Michael’s Dispute Over Moses's Body
An enigmatic passage in the letter of Jude reads,
“But Michael the archangel, when he disputed with the devil and argued about the body of Moses, did not dare pronounce against him an abusive judgment but said, ‘The Lord rebuke you!’” (Jude 1:9, NASB)
This reference has long puzzled readers and scholars alike, as Israel's Scriptures offer no direct account of such a confrontation. The Assumption of Moses, also known as the Testament of Moses, is a first-century Jewish apocryphal work describing Moses’s final instructions and death. In a tradition reflected there, Michael disputes with the devil over Moses’s body and refuses to pronounce a reviling judgment.
Although this episode has no parallel in canonical Scripture, it closely matches a lost ending or variant tradition of the Assumption of Moses to which early Christian writers such as Origen and Gelasius refer. This suggests that Jude is deliberately alluding to that text—much as he does to 1 Enoch elsewhere in the letter (Jude 1:14–15).
Jude may also allude to the book of Deuteronomy. However, many modern Bible translations obscure a crucial detail in Deut 32:8, which makes its connection to Jude 1:8–9 easy to overlook.
Traditional translations such as the KJV, NIV, and NASB—based on the medieval Masoretic Text—read that God fixed the boundaries of the nations “according to the number of the sons of Israel.” However, earlier manuscript witnesses tell a different story. Older sources such as the Dead Sea Scrolls (2nd–1st century BCE) and the Septuagint (3rd century BCE) preserve the original reading: not "sons of Israel," but “sons of God.”
This earlier wording is reflected in translations like the ESV, NRSV, NET, and NABRE, which speak of heavenly beings rather than earthly Israelites. The older reading fits the biblical context well: following the Tower of Babel (Genesis 11), the nations listed in Genesis 10 are apportioned among the “sons of God,” while the Most High God reserves Israel for Himself (Deut 32:9).
The later substitution of “sons of Israel” likely reflects a scribal effort to safeguard monotheism amid surrounding polytheistic traditions. This change—made sometime between the Septuagint and the Masoretic Text—reframed the passage in a theologically safer way and remained largely unnoticed for centuries, a point noted by scholars such as Emanuel Tov.
According to Deuteronomy 34:1–6, Moses died on Mount Nebo in the land of Moab, “in the valley opposite Beth-peor,” and was buried there by the Lord, though no one knows the location of his grave.
This setting is significant. Beth-peor—literally “House of Peor”—was a major cult center dedicated to the Canaanite god Baal of Peor. In ancient Israelite thought, the wilderness itself was often associated with chaos, danger, and demonic presence, standing in contrast to the ordered, life-giving land. This worldview helps explain why Jesus is tempted by the devil in the wilderness (Matt 4:1): while God can act there, the wilderness is not portrayed as neutral space.
The phrase “And He buried him” (Deut 34:6) may not necessarily refer to God directly; some have suggested that Michael the archangel carried out the burial, a possibility that resonates with Jude 1:9. Building on this, Michael Heiser has proposed that Moses’ burial near Beth-peor—outside Israel’s allotted inheritance—could have provided Satan with a territorial claim. As a prominent site of Baal worship, the area may have fallen under the authority of a rebellious “son of God,” offering a plausible backdrop for the dispute described in Jude.
Ancient peoples did not define divinity the way modern readers often do. Today, God is commonly described in terms of attributes—omnipotent, omniscient, omnipresent. In the ancient world, however, divinity was primarily a matter of residence: humans belonged to the earthly realm, while gods belonged to the heavenly or spiritual one.
Scripture reflects this worldview clearly. God presides over a divine council (Ps 82:1), Satan appears alongside the “sons of God” before the LORD (Job 1:6), and the God of Israel is proclaimed as supreme above all gods (Ps 135:5). The Bible also depicts powerful heavenly beings associated with specific territories. In Daniel 10, a heavenly messenger explains his delay by describing resistance from the “prince of the kingdom of Persia,” until Michael, one of the chief princes, comes to his aid (Dan 10:12–13).
For readers concerned about monotheism and the Shema—“Hear, O Israel: the LORD is our God, the LORD alone” (Deut 6:4)—this language does not undermine God’s uniqueness. Rather, it affirms that while other divine beings may exist, Israel’s God is the Most High. He alone is to be worshiped and obeyed.
In this episode, Satan’s claim may have sounded like a legal argument: Moses sinned and died within territory associated with Baal-Peor—a domain under the authority of a rebellious divine power. Therefore, Satan could assert that Moses’ body belonged to the powers governing that realm, and that Michael had no jurisdiction to remove it. The dispute, then, was not a personal clash between angelic beings but a challenge over territorial sovereignty.
Michael’s response—“The Lord rebuke you” (Κύριος ἐπιτιμήσαι σοι)—is a decisive legal maneuver. Rather than contesting Satan’s claim on its own terms, Michael refuses to acknowledge any rival authority. By appealing directly to the Lord, the Most High, he invokes the supreme ruler whose will overrides all territorial boundaries and spiritual hierarchies (Ps 135:6). The rebuke functions as a sovereign decree that nullifies lesser claims and silences opposition.
Moses sinned, and he died outside the land, in a valley associated with death and foreign worship. By every accusation, his body seemed claimable. Yet when the dispute arose, Michael did not debate the charge or recognize any rival authority. He simply appealed to the highest one: “The Lord rebuke you.”
Moses’s tomb is empty not because he was without sin, but because death had no final claim over what belonged to God. That pattern reaches its fulfillment in the empty tomb of Jesus, where every competing authority is decisively overruled. Like Moses, we fail. Yet we are claimed—not by merit, but by the authority of the One who rules over every realm.
