---

(2026)

I. Introduction
II. A Matter of Trust
III. Volume 1: Evidences; and Volume 2: Refutations
     1. Significant Omissions
            a. Legal Apologetics
            b. Missing Arguments
     2. Definitions
     3. Burden of Proof—Naturalistic Theories
     4. Undisputed or Irrelevant Issues
            a. Straw Men
            b. Historiography
     5. Miracles
     6. Two-Step Argument
     7. Special Pleading
IV. Volume 3: Scholarly Perspectives
     1. Reference Book
     2. No Evidence of “Vast Majority” of Scholars
V. Volume 4: Theology and Practice
VI. Conclusion

Review: Gary Habermas. 2024-2025. On the Resurrection, Volumes 1-4. Brentwood, TN: B & H Academic. 1072 pp. [Vol. 1]; 896 pp. [Vol. 2]; 992 pp. [Vol. 3]; 720 pp. [Vol. 4].

I. Introduction

Gary Habermas pioneered his influential “minimal facts approach” (MFA) for proving Jesus’ resurrection in his 1976 dissertation. Habermas asserts that a few facts accepted by even skeptical scholars are sufficient to prove that Jesus rose from the dead. He has spent the last fifty years researching and writing about this theory, and he has now published his four-volume magnum opus on the subject.

In my opinion his On the Resurrection is dense, verbose, and poorly reasoned. I will discuss some examples that I hope will make my point. However, this is a book review, not a comprehensive critique or response.

I must confess that I did not read every word of these tomes. The four volumes total 3,712 pages and about 15 pounds. But I have already read several of Habermas’ books and essays, and I spent many fruitless hours searching for anything new or interesting in this most recent work. With that background knowledge I read enough to get the gist of them.

I also purchased the searchable Kindle versions of the first three volumes to focus on certain specific issues. For example, I can quickly find all twenty-four times that the first three volumes use the word “legal” and that they never use the word “juridical.” This is how I can make sweeping statements about Habermas never so much as mentioning legal apologetics. The pagination of the Kindle books differ from the print editions because Kindle uses endnotes and the hardcovers use footnotes. My citations use the page numbers of the hardcover editions.

On the Resurrection consists of four volumes:

Volume 1: Evidences
Volume 2: Refutations
Volume 3: Scholarly Perspectives
Volume 4: Theology and Practice

As my title indicates, this review evaluates On the Resurrection from a lawyer’s point of view. Most of this review addresses the first seventeen chapters of volume 1 because those pages are most relevant to legal apologetics.

Most contemporary evangelical apologists make similar arguments—for example, “no one dies for a lie.” Habermas makes the usual arguments, and I have already responded to most of them in five previous articles:

You be the Judge: An Unopposed Brief Challenging Legal Apologetics
A Lawyer Evaluates Evidence of Supernatural Events
A Lawyer Evaluates the Minimal Facts Approach
A Lawyer Evaluates Philosophical Arguments for Miracles
Simon Greenleaf and the Atheist Professor Urban Legend

Habermas’ supposed evidence of the Resurrection would not stand up in a court of law, but to be fair, he has never claimed that it would. Nonetheless, I believe that legal analysis provides a valuable perspective on evidentiary issues.

II. A Matter of Trust

I discussed in a previous essay how the authorities that Habermas cited in footnotes did not support his claims. In On the Resurrection Habermas still mischaracterizes the opinions of skeptical scholars, but he is now a bit more subtle about it.

Foremost among the biblical historians misrepresented by Habermas is Bart Ehrman. Habermas cites Ehrman over 270 times in the first three volumes—about twice as much as that of anyone else in the author index. For example, Habermas claims that:

[Ehrman] agreed that the disciples certainly had real experiences that they thought were experiences of the risen Jesus, which he calls “a matter of public record … it is a historical fact.[1]

But Ehrman actually wrote:

Christianity is not the resurrection of Jesus, but the belief of the resurrection of Jesus. Historians, of course, have no difficulty whatsoever speaking about the belief in Jesus’ resurrection, since this is a matter of public record. For it is a historical fact that some of Jesus’ followers came to believe that he had been raised from the dead shortly after his execution [emphasis added].[2]

There is a big difference between “the disciples” and “some of Jesus’ followers.” “The disciples” implies that all the disciples had “real experiences.” Ehrman actually wrote that his “tentative suggestion is that three or four people—though possibly more—had visions of Jesus sometime after he died.”[3]

And what exactly does Habermas mean by “real experiences?” “Real” implies that the experience actually happened, and was not imagined. Ehrman wrote that people had “visions,” and he explained exactly what he meant by the word.[4] Why does Habermas use an ambiguous and undefined term to describe Ehrman’s opinion when Ehrman was so precise?

