A Meta-Study of the Debate over the Meaning of “Head” (Kephalē) in Paul’s Writings

Since the middle of the twentieth century there has been an ongoing, sometimes acrimonious debate over the meaning of “head” (Greek, kephalē) in Paul’s letters, especially 1 Corinthians 11:3 and Ephesians 5:23. The literature is extensive. The debate continues, but few have taken the time to read all the significant discussions or have access to the actual articles, much less the resources to critique such. This article is an attempt to review the most significant scholarly literature that has emerged in the debate and to summarize each without critique. The focus is narrow and should not be taken as a meta-study of the whole debate on male and female relations in the church, home, and world.

Since no evaluation can be completely free of prejudice or bias, I will state my current position. I hold a critical and qualified acceptance of the evangelical egalitarian viewpoint. I offer the following review as the fairest attempt that I can give of the history and current state of the issue. In conclusion, I offer my own application of the results to 1 Corinthians 11:3 and Ephesians 5:23. Only the most significant contributions (in my estimation) from all sides can be included. I offer my apologies to any who were overlooked.

The history of the debate

Stephen Bedale (1954)

We begin with an early seminal article by Stephen Bedale.¹Amazingly brief for the firestorm it sparked (4 pages), the points Bedale raised continue to be played out in the current debate. Bedale argued that since the normal Greek metaphorical meaning of kephalē would not be understood as ‘ruler’ or ‘chief,’ Paul must have been influenced by the Greek version of the Old Testament (lxx) where kephalē was used sometimes to translate the Hebrew rọsh (when it meant ‘ruler’ or ‘chief’).

However, rọsh could have a second figurative meaning as well in other contexts, ‘first’ or ‘beginning’ (translated by the Greek, archē, ‘first,’ ‘beginning,’ ‘principal’). The two words (archē and kephalē) became “approximate in meaning” in biblical Greek (i.e., Greek influenced by the lxx). Thus in Colossians 1:18, kephalē in the sense of ‘ruler’ or ‘chief’ would be an “irrelevant intrusion into the context which is wholly concerned with Christ as archē, the ‘beginning’ and ‘first principle’ alike in Creation and Redemption (cf. Rev. iii.14, hē archē tēs ktiseōs)” (213). Likewise in Colossians 2:19 and Ephesians 4:15 where the body is said to derive its growth and development from the head, it is very difficult to make any sense of it at all so long as kephalē is understood as ‘overlord.’ But when Christ is understood to be archē in relation to the church, it is possible to see how Christians can grow up into him, as the archetypal image of the Second Adam is progressively realized in them. At the same time it is possible to think of the body as the ‘fullness’ or ‘fulfillment’ of the kephalē (Eph. 1:23).

On the other hand, and this is important, for Bedale kephalē can also occasionally in certain contexts mean the ‘overlordship’ of Christ (Eph. 1:22). In other contexts kephalē stresses the relationship of one being to another in the sense of archē archē (‘first,’ ‘beginning’) and that priority (causal and not merely temporal) “unquestionably carries with it the idea of authority” (1 Cor. 11:3; Eph. 5:23) (215). As a result, the female is socially ‘subordinate’ to the male as part of the order of creation while otherwise remaining equal in spiritual status or capacities.

Bedale used the word ‘source’ only once in the article as the meaning of kephalē and relates this specific sense to two passages only (Eph. 4:15; Col. 2:19). However, his practical equivalence of kephalē with archē extends the idea of source as ‘origin’ or ‘first’ much further. Commentaries quickly began adopting some or all of Bedale’s views (e.g., Leon Morris [1958]²; C.K. Barrett [1968]³F.F. Bruce [1971]⁴).

Morna D. Hooker (1963-64)

A brief, but well known and enduring study by the honored Cambridge scholar Morna D. Hooker contributed two major points in the understanding of 1 Corinthians 11:3-10.⁵ First, she clarified the double sense of kephalē in the passage. Paul seems to use the word to simultaneously refer to both physical and metaphorical head. According to Hooker,

Every man who prays and prophesies with his head covered dishonours his head, whereas every woman who prays or prophesies with her head uncovered dishonours her head. The reason for this differentiation is given in v. 6, and is based on social custom: in Paul’s eyes an uncovered head is as great a disgrace for a woman as one that is shorn….In communities where it is no longer a disgrace for a woman to be ‘shorn,’ the argument has lost its point….When he speaks of a head being covered or shorn, then it is obvious that he is referring to the man’s or the woman’s own heads, but when he says that a head is dishonoured, we must ask whether the word ‘head’ is to be taken literally or metaphorically….The answer is probably that he does both, but the primary point is that he brings shame on Christ. It is here that we see the relevance of v. 3 to Paul’s argument: the man or woman who dishonours his or her own head in the literal sense brings dishonour also on his or her metaphorical head.… (410-11) Hooker’s second major contribution is to clearly establishes that the word “authority” (Greek, exousia) in verse 10 refers not to a sign of male authority over the woman, but rather to the woman’s own authority to fully participate in worship that glorifies God.⁶ As a redeemed woman she now has the authority to proclaim.

Far from being a symbol of the woman’s subjection to man, therefore, her head-covering is what Paul calls it—authority: in prayer and prophecy she, like the man, is under the authority of God. Although the differences in creation remain, and are reflected in the differences of dress, it is nevertheless true that in relation to God ‘there is neither male nor female; for you are all one in Christ Jesus.’ (416)

Unfortunately, while many commentators have followed this interpretation, only a few modern translations have captured this sense (e.g., “… as a sign of her authority,” cev; “… the woman ought to have authority over her own head,” TNIV).

Robin Scroggs (1972)

Robin Scroggs defended Paul against the allegations that he was the chief chauvinist in the Bible.⁷ According to Scroggs, Paul was in fact the “only consistent spokesman for the liberation and equality of women in the New Testament” (283). Paul’s deepest theological conviction about the relationship between men and women is found in Galatians 3:28. Any value judgments based on the distinctions between persons in the society, including men and women, are nullified by their baptism.

In practical application of this fundamental Christian principle (Gal. 3:28) to a specific problem at Corinth in their worship services, Paul appeals to the fact that Christ has his source in God, man his source in Christ, and the woman her source in the man (1 Cor. 11:3). Scroggs follows Bedale in adopting ‘source’ for the meaning of kephalē, but rejects Bedale’s sense of ‘overlordship’ as its meaning in verse 3.

