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Grounds for Divorce: Why I Now Believe There Are More Than Two

June 10, 2020

Editor’s Note: The following essay appears in the Spring 2020 issue of Eikon.

Until 2019, I held the common, historic Protestant view of divorce, namely, that adultery and desertion were the only two legitimate grounds for divorce allowed by Scripture.[1] This is the position set forth, for example, in the Westminster Confession of Faith (1646):

In the case of adultery after marriage, it is lawful for the innocent party to sue out a divorce: and, after the divorce, to marry another, as if the offending party were dead. . . . Nothing but adultery, or such willful desertion as can no way be remedied by the church or civil magistrate, is cause sufficient of dissolving the bond of marriage. (24.5, 6)

I defended this position and interacted extensively with numerous other positions in a forty-five page chapter in my book, Christian Ethics, and I will not repeat those arguments here.[2]

However, as a result of additional research that I carried out in 2019, I now believe that 1 Corinthians 7:15 implies that divorce may be legitimate in other circumstances that damage the marriage as severely as adultery or desertion. This change in my position has come because I reached a new understanding of Paul’s expression “in such cases” in 1 Corinthians 7:15.

A. A new and broader understanding of “in such cases” (1 Corinthians 7:15). Here is the key verse where Paul allows for divorce in cases of desertion by an unbeliever:

But if the unbelieving partner separates, let it be so. In such cases the brother or sister is not enslaved. God has called you to peace. (1 Cor. 7:15)

The Greek phrase translated “in such cases” is en tois toioutois. The phrase does not occur anywhere else in the New Testament, nor does it occur in the Septuagint. This phrase does occur in Greek literature outside the Bible, but, so far as I could tell, no interpreter of 1 Corinthians has ever studied its use in extra-biblical literature.[3] Most commentaries just assume that it means “in cases of desertion by an unbeliever,” which is the specific situation that Paul mentions. But could its meaning be broader?

I found several examples where this phrase clearly referred to more kinds of situations than the specific situation that the author was discussing. Here are some of those examples:

(1) Philo (Jewish author; ca. 30 B.C. – A.D. 45): In commenting on the tenth plague on Egypt, when the Egyptians discovered that all their firstborn sons and firstborn cattle had been killed, Philo comments,

And, as so often happens in such cases (en tois toioutois), they thought that their present condition was but the beginning of greater evils, and were filled with fear of the destruction of those who still lived. (The Life of Moses, 1. 38).

The specific situation that Philo names is the sudden death of their firstborn sons. But “in such cases” cannot be limited to that situation only, because that had never happened before. Yet Philo is referring to something that happens quite often, for he says “as so often happens in such cases.” His meaning must be, “as so often happens when sudden tragedy strikes,” which is a much broader category than just the death of all the firstborn sons in a nation.”

(2) Lysias (Greek orator, ca. 459 – ca. 380 B.C.):

When Phrynichus had to pay a fine to the Treasury, my father did not bring him his contribution of money: yet it is in such cases (en tois toioutois), that we see the best proof of a man’s friends. (Pro Polystrato 12:4).

In this statement, Lysias cannot be claiming that “the best proof of a man’s friends” comes only when someone suddenly has to pay a fine to the Treasury, for such circumstances are uncommon. He must mean that “the best proof of a man’s friends” comes when someone suddenly has an unexpected need for money — then you will find out who your friends really are. Here again, the expression “in such cases” refers to a much broader category of situations than the specific example named.

(3) Euripides (Greek tragedian, ca. 480 – ca. 406 B.C.):

But go inside the house at once and make things ready there. Surely a woman, if she wants to, can find many additions to a meal. Really there is still enough in the house to cram them with food for one day at least. It is in such cases (en tois toioutois) . . .  that I see how wealth has great power, to give to strangers, and to expend in curing the body when it falls sick. (Electra, line 426)

The specific situation named is a sudden need for food to feed to unexpected guests, but “in such cases” refers more broadly to any situation in which wealth provides the ability to meet unexpected needs.

Other examples could be given,[4] but it should be clear from these examples that, when Paul used en tois toioutois to say that “in such cases the brother or sister is not enslaved” (1 Cor. 7:15), he implied that divorce was a legitimate possibility not only in cases of desertion by unbeliever, but also in other circumstances similar to but not necessarily exactly like desertion. A reasonable possibility is that “in such cases” in 1 Corinthians 7:15 means “in this and other similarly destructive situations” (that is, situations that destroy a marriage as much as adultery or desertion).

