Wilson Paroschi
There are important differences between John and the Synoptics concerning the theme of the Holy Spirit. The fact that John writes from the perspective of his own time, rather than from that of Jesus Himself as the other evangelists do, certainly helps to explain some of the differences. For John the coming of the Spirit was a past event (John 7:39), and His presence in the life and mission of the church was even more essential than that of the incarnate Christ (16:7). Thus, what he says about the Spirit takes on new levels of definition and significance. This essay represents a brief study of what the Fourth Gospel says about the Spirit. It is divided into three parts: (1) the Johannine teaching on the Spirit in the narrative sections of the Gospel (chaps. 1-13, 18-21); (2) the passages—unique to John—that refer to the Spirit as the Paraclete and that are found in the so-called Farewell Discourses (caps. 14-17);1 and (3) the alleged grammatical evidence for both the personality and the divinity of the Holy Spirit. The essay ends with some short considerations on the relevance of the discussion to SDA theology.
Even if John is not the NT writer who most often refers to the Holy Spirit, he stands out among the evangelists not only in number but also in the scope and relevance of the references.2 In the Synoptics, as in the OT, the Spirit is not so much an independent or distinct entity, but God’s power in operation. The fundamental idea is that of empowerment or qualification to some specific activity.3 So Jesus is empowered by the Spirit to fulfil His messianic mission (Matt 3:16; 12:18, 28; Mark 1:10; Luke 3:22; 4:14, 18; cf. Acts 10:38), which includes sharing this same gift (Matt 3:11; Mark 1:8; Luke 3:16; 11:13), especially with the disciples, so that they could also perform the work that would be required of them (Luke 24:49; cf. Matt 10:20; Mark 13:11; Luke 12:12).4
In John the situation is completely different, though not necessarily contradictory. Not that the idea of empowerment is not present; it is, but always implicitly, as in the descent of the Spirit upon Jesus at His baptism (John 1:32-34). In John’s Gospel, the phenomenon is more a sign to John the Baptist than Jesus’ actual empowerment for ministry. The Baptist is recorded as having received a divine revelation that allowed him to identify “the Lamb of God, who takes away the sin of the world” (vs. 29),5 who would come next (vs. 30) and who would baptize with the Holy Spirit: “He on whom you see the Spirit descend and remain, this is he who baptizes with the Holy Spirit” (vs. 33). Nevertheless, in view of 3:34, it is probable that the evangelist also saw the episode in terms of a supernatural empowerment: “He whom God has sent utters the words of God, for He [God] gives the Spirit [unto the Son] without measure.” In order to baptize with the Spirit and give the Spirit to His disciples, Jesus had to be full of the Spirit, something that John, however, only seems to assume, possibly in connection to Jesus’ baptism itself.6 The fact that John never mentions Jesus performing miracles through the power of the Spirit may only have to do with his emphasis on Jesus’ divine nature, just as his silence about Jesus’ virginal birth seems to be due to the importance he gives to Jesus’ incarnation, which fits better the concept of preexistence.7 Notwithstanding, John is careful enough to tie Jesus’ miracles (sēmeia) not only to His divine sonship (the preexistent Son of God) but also to His messianic status (20:30-31), which somehow does preserve the notion of supernatural empowerment (cf. At 10:38). Once again, the evangelist may only be assuming that which is explicit in the other Gospels.