Here no subordination of woman to man is intended; what is expressed is the order of the creative events.…Again we have a clear distinction between the sexes, but in this strophe no justification is given for the rule [about head coverings] nor any value judgment made on the basis of the rule. (301)

However obscure the passage as a whole may seem (1 Cor. 11:2-16), Paul strongly affirms the authority of the woman (v. 10). The apostle actually offers a radically new vision of women’s equality and freedom from which the church quickly departed and reinterpreted the texts to teach the older vision of the subordination of women (even in the deutero-Pauline letters).

Fred D. Layman (1980)

Coming from a Weslyan perspective, Fred D. Layman⁸ wrote an informed article on the question of male headship. Layman states his thesis this way:

Paul did not use the idea of male headship in a governmental nor ontological way as establishing a hierarchical relationship between male and female in which the one was dominant and the other submissive. Rather, he used it (1) to designate the proper relationship between the sexes in the context of the new order, and (2) to insist on the continuation of sexual distinctions and the validity of marriage in the new creation in a polemic with Gnostic claims to the contrary. (47)

After carefully explaining what he means by Gnostic-like thought, Layman examines Ephesians 5:21-33 and 1 Corinthians 11:2-16. In the first reference he points out that in most traditional interpretations of this passage, the kephalē metaphor is understood as a physiological metaphor, i.e., the kephalē is ‘prior,’ that part which ‘determines’ or ‘governs’ the body (e.g., “The man is the head of the woman”). Layman denies that Paul ever uses the head-body metaphor in such a physiological sense. On the other hand, Paul does use the body metaphor for the church in a physiological sense as analogous to Christians relating to each other but without the idea of headship present (Rom. 12:4-8; 1 Cor. 12:12-31). Furthermore, Paul spoke of the kephalē in isolation from any reference to a body (1 Cor. 11:3; Eph. 1:22; Col. 2:10).

The body metaphor addressed the matter of mutuality within the believing community; the head metaphor spoke of Christ as the source, beginning, savior, and conserver of the church. The two metaphors do not change these meanings when they are brought into proximity to each other, and to interpret them in correspondence to a physiological model is to create numerous absurdities. Ephesians 4:16 and Colossians 2:19 refer to the church as the ‘whole body,’ which if a physiological model is intended, would have two heads. Nor would the language about the body growing up into the head (Eph. 4:15) make any sense. (52)

Christ’s lordship and his headship are two different but related ideas for Paul. As Lord he is the governing rule of all creation. His headship speaks of him as the beginning, origin, and ground of all being and of the new, redeemed creation. Only Christ’s headship not his lordship is held up as a model for the Christian husband. Christ’s headship toward the church is expressed in his love, self-sacrifice, and provision for the church. Submission to this loving headship is voluntary and becomes transformed into a relationship of mutual reciprocity. Finally, it should be noted that Paul never refers to the wife as the body of the husband (only the husband’s own body).

In the other main passage (1 Cor. 11:3), kephalē is not female subordination, but Paul’s way of stressing that man is the source of the woman (Eve being taken out of Adam, Gen. 2:18-25). Following Hurley (1973—see below), Layman considers the major problem addressed in 11:2-16 to be not the issue of some type of cloth coverings but the problem of hair on the head (either long/short or loose/bound up on the top of the head). The most likely reason for their reversing the normal way the hair was worn was related to a pagan cult that abolished the distinctions between men and women as culturally indicated by hairstyles. This practice in the Christian gatherings for worship would bring dishonor not only on the persons involved but also upon the public moral perception of the gospel of Christ.

James B. Hurley (1981)

In James B. Hurley’s publication⁹ of his earlier doctoral dissertation (Cambridge, 1973) we find a rejection of kephalē meaning ‘source’ and a case presented for kephalē in 1 Corinthians 11:3 as meaning ‘head over’ in the sense of authority (actually quoting and following Bedale at this point!). The passage establishes “a hierarchy of headship authority…and that it is ordered” (167). In Ephesians 5:23, kephalē has the same sense of ‘head over’ (authority) in connection with the husband’s relation to the wife.

On the other hand, Hurley does recognize that this ‘head over’ sense does not fit kephalē passages such as Ephesians 4:15 and Colossians 2:19 where ‘source’ is “clearly” more appropriate and the concept of authority is not introduced. Still further, in some texts the idea of ‘authority,’ ‘source,’ and ‘union’ may coalesce (Col. 1:15-20).

In some respects Hurley may best represent the full thought of Bedale more than any recent scholar on either side of the debate. This still leaves open the question of whether Bedale is completely correct or not.

Gilbert Bilezikian (1985)

Gilbert Bilezikian wrote Beyond Sex Roles¹⁰ principally to refute Hurley’s central thesis of male authority over women. In the sections of the work that deal with kephalē, Bilezikian first cautions us not to equate the English word ‘head’ with the Greek kephalē, especially in the English use of ‘head’ to signify ‘chief,’ ‘boss,’ ‘authority,’ ‘ruler.’ In the biblical texts themselves, the idea includes the meanings ‘derivation,’ ‘origin,’ ‘starting point,’ and ‘nurture,’ but not ‘chief,’ ‘boss,’ or ‘authority.’

In 1 Corinthians 11:3, Bilezikian indicates what he feels is the correct sense of kephalē in Greek.

The concept might be better served by the expression fountainhead or life-source. Thus, in the perspective of creation it makes sense to say that Christ is the ‘fountainhead’ of man’s life, and that man is the fountainhead of woman’s life. Likewise from the perspective of the incarnation, God is the fountainhead of Christ’s life. (137)

No lexical evidence for this sense is given beyond the New Testament usage. (Bilezikian does provide this in an appendix in the 2nd edition. See below.) He then concludes that the idea that kephalē means ‘ruler’ or ‘authority’ would change the whole meaning of the passage. The order of the couplets (Christ-man, man-woman, God-Christ) shows that a hierarchy of authority was not in Paul’s mind.

In discussing Ephesians 5:23 (“the husband is the head of the wife”), Bilezikian examines the other relevant texts containing the kephalē wording (Eph. 1:22; 4:15; Col. 1:18; 2:18, 19). Christ is kephalē not to the universe but only to the church that is his body in that he supplies the church with its fullness and nurture for growth (kephalē means ‘source of life’). The head-body duality stresses not ‘authority over,’ but reciprocity.