Although I do not question Habermas’ sincerity or integrity, the plain fact is that you cannot trust that his citations support his text. I suspect that Habermas may be hampered by tunnel vision, but that may be the pot calling the kettle black—tunnel vision being an occupational hazard for advocates.

III. Volume 1: Evidences; and Volume 2: Refutations

Volumes 1 and 2 concern Habermas’ alleged evidence for Jesus’ resurrection, and the response of critical scholars to the claim that such evidence proves the Resurrection, respectively. I will discuss these volumes together.

1. Significant Omissions

Justice Frank M. Coffin, former Chief Judge of the United States Court of Appeals for the First Circuit, wrote: “The most telling discovery a judge can make is that a brief has neglected to deal with an issue.”[5] Justice Coffin understood that people who have no intelligent response to an argument will often remain silent rather than say something transparently stupid. Lawyers often resort to this ploy when the law and/or facts are against them.

Habermas wrote that “the present work makes no pretense to being exhaustive.”[6] Nonetheless, one has to think that he might have found room to discuss some of the issues sketched below.

a. Legal Apologetics

Dutch jurist Hugo Grotius wrote On the Truth of the Christian Religion in 1622. In his overview of the history of legal apologetics, William P. Broughton notes: “Several salient features of legal apologetics as it exists today, including its structure and focus on the resurrection, can be traced back to this seminal work.”[7] Habermas and other evidential apologists fail to acknowledge their debt to Grotius and legal apologists such as Thomas Sherlock and Simon Greenleaf.

The recently deceased John Warwick Montgomery was the leading legal apologist of recent times. He wrote quite forcefully about the superiority of legal apologetics:

The advantage of a jurisprudential approach lies in the difficulty of jettisoning it: legal standards of evidence developed as essential means of resolving the most intractable disputes in society (dispute settlement by self-help—the only alternative to adjudication—will tear any society apart). Thus one cannot very well throw out legal reasoning merely because its application to Christianity results in a verdict for the Christian faith.”[8]

I agree. However, the same logic means that one cannot throw out legal reasoning merely because its application results in a verdict against the Christian faith.

Legal rules of evidence are particularly appropriate for resolving historical issues because historians have no clear and binding rules of their own:

Specific canons of historical proof are neither widely observed nor generally agreed upon. There is no historiographical Wigmore … and no body of precedents recognized as reliable guide.[9]

As Michael Licona notes, “every critic is inclined to make his own rules.”[10] Applying legal rules of evidence brings clarity and order to an otherwise lawless endeavor.

But Habermas never so much as mentions legal apologetics in On the Resurrection. He cites Montgomery on a couple of noncontroversial points, but says nothing about his advocacy for legal apologetics. Habermas devoted two chapters in volume 2 to the eighteenth-century Scottish philosopher David Hume and four chapters to nineteenth-century critics, yet apparently could not find the space to acknowledge the existence of legal apologetics. It seems to me that the legal apologetics of Montgomery—and the roots of evidential apologetics in Grotius, Sherlock, and Greenleaf—are a lot more relevant to modern readers than the nineteenth-century higher criticism found in David Strauss’ theories about the historical Jesus.

I emailed Habermas asking him why he made no mention of Montgomery or legal apologetics. And I’m grateful that he replied to my email. I have sent numerous letters and emails to Christian lawyers and apologists in my fruitless search for a debate opponent. Habermas and Montgomery (before his death) are the only ones who gave me the courtesy of a response. Habermas and I believe that people with different beliefs can engage in a civil discussion.

As I read between the lines in his private reply, his position is vulnerable to attack, so he simply ignored the issue. But he had other options.

In Volume 3: Scholarly Perspectives, Habermas explained that—in that volume—he presented the sometimes conflicting views of scholars with no editorial comment or attempt to reconcile them. His purpose was chiefly to present a scholarly “lay of the land.”[11] However, he did not include a single scholarly perspective by Montgomery or any other legal apologist. Habermas could have reported some of Montgomery’s positions without expressing a legal opinion.

b. Missing Arguments

Evidential apologists have had pretty much the same evidence to work with for the last two millennia—mostly early Christian documents. Archeological discoveries—such as the Dead Sea Scrolls—have not changed the fact that the primary evidence for Jesus’ resurrection is still the New Testament.