It is likely that the idea of empowerment is also present in Jesus’ act of breathing the Spirit on the disciples at the moment He entrusts to them the evangelical commission (John 20:21-22). It is true that nothing is said about the purpose of sending them into the world, and the comment that follows refers to the forgiveness of sins (vs. 23), but it is difficult to interpret the episode without relating it to Luke 24:45-49 (cf. Acts 1:8).8 Yet, the passage presents some difficulty in view of the descent of the Spirit at Pentecost, which has led several scholars to suggest two endowments of the Spirit: one to the believers in general, here represented by the disciples, and another ten days after the ascension (Acts 2). In the first case, as Brown argues, Jesus’ act of breathing (emphysaō) the Spirit would be an allusion to the creative breath of God mentioned in passages such as Gen 2:7 and Ezek 37:5-6 (cf. Wis 17:11). The meaning of the Johannine expression, then, would be that as God in the beginning breathed the spirit of life upon humanity, so in the moment of the new creation He breathes the Holy Spirit upon the disciples, granting them eternal life.9 Herman Ridderbos, on the other hand, though conceding that the reference is to the disciples’ empowerment for mission, does not see here any allusion to Pentecost, as in John 7:39. For him 20:22 speaks of a more limited giving of the Spirit to the disciples only, and not of His indistinct outpouring upon “all flesh” as in the episode of Acts 2 (cf. 17).10
The importance of John 7:39, however, cannot be underestimated. For John, the Spirit could not be given before the ascension and glorification of Jesus (cf. Acts 2:32-33); the glorification would be confirmation by the Father that the Son had completely fulfilled His mission (John 17:4-5). It is for this reason that it was to the disciples’ advantage that Jesus go to the Father (16:28), because if He did not go, the Spirit would not come (vs. 7).11 This explains Jesus’ expectation that the disciples would rejoice upon His departure (14:28; cf. 17:13). In addition, the missiological purpose of the gift in 20:22 cannot be ignored (cf. vss. 21-23), even if the emphasis falls on the forgiveness of sins. And, finally, there is no evidence that the disciples had initiated the apostolic mission except after Pentecost. On the contrary, they still nurtured doubts (vss. 24-25) and fear (vs. 26), and some of them even seemed tempted to return to their old occupations (21:1-3). The breathing of the Spirit in 20:22, therefore, perhaps should be taken merely as a symbolic anticipation, a kind of dramatized parable of something that would effectively be fulfilled only at Pentecost.12 And there is little if any question that the account had a theological motivation. According to James D. G. Dunn, by placing the gift of the Spirit at that moment, the apostle only wishes to affirm the continuity between Jesus and the Spirit. “The Spirit,” he says, “is the other Paraclete (14:16-17) whose coming fulfills Jesus’ promise to return and dwell in His disciples.”13
Jesus’ words that those who believed in Him would do the same works He did, and even greater ones, because He was going to the Father (John 14:12), also seem to refer to the empowerment by the Spirit, especially when they are read in connection to 7:39 and 16:7. It is true that the subject in 16:6 is not the performance of miracles (cf. vss. 8-14), but this only reinforces the observation that the supernatural empowerment by the Spirit in John is not present, but only in the background. On the other hand, it cannot really be argued that the “works” (erga) in 14:12 exclude miraculous signs,14 but even if the reference is restricted to evangelistic works, this would be enough to interpret the text in terms of the coming of the Spirit. “What Jesus means,” comments Leon Morris, “we may see in the narratives in Acts.”15 And what warrants such interpretation is the reference to the Son’s ascent to the Father, for the Spirit could not come while the Son was still on earth (7:39). The departure of the Son, therefore, was convenient to the disciples (16:7). It would allow this new phase of salvation history to be handled directly from heaven (14:28), thus avoiding the limitation imposed by the physical presence of Jesus.16
The Johannine presentation of the Holy Spirit takes on even more distinct contours in Jesus’ dialogue with Nicodemus (John 3:1-15). There the Spirit is presented as a source of spiritual renewal, a function virtually absent in the Synoptics, though known in Jewish tradition both biblical (Gen 2:7; Ezek 37:5-6, 14) and extra-biblical (Wis 17:11). The point that is stressed by such texts is that God brings (new) life through the activity of the Spirit (cf. Titus 3:5; 1 Pet 1:3, 23). It is in this sense that Jesus’ words to Nicodemus—“unless one is born of water and the Spirit, he cannot enter the kingdom of God” (John 3:5)—must be understood.17 The explanation is given next: “That which is born of the flesh is flesh, and that which is born of the Spirit is spirit” (vs. 6). “Flesh,” therefore, is the reality of the first birth, whereas “spirit” is the reality of the new birth (cf. vss. 3, 7).18 The idea is that, of themselves, humans do not possess spiritual life; such life is possible only through the inner operation of the Spirit of God.19 And the final dialogue highlights that the condition to be met to receive this life is to believe in (pisteuō eis) Jesus Christ (vs. 15). The believer, then, belongs to a different order from that of the natural human being. In the Gospel’s Prologue (1:1-18), John anticipates the concept of the two orders, one natural and one spiritual (vs. 13), as well as the role played by faith in allowing the person to move from one to the other (vs. 12c). In fact, nobody can pass from one to the other. Whoever is born in the natural order remains there unless he/she is born again.20 This change of order comes with a change of status: those who experience it become “children [tekna] of God” (vs. 12b). Both the new birth and the divine filiation, therefore, are gifts of the Spirit to those who believe in Jesus.21