Berkeley and Alvera Mickelsen (1979, 1981, 1986)

The Mickelsens published three Christianity Today articles¹¹ on the meaning of kephalē. I will concentrate on their last article, which incorporated their earlier, more popular statements. The Mickelsens point out that though the standard classical lexicon for ancient Greek, Liddell-Scott-Jones (lsj), gives twenty-five different figurative meanings for kephalē, it never mentions ‘authority,’ ‘superior rank,’ ‘leader,’ or ‘director’ as possible meanings of kephalē. This, the Mickelsens claim, is true for other lexicons of ancient Greek except the Bauer-Arndt-Gingrich-Danker lexicon (bagd) that gives ‘superior rank’ as a possible sense citing two late examples (2nd and 6th cent. a.d.) and two lxx references despite the fact that this meaning for kephalēdoes not appear in the secular Greek of New Testament times.

Their examination of the lxx metaphorical uses of kephalē opened up a new debate on whether the term is “naturally” and “frequently” used in the sense of ‘leader,’ ‘chief.’ The Hebrew term rọsh (‘head’) is used in the Old Testament 180 times for a ‘chief something’ (e.g., man, city, nation). In 109 of these times, rọsh is translated by archon (‘leader,’ ‘chief’) rather than kephalē. Kephalē is used only eight times (less than four percent) when rọsh means ‘leader,’ ‘chief.’ The conclusion is that the use of kephalē to translate rọsh as ‘leader’ is “rare” and is not found in well-known passages, thus limiting the knowledge of this sense.

In the New Testament, kephalē is better translated ‘source of life,’ ‘top or crown,’ ‘exalted originator,’ ‘completer,’ and not by ‘authority over.’ These meanings, however, are derived not from extrabiblical or lxx uses, but primarily from the context of Paul’s argument in passages containing the words. Thus in 1 Corinthians 11:3, kephalē means ‘source,’ ‘base,’ ‘derivation.’ In Ephesians 5:23, kephalē means ‘the one who brings to completion,’ stressing on the one hand, the unity of Christ and the church, husband and wife, and on the other, the mutually interdependent relation between the two in each of the pairs.

Wayne Grudem (1985)

With Wayne Grudem,¹² we have the beginning of what has come to be called “the battle of the lexicons.” His first study challenges the position of Bedale, the Mickelsens, Bilezikian, and even the well-respected lsj lexicon. The charge against Bedale, the Mickelsens, and Bilezikian is that under close examination, Grudem can find no non-biblical Greek examples (including the lxx) where kephalē means ‘source.’ (In two cases he allows the possibility but argues that another sense fits better.)

He then builds a case for the meaning of kephalē as ‘authority over’ and concludes that this sense was a “well-established and recognizable meaning” in the New Testament period (59). Here he faults lsj for not including this meaning in its range of meanings for kephalē. On the other hand, bagd is the lexicon of preference because it correctly includes the lxx usage of kephalē as ‘authority over’ as well as several other references with the same sense.

Grudem obtained a printout from the University of California’s database of all known Greek literature (Thesaurus Linguae Graecae—tlg) from the eighth century b.c. onward. Some 12,000 instances were narrowed to 2,000, of which Grudem found 323 additional word uses. From these he found 49 metaphorical uses (including the lxx and the New Testament) of kephalē where he painstakingly argues in each of these examples that kephalē means ‘authority over’ as the best sense. He then shows how all the references to kephalē in the New Testament can be explained best by the meaning ‘authority over’ and not ‘source.’ Furthermore, it is a proper extension of this ‘authority over’ sense to include ‘leadership,’ ‘guidance,’ and ‘direction.’

To Grudem’s credit, he focused the discussion on the actual evidence of non-biblical Greek examples and attempted to explain these references in the context of where they were found. He also correctly acknowledged that the Mickelsens did in fact recognize that ‘authority over’ was a possible sense of kephalē in ancient Greek, however rare it might be. Unfortunately, he like most others, did not define what he meant by the English word ‘source.’

Gilbert Bilezikian (1986)

The first major response to Grudem’s challenge came from Gilbert Bilezikian in a paper presented for a plenary session of the annual meeting of the Evangelical Theological Society.¹³ He takes up and examines Grudem’s fifteen non-biblical examples of ‘authority over’ in ancient Greek. In each case, Bilezekian deconstructs the argument Grudem advances for the sense of ‘authority over.’

He concludes that “the survey…did not yield a single instance in which head is used with the meaning of ‘ruler or person of superior authority or rank’” (233). Instead, in the New Testament kephalē means “a person or thing from which something else is derived or obtained” (235). However, Bilezikian admits that this sense is rare and “only occasionally is used in this way” (235). But Paul could have picked this meaning up and used it with a Christian sense in his letters. Furthermore, kephalē is never used in ancient Greek in a male-female context.

Bilezikian proposes that in 1 Corinthians 11:3, kephalē means ‘source’ or ‘origin,’ and in Ephesians 5:23, it means ‘source’ of life (Saviorhood), source of servanthood (gave himself), source of nurture.

Walter L. Liefeld (1986)

In his early study of 1 Corinthians 11:2-16,¹⁴ Walter L. Liefeld rejected as unlikely the popular and traditional understanding of kephalē as ‘ruler’ and the implication that what Paul was doing in 11:3 was setting up a “chain of command.” He warned, however, that we should beware of pressing “one meaning fits all” for kephalē and suggested that there was no single or even dominant meaning for kephalē and its sense might even change in a single passage. (In this he anticipates Dawes—see below).

Liefeld, at least initially, sided in part with Grudem stating that

the meaning ‘source’ adduced by Bedale as a clue to some of Paul’s passages, lacks clear evidence.…Those who would claim such a meaning in the New Testament have to rely only on the context, not on any external evidence prior to the first century. (139)

Further, Liefeld warns that there is no single metaphorical use of kephalē above the others (contra Grudem, Bilezikian, Mickelsens). He wants to keep kephalē in the mainstream of Greek and lxx thought and see kephalē as that part of the body that was (1) prominent, (2) representative, and less frequently, (3) eminent or most honored part of the body in the common perceptions of honor and dishonor with respect to the head in the first century.

Finally, Liefeld states plainly that in light of Grudem’s study “it is no longer possible to dismiss the idea of ‘rulership’ from the discussion” of kephalē (139). Whether Paul uses this sense or whether it is the main meaning throughout Paul is another matter. In 1 Corinthians 11:3, it makes more sense to Liefeld to see kephalē as meaning ‘prominent’ or ‘honored’ member than as ‘source’ or ‘ruler.’

