley, ‘“Under a Curse”’, 500–1; Young, ‘Who's Cursed’, 88–9; Reinbold, ‘Erfüllbarkeit’, 98. Similarly, Aletti, ‘L'argumentation’, 188 speaks of ‘le risque de malédiction’ and reasons, ‘En admettant même que beaucoup aient encouru la malédiction, le v. 10 ne suffit pas comme preuve, car il y a encore tous ceux qui font leurs délices de la Loi de Dieu’ (189). Against the view that the expression ὑπὸ κατάραν refers only to the threat of a curse, see Trick, Abrahamic Descent, 81 n. 51.
15 E.g. Reinbold, ‘Erfüllbarkeit’, 97; Aletti, ‘L'argumentation’, 189.
16 Scott, ‘Curse’, 193; Das, Paul, 148; Kim, Paul and the New Perspective, 134; Matlock, ‘Helping’, 175–6.
17 Fuller, ‘Paul and “the Works of the Law”’, 33.
18 Dunn, ‘Works of the Law’, 534; Dunn, Galatians, 173. Similarly, see D. Garlington, ‘Role Reversal and Paul's Use of Scripture in Galatians 3.10–13’, JSNT 19/65 (1997) 85–121, at 86, 109, 120, who argues that those of works are cursed because they fail to love and to fulfil the eschatological design of the law for the unity of Jew and gentile. While agreeing with the theology of the traditional view, M. Silva, ‘Abraham, Faith, and Works: Paul's Use of Scripture in Galatians 3:6–14’, WTJ 63 (2001) 251–67, at 263–4 also argues that Paul's focus in 3.10 is on the specific transgression of Paul's opponents, appealing to 6.13 for support. He finds Garlington's description of their transgression to be plausible (Silva, ‘Abraham’, 263 n. 36).
19 Gombis, ‘The “Transgressor”’, 90; see also 89, 92.
20 The criticism of Dunn's proposal in Westerholm, Perspectives, 317–19 may apply mutatis mutandis to other views that narrow Paul's focus in 3.10 to a specific kind of transgression.
21 Thielman, Plight, 65–72; A. B. Caneday, ‘“Redeemed from the Curse of the Law”: The Use of Deut 21:22–23 in Gal 3:13’, TJ 10 (1989) 185–209, at 195; Wright, Climax, 137–56; Scott, ‘Curse’; S. J. Hafemann, ‘Paul and the Exile of Israel in Galatians 3–4’, Exile: Old Testament, Jewish, and Christian Conceptions (ed. J. M. Scott; JSJSup 56; Leiden: Brill, 1997) 329–71; J. Willitts, ‘Context Matters: Paul's Use of Leviticus 18:5 in Galatians 3:12’, TynBul 54 (2003) 105–22, at 120; Morales, Spirit, 92–6; Barclay, Paul and the Gift, 405–6 n. 39; McCaulley, Sharing, 115–27. The essay of M. Noth, ‘“For All Who Rely on Works of the Law Are under a Curse”’, The Laws in the Pentateuch and Other Studies (trans. D. R. Ap-Thomas; Edinburgh: Oliver & Boyd, 1966) 108–17 was seminal to this approach.
22 However, Morales, Spirit, 86–7, 106–9 argues that the curse is better conceptualised as death. This variation is followed by Barclay, Paul and the Gift, 405–6 n. 39. On the status of the continuing exile thesis in NT studies, see N. G. Piotrowski, ‘The Concept of Exile in Late Second Temple Judaism: A Review of Recent Scholarship’, CBR 15 (2017) 214–47.
23 A notable exception is F. Thielman, Paul and the Law: A Contextual Approach (Downers Grove, IL: IVP Academic, 1994) 127: ‘[T]hey are cursed … because they, as a people and as individuals, have not kept the law.’
24 See especially Wright, Climax, 145–6, though the distinction seems more muted in Wright, Faithfulness, 1034. In general, the fact that many proponents of this view cite Phil 3.6 as a problem for the traditional interpretation suggests that they see their own reading as avoiding this objection.