Jesus’ words to Nicodemus connect “water” and “Spirit” (John 3:5), which seem to evoke the theme of baptism.22 Perhaps this is why baptism is mentioned in the same context (vss. 22-26).23 In John 7:38-39a, “water” and “Spirit” are once again mentioned together. “Whoever believes in me, as the Scripture has said, Out of his heart will flow rivers of living water. Now this he said,” John continues, “about the Spirit, whom those who believed in Him were to receive.” The difference, however, is that water here does not come with the Spirit (water + baptism), but represents a symbol for the Spirit (water = Spirit), whereas the future tense of the verb points to the Spirit’s dispensation, that is, to the new age in the history of salvation that would follow the ascension and glorification of Jesus, “for as yet the Spirit had not been given, because Jesus was not yet glorified” (vs. 39b). Whatever the specific meaning of waters flowing from within the believer (cf. 4:14), the notion of a renewing and transforming power cannot be altogether excluded.24 Jesus’ words refer to the abundant gift of the Spirit in the lives of those who believed in Him.25
Another passage that also seems related to Jesus’ dialogue with Nicodemus is 6:63: “It is the Spirit who gives life; the flesh is no help at all. The words that I have spoken to you are spirit and life.” The first part of the text is difficult, but there should be no question that pneuma there refers to the Holy Spirit and not to the human spirit, as the human spirit is in no way entitled to “give life” (zōopoieō).26 Such prerogative belongs only to God’s Spirit (Isa 40:6-8; 2 Cor 3:6; cf. John 5:21; 1 Cor 15:45). The subject matter in the previous verses (John 6:60-62) is the inability of those who were listening to Jesus to understand the teaching about His death. It is likely, then, that Jesus wanted to emphasize that the natural person (“flesh”), that is, the person not yet renewed by the Spirit, is indeed unable to understand the meaning of His death, for spiritual matters can only be discerned spiritually (cf. 1 Cor 2:6-16).27 If Jesus’ words are “spirit and life,” then only those who have been renewed by the Spirit and who now belong to the spiritual order are able to understand them completely. The following verse (John 6:64) resumes the theme of faith, making it implicit that only the lives of those who respond with faith can be renewed. Instead of rejecting Jesus as “the bread that came down from heaven” (vss. 41, 51, 58), who is the only One that can actually give life to the world (vs. 51), those who respond with faith allow the Spirit to operate their new birth and transform them in spiritual persons, thus enabling them to understand the meaning of Jesus’ death and to foretaste eternal life and the assurance of resurrection (vss. 27, 40, 47, 54).28
In John’s narrative sections, therefore, the Spirit is a life-giving power through whom God regenerates and transforms those who believe. Through the Spirit the believers are born again (3:3, 5-6), now as God’s children (1:12-13), receive life, and can understand spiritual matters (6:63; 7:37-38). In some instances, the symbol of water is used possibly in connection with baptism (3:5) and for the purpose of stressing the abundance of the gift of the Spirit that is available to those who believe (7:38-39a). The idea of supernatural empowerment, typical of the Synoptics, is also present, but always in the background. When this happens, John’s emphasis is more in the Spirit’s witness to Jesus (1:32-34), as well as in the forgiveness of sins through the authority of the Spirit (20:22-23). John is also clear enough about the time of the Spirit’s coming: Jesus would first have to be glorified (7:39b); otherwise, the Spirit could not come (16:7). For the evangelist, the dispensation of the Spirit cannot begin before Jesus finishes His work.29 The point, however, is not only chronological, but mainly teleological. The glorification of Jesus means the confirmation by the Father that the mission of the Son was successful (17:4-5; cf. Acts 2:33-36; Eph 4:7-10; Rev 5:1-14).30
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1 Besides “Paraclete,” other expressions used in the Farewell Discourses are “Spirit of Truth” and “Holy Spirit.” In the narrative sections, John refers almost exclusively to the “Spirit,” with no qualification of any kind. The only exception is John 1:33, where John the Baptist announces that Jesus would baptize with the “Holy Spirit.” It is interesting, therefore, that the only occasion outside chaps. 14-17 in which the evangelist uses terminology other than “Spirit,” is the reference to something that Jesus would do sometime (not specified) in the future.