Catherine C. Kroeger (1987)

Catherine C. Kroeger¹⁵ begins her discussion of kephalē with the following statement: “The concept of head as ‘source’ is well documented in both classical and Christian antiquity and has been long accepted by scholars” (267). For evidence of this she turns first to older Latin-Greek dictionaries that list among definitions for kephalē the Latin origo (‘source’ or ‘origin’). Turning to church leaders of the fourth and fifth centuries a.d., Kroeger argues that they refer to kephalē as the ‘source’ (where this is her translation of their word archē, ‘beginning,’ ‘origin’). Ancient views of the function of the head physiologically lead to the conclusion that they viewed the head as the source of sperm and hence of the source of the generation of life or of the whole bodily condition.

Furthermore, she argues from other church leaders of the fourth and fifth centuries a.d. that they viewed God as the ‘source’ (archē) of Christ and quoted 1 Corinthians 11:3, “God is the head of Christ.” In all of these examples it should be noted that Kroeger assumes that archē means the same thing as the English word ‘source.’ There is no discussion of the possible difference between ‘beginning’ or ‘first,’ and ‘source’ or ‘origin.’

Finally, it should be noted that though Kroeger believes that ‘source’ is a well-documented sense of kephalē, she does admit that in the New Testament period, kephalē may rarely have had the sense of ‘boss’ or ‘chief’ as it does in English and Hebrew.

Richard S. Cervin (1989)

The principal challenge to Grudem’s study of kephalē as ‘authority over’ comes from Richard S. Cervin.¹⁶ Cervin first critiques Grudem’s method and states that fourteen ancient Greek lexicons do not give ‘authority over’ as a possible meaning of kephalē. Only one does and it indicates that ‘leader’ is a Byzantine period sense (5th cent. a.d.). He then somewhat agrees with Grudem that kephalē meaning ‘source’ is certainly not common, but disagrees that it never means ‘source,’ citing two positive cases.

After setting aside the twelve Pauline references as evidence (since these are contested), Cervin then examines in detail all the examples that Grudem gives for kephalē meaning ‘authority over.’ He finds only four unambiguous cases where kephalē could possibly mean ‘ruler’ or ‘leader’ (three from the lxx) and one case where ‘source’ would be better (Shepherd of Hermas). Otherwise in all the other examples Grudem cites of kephalē meaning ‘authority over,’ Cervin finds that the meaning of kephalē is better understood as ‘preeminence.’ In other words, the bulk of Grudem’s examples turn out in Cervin’s view as non-examples.

Finally, Cervin reviews the first study of Fitzmyer (1989—see below) that largely agrees with Grudem, and finds his evidence also lacking. He grants, however, that ‘leader’ or ‘authority over’ could possibly be meant in some texts, but there are no unambiguous examples.

Cervin raised the bar in the discussions to press for an even closer examination of the fuller contexts of the word’s usage.

Joseph A. Fitzmyer, S.J. (1989, 1993)

Entering into the discussion of the issue of the meaning of kephalē is the prominent (no pun intended) Roman Catholic scholar. An earlier piece¹⁷ basically argued against the kephalē as ‘source’ held by Scroggs and Murphy-O’Connor.¹⁸ Instead, Fitzmyer argued from the lxx uses of kephalē, several Philo texts, an example from Josephus’ Jewish War, and a fourth century church leader that “a Hellenistic Jewish writer such as Paul of Tarsus could well have intended that kephalē in 1 Cor 11.3 be understood as ‘head’ in the sense of authority or supremacy over someone else” (510). He also would like to change lsj to include this sense.

In a more recent article (1993),¹⁹ Fitzmyer engages Grudem and Cervin and uses the tlg source to add many more examples than in his previous study. Fitzmyer concludes (1) that kephalē could indeed be used in the sense of ‘source’ (contra Grudem), (2) in at least a dozen examples, kephalē clearly has the sense of ‘ruler’ or ‘leader,’ and in some cases it is even so explained (agreeing with Grudem). This latter sense did not appear in Greek literature until the last pre-Christian centuries and at the beginning of the Christian era. While conceding that four leading lexicons of ancient Greek usage omit this meaning, Fitzmyer does cite two other German lexicons of ancient Greek that do list ‘ruler’ or ‘leader’ as a possible sense of kephalē.

Wayne Grudem (1990)

This article by Wayne Grudem²⁰ is primarily a response to Cervin (1989) but includes critiques also of the Mickelsens (1981; 1986), Bilezikian (1985), Tucker (1986), Payne (1986), Liefeld (1986), Kroeger (1987), and Fee (1987). According to Grudem, Cervin has rightly shown the weakness of the argument for ‘source’ as a common meaning for kephalē. He wrongly dismissed the Pauline texts as evidence for the meaning of kephalē. Furthermore, he wrongly dismisses the lxx evidence and the bagd lexicon that includes it. Cervin also wrongly rejects the Plutarch texts because they are affected by the Latin caput. He unwisely discounts the Apostolic Fathers as evidence for the meaning of kephalē even though they postdate Paul.

The references of kephalē in Ephesians 4:15 and Colossians 2:19 are better understood not as ‘source,’ but as ‘nourishment’ and the idea of ‘leader’ or ‘authority’ is never absent since Christ, who is the person referred to, is the authority and leader. However, some secondary overtones of ‘preeminence’ could be possible for kephalē, if we include also the meaning of ‘authority over’ as the reason why there is preeminence.

As for the Mickelsens’ views, there is no lxx evidence for ‘source’ as the meaning of kephalē. However, Grudem does admit that kephalē as ‘ruler’ or ‘leader’ is not common, but is nevertheless a valid sense. The Mickelsens’ meanings of kephalē for the Pauline texts have no support from actual uses in contemporary Greek. Payne’s (1986)²¹ criticism of ‘authority over’ for the sense “the head of Christ is God” (1 Cor. 11:3) because it suggests a subordinationist view of Christ that the church denied, is rejected by Grudem. He says, “From the time of the eternal generation of the Son [a.d. 325],” the doctrine of the Trinity “has been taken to imply a relationship between the Father and the Son that eternally existed and that will always exist—a relationship that includes a subordination in role, but not essence or being” (457).