A confirming argument comes from Paul’s use of the plural expression “in such cases,” whereas he could have just used the singular expression en touto (“in this case”) if he had wanted to refer only to the case of desertion by an unbeliever (he uses the singular phrase in 1 Cor. 11:22 and 2 Cor. 8:10, for example).

Someone might object that Paul uses a plural expression because he mentions “the brother or sister,” which includes two people. But that objection is not persuasive because the sense of the expression “such cases” (toioutois) requires that it refer to something previously mentioned, and therefore it must refer back to the “if” clause in Paul’s argument, “if the unbeliever separates.”

B. What other kinds of situations might be harmful enough to include in “in such cases”?

Paul did not specify a list of any other specific situations in which divorce might be considered legitimate. He must have been aware of Jesus’ teaching while on earth, “What therefore God has joined together, let not man separate” (Matt. 19:6), for he says that it is a command from “the Lord” that “the wife should not separate from her husband” and “the husband should not divorce his wife” (1 Cor. 7:10–11). But in this same context Jesus had also taught that adultery was a legitimate reason, in fact the only legitimate reason, for divorce (see Matt. 19:9), and Paul no doubt was also aware of that teaching.

1. Paul’s reasoning: In light of this background, what reasoning led Paul, with his apostolic authority, to add desertion (which was not specified by Jesus) as another legitimate ground for divorce? In order to do this, he must have been persuaded that desertion by an unbeliever destroyed a marriage as much as adultery did.[5] Once the unbeliever has departed, the man and woman are no longer living together and no longer acting in any sense as husband and wife. If the deserting spouse is an unbeliever, then he or she is beyond the reach of church discipline, and there is no reasonable human hope that the man and woman will ever again function as if they are husband and wife. The marriage has been destroyed. Recognizing this reality, Paul says, “In such cases the brother or sister is not enslaved” (1 Cor. 7:15). And when he uses the broad category “in such cases,” he suggests that other situations might also be included, following the same line of reasoning. We might even consider translating the phrase as “in cases similar to this.”

2. “Not enslaved”: Paul gives another indication of the kinds of situations that would fall in this category when he permits divorce by using the unusual expression “is not enslaved” (Greek douloō, “to enslave”; this is the Greek verb that corresponds to the common noun doulos, “slave, bondservant, servant”). The Bible never uses the verb douloō anywhere else to refer to marriage, and by using it here Paul implies that forbidding a deserted spouse to be divorced would be akin to trapping that spouse in slavery. But God does not require his children to live their entire lives in a slave-like situation, Paul assures his readers, because instead of slavery, “God has called you to peace” (Greek eirēnē, “peace, harmony, well-being,” with echoes of the Old Testament concept of shālôm, “peace, well-being”).

3. Other situations that require wise consideration: With this background, we can now ask what other kinds of situations might destroy a marriage to the same extent that adultery or desertion would destroy it, and what other situations would trap a spouse in a slave-like condition that can only be remedied by divorce. Several categories of situations come to mind.

(1) Abuse: If an abused spouse is forced to flee from the home for self-protection from ongoing, violent abuse, in my judgment, that would be a situation where the damage is sufficiently similar to the damage from adultery or desertion, so that divorce would be a legitimate option.[6] In some ways such abuse is worse than desertion because it involves repeated demonstrations of actual malice, not simply indifference. Abuse is actively malevolent, and the result is the same (the couple is no longer together). The abusing spouse has not technically “deserted,” but he or she bears the moral guilt of causing the separation.

This was in fact the view of the church father Chrysostom (ca. 349–407); in commenting on 1 Corinthians 7:15 he wrote,

But what is the meaning of, “if the unbelieving departeth?” For instance, if he bid thee sacrifice and take part in his ungodliness on account of thy marriage, or else part company; it were better if the marriage were annulled, and no breach made in godliness. Wherefore he adds, “A brother is not under bondage, nor yet a sister, in such cases.” If day by day he buffet (pukteuō, box, punch) thee and keep up combats (polemos, war, battle, fighting) on this account, it is better to separate. For this is what he glances at, saying, “But God has called us in peace.” For it is the other party who furnished the ground of separation, even as he did who committed uncleanness (porneuō). (Homily 19 on 1 Corinthians in NPNF, 1.12, 108).