2 In John there are nineteen references to the Spirit altogether, including those that relate to the Paraclete (14:16, 26; 15:26; 16:7), compared to twelve references in Matthew, six in Mark, and sixteen in Luke. In the case of the individual authors, Paul is the NT writer who most often refers to the Holy Spirit (114 times, including Hebrews); Luke comes next (106 times, most of them in Acts). No individual author, however, has contributed more to the church’s understanding of the person of the Holy Spirit than John, especially in the Gospel.
3 “It must be accepted that the major background for the synoptic presentation of the Spirit’s work is the OT” (Donald Guthrie, New Testament Theology [Downers Grove: InterVarsity, 1981], 525). On the basic concept of rûah in the OT, see M. V. van Pelt, W. C. Kaiser Jr., and D. I. Block, “Rûah,” NIDOTTE, 3:1073-1078.
4 This concise summary does not take into consideration several important questions about the Spirit in the Synoptic Gospels. For fuller discussions, see Guthrie, 514-526; C. K. Barrett, The Holy Spirit and the Gospel Tradition, 2d ed. (London: SPCK, 1966); and esp. Craig S. Keener, The Spirit in the Gospels and Acts: Divine Purity and Power (Peabody: Hendrickson, 1997).
5 Unless otherwise indicated, all biblical quotations are from the ESV.
6 The phrase “for he gives the Spirit without measure” (vs. 34b) is difficult, for neither the subject (whether the Father or the Son) nor the recipient (whether the Son or the believers) of the verb “to give” is mentioned. When it is read in connection with the following statement (vs. 35), however, the idea that it is the Father who gives the Spirit without measure and that it is the Son who receives it seems preferable. This is what most commentators think. For references, see Craig S. Keener, The Gospel of John: A Commentary, 2 vols. (Peabody: Hendrickson, 2003), 1:582-583.
7 Not that there is no room for the virgin birth in John’s theology, but “there exists no suggestion of pre-existence as with the concept of incarnation, whereby a figure who was previously with God takes on flesh” (Wilson Paroschi, Incarnation and Covenant in the Prologue to the Fourth Gospel (John 1:1-18), EUS [Frankfurt: Peter Lang, 2006], 9 n. 4). Raymond E. Brown adds: “Incarnational thought is indicative of pre-existence Christology … and works reflecting that Christology [cf. Phil 2:7; John 1:14] show no awareness of or interest in the manner of Jesus’ conception” (The Birth of the Messiah: A Commentary on the Infancy Narratives in the Gospels of Matthew and Luke, rev. ed., ABRL [New York: Doubleday, 1993], 141).
8 For Werner G. Kümmel, however, the gift of the Spirit in John 20:22 relates on to the forgiveness of sins. He argues that John “says nothing at all of the divine Spirit’s enabling one to perform miraculous deeds” (The Theology of the New Testament according to Its Major Witnesses: Jesus, Paul, John, trans. John W. Steely [Nashville: Abingdon, 1973], 313).
9 Raymond E. Brown, The Gospel according to John, 2 vols., AB (New York: Doubleday, 1966-1970), 2:1037.
10 Herman Ridderbos, The Gospel of John: A Theological Commentary, trans. John Vriend (Grand Rapids: Eerdmans, 1997), 643. Another possibility is that John was not aware of Pentecost: while Luke records the episode as having occurred ten days after Jesus’ ascension, John thought it had taken place later on the resurrection day (so, C. K. Barrett, The Gospel according to St. John, 2d ed. [Philadelphia: Westminster, 1978], 570). Though convenient to a sectarian view of John’s Gospel, still rather common in some circles, this hypothesis is definitely not the best way to understand the peculiarities of Johannine theology. On the relationship between John’s Gospel and Christian tradition as it appears elsewhere in the NT writings, see Stephen S. Smalley, John: Evangelist and Interpreter, 2d ed., NTP (Downers Grove: InterVarsity, 1998), 187-229.