Grudem admits to some corrections from Bilezikian’s critique, but basically disagrees with his conclusions that kephalē means ‘source.’ The same challenge is given to Kroeger and Fee.²² Based on recent studies by Cottrell and Max Turner (1989)²³ which confirmed that ‘source’ is not a recognized meaning of kephalē, Grudem concludes that even if ‘source’ or ‘prominent part’ is valid (he does not concede that this is clear), it must include also the idea of ‘authority over’ for persons who are designated as ‘head.’ Unfortunately, Grudem does not define either ‘source’ or what he means by ‘metaphor.’

Andrew C. Perriman (1994)

Andrew C. Perriman²⁴ reexamines the lexical texts cited by both Grudem and Fitzmyer for ‘authority’ and ‘leadership’ and in each case finds that the texts do not refer to ‘ruler’ or ‘leader’ in using the metaphor kephalē. Rather, in each case the thought is ‘representative,’ ‘prominent,’ or ‘illustrious.’ While these examples illustrate a certain association of kephalē with the figure of a ruler or leader, we cannot assume that the same association lies behind the Pauline texts. Further, no text can be cited where kephalē denotes the authority or sovereignty of one man or of men over others.

As to kephalē meaning ‘source’ or ‘beginning’ of something, Perriman states that Bedale’s argument is flawed, and ‘source’ and ‘beginning’ are not the same or interchangeable.

Metaphor is a form of speech that is particularly sensitive to context, and while it is the case that when the reference is to a river, the idea of ‘source’ may emerge quite naturally as a secondary connotation, there is no reason to suppose that the same connotation is relevant when the metaphor is applied to some quite different subject…what J. Barr calls ‘illegitimate totality transfer.’ (613)

The texts cited by Cervin and others are either non-cases or ‘beginning’ (archē), not ‘source.’

First Corinthians 11:3 must be understood in its context as a unique use of kephalē as a metaphor. It has nothing to do with a man’s authority over a woman. The main theme of the passage concerns the shame or dishonor that attaches to a woman if she prays or prophesies with her head uncovered; it is a question of whether the woman’s behavior brings glory or dishonor on the man.

He concludes his study by noting (1) both current positions are weak lexicographically, (2) ‘prominent’ fits the texts well, (3) we cannot use other Pauline passages to define 1 Corinthians 11:3, and (4) the passage does not teach the ‘authority’ of a hierarchy.

Judith Gundry-Volf (1997)

Judith Gundry-Volf²⁵ offers a genuine breakthrough in the interpretation of 1 Corinthians 11:2-16 that Anthony Thiselton (2000—see below) characterizes as “the most seminal study of all.”²⁶ She believes that the lexical debate alone is insufficient to understand Paul’s intent. Gundry-Volf wants to integrate Paul’s (1) creation, (2) cultural-societal, and (3) eschatological or new creation concerns into her exegesis. Gundry-Volf proposes that Paul’s goal in the whole section of 1 Corinthians 8:1-11:1 is to correct behavioral problems at Corinth that have diminished the credibility of the gospel in the wider society.

In 11:2-16, Paul addresses the problem of shame/dishonor that both men and women are causing each other, as well as the adverse consequences that this shameful behavior has for the mission of the church because of the way they are covering or uncovering their heads in worship (vv. 4-6). This is not a problem of women free spirits who are insubordinate to male authority, or a problem of homosexuality, or female sexual provocation, or even the problem of women obscuring male glory to God by being uncovered. Rather some in the church ignored the social boundaries between men and women signified by the cultural rules of distinguishing male from female by how they covered their heads. The women dishonored the men (their ‘heads’) and the males shamed in turn Christ (their ‘head’).

Therefore the question of what kephalē means in verse 3 is not to be sought by going elsewhere in Paul’s writings or by immediately jumping to verses 7-9 and reading an authority-subordination sense back into verse 3. Instead, the sense of kephalē should come from verses 4-5 which presuppose the meaning of kephalē in verse 3. “To shame one’s head is to do the opposite of what is expected, namely, to honor the head. For the head signifies what is preeminent” (following Cervin) (159). Nevertheless, “the patriarchal connotations of 11:3 do not disappear when one opts for the translation of kephalē as ‘one who is preeminent’ rather than ‘ruler’ or ‘source.’ All these possible translations have patriarchal connotations” (159). Verses 7-9 then explicitly take up this problem by drawing out the theme of ‘glory’ from the creation accounts in Genesis 1 and 2 read through a gender-based patriarchal interpretive lens. Paul argues from this that a woman’s head should be properly covered to show respect or honor to a man in a patriarchal social-cultural situation.

However, this is not the whole story. Paul abruptly turns and shows that he can also argue from the creation order now (“man comes through a woman,” 11:11-12) that in the new creation (“in the Lord”) woman is now prior to man and “all things are from God” including the woman, a view that denies the exclusive privilege of man argued for in 11:7-9.

Paul is not claiming here that man needs woman as his subordinate and woman needs man as her ‘head,’ nor even simply that they are essential to each other according to God’s design, but that since neither exists without the other, neither has exclusive priority over the other and therefore gender does not determine priority in their relationship ‘in the Lord.’ In 11:11, therefore, Paul undermines gender-based hierarchy in the body of Christ.…At the same time the difference between man and woman remains. (163)

This tension must be maintained between the redeemed order where gender distinctions remain but are socially relativized, and the way this is expressed in the cultural situation of patriarchy. Unfortunately, Gundry-Volf’s work on this passage and Galatians 3:28 is buried in little-known scholarly publications. She warrants more widespread reading.

Gregory W. Dawes (1998)

Gregory W. Dawes’ work on Ephesians 5:21-33 is not well known in the larger discussion.²⁷ The first seventy-six pages of this book deal with the mostly neglected subject of metaphor. Dawes not only distinguishes metaphor from analogy and model, but also clarifies ‘dead’ metaphor from ‘live’ metaphor. The meaning of a ‘dead’ metaphor (one having a common range of meanings) can be studied lexically and its meaning possibilities listed. ‘Live’ metaphors on the other hand cannot be studied lexically since they are the creation of the author and get their meaning from some unexpected association with something else.

I remember a seminary professor who regularly prayed that the Holy Spirit would ‘electrify’ our lives. I had heard of ‘electrify’ before but never in connection with the Holy Spirit. This is a ‘live’ metaphor and will not be found in dictionaries under the word ‘electrify.’ Only the context of the term can determine its sense. Further, an author may vary the metaphorical meaning of an expression from one context to another and even within the same context! This is a point that has not been sufficiently noticed in the debate over the meaning of ‘head.’