We should therefore not be surprised that apologists with the same goal (proving Jesus’ resurrection) and the same evidence often make the same arguments. No work of evidential apologetics would be complete without the “no one dies for a lie” argument. As Robert M. Price observes, “traditional apologetics have now become as fully a part of the evangelical creed as the doctrines they are meant to defend!”[12]

However, Habermas does not address at least eight of these standard arguments. I have already covered seven of them:

• Fulfilled prophecy
• Historical details
• Legendary development
• Ring of truth
• Christianity’s success
• Parol evidence rule
• Functional equivalence of cross-examination

In addition to these seven arguments, Habermas ignores one more alleged proof of the Resurrection (for a grand total of eight): the appeal to authority. Some of the most popular apologists, such as Lee Strobel, Josh McDowell, Norman Geisler, and Frank Turek—along with several bloggers—assert that many eminent lawyers believe that evidence supports the Resurrection, and therefore you should believe it, too. I have written about a similar appeal to authority in the context of an evangelegend.

My guess is that Habermas considers all eight of these omitted arguments unworthy of discussion by academics like himself. He wrote that:

[T]he fulfilled prophecy has almost dropped completely off the stage in scholarly discussions in the twentieth and twenty-first centuries, at least in other than popular circles where it is still employed [footnote omitted].[13]

I believe that Habermas would probably say the same thing about the other seven omitted arguments. Real scholars do not stoop to recognize these silly ideas bandied about in “popular circles.” Habermas discussed who he considers to be “critical scholars” that should be included in discussions about evidence for the Resurrection. Although he allowed “many exceptions,” he prefers academics who:

1. Hold a research doctorate in a relevant field;
2. Occupy a related teaching position; and
3. Have peer-reviewed publications.[14]

Other than Montgomery (who argues for the parol evidence rule and the functional equivalence of cross-examination), I know of no such academics who espouse any of the eight omitted arguments. Montgomery had impeccable academic credentials, but Habermas apparently could not discuss such arguments because they involve legal apologetics.

2. Definitions

Habermas’ writing would be easier to follow if he had included a glossary—especially because he makes up new meanings for words. For example, Habermas devotes chapter 2 of volume 1 to “Historiography: The Tools and Rules of the Discipline,” but he never defines exactly what he means by “tools” or identifies anything that a lawyer might consider a “rule.” He writes that:

[T]he historical tools are the materials with which the historian must work to accomplish her goals regarding the sifting of past remains so as to present the most likely scenarios. Whether eyewitness reports, traditions of various sorts, written or printed records, or archeological artifacts, these sources of information are exceptionally vital data upon which sometimes crucial decisions are rendered.[15]

This explanation seems to be a long-winded and pretentious way of saying that “tools” are synonymous with “evidence.”[16] The Federal Rules of Evidence do not define “evidence,” and courts use the plain English meaning of the word. The written or printed records and archeological artifacts, which Habermas calls “tools,” are called “evidence” in any court.

Habermas writes that there is little disagreement about “what we have termed the ‘tools’ of research.”[17] This statement acknowledges that he made up a new meaning for the word “tools.” There is nothing wrong with historians inventing specialized meanings for words, but it would certainly help if Habermas defined any terms he uses in an idiosyncratic way.

Likewise, Habermas never defines exactly what he means by the term “rules.” Habermas claims that historians “take different paths on moving from the tools to the rules.”[18] However, he identifies no other historians who have found such paths. Nonetheless, I think that I have figured out what Habermas means when he says “rules.” He enumerates eight “criteria of authenticity”[19]:

1. Early sources
2. Eyewitness testimony
3. Multiple attestations
4. Dissimilarity
5. Palestinian origin
6. Embarrassment
7. Enemy attestation
8. Coherence

He also refers to these “criteria of authenticity” as “authenticity criteria”[20], “textual criteria of authenticity”[21], “critical criteria”[22], “historical criteria”[23], or simply “these criteria”[24], but these terms all refer to the same eight enumerated criteria. Habermas also explains that:

The textual criteria of authenticity are the rules that support the likelihood of particular sayings or events in history, in this case, from the life of Jesus [emphasis added].[25]

Clear and simple definitions for “criteria” and “rules” may be somewhat slippery, but they do not mean the same thing. In my opinion, Habermas’ “criteria” and “rules” are neither criteria nor rules. Instead, each of them is a purported basis for an inference.

For example, Habermas explains that contemporaneous or early sources are better than later data.[26] Habermas contends that the New Testament is based on early sources, and that you can therefore infer that it is more likely to be accurate than if the authors had used later data.