11 John frequently associates Jesus’ glorification with His departure from the world (7:39; 12:16, 23; 13:31-32; 16:14; 17:1, 5, 24) or with His “hour” (12:23, 27-28; 17:1), which is normally interpreted in relation to Jesus’ death (e.g., Rudolf Schnackenburg, The Gospel according to St. John, 3 vols., trans. Kevin Smyth et al. [New York: Herder & Herder, 1968-1982], 2:382-383). Godfrey C. Nicholson, however, has convicingly shown that “the hōra of Jesus in the Fourth Gospel is not the hour of His death, but the hour of His return to the Father, in which hour the death played a part” (Death as Departure: The Johannine Descent-Ascent Schema, SBLDS 63 [Chico: Scholars, 1983], 147). He adds: “Just as the hōra of Jesus is not a reference to His death but to His return above to the Father, so too the ‘glorification of the Son of man’ does not refer to the death of Jesus but to something which the Father does to the Son, either coincident with or subsequent to, the return of Jesus above” (ibid., 149). For further information and references, see Paroschi, Incarnation and Covenant in the Prologue to the Fourth Gospel, 140.
12 George E. Ladd, A Theology of the New Testament, rev. ed. (Grand Rapids: Eerdmans, 1993), 325. D. A. Carson adds: “Unless one adopts a literalistic and mechanical view of the action, understanding the Holy Spirit to be nothing less than Jesus’ expelled air, one is forced to say that the ‘breathing’ was symbolic” (The Gospel according to John [Grand Rapids: Eerdmans, 1991], 652).
13 James D. G. Dunn, Christ and the Spirit, 2 vols. (Grand Rapids: Eerdmans, 1998), 2:214. Rudolf Bultmann says basically the same, though he certainly goes too far when he declares that, by combining Jesus’ resurrection (or return) with the gift of the Spirit (14:16-20, 21-26; 16:12-24), John is reinterpreting “the traditional motif of the expectation of the Parousia,” stripping it “of its original mythological character” (The Gospel of John: A Commentary, trans. G. R. Beasley-Murray [Philadelphia: Westminster, 1971], 585-586). Based on texts such as John 14:3 and 21:22 (cf. 1 John 3:2), however, Ladd concludes that “Jesus’ words about coming in the Paraclete and his eschatological coming reflect the tension between realized and futuristic eschatology” (340).
14 There is a tendency to limit such “works” to the missionary accomplishments of the apostolic church (for references, see Francis J. Moloney, The Gospel of John, SPS 4 [Collegeville: Liturgical, 1998], 399), but in John the term erga generally refers to the miraculous signs of Jesus (5:20, 36; 7:3; 9:3-4; 10:25, 32-33, 37-38; 14:10-12; 15:24), whereas the singular ergon describes His mission as a whole (4:34; 17:4). See discussion by Keener, The Gospel of John, 2:946-947.
15 Leon Morris, The Gospel according to John, rev. ed., NICNT (Grand Rapids: Eerdmans, 1995), 574. See also C. K. Barrett, “The Parallels between Acts and John,” in Exploring the Gospel of John: In Honor of D. Moody Smith, ed. R. Alan Culpepper and C. Clifton Black (Louisville: WJK. 1996), esp. 171-172.
16 The statement “the Father is greater than I” (John 14:28) is difficult from the Trinitarian perspective. The reference, however, is usually understood to be functional, i.e., with regard to the incarnate state of Jesus, rather than ontological. That is, it must be seen together with 10:30: “I and the Father are one.” Ridderbos explains: “That the Father is ‘more’ than Jesus means only that His return to the Father is the beginning of a new dispensation of grace, one based in heaven and therefore coming down from the Father. This new dispensation will exceed the limitations of the dispensation represented by Jesus’ presence on earth (cf. vs. 12), just as the glory that Jesus will receive as the Son who returns to the Father will be greater than His earthly glory (17:5, 24), even though both issue from His oneness with the Father” (512).
17 The closest Synoptic parallel is Mark 10:15 (=Luke 18:3): “Truly, I say to you, whoever does not receive the kingdom of God like a child shall not enter it.” Though the form is similar, there is no mention of spiritual rebirth, but only the metaphorical use of “child” to express the concept of discipleship.