25 Caneday, ‘Redeemed’, 195; Wright, Climax, 140, 145–6; Scott, ‘Curse’, 195; Willitts, ‘Context’, 120; Morales, Spirit, 91–3; McCaulley, Sharing, 117. Most of these authors point to Paul's blended citation – his substitution of τοῖς γεγραμμένοις ἐν τῷ βιβλίῳ τοῦ νόμου, which resembles a common phrase in Deut 28–30 (28.58, 61; 29.19, 20, 26; 30.10), for the original wording τοῖς λόγοις τοῦ νόμου τούτου in Deut 27.26 – as evidence that Paul meant to appeal to the larger context and its prediction of Israel's national sin, exile and restoration. However, the significance of this change may be interpreted differently, as discussed by Cowan, ‘The Curse of the Law’, 223. For instance, Bachmann, ‘Zur Argumentation’, 527 claims: ‘Wenn Paulus stattdessen schreibt ἐν τῷ βιβλίῳ τοῦ νόμου, so meint er offenkundig die gesamte Tora – und in ihr genauer alle Regelungen.’
26 A. A. Das, ‘Beyond Covenantal Nomism: Paul, Judaism, and Perfect Obedience’, ConJ 27 (2001) 234–52, at 243; Matlock, ‘Helping’, 167–8; Trick, Abrahamic Descent, 87; Cowan, ‘The Curse of the Law’, 223.
27 Recently, McCaulley, Sharing, 120 has advanced the defence of the corporate view by arguing, on the basis of allusions to Deut 29 in CD 3: ‘Second Temple authors could use texts that refer to individuals to speak about national curses.’ However, it may be questioned how much this single example supports a generalisation about Second Temple authors and also whether the allusive references in CD 3 to Deut 29 provide a sufficient parallel to Paul's explicit citation of Deut 27.26. The individual language of Deut 27.26 remains a weakness for an exclusively corporate view of the sin and curse in Gal 3.10.
28 This observation is generally true even for those who deny that 3.10 contains an implied premise, e.g. Fuller, ‘Paul and “the Works of the Law”’, 33; Bachmann, ‘Zur Argumentation’, 538. Silva, ‘Abraham’, 261–2 rightly notes that unstated assumptions run throughout Paul's argument.
29 These references to Ps 143.2 in Gal 2.16 and Rom 3.20 are broadly recognised, though scholars differ over whether to describe them as allusions or quotations. In favour of allusion, see e.g. B. Lindars, New Testament Apologetic (London: SCM Press, 1961) 224, 239, though he also calls it a ‘quasi-quotation’ (224); D. A. Koch, Die Schrift als Zeuge des Evangeliums: Untersuchungen zur Verwendung und zum Verständnis der Schrift bei Paulus (BHT 69; Tübingen: Mohr Siebeck, 1986) 18; R. B. Hays, Echoes of Scripture in the Letters of Paul (New Haven: Yale University Press, 1989) 51; J. P. Ware, ‘Law, Christ, and Covenant: Paul's Theology of the Law in Romans 3:19–20’, JTS 62 (2011) 513–40, at 527 n. 41; Moo, Galatians, 159. In favour of quotation, see e.g. M. Silva, ‘Galatians’, Commentary on the New Testament Use of the Old Testament (ed. G. K. Beale and D. A. Carson; Grand Rapids: Baker Academic, 2007) 785–812, at 790; W. N. Wilder, Echoes of the Exodus Narrative in the Context and Background of Galatians 5:18 (StBibLit 23; New York: Lang, 2001) 223. R. E. Ciampa, The Presence and Function of Scripture in Galatians 1 and 2 (WUNT ii/102; Tübingen: Mohr Siebeck, 1998) 182 speaks of ‘allusion … or interpretive citation’. In this study I use the commoner designation ‘allusion’ while affirming with Silva, ‘Galatians’, 790 that Paul ‘is directly appealing to Ps. 143 as providing some kind of evidence for his doctrine of justification’.
30 A. Rahlfs, ed., Psalmi cum Odis (Septuaginta. Societatis Scientiarum Gottingensis auctoritate 10; Göttingen: Vandenhoeck & Ruprecht, 1931) 328.
31 On the transitional nature of this text, see B. R. Gaventa, ‘Galatians 1 and 2: Autobiography as Paradigm’, NovT 28 (1986) 309–26, at 317–18.
