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Rom. 3:28 For we maintain that a man is justified by faith apart from observing the law.
James 2:24 You see that a person is justified by what he does and not by faith alone.
The alleged disagreement between James and Paul has formed the ground for a variety of theories, ranging from Baur's seminal "faith vs works split in early Christianity" to Robert Eisenman's attempts to make Romans 14:2 a polemic by Paul against James' supposed vegetarianism (evidenced only by later 2nd century documents). We have looked at the "Peter vs. Paul" aspect of that argument at Link 1 below, and now we look at this other alleged disagreement.
To begin, those who see division on this matter are not mindful of the underlying premise of Semitic Totality (Link 2 below) within which James and Paul worked. Briefly, under this rubric, one's faith always and inexorably, if a real and living faith, resulted in works. This is clear in James, as we will see. It is also clear in Paul's numerous admonitions to believers to realize their position in Christ and behave themselves accordingly.
Now let us consider the contextual matters of each verse. Paul's thrust in Romans 3 is that "by the deeds of the law there shall no flesh be justified in his sight: for by the law is the knowledge of sin." (3:20) The essence: No one shall be justified by doing the law, because no one does the law.! We all violate it at some point.
Paul is therefore speaking of a time prior to conversion and a commitment of faith. James 2:10 makes the sentiment even more perilous: "For whosoever shall keep the whole law, and yet offend in one point, he is guilty of all."
And is not James writing to correct bad behavior and therefore what Paul would consider violations of the law? The two men are in perfect agreement thus far: The law does not save, because no one is able to perfectly fulfill it.
But what of James' supposed "reply"? James' own interpretive key os James 2:17, "Even so faith, if it hath not works, is dead, being alone." That word "dead" says it all. Under Semitic Totality, someone who does not do works clearly has no faith to speak of, none that is living. Paul's admonitions to good behavior would find no more matching sentiment than James 1:22-24:
But be ye doers of the word, and not hearers only, deceiving your own selves. For if any be a hearer of the word, and not a doer, he is like unto a man beholding his natural face in a glass: For he beholdeth himself, and goeth his way, and straightway forgetteth what manner of man he was.
This passage is also offering an expression of Semitic Totality that could hardly be clearer. "Hearers" who are not "doers" are deceiving themselves, not knowing what they are really like, just like the "man in the mirror" does not know his own appearance.
And there is more. Paul and James are NOT even addressing the same issues. Paul is teaching justification over and against specific observation of the Jewish law, such as circumcision (Rom. 3:1), and doing so with reference to a person prior to conversion. James is advocating the practical outworking of faith (i.e. validation) through generally moral behavior, but not through anything uniquely associated with the Jewish law, and after conversion.
Is there any mention of circumcision or Jewish holidays in James? No -- he is concerned with caring for the poor, treating all people fairly, and holding one's tongue in check, once one is a believer. Quite simply, as Letham puts it, "The works of faith which James advocates are different from the works of the law that Paul condemns."
Let's explain it in more detail. The OT law was no cold moral code; it was a written and temporal expression of God's moral law that permeated the universe. Paul knew this (Romans 1-2) as did every other rabbinic exegete before and since.
The legalists of Paul's time, however, had the idea that "if we just followed the law to the letter" they would please God through their strict adherence and the OT promises would come true (we call this today "covenantal nomism"). Thus, to the Roman church, Paul stresses the universality behind the code; he emphasizes that the purpose of the code was to increase consciousness of sin (3:19-20) - as opposed to those who asserted that following the letter, to the point of circumcision (4:9-12), was what was the key to salvation. (Note that this resembles the Galatian heresy Paul fought, and within which he did not implicate James.)
He points out, through his example of Abraham, that faith came first and was given credit, for after all, Abraham was counted as righteous before Moses saw the light of day! (4:9ff) Thus it can NOT be following the bare moral code that leads to salvation.
In contrast, James says not a word about circumcision or following the written code. He speaks of application as a result of a living faith, after putative conversion. Nor does he use Abraham's following of the "law" as proof of his righteousness: He points to his validating actions that proved his faith in God. Paul and James are talking apples and oranges here. They are answering different questions - and their answers are harmonious.