3. Burden of Proof—Naturalistic Theories

Habermas believes that skeptics bear the burden to provide naturalistic explanations for the Resurrection. I touched on this issue in three previous essays—on evidence of supernatural events, philosophical arguments for miracles, and the minimal facts approach. Therefore, I will here focus on one issue that I have not previously covered—speculation.

Habermas asserts that critics “are unable to come up with a coherent and plausible story that accounts for the evidence at hand.”[27] I have previously discussed why I believe that “the evidence at hand” is insufficient and that it is disingenuous for evidentialists like Habermas to claim that skeptics have no naturalistic explanations for such evidence.

He adds that few skeptics “have been willing to choose a single natural proposal and move forward with it, perhaps implying an unwillingness to chance having that view dismantled.”[28] On the other hand, perhaps they simply did not have enough evidence to form an opinion.

Habermas is quite condescending to skeptical scholars who do not limit themselves to a single theory about the Resurrection. At minute 26 of this Ultimate Resurrection Panel video Habermas brags about goading an atheist to pick a theory. An instance using Bart Ehrman as an example illustrates why I believe that Habermas’ superior attitude is undeserved.

In How Jesus Became God: The Exaltation of a Jewish Preacher from Galilee, Ehrman discussed alternative theories for why Jesus’ tomb—if it ever existed—might have been empty, and then he explained “I don’t subscribe to any of these alternative views because I don’t think we know what happened to the body of Jesus.”[29] Habermas ridicules Ehrman for his unwillingness “to choose a specific naturalistic comeback” to belief in the empty tomb.[30] Habermas implies that there is something deceptive or evasive about believing that insufficient evidence exists to reach a conclusion.

From a legal standpoint, Ehrman is an expert witness and is qualified to testify about his opinions. However, an expert must base his opinions on sufficient evidence.[31] Opinions that are not based on facts or data are mere speculation, and courts do not allow such testimony.

In layman’s language, Ehrman refused to speculate when he did not have the facts to back up an opinion. In court—or anywhere else—getting the facts straight before spouting opinions is a good thing. Habermas cannot seem to get his mind wrapped around the idea that we should reserve judgment when we do not have sufficient evidence to reach a conclusion.

Habermas here commits a logical fallacy known as a false dilemma or false dichotomy. A false dilemma depends on a faulty premise—considering only two possible choices out of many possibilities. Allowing only a disjunctive choice between two alternatives is valid only if the choices are mutually exclusive. Habermas’ insistence that skeptics “choose a specific naturalistic comeback” limits the discussion to two possibilities when there is actually an ocean of possibilities.

4. Undisputed or Irrelevant Issues

Habermas explains:

These present volumes are chiefly concerned with the philosophical and historical issues relevant to whether or not, and in what sense, the resurrection of Jesus really occurred.[32]

However, he spills a great deal of ink on issues that contribute more to the length of the books than they do to the likelihood of the Resurrection.

a. Straw Men

Habermas makes many claims that are similar to straw man fallacies. A true straw man fallacy mischaracterizes an opponent’s position and attacks the mischaracterization—an argument that the opponent never made. Habermas’ arguments are not quite so dishonest. However, he devotes hundreds of pages to knocking down arguments that few critical scholars make today. For example, Habermas discredits the swoon theory of the Resurrection even though it was rarely used after 1864 and is now (other than in an entertaining independent film) “only a curiosity of the past.”[33] Beating a dead horse is a waste of time, even if it is an opponent’s horse.

Before a trial in federal court, parties must submit to the judge a statement of disputed and undisputed issues of law and fact. This allows the court to focus on the disputed issues without wasting time on undisputed matters. Likewise, most critical scholars do not dispute many of Habermas’ assertions. The following claims are probably true:

• Jesus was not a mythical dying and rising god.
• He existed.
• He lived in Judea.
• The Romans crucified him.
• He died on the cross.
• Some of Jesus’ disciples came to believe that Jesus was raised from the dead shortly after his crucifixion.
• Although some epistles are forgeries[34], the New Revised Standard Version (NRSV) of the New Testament is a reasonably accurate reconstruction and translation of the original Greek manuscripts.
• Paul had some sort of experience on the road to Damascus.
• Christians’ belief in Jesus’ resurrection turned the world on its ear.