32 Following e.g. Betz, Galatians, 121; Moo, Galatians, 153. However, resolving whether all or any of 2.15–21 is part of Paul's speech to Peter is not essential to my argument.
33 The participle εἰδότες has a causal force: ‘since we know …, we also have believed’.
34 For the present study, it is not necessary to engage in the debate over the nuance of the genitive Χριστοῦ, on which see M. F. Bird and P. M. Sprinkle, eds., The Faith of Jesus Christ: Exegetical, Biblical, and Theological Studies (Peabody, MA: Hendrickson, 2010).
35 The prior denials of justification by works in 2.16 probably also echo Ps 143.2, as Ciampa, Presence, 182 notes. Lindars, Apologetic, 224 sees this as evidence of the text's importance to Paul: ‘The manner in which the allusion is introduced in Gal. 2.15f., first as a general statement known to all at the beginning of the sentence, then as a quasi-quotation to clinch the matter at the end of it, suggests that this verse, if not the whole psalm, is another passage which is already fundamental to Paul's thinking.’
36 This classification is widely held, see N. L. DeClaissé-Walford, R. A. Jacobson and B. L. Tanner, The Book of Psalms (NICOT; Grand Rapids/Cambridge: Eerdmans, 2014) 980; F.-L. Hossfeld and E. Zenger, Psalms 3: A Commentary on Psalms 101–150 (trans. L. M. Maloney; Hermeneia; Minneapolis: Fortress, 2005) 571.
37 Among the various proposals for the structure of the psalm, commentators generally agree that the opening two verses are an invocation and that the psalm divides in half between verses 6 and 7. The outline proposed here mostly follows that of Hossfeld and Zenger, Psalms 101–150, 572. On the inclusio between vv. 1–2 and 11–12, see M. Müller, ‘Die Vergewisserung einer Beziehung: Eine Auslegung zu Ps 143 und seine liturgische Verortung’, BN 151 (2011) 71–94, at 77–8.
38 See R. B. Hays, ‘Psalm 143 and the Logic of Romans 3’, JBL 99 (1980) 107–15; Thielman, Plight, 64; Wilder, Echoes, 175–249.
39 DCH 7 s.v. ‘צדק’ lists Ps 143.2 under the meaning ‘be declared righteous, be justified, be vindicated’, but also notes that this meaning is not always clearly distinguishable from ‘be righteous, be innocent, be blameless, be right’. Even if the verb refers to judicial declaration or standing rather than moral righteousness, that declaration is based on the evaluation of the person's moral condition, a point confirmed by the parallels with Ps 130.3 and Job 25.4–6, noted below. Thus, whether the verb here is translated ‘be declared/found righteous’, ‘be in the right’ or ‘be righteous’, commentators rightly recognise that v. 2 confesses humanity's universal sinfulness. See e.g. L. C. Allen, Psalms 101–150 (WBC 21; Nashville, TN: Thomas Nelson, 1983) 355, ‘general sinfulness’; S. Terrien, The Psalms: Strophic Structure and Theological Commentary (ECC; Grand Rapids: Eerdmans, 2003) 893, ‘none is sinless in the divine presence’; Hossfeld and Zenger, Psalms 101–150, 573, ‘sinful weakness’; DeClaissé-Walford, Jacobson and Tanner, The Book of Psalms, 981, ‘The singer of Psalm 143:2 does not proclaim innocence, but appeals to the common human condition.’
40 Allen, Psalms 101–150, 355: ‘Alongside the confession of general sinfulness in v 2b, one may set Ps 130:3. These two psalms are rare in implying that the covenant relationship can be sustained only on the basis of continual divine forgiveness’; see also H. McKeating, ‘Divine Forgiveness in the Psalms’, SJT 18 (1965) 69–83, at 76; H.-J. Kraus, Psalms 60–150: A Commentary (trans. H. C. Oswald; Minneapolis: Augsburg, 1989) 536; J. L. Mays, Psalms (IBC; Louisville, KY: Westminster John Knox, 1994) 433; Hossfeld and Zenger, Psalms 101–150, 573.
41 Hossfeld and Zenger, Psalms 101–150, 572–3; DeClaissé-Walford, Jacobson and Tanner, The Book of Psalms, 981.
42 Translation and versification from M. O. Wise, M. G. Abegg and E. M. Cook, The Dead Sea Scrolls: A New Translation (revised and updated edn; New York: HarperCollins, 2005).