Let me be very clear at this point. I am not saying that divorce is legitimate in every case where  a spouse claims to be abused (whether physically, verbally/emotionally, or both). But I am saying that there are some cases where the abuse (whether physical or verbal/emotional) has damaged the marriage  as much as adultery or desertion would damage it, and “in such cases” in 1 Corinthians 7:15 would apply, and divorce would be legitimate. In some cases, even a single instance of abuse may be so violent (even resulting in broken bones and hospitalization) that it would be dangerous for the abused spouse to return, and in such a situation it would be legitimate to seek a divorce.

(2) Abuse of children: The same reasoning would apply if the abuse is directed against the children instead of the spouse.

(3) Extreme, prolonged verbal and relational cruelty that is destroying the other spouse’s mental and emotional stability could be so severe that it would fall in the category of “in such cases,” and would be a legitimate ground for divorce.

(4) Credible threats of serious physical harm or murder of a spouse or children could also, in some cases, fall in this category.

(5) Incorrigible drug or alcohol addiction, accompanied by regular lies, deceptions, thefts, and/or violence might, in some cases, be so destructive to the marriage that it would also fall in this category.

(6) Incorrigible gambling addiction that has led to massive, overwhelming indebtedness could also, in some cases, fall in this category.

(7) Incorrigible addiction to pornography might also fall in this category. But I also think that this kind of addiction could be included under the meaning of “sexual immorality” (Greek porneia) in Matthew 19:9.

(8) Situations that are not legitimate grounds for divorce: In the midst of a secular culture where divorces are far too easy and far too common, it is good to remember that Scripture does not allow divorce just because a marriage is difficult, or because a husband and wife are not getting along, or because one spouse wants to marry another person. We need to be reminded again of the warnings of Jesus that such divorces are contrary to God’s will and commonly result in what God considers to be adultery (see Matthew 19:3–9).

4. The need for wisdom: Pastors, elders, and Christian counselors, if asked for counsel about whether divorce is a legitimate option in specific cases, need much wisdom and discernment (see Phil. 1:9; James 1:5–6) in order to rightly evaluate the actual degree of harm in individual cases, and whether there is a reasonable basis for hope that the destructive behavior has ended and the marriage can be saved. This is why I have repeatedly used the words “might” and “could” in the list above. No general academic article on divorce (such as this article) can possibly specify all the complex details that will be part of every real-life situation.

C. Additional note: churches need to aggressively protect an abused spouse.

I want to emphasize at this point that in all churches, including churches that only recognize two legitimate grounds for divorce, when a situation of abuse becomes known, the church must quickly protect the abused spouse.

In a case of physical abuse, something — perhaps several things — must be done quickly to prevent the abused spouse from having to endure further suffering. As soon as church leaders become aware of a situation of physical abuse, they should act to bring the abuse to an immediate halt, often by encouraging the abused spouse to separate and move to another, perhaps undisclosed, living location (for the eventual purpose of bringing restoration of the marriage along with the complete cessation of the abuse). In addition, other actions may need to be taken, and these will vary from case to case. These actions may include church discipline, confrontation and counseling, police intervention, a court order, and other kinds of intervention by church members, family members, and friends. As I have argued elsewhere, when a person is facing the likelihood of physical assault, self-defense or fleeing from the danger are both morally right actions.[7] In some cases, filing a complaint with local police and pressing charges may also be appropriate, because violently attacking one’s spouse and doing physical harm is a criminal act and subject to legal penalties. Using every available means, the abuse must be stopped and the abused spouse must be protected.

D. Restoration of the marriage, if possible, must remain the first goal. It is important to remember that God established marriage as a lifelong commitment (see Matt. 19:3–9; 1 Cor. 7:10–14). So long as it is consistent with the necessary protection for an abused spouse, pastors and counselors should first seek to restore a marriage to health and obedience to God’s instructions about marriage. If the abusing spouse is a professing Christian, church discipline should be initiated, and it will frequently bring a good result and the marriage will be saved.

E. Objections. There are several possible objections that may be brought against my argument about “in such cases” in 1 Corinthians 7:15.

(1) Objection: In a case of abuse, why not just counsel lifelong separation without divorce?

My answer is that this would be leaving the abused spouse “enslaved” to the marriage and the abusing spouse, but Paul says such a spouse is “not enslaved” in situations like this.