18 The Greek anōthen (vs. 3) may mean “again/anew” or “from above.” Nicodemus understood it as “again” (vs. 4), but the most common meaning, also in John (3:31; 19:11, 23), is “from above;” this is also the meaning that fits better the vertical dualism of the Gospel (3:13, 31; 6:33, 38, 41, 50, 51, 58, 62; 8:23). Anyway, being born “from above” implies being born “again,” though not the way Nicodemus understood it. Some even say that this is one of the several instances in which John intentionally uses words with a double meaning (e.g., E. Richard, “Expressions of Double Meaning and Their Function in the Gospel of John,” NTS 31 [1985]: 96-112, esp. 103).
19 Ladd, 326.
20 “There is no evolution from flesh to spirit” (Edwyn C. Hoskyns, The Fourth Gospel, 2d ed., ed. Francis N. Davey [London: Faber & Faber, 1947], 204).
21 Note how vss. 12-13 combine the idea of divine filiation with that of (new) birth, which means that, for John, the child is the one who was born again (“of God” or “of the Spirit”). The relation between divine filiation and the Spirit, however, is more explicit in Paul than in John (cf. Rom 8:15-17; Gal 4:6).
22 So, Kümmel, 312-313; Keener, The Gospel of John, 1:546-550.
23 It is likely that in vs. 5 Jesus is making an allusion to proselyte baptism as practiced by Judaism; otherwise, His words would not make much sense to Nicodemus. To Christian readers of the end of the first century, however, which supposedly was when John’s Gospel was written, it is impossible that such words would not be seen in association with Christian baptism. For a brief discussion concerning whether proselyte baptism already existed in the first century, see Wilson Paroschi, “Acts 19:1-7 Reconsidered in Light of Paul’s Theology of Baptism,” AUSS 47 (2009): 80 n. 35.
24 “The reference is to the refreshment and renewal of ‘the inner person’” (Ridderbos, 274). Some scholars have suggested a different punctuation for John 7:38-39, one that makes Christ, not the believer, the source of such “rivers of living water” (e.g., C. H. Dodd, The Interpretation of the Fourth Gospel [Cambridge: Cambridge University Press, 1953], 349). Even so, the notion of a life-giving and transforming power remains unchanged.
25 Besides punctuation, vss. 38-39 present a second problem: there is no Scripture that speaks of living water flowing from the believer’s heart (or of Christ, in case the alternative punctuation is adopted). What we have are passages such as Ezek 47:1-12, Joel 3:18, and Zech 14:8 that come a bit closer, but not to the point of matching Jesus’ statement. For a brief analysis of the several solutions that have been suggested, see Keener, The Gospel of John, 1:724-730. For a comprehensive and well-documented study, see Germain Bienaimé, “L’annonce des fleuves d’eau vive en Jean 7:37-39,” RTL 21 (1990): 281-310, 417-454.
26 In the KJV and the NRSV, “spirit” appears in lowercase, making it a reference to the human spirit (cf. NKJV).
27 So, Andreas J. Köstenberger, John, ECNT (Grand Rapids: Baker, 2004), 219.
28 Marianne M. Thompson comments: “If the Spirit is not given until after Jesus’ death, what then are the implications for eceiving life from Jesus during the time of His ministry? For elsewhere Jesus refers to His words as ‘spirit and life’ (6:63) and speaks of the life He confers as a present reality (“Whoever believes in the Son has eternal life,” 3:36; cf. 5:24; 6:47). Jesus warns that unless one is ‘born by the Spirit,’ that person will never receive life. To the extent that the Spirit and life are identified with each other, then the actual reception of life seems to be deferred until after Jesus’ death. Consequently, when Jesus speaks of giving life (e.g., 3:5-8; 6:63), He speaks proleptically of a situation that will obtain only after His death. Similarly, Jesus’ gift of the Spirit is subsequent to His death and glorification. Jesus’ death and resurrection seal the effects of His ministry” (The God of the Gospel of John [Grand Rapids: Eerdmans, 2001], 178).
29 “What the evangelist means is that the Spirit of the dawning kingdom comes as the result—indeed, the entailment—of the Son’s completed work, and up to that point, the Holy Spirit was not given in the full, Christian sense of the term” (Carson, 329).
30 Two other passages that are sometimes interpreted in connection with the Holy Spirit are John 4:23-24 (“in spirit and truth”) and 19:30 (Jesus “released the spirit”) (so, Andrew T. Lincoln, The Gospel according to Saint John, BNTC [Peabody: Hendrickson, 2005], 177-178, 478). In both cases, however, the arguments are not sufficiently convincing (see Morris, 239-240, 720-721).