43 See fuller discussion in Ware, ‘Law’, 534–5; F. Mussner, Der Galaterbrief (2nd ed.; HThKNT; Freiburg im Breisgau: Herder, 1974) 168–9.
44 Wilder, Echoes, 224–5; Silva, ‘Galatians’, 791. This understanding of works is not strictly necessary to my argument here. Even if Paul's focus in Gal 2.16 is on works as boundary markers, his denial of works as a basis for justification could still rest on the idea of universal sinfulness in Ps 143.2. Paul's point would then be, as Dunn, Galatians, 140 says: ‘If no one could claim to be sinless or just before God, that included members of the covenant people’ (emphasis original). However, Paul's addition of ἐξ ἔργων νόμου makes more sense as an interpretive expansion of the psalm text if ἔργα νόμου are understood not only as distinguishing Jew from gentile but also as contributing to or constituting moral worth. Paul's use of ἔργα elsewhere with this sense, e.g. Rom 9.11, adds weight to this interpretation. For further defence of this understanding of ἔργα νόμου in Paul, see Moo, ‘“Law”, “Works of the Law”, and Legalism in Paul’, 92–6.
45 Rightly, Keener, Galatians, 190.
46 The reference to Ps 143.2 in 1 En 81.5 also has ‘all flesh’, as noted by C. H. Cosgrove, ‘Justification in Paul: A Linguistic and Theological Reflection’, JBL 106 (1987) 653–70, at 655 n. 9.
47 Silva, ‘Galatians’, 790 suggests that Paul quotes freely from memory, using a more common biblical phrase.
48 Thielman, Plight, 63; Wilder, Echoes, 231, 236; T. R. Schreiner, Galatians (ZECNT 9; Grand Rapids: Zondervan, 2010) 166–7; Dunn, Galatians, 140, who also sees a reference to ‘the realm where outward and ethnic distinction is most clearly marked’. By contrast, Cosgrove, ‘Justification’, 655 n. 9 argues that σάρξ is neutral, in parallel with ἄνθρωπος at the beginning of 2.16.
49 Hossfeld and Zenger, Psalms 101–150, 573.
50 T. Pola, ‘Psalm 143: der siebte Busspsalm’, TBei 34 (2003) 34–40, at 38.
51 Lindars, Apologetic, 224.
52 Both sections, Gal 3.1–5 and 3.26–29, are set off by Paul's frequent use of the second person plural, which he employs nowhere else in the chapter.
53 Betz, Galatians, 114; T. L. Donaldson, ‘The “Curse of the Law” and the Inclusion of the Gentiles: Galatians 3.13–14’, NTS 32 (1986) 94–112, at 97; Dunn, Galatians, 132; F. J. Matera, Galatians (Collegeville, MN: Liturgical Press, 2007) 98; Gombis, ‘The “Transgressor”’, 86; Moo, Galatians, 153–4; Keener, Galatians, 167.
54 Gombis, ‘The “Transgressor”’, 86. See similarly Bonneau, ‘Logic’, 80.
55 The likelihood that within 2.15–21 Paul draws especially from 2.16 is further strengthened by the fact that it is in 2.15–16 that Paul sets forth ‘[t]he points of presumed agreement’ (Betz, Galatians, 114); see also Keener, Galatians, 171–2. This statement of common ground would be a natural basis for argument.
56 Compare οὐ δικαιοῦται ἄνθρωπος ἐξ ἔργων νόμου in 2.16 with ἐν νόμῳ οὐδεὶς δικαιοῦται in 3.11. These are the only two verses in Galatians in which the verb δικαιόω is negated (cf. other occurrences of δικαιόω in 2.17; 3.8, 24; 5.4).
57 Wright, Climax, 142.
58 Gal 3.8 so links blessing and justification that it may be reasonably concluded that one cannot be had without the other. Since, as covenant sanctions, blessing and curse are mutually exclusive, jointly exhaustive outcomes, it may also be inferred that those who are not justified are cursed (= not blessed) and vice versa.