None of these agreed facts require a resurrection or any other supernatural explanation.

b. Historiography

Chapters 1 and 3 of volume 1 illustrate the redundant and verbose nature of this four-volume project. Habermas posits in chapter 1 that:

Logically, before the study of various historical epochs, key individuals, important times, and influential ideas throughout the centuries, a smaller number of scholars also discuss the far more theoretical areas of meta history.[35]

I interpret this to mean that a small number of deep thinkers must discuss how and why history is written before less sophisticated historians can research and write about mundane facts like names, dates, and events. In chapter 1 of volume 1 Habermas discusses many thorny philosophical issues and concludes that, with sufficient evidence, historians can establish that some events in the past probably happened. Habermas also writes that no one really disputes this conclusion, which seems to make this chapter rather pointless.[36]

In chapter 3 Habermas defines postmodernism as “a term used to describe several trends of thought involving the more or less radical questioning of objective knowledge across differing disciplines.”[37] After much deep and dense analysis, Habermas concludes that historians can research the past and sometimes decide what probably happened.[38] Since Habermas had already reached this conclusion in chapter 1, I do not see the point of chapter 3.

5. Miracles

According to historian C. Behan McCullagh, “[h]istorians simply assume, as do most people, that the world is logically and materially consistent, so that for beliefs about it to be true, they must refer to compatible events and states of affairs.”[39] In contrast, Habermas asserts that:

The concept of a miracle is an elusive one. We all know roughly what it is and we can easily cite some well-known examples. Yet we struggle to state a precise definition. In fact, the proper definition of a miracle has been a matter of dispute among philosophers for centuries.[40]

Habermas is quite condescending to skeptical scholars who do not engage in such philosophical diversions:

[N]aturalistic and similar views such as those of Ehrman … along with many others sometimes exhibit a startling lack of philosophical perspective and introspection. Why should their assumption of naturalism’s truth be allowed to stand solely because they have repeatedly asserted that this is so? Further, how can such a fideistic[41] “foundation” then be allowed to judge all other worldviews, including those that are supported by arguments? This is simply a stunningly evasive maneuver.[42]

This is a straw man argument. Ehrman has never assumed “naturalism’s truth.” Instead, he has consistently maintained that historians cannot prove that miracles happened. Ehrman’s position is crystal clear:

Let me be clear at the outset: I am not saying that Jesus—or Apollonius of Tyana or Hanina ben Dosa or anyone else—did not perform miracles. I’m saying that even if they did, the historian cannot demonstrate it.[43]

Ehrman’s position is analogous to how courts treat miracles. No court has ever held that miracles do not happen. However, even if a miracle did happen, lawyers could not prove it because the physical facts rule bars evidence of events that could not have occurred under natural or scientific laws. Habermas may consider this a stunningly evasive maneuver, but courts do not quibble over philosophical issues when applying this well-established rule.

6. Two-Step Argument

Habermas might accuse me of putting words in his mouth because he never explicitly describes the “minimal facts approach” (MFA) as a two-step process. However, it is “implicit” in his argument. He writes:

Two commonly mentioned methods in historical investigation (and in other subjects too) that frequently overlap are induction and abduction (with the latter also being called “inference to the best explanation”)…. Abduction applies conditions such as explanatory scope, explanatory power, plausibility, less ad hoc, and conformity to other beliefs. A number of these and similar applications are implicit throughout the investigation that follows in these volumes [emphasis added].[44]

The Merriam-Webster Dictionary tells me that implicit means “capable of being understood from something else though not clearly or directly stated.” “Implicit” is an accurate description of Habermas’ argument; he never clearly or directly states that he is using inference to the best explanation, but he claims that it can be understood “throughout the investigation.”

Therefore, Habermas recognizes that there are two steps in his argument. First, he uses the “textual criteria of authenticity” (such as early sources, multiple attestation, etc.) to infer that the minimal facts are true. Second, he “applies conditions such as explanatory scope” to infer that the Resurrection is the best explanation for the minimal facts.[45]

One would think that in such a lengthy and comprehensive volume, Habermas would make an explicit argument on an essential step in his case. Licona devotes 142 pages to inference to the best explanation in his book on the Resurrection.[46] In my opinion Licona’s abductive reasoning does not hold water, but at least he reveals his reasoning.

Even if Habermas could establish the minimal facts, there exists a huge gap between those facts and the conclusion that Jesus rose from the dead. Habermas leaves this gap in his case. He mentions inference to the best explanation only in two cryptic comments.

First, Habermas posits that Jesus performed healings and exorcisms, and “there are plenty of data to solve this issue by taking the historical route of inference to the best explanation.”[47] What is this “historical route” of which he writes? I thought that the whole four-volume doorstop was supposed to be a historical route.