In a chapter on kephalē, as in “The husband is the head of the wife” (Eph. 5:23), Dawes concludes, presumably to Professor Grudem’s delight, that

whatever other [metaphorical] senses the word kephalē may have had, the context in which it is used in Ephesians 5:22-24 demands that the meaning ‘authority over’ be adopted. For in verses 22-24 the word is used…to reinforce the case for the ‘subordination’ of wives. It can only fulfill this function if it carries with it some sense of authority. (134)

However, he criticizes both the patriarchal-traditionalists for finding only this meaning in the word regardless of the context, and also the egalitarians for refusing to see ‘authority over’ as the sense in this context of Ephesians 5:21-33.

However, egalitarians should not despair because Dawes finally concludes that

[A] close reading shows that what Ephesians asks is that both wives and husbands live lives of mutual subordination and

self-sacrificing love, after the example of Christ.…While married couples are joined in a particularly intimate, bodily union (Eph 5:31), a union which demands that they care for and take responsibility for one another, it is also because they are ‘members of…[the] body of Christ’ (cf. Eph 5:30), and therefore ‘members of one another’ (Eph 4:25), that they are bound to this new and distinctively Christian ethic. (233)

Ultimately, the same tension exists here in Ephesians 5:21-33 between loving mutuality based on equality of genders and the patriarchal submission order, between one-directional subordination and the subversion of patriarchal order, as is found in 1 Corinthians 11:2-16 where the apostle concludes by saying, “Nevertheless, in the Lord woman is not independent of man or man independent of woman. For just as woman came from man, so man comes through woman; but all things come from God” (vv. 11-12).

Anthony C. Thiselton (2000)

In perhaps the premier and definitive interpretive commentary on 1 Corinthians to date, Anthony C. Thiselton²⁸ has reviewed the debate in depth, referring to more than eighty publications. Three viewpoints on the metaphorical sense of kephalē have emerged: (1) ‘authority over’ (Fitzmyer 1989, 1993; Grudem 1985, 1990, 2001); (2) ‘source,’ ‘origin,’ ‘temporal priority’ (Bedale 1954; Bruce 1971; Murphy-O’Connor 1989, 1997; Fee 1987; Schrage 1995); and (3) ‘preeminent,’ ‘foremost,’ ‘representative’ (the part representing the whole) (Cervin 1989; Perriman 1994). After critically examining each view in detail, Thiselton leans toward the third view and highlights Gundry-Volf’s exegesis of the passage in 1 Corinthians 11:3-16. He prefers to use three English words to express the meaning of kephalē in 11:3: ‘preeminent’ (of Christ), ‘foremeost’ (of man), and ‘preeminent’ (of God) while retaining the translation of kephalē as ‘head,’ with the qualification that the English word ‘head’ does not exactly coincide with Paul’s use of kephalē.

He remarks that the evidence for kephalē meaning ‘authority over’ and ‘source’ is definitely shrinking. This makes it increasingly difficult to argue for either ‘authority over’ or ‘source’ as exclusive senses or to argue any longer that either is the common meaning of kephalē in the New Testament period, much less in Paul’s writings.

Wayne Grudem (2001)

Again Wayne Grudem²⁹ responds to several authors who had written studies on kephalē since his earlier response (1990) and with whom he mostly disagrees. The bulk of the article focuses on a critique of an entry on “head” by Catherine Kroeger in the Dictionary of Paul and His Letters (1993). In that article Kroeger argues that early evidence from church leaders supported the meaning of kephalē as ‘source’ as well as some new evidence from non-Christian sources. Aside from some petty inaccuracies, Grudem’s main criticisms are as follows. Kroeger has given the impression that Chrysostom (a.d. 347-407) believed that kephalē meant ‘source’ and not ‘authority over.’ Grudem counters that in the full context of the statements this is false. Additional statements from Chrysostom show he believed firmly in male authority over women and understood kephalē in this way.

Further theological questions are raised. Does “the head of Christ is God” (1 Cor. 11:3) teach (given the sense of kephalē as ‘authority over’) the “eternal subordination of the Son” (Grudem’s view but understood by Kroeger as heretical) in the Trinitarian Godhead? Or if kephalē means ‘source’ (Kroeger’s view), how do we avoid the Arian heresy of the Son being created by the Father?

The last criticism comes in the form of a detailed analysis of fourteen further examples she gives of kephalē meaning ‘source.’ Grudem claims all of these are false and do not prove her case.

The article closes with brief attention to articles by Turner,³⁰Fitzmyer,³¹ Arnold,³² Dawes,³³ Perriman,³⁴ May and Joe,³⁵Brown,³⁶ Keener,³⁷ and Groothuis,³⁸ some agreeing and some disagreeing with Grudem. He concludes that ‘authority over’ as the meaning of kephalē is “firmly established” (64).

Concluding observations and implications for understanding 1 Corinthians 11:3 and Ephesians 5:23

Where does the above summary of the debate leave us? How can we move forward in our understanding of the key texts that affect our Christian attitude and practice in the home and church? Let me try to summarize what I have learned through this meta-study. In my judgment (not all will agree) the following points should be taken into consideration in all future discussions of kephalē and how 1 Corinthians 11:3 and Ephesians 5:23 are interpreted and applied.

The lexical battle

1. The actual evidence outside the Bible for kephalē meaning ‘source’ and kephalē meaning ‘authority over’ in the New Testament period is shrinking. Which option is ‘weaker’ remains debatable.
2. Most all parties now agree that in certain contexts kephalē may mean either ‘authority over’ or ‘source.’ Whether both are always present is debatable.
3. A discernable trend may be noticed to accept the general background of the metaphorical sense of kephalē as stemming from the anatomical relation of the head to the body as its most ‘prominent,’ ‘respected,’ ‘preeminent,’ or ‘illustrious’ part.
4. There seems to be growing agreement that kephalē as a metaphor can have a different sense in a different context and even different senses in the same context.
5. If Paul is using kephalē as a ‘living’ metaphor (a rare or unique use) in any place, the precise sense of kephalē may be ascertained only by the context, not by lexical studies of ‘dead’ metaphors (having a standard sense).
6. Prejudice seems evident in those studies that fail to recognize possible multiple meanings of kephalē and instead continue to force all texts in Paul to conform to a single primary meaning, whether ‘source’ or ‘authority over.’
7. Several of the studies above may operate with the fallacy of reading modern ‘egalitarian’ models back into the biblical texts or to see more recent ‘modified patriarchal’ positions as present in the Pauline uses of kephalē.
8. If there is any change in the lsj lexicon to include ‘authority over,’ there should be also a corresponding change in the bagd lexicon to include ‘source’ or ‘origin’ as another rare but possible sense of kephalē.
9. The word kephalēshould continue, as in most translations, to be rendered by ‘head’ yet with the recognition that the English word is not an exact equivalent of the Greek.