59 As argued by Moo, Galatians, 205, because Paul consistently uses Scripture as a ground in Gal 3.8, 10, 12 and 13, it seems preferable to understand ὅτι … δῆλον ὅτι in 3.11 in the usual way, ‘that … is evident, for’. However, the increasingly favoured alternative ‘because … it is evident that’, defended e.g. by Thielman, Plight, 127–8, A. H. Wakefield, Where to Live: The Hermeneutical Significance of Paul's Citations from Scripture in Galatians 3:1–14. (AB 14; SBL, 2003) 207–14 and Barclay, Paul and the Gift, 406 n. 40, is also compatible with the view of 3.10 proposed here.
60 This understanding of the minor premise, of course, assumes that the unrighteous do not remain in or do the law. This equation raises again the question of the law's provision for sin, which will be addressed further below. The point to be noted here is that, as argued in section 2, the thought that ‘no one is righteous, all sin’ is precisely what is expressed in Ps 143.2 and underlies Paul's denial of justification by works of the law in Gal 2.16. If Paul views this reason as sufficient to exclude justification by works, then he also views it as sufficient to claim that those of works are under a curse, since he associates not being justified with being under a curse.
61 See Gombis, ‘The “Transgressor”’, 89–91; Silva, ‘Abraham’, 263, respectively.
62 So also it is unlikely that Paul has no sin in mind, but seeks only to associate the curse with the law, as argued by Sanders, Paul, the Law, 20–3; de Boer, Galatians, 200, noted above.
63 On the basis of the link to Ps 143.2 in Gal 2.16, the traditional view also seems more plausible than the reconstructions of Paul's logic in Bachmann, ‘Zur Argumentation’ and D. Hunn, ‘Galatians 3.10–12: Assumptions and Argumentation’, JSNT 37 (2015) 253–66. Differing in details, both authors argue that Paul demonstrates that those of works are cursed by appealing to Deut 27.26 in conjunction, not with the traditional implied premise, but with 3.11a, ‘no one is justified by the law’, which in turn is established by 3.11b–12. However, given the connection with the foundational statement of Gal 2.16 and its use of Ps 143.2, it seems, pace Hunn, 257, that Paul expected the Galatians to supply a premise of human sinfulness and inability in conjunction with the threat of Deut 27.26. Thus, while Gal 3.11–12 may reinforce that the law has been violated and the curse incurred, these verses are not necessary to the argument of 3.10 in quite the way that Bachman and Hunn propose.
64 This is why Wright's appreciation of the connection between Gal 2.16 and 3.10 in Climax, 155 is inadequate: ‘The Torah brings the curse for Israel, because Israel has not kept it. I do not mean by this that individual Jews do not keep it fully; that is not what is here at issue … Rather, Israel as a whole has failed in her task of being the light to the nations … This is the central affirmation, I think, of 2:16 f.: this is why “by works of the Torah shall no flesh be justified”.’
65 Affirming both individual and corporate in Gal 3.10–14, see T. R. Schreiner, The Law and its Fulfillment: A Pauline Theology of Law (Grand Rapids: Baker, 1993) 49–50.
66 Compare Paul's explicit appeal to David in Rom 4.6–8 (Ps 32) as a witness to righteousness apart from works.
67 Israel's transgression of the law from the beginning of its history is rightly noted by e.g. Willitts, ‘Context’, 114; Morales, Spirit, 101–3. However, what remains absent from their discussion is the place of universal, individual unrighteousness and inability, expressed by Ps 143.2, in Paul's argument.
68 Pola, ‘Psalm 143: der siebte Busspsalm’, 36.
69 See similarly M. Silva, Philippians (BECNT; Grand Rapids: Baker Academic, 20052) 151–2, noting Luke's description of Elizabeth and Zechariah as ‘righteous’ and ‘blameless’ (Luke 1.6). Likewise, J. M. Espy, ‘Paul's “Robust Conscience” Re-Examined’, NTS 31 (1985) 161–88, at 165–6 argues that Paul's ‘blamelessness’ refers to the scrupulosity of the Pharisees, which, though commendable, is not to be identified with sinless perfection. Alternatively, the fact that Paul sees it as an achievement of the flesh in contrast with the Spirit (Phil 3.3) may indicate a more negative evaluation, as argued by Westerholm, Perspectives, 403.
70 Ware, ‘Law’, 532.
71 Ware, ‘Law’, 535–7.