Second, Habermas asserts that alternative theories (like the swoon theory) fail and that the “more these natural options fail, the more Jesus’ appearances emerge as the best historical explanation.”[48] This is eliminative induction—a method of reasoning famously employed by Sherlock Holmes. The fictional detective said: “If one has ruled out all impossible cases, then whatever remains, no matter how improbable, must be the truth.”

This is a valid type of reasoning, but it rests on the assumption that one can identify all possible explanations. I explained in a previous article why this reasoning would not fly in court.

7. Special Pleading

McCullagh identified three main theories regarding how historians attempt to forge accurate narratives out of the available evidence, and inference to the best explanation is the most popular one.[49] The MFA is a variation of the argument to the best explanation. If the MFA were a better way to resolve historical issues regarding Jesus, then it should also be valid in other subjects like medieval or Chinese history. However, so far as I know, Habermas and other Christian apologists who have followed his lead are the only people to adopt the MFA.

Furthermore, Christian apologists use the MFA only for Jesus’ resurrection. Apologists weigh in on numerous historical issues, such as the martyrdom of the Apostles. However, they never identify any minimal facts that would prove common Christian myths like the upside down crucifixion of Peter. Using the MFA for the Resurrection and only for the Resurrection is special pleading.

Habermas claims:

Another noteworthy elucidation is that these criteria are not specifically New Testament tools per se. Rather, these delimitations have also been used by secular historians. This is hardly surprising given that this enterprise is of a historical nature.[50]

Habermas cites three “secular historians” who claim that they use the “minimalist [sic] facts approach”—Jerry Newcombe, Peter Lillback and Mark A. Beliles.[51] Rather than being secular, they are strong advocates for Christianity. For example, Newcombe is the executive director of the Providence Forum—a Christian organization founded by Lillback.

IV. Volume 3: Scholarly Perspectives

1. Reference Book

Volume 3 is not meant to be read from cover to cover and is primarily a reference book. Habermas explains his methodology for volume 3 thus:

In this third volume we pivot away almost totally from evidential concerns to a different categorical approach, namely, that of identifying thousands of scholarly considerations over a wide variety of related topics.[52]

Habermas organizes the “scholarly perspectives” by subject. He arranges about 250 topics into ten chapters, and provides a detailed table of contents. In addition, the volume includes author, subject, and scripture indexes.

One caveat about this reference book is that most of the sources date before 2015.[53] Habermas explained his reasons for this cutoff, but such reasons are not really relevant. The book is what it is—ten years out of date when published.

Nonetheless and much to my surprise, I found it to be a useful reference book. For example, volume 3 might have come in handy for some of my previous research on the tendency of some people to believe weird stories without evidence.

In a previous article I discussed how lawyers reason by analogy and by comparing cases. I compared evidence for the Resurrection to more recent cases of alleged supernatural events. My argument assumes that human nature is basically the same now as it was in the first century. This is not a controversial claim, and both apologists and nonbelievers invariably take this assumption for granted. Nonetheless, my argument might have been stronger if I had researched this previously ignored issue.

Chapter 1 of volume 3 (on scholarly perspectives) includes a topic for “first-century gullibility,” in which Habermas summarizes in a few words the opinions of four scholars—Craig A. Evans, David Peterson, E. P. Sanders, and Peter Stuhlmacher.[54] These scholars generally support the position that some of the ancients were credulous and some were more skeptical. This information might have been useful when I compared first-century Christianity to nineteenth-century spiritualism and the Mormons.

2. No Evidence of “Vast Majority” of Scholars

Habermas states that there are two prerequisites for an event to be designated a “minimal fact.” Such an event “must be established by an abundance of strong evidence” and “the vast majority of published contemporary scholars with credentials in relevant fields of study have to acknowledge the historicity of the event.”[55]

Habermas has sent mixed signals regarding which of the two is more important, but both are prerequisites. Regarding what constitutes a “vast majority,” he explains: “At least when referencing the shorter list of minimal historical facts, I most frequently think in terms of a 90-something percentile head count.”[56]

Habermas may think of those alleged historical facts in those terms, but he makes no head count and provides no evidence or calculation for his 90 percentile figure. Habermas explains:

[T]he lists of scholars in this volume are unrelated to the “scholarly counts” referenced in the first two volumes. They do not comprise any extrapolated figures from which “headcount” comments were made earlier. The task here was simply to provide an overview of hundreds of scholarly opinions across a multitude of topics, including over 7,000 footnotes. As noted previously, this volume was originally longer, but much of it had to be condensed.[57]

What the devil does that mean? Does he still have the backup for his 90 percentile figure, and was it “condensed” out? Critics who have often complained about Habermas’ lack of transparency about the numbers were not impressed by this explanation.