Applying this study to two key Pauline texts

Briefly but hopefully with profit I would like to suggest how this study might be applied to 1 Corinthians 11:3 and then to Ephesians 5:23.

“The head of every man is Christ, and the head of the woman is man, and the head of Christ is God” (1 Cor. 11:3 TNIV). Female insubordination to male authority is not the primary problem Paul addresses here. Rather, as the text goes on to tell us, it was dishonoring behavior of culturally inappropriate head/hairstyles practiced by both men and women as they were alternating in leading prayer and preaching in the worship of the church (vv. 4-6; 11-16).³⁹ Paul uses kephalē as ‘prominent’ or ‘honored’ of the male-female relation along with a Jewish, gendered reading of the creation accounts (Gen. 1 interpreted by Gen. 2) to root out this unacceptable practice (vv. 7-9). The use here of kephalē includes overtones of patriarchal cultural expectations regarding male honor that Paul wants to preserve for the sake of the mission of the church. We must remember that the church met in homes that were open to the public as they met. Any deviance from the patriarchal norms of male respect or honor, evidenced outwardly by the way the hair was worn on the head, would be seen as a radical social aberration and would produce unnecessary serious opposition to the fledgling church at Corinth.

Such a reading of 11:3-10 addresses the honor/shame problem and at the same time preserves the biblical distinction between male and female that Paul wants to preserve. He thus adapts the gospel to the surrounding culture without compromising its essential message. It also prevents serious Christological problems with the expression “the kephalē of Christ is God” that result by interpreting kephalē either as ‘authority over’ (Grudem’s eternal subordination of the Son) or as ‘source’ (suggesting the Arian heresy).

That Paul can in another context, that of the actual nature and functioning of the church (“in the Lord”), argue for a completely non-gendered and egalitarian understanding of creation is witnessed to in 11:11-16. Both readings of creation must be kept in tension and not reduced to an either/or approach.

“The husband is the head [kephalē] of the wife as Christ is the head [kephalē] of the church” (Eph. 5:23 TNIV) presents another interpretive challenge. Complementarians will argue that since kephalē means ‘authority over’ in reference to Christ in other passages (Eph. 1:22; Col. 2:10) his headship here is also to be understood as ‘authority over.’ This is confirmed by the command for wives to submit themselves to their husbands’ authority over them (v. 22). Yet, the cultural context of patriarchalism is ignored or relativized in terms of how this injunction might be understood in a non-patriarchal or egalitarian culture such as most of the Western world today.

Another approach would be to retain the sense of kephalē as ‘authority over’ in this context, but to argue that in a changed cultural context such as ours the best application of Paul’s teaching is ‘mutual submission’ or ‘mutual yielding’ or ‘deference’ (Dawes; Johnson).⁴⁰ As Kevin Giles, aware of the discussion outlined above, and adopting the sense of kephalē as ‘authority over’ for this passage has recently argued:

The word [kephalē], however, is given new content. To be the “head” of one’s wife, Paul explains, involves not rule, but sacrificial, self-giving, agape-love. Jesus exemplifies this kind of leadership in his self-giving on the cross. It is the leadership of the servant who is willing to serve even to the point of giving one’s life for the other. Not one word is said in this passage about who makes the final decision on important matters. In Ephesians 5:21ff, Paul is seeking in his cultural setting to transform patriarchy—male authoritative leadership—not endorse it. When first read it would have been the men in that church who felt threatened by the counter-cultural teaching Paul enunciates. In its original historical context, this was a liberating text. It should be read in this way today.⁴¹

Still another approach would be to understand kephalē as in 1 Corinthians 11:3 as ‘prominent’ or ‘honorable’ of the husband vis-à-vis the wife in terms of the patriarchal social structure of the day. Paul then redefines this honored position not in terms of Christ’s lordship over the church, but his kephalē that is manifest in his love and servant-self-giving and other nurturing and promoting aspects of his relationship to the church. This same model is to be the example that a Christian husband follows as he relates to his wife and she in turn yields herself in respect to this kind of person. Again in our non-patriarchal culture (one not requiring male honor), mutual yielding (v. 21) and mutual respect in my judgment best fulfills this model of Christ. His example is beautifully portrayed in the footwashing account and commanded to all believers, including husbands and wives, in their relation to each other (John 13:1-17).