(2) Objection: This will open the floodgates to many needless divorces in marriages that could have been saved.

My answer is that I am not advocating for “needless divorces.” A genuine effort to save the marriage should be attempted first. But allowing for these additional possible grounds for divorce will save thousands of sincere Christian believers from suffering horrible abuse for decades.

(3) Objection: Staying in an abusive marriage is a better way to give a witness to society about the goodness of God’s plan for lifelong marriage.

But I would reply that leaving an abusive marriage with the blessing of the church is a better way to give witness to society that God is pleased when we can help to rescue those who suffer unjustly.

(4) Objection: Sometimes God calls his children to endure suffering. In fact, Peter says, “If when you do good and suffer for it you endure, this is a gracious thing in the sight of God” (1 Pet. 2:20).

In response, I agree that God sometimes calls his people to endure suffering, but there is more to the story. God also rescues his people from suffering and calls them to escape from suffering when possible: “I am the Lord your God, who brought you out of the land of Egypt, out of the house of slavery” (Ex. 20:2). “And lead us not into temptation, but deliver us from evil” (Matt. 6:13). “When they persecute you in one town, flee to the next” (Matt. 10:23). “Were you a bondservant when called? Do not be concerned about it. (But if you can gain your freedom, avail yourself of the opportunity.)” (1 Cor. 7:21).

F. Conclusion

In 1 Corinthians 7:15, Paul writes as follows:

But if the unbelieving partner separates, let it be so. In such cases (en tois toioutois) the brother or sister is not enslaved. God has called you to peace.

Several examples from extra-biblical literature show that the expression “in such cases” (en tois toioutois) often refers to a variety of situations that are similar to but clearly not identical to the specific situation mentioned. This suggests that Paul considered divorce a legitimate possibility not only in cases of desertion by an unbeliever, but also in other situations that similarly brought extensive and severe damage to the marriage.

Wayne Grudem is Distinguished Research Professor of Theology and Biblical Studies at Phoenix Seminary in Scottsdale Arizona.

[1] This article is adapted from my forthcoming book, What the Bible Says about Divorce and Remarriage (Wheaton: Crossway, 2020), and is used with permission of Crossway Books.

[2] Chapter 32 in Wayne Grudem, Christian Ethics (Wheaton: Crossway, 2018), 799–843.

[3] I could not find any discussion of en tois toioutois in literature outside the Bible in any of the numerous academic commentaries on 1 Corinthians that I have in my home library, nor could my teaching assistant Brett Gray find any such research in any of the commentaries in the Phoenix Seminary library.

I do not think any such study of a 3-word Greek phrase would have been possible before the development of the TLG (Thesaurus Linguae Graecae) database at the University of California-Irvine, which did not become available for academic research by outside scholars until the early to mid-1980s.

[4] See Euripides, Troiades, line 303; Diodorus Siculus, Bibliotheca historica 1.23.7; Sophocles, Electra, line 990; and Epictetus, Dissertationes ab Arriano digestae 1.1.21. I did find other examples where “in such cases” referred to a broad category of actions or things that were the same or very similar to the specific situation named (such as Josephus, Jewish Antiquities 8. 379), but none of these examples was exactly parallel to 1 Corinthians 7:15, because they all had a plural antecedent, which is different from Paul’s singular example “if the unbeliever departs.” I examined 52 examples of en tois toioutois (I chose them because the English translations were most readily available to me), and I did not find one example where the phrase referred to a singular antecedent (like 1 Cor. 7:15) and the context implied that “such cases” were limited to situations that were exactly the same as the one named by the author.


[5] David Clyde Jones also sees this as the reason, for, in explaining why adultery and desertion are the two grounds for divorce given in Matthew 19:9 and 1 Corinthians 7:15, he writes, “The exceptional circumstance common to both instances is willful and radical violation of the marriage covenant” in Biblical Christian Ethics (Baker, 1994), 202.


[6] John M. Frame, The Doctrine of the Christian Life: A Theology of Lordship (Phillipsburg, NJ: P&R, 2008), 781, sees abuse as a legitimate ground for divorce in some cases. David Clyde Jones also thinks that physical abuse so violates the marriage covenant that it is a sufficient ground, as well as adultery and desertion, for divorce. See his Biblical Christian Ethics (Grand Rapids, MI: Baker, 1994), 177–204.

[7] See chapter 20 in Wayne Grudem, Christian Ethics, 551–65.

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