IV. Volume 4: Theology and Practice

As I write this, the fourth and last volume of On the Resurrection has not yet been published and is set for release in August 2026. Therefore, I have not read it. Nonetheless, I see no reason to hold up this review. Volume 4 will discuss Christian theology and practice. I doubt that I, as a lawyer, will have anything intelligent or useful to say on that subject.

Conclusion

On May 16, 2025, Real Seekers Ministries published on YouTube a panel discussion about Gary Habermas’ four-volume magnum opus: “The Ultimate Resurrection Panel—Celebrating the Legacy of Gary Habermas.” At minute 36 the moderator asked Habermas’ research assistant, Ben Shaw, what argument or evidence “really stood out” to him in the books. Shaw replied that the argument that stood out the most was “cumulative force.” He explained that the volumes were very heavy and that “when you drop those books down there’s a force to them.”

The four volumes weigh a total of about 14½ pounds, but sheer length is no measure of a book’s quality or the validity of its arguments. Quite the opposite is often true. Complicated and verbose argument may indicate more than one logical fallacy—proof by verbosity, argument by repetition, the smokescreen fallacy, and the Gish gallop. Judges often view excessively long filings as a sign of weak logic.

“Weight of evidence” or “weight of argument” in a legal context refers to the persuasiveness, credibility, and value of evidence or legal arguments, not their length or volume. Fundamental legal maxims provide that “arguments should be weighed, not counted” (argumenta ponderantur, non numerantur) and “testimonies are to be weighed, not numbered” (testes ponderantur, non numerantur). These maxims mean that a single strong and logical argument is more powerful that several flimsy arguments.

Of course, Habermas does not agree that his arguments are weak, but without doubt they cannot withstand legal analysis. I have identified three simple and independent reasons that apologists cannot prove Jesus’ resurrection in court, and no one can refute them.

I can say without fear of contradiction that Habermas and all other evidential apologists understand that my brilliant brief completely discredits all of their silly claims about a first-century itinerant preacher rising from the dead. This hyperbole may not be true, but still I do not fear contradiction—I seek it.

1 Peter 3:15-16 mandates that Christians must “Always be ready to make your defense to anyone who demands from you an accounting for the hope that is in you.” I have been trying for almost three years to get any Christian to obey this command, but to no avail. See my open letter to Bradley J. Lingo, another open letter to Bradley J. Lingo, and finally an open letter to Adam Francisco (Lingo’s successor). Apparently, no Christian is willing to step forward to defend their faith from my demand for an accounting. Why do you suppose that is so?

Notes

[1] Gary R. Habermas, On the Resurrection, Vol. 1: Evidences (Brentwood, TN: B&H Academic, 2024), p. 405.

[2] Bart D. Ehrman, Jesus: Apocalyptic Prophet of the New Millennium (Oxford, UK: Oxford University Press, 1999), p. 231.

[3] Bart D. Ehrman, How Jesus Became God (New York, NY: HarperCollins, 2014), p. 192.

[4] Ehrman, How Jesus Became God, p. 182.

[5] Frank M. Coffin, The Ways of a Judge, Reflections from the Federal Appellate Bench (Boston, MA: Houghton Mifflin Company, 1980), p. 104.

[6] Habermas, On the Resurrection, Vol. 1: Evidences, p. 1.

[7] William P. Broughton, The Historical Development of Legal Apologetics (Longwood, FL: Xulon Press, 2009), p. 39.

[8] John Warwick Montgomery, “The Jury Returns: A Juridical Defense of Christianity” in Christians in the Public Square ed. John Warwick Montgomery (Edmonton, Canada: Canadian Institute for Law, Theology & Public Policy, 1996): 223-250, p. 224.

[9] David Hackett Fischer, Historian’s Fallacies, Toward a Logic of Historical Thought (New York, NY: Harper & Row, 1970), p. 62.

[10] Michael Grant, quoted in Michael R. Licona, The Resurrection of Jesus: A New Historiographical Approach (Downers Grove, IL: InterVarsity Press, 2010), p. 100.

[11] Gary R. Habermas, On the Resurrection, Vol. 3: Scholarly Perspectives (Brentwood, TN: B&H Academic, 2025), p. 1.

[12] Robert M. Price, The Case Against The Case for Christ (Cranford, NJ: American Atheist Press, 2010), p. 17.

[13] Habermas, On the Resurrection, Vol. 1: Evidences, p. 874.

[14] Habermas, On the Resurrection, Vol. 1: Evidences, p. 96.