Notes

1. Stephen Bedale, “The Meaning of kephalē in the Pauline Epistles,” Journal of Theological Studies n.s., 50 (1954): 211-15.
2. Leon Morris, The First Epistle of Paul to the Corinthians, Tyndale New Testament Commentary (Grand Rapids, Mich.: Eerdmans, 1958).
3. C.K. Barrett, The First Epistle to the Corinthians (New York: Harper & Row, 1968).
4. F.F. Bruce, 1 and 2 Corinthians, New Century Bible Commentary (Grand Rapids, Mich.: Eerdmans, 1971).
5. Morna D. Hooker, “Authority on Her Head: An Examination of 1 Cor. XI.10,” New Testament Studies 10 (1963-64): 410-16.
6. Fee adds further evidence for this meaning by pointing out that exousia never has the passive sense, and that the idiom “to have authority over” never refers to an external authority different than the subject of the sentence. Gordon D. Fee, The First Epistle to the Corinthians, New International Commentary on the New Testament (Grand Rapids, Mich.: Eerdmans, 1987), 519.
7. Robin Scroggs, “Paul and the Eschatological Woman,” Journal of the American Academy of Religion 40,3 (1972): 283-303.
8. Fred D. Layman, “Male Headship in Paul’s Thought,” Wesleyan Theological Journal 15,1 (Spring 1980): 46-67. Available online at http://wesley.nnu.edu/wesleyan_theology/theojrnl/11-15/15-04.htm.
9. James B. Hurley, Man and Woman in Biblical Perspective (Grand Rapids, Mich.: Zondervan, 1981).
10. Gilbert Bilezikian, Beyond Sex Roles (Grand Rapids, Mich.: Baker, 1985). Page numbers refer to the 2nd ed.
11. Berkeley and Alvera Mickelsen, “Does Male Dominance Tarnish Our Translations?” Christianity Today, Oct. 5, 1979, 23-26; “The Head of the Epistles,” Christianity Today, Feb. 20, 1981, 20-23; “What Does Kephalē Mean in the New Testament?” in Women, Authority and the Bible, ed. Alvera Mickelsen (Grand Rapids, Mich.: Zondervan, 1986), 97-132.
12. Wayne Grudem, “Does kephalē (Head) Mean ‘Source’ or ‘Authority Over’ in Greek Literature? A Survey of 2,336 Examples,” Trinity Journal n.s., 6 (1985): 38-59.
13. Gilbert Bilezikian, “A Critical Examination of Wayne Grudem’s Treatment of Kephalē in Ancient Greek Texts,” paper presented for a plenary session of the annual meeting of the Evangelical Theological Society in Atlanta, Ga., Oct. 20, 1986. The paper is included as an appendix in Beyond Sex Roles, 2nd ed. (Grand Rapids, Mich.: Baker, 1985), 215-52. Page numbers refer to the version published in this appendix.
14. Walter L. Liefeld, “Women, Submission & Ministry in 1 Corinthians,” in Mickelsen, Women, Authority & the Bible, 134-53.
15. Catherine C. Kroeger, “The Classical Concept of Head as ‘Source’” in Gretchen Gaebelein Hull, Equal to Serve (Old Tappan, N.J.: Fleming Revell, 1987), 267-83.
16. Cervin, Richard S. “Does Kephalē Mean ‘Source’ or ‘Authority Over’ in Greek Literature? A Rebuttal,” Trinity Journal n.s., 10 (1989): 85-112.
17. Joseph A. Fitzmyer, “Another Look at Kephalē in 1 Corinthians 11:3,” New Testament Studies 35 (1989): 503-11.
18. Jerome Murphy O’Connor, “Sex and Logic in 1 Corinthians 11:2-16,” Catholic Biblical Quarterly 42 (1980): 482-500; “Interpolations in 1 Corinthians,” Catholic Biblical Quarterly 48 (1986): 81-94.
19. Joseph A. Fitzmyer, “Kephalē in 1 Corinthians 11:3,” Interpretation 47,1 (Jan. 1993): 52-59.
20. Wayne Grudem, “The Meaning of Kephalē (‘Head’): A Response to Recent Studies,” in Recovering Biblical Manhood and Womanhood, ed. John Piper and Wayne Grudem (Wheaton, Ill.: Crossway, 1991), 425-68.
21. Philip B. Payne, “Response,” in Mickelsen, Women, Authority and the Bible, 121-124.
22. Fee, First Epistle to the Corinthians, 501-505.
23. Peter Cotterel and Max Turner, Linguistics and Biblical Interpretation (Downers Grove, Ill.: InterVarsity, 1989), 144.
24. Andrew C. Perriman, “The Head of a Woman: The Meaning of Kephalē in 1 Cor. 11:3,” Journal of Theological Studies 45,2 (1994): 602-22.
25. Judith M. Gundry-Volf, “Gender and Creation in 1 Corinthians 11:2-16: A Study in Paul’s Theological Method,” in Evangelium, Schriftauslegung, Kirche Feschrift für Peter Stuhlmacher, ed. Jostein Ådna, Scott Hafemann, and Otfried Hofius (Göttingen, Germany: Vandenhoeck & Ruprecht, 1997), 151-71.
26. Anthony C.Thiselton, The First Epistle to the Corinthians, New International Greek Testament Commentary (Grand Rapids, Mich.: Eerdmans, 2000), 803.
27. Gregory W. Dawes, The Body in Question: Metaphor and Meaning in the Interpretation of Ephesians 5:21-33, Biblical Interpretation 30 (Leiden, Netherlands: Brill, 1998).
28. Thiselton, First Epistle to the Corinthians, 812-23.
29. Wayne Grudem, “The Meaning of Kephalē (‘Head’): An Evaluation of New Evidence, Real and Alleged,” Journal of the Evangelical Theological Society 44,1 (March 2001): 25-66.
30. Max Turner, “Modern Linguistics and the New Testament,” in Hearing the New Testament , ed. Joel Green (Grand Rapids, Mich.: Eerdmans; Carlisle, UK: Paternoster, 1995), 165-172.
31. Fitzmyer, “Kephalē in 1 Corinthians 11:3,” 52-59.
32. Clinton Arnold, “Jesus Christ: ‘Head’ of the Church (Colossians and Ephesians),” in Jesus of Nazareth: Lord and Christ, ed. Joel B. Green and Max Turner (Grand Rapids, Mich: Eerdmans; Carlisle, UK: Paternoster, 1994) 346-366.
33. Dawes, The Body in Question.
34. Andrew C. Perriman, “The Head of a Woman,” 602-622.
35. Grace Ying May and Hyunhye Pokrifka Joe, “Setting the Record Straight,” Priscilla Papers 11,1 (Winter 1997): 1-10.
36. Judy Brown, “I Now Pronounce You Adam and Eve,” Priscilla Papers 13,4 (Fall 1999): 2-3.
37. Craig Keener, Paul, Women, and Wives (Peabody, Mass.: Hendrickson, 1992), 34.
38. Rebecca Groothuis, Good News for Women (Grand Rapids, Mich.: Baker, 1997), 151.
39. The question of whether Paul is dealing with hair itself (long or short; loose or pinned up) or some cloth hood is still debated. Veiling is considerably less likely. A growing number of scholars are now arguing that ‘hair’ style itself is the marker of sexual identity (Hurley, Layman, Padgett, Gundry-Volf, Blattenberger, Johnson, Payne). It was apparently the view also of John Chrysostom (4th cent., see The Homilies of Chrysostom on Corinthians, 152).
40. Alan F. Johnson, “A Christian Understanding of Submission,” Priscilla Papers 17,4 (Fall 2003): 11-20.
41. Kevin Giles, unpublished lecture notes. See his related comments in his essay in this volume, and his discussion of “An Egalitarian-Complementarian Reading of Scripture” in The Trinity & Subordinationism: The Doctrine of God & the Contemporary Gender Debate (Downers Grove, Ill.: InterVarsity Press, 2002), 203-08.