[15] Habermas, On the Resurrection, Vol. 1: Evidences, pp. 40-41.

[16] To a lawyer, the plural of “evidence” is also “evidence.” For example, a lawyer or judge would say that the evidence in a case is sufficient, as opposed to saying that the evidences are sufficient.

[17] Habermas, On the Resurrection, Vol. 1: Evidences, p. 36n1.

[18] Habermas, On the Resurrection, Vol. 1: Evidences, p. 41.

[19] Habermas, On the Resurrection, Vol. 1: Evidences, pp. 44-53.

[20] Habermas, On the Resurrection, Vol. 1: Evidences, p. 44.

[21] Habermas, On the Resurrection, Vol. 1: Evidences, pp. 42-43.

[22] Habermas, On the Resurrection, Vol. 1: Evidences, p. 41.

[23] Habermas, On the Resurrection, Vol. 1: Evidences, p. 42.

[24] Habermas, On the Resurrection, Vol. 1: Evidences, p. 43.

[25] Habermas, On the Resurrection, Vol. 1: Evidences, pp. 42-43.

[26] Habermas, On the Resurrection, Vol. 1: Evidences, pp. 44-45.

[27] Habermas, On the Resurrection, Vol. 2: Refutations, p. 637, quoting James D. G. Dunn, The Evidence for Jesus (Louisville, KY: Westminster, 1885), p. 76.

[28] Habermas, On the Resurrection, Vol. 2: Refutations, p. 636.

[29] Bart D. Ehrman, How Jesus Became God (New York, NY: HarperCollins, 2014), p. 165.

[30] Habermas, On the Resurrection, Vol. 2: Refutations, p. 636n3.

[31] Federal Rule of Evidence 702(b).

[32] Habermas, On the Resurrection, Vol. 1: Evidences, p. 875.

[33] Habermas, On the Resurrection, Vol. 2: Refutations, p. 476.

[34] Bart D. Ehrman, Forged (New York, NY: HarperCollins, 2011), pp. 92-114.

[35] Habermas, On the Resurrection, Vol. 1: Evidences, p. 9.

[36] Habermas, On the Resurrection, Vol. 1: Evidences, pp. 32-33.

[37] Habermas, On the Resurrection, Vol. 1: Evidences, p. 57.

[38] Habermas, On the Resurrection, Vol. 1: Evidences, p. 67.

[39] C. Behan McCullagh, Justifying Historical Descriptions (London, UK: Cambridge University Press, 1984), p. 28.

[40] Habermas, On the Resurrection, Vol. 1: Evidences, p. 227.

[41] I do not understand what Habermas means by fideistic in this context.

[42] Habermas, On the Resurrection, Vol. 1: Evidences, pp. 948-949.

[43] Bart D. Ehrman, The New Testament: A Historical Introduction to the Early Christian Writers, 4th ed. (New York, NY: Oxford University Press, 2008), pp. 240-244 (chapter 15). Habermas cited the 2nd edition of this book, which has different pagination. pp. 208-211 in the 2nd edition are in chapter 15 of the 4th edition.

[44] Habermas, On the Resurrection, Vol. 1: Evidences, p. 42.

[45] Habermas, On the Resurrection, Vol. 1: Evidences, p. 42.

[46] Licona, The Resurrection of Jesus: A New Historiographical Approach, pp. 465-610.

[47] Habermas, On the Resurrection, Vol. 2: Refutations, p. 159.

[48] Habermas, On the Resurrection, Vol. 2: Refutations, p. 752.

[49] C. Behan McCullagh, Justifying Historical Descriptions (Cambridge, UK: Cambridge University Press, 1984), pp. 16-17.

[50] Habermas, On the Resurrection, Vol. 1: Evidences, p. 139.

[51] Habermas, On the Resurrection, Vol. 1: Evidences, p. 139n33.

[52] Habermas, On the Resurrection, Vol. 2: Refutations, p. 752.

[53] Habermas, On the Resurrection, Vol. 3: Scholarly Perspectives, pp. 2-3.

[54] Habermas, On the Resurrection, Vol. 3: Scholarly Perspectives, p. 48.

[55] Habermas, On the Resurrection, Vol. 1: Evidences, pp. 91-92.

[56] Habermas, On the Resurrection, Vol. 1: Evidences, p. 94.

[57] Habermas, On the Resurrection, Vol. 3: Scholarly Perspectives, p. 3.

Copyright ©2026 by Robert G. Miller. This electronic version is copyright ©2026 by Internet Infidels, Inc. with the permission of Robert G. Miller. All rights reserved.