One of the perennial arguments in favor of definite atonement (that Jesus did not die except for a subset of humanity) is that if Jesus paid for the sins of all humanity, then it is logically impossible for those same people to suffer condemnation, or that it would be unjust to exact the same penalty twice. If some suffer condemnation and hell, how could it be possible for someone whose debt of sin has been paid? A double payment would be unfair, so this argument goes. (An alternative presentation of this says that if Jesus died for the sins of all must inevitably lead to universalism—the belief that all humanity will be saved.)
It is important to note that this argument is a logical one, not a biblical one, for there is no Scripture anyone can point to that presents the death of Christ bringing salvation to anyone apart from faith. It is believers, and believers only, who are redeemed. Indeed, several Calvinists have seen the fallacy of the double payment argument and the distorted view of the atonement it represents.
To see the atonement in monetary or commercial terms, is frequent among those holding to definite atonement. John Owen, held up as the ultimate defender of definite atonement, puts it in these terms:
“To whom any thing is due from any man, he is in that regard that man’s creditor; and the other is his debtor, upon whom there is an obligation to pay or restore what is so due from him, until he be freed by a lawful breaking of that obligation, by making it null and void; which must be done by yielding satisfaction to what his creditor can require by virtue of that obligation: as, if I owe a man a hundred pounds, I am his debtor, by virtue of the bond wherein I am bound, until some such thing be done as recompenseth him, and moveth him to cancel the bond; which is called satisfaction.”
That Owen conceives of sin and the atonement in bookkeeping terms is plain. Thus Christ, says Owen, has paid in full the debt of the elect, and their debt only, thereby freeing them from obligation for their sins. Indeed, Owen believes his case is airtight, and asks “If the full debt of all be paid to the utmost extent of the obligation, how comes it to pass that so many are shut up in prison to eternity, never freed from their debts?”
The answer, in part, comes from Owen’s fellow Calvinist Charles Hodge, who identifies the error in conceiving of the atonement in monetary, debt language. “There is no grace in accepting a pecuniary satisfaction. It cannot be refused. It ipso facto liberates. The moment the debt is paid the debtor is free; and that without any condition. Nothing of this is true in the case of judicial satisfaction.”
Hodge identifies a critical distinction between a pecuniary satisfaction and a judicial one. Pecuniary means “of or relating to money” and if a debt is owed, and paid by a third party, the matter is settled then and there. Imagine someone has a large balance on their credit card, and someone pays it on their behalf. It is wiped from the books and there would from that moment, be no outstanding balance. Owen wants to say this is exactly what happens with our sins—but it is false. If it were true, then the elect could never be called to faith, they could never be termed “children of wrath,” they could never be warned of coming judgement and urged to repent. For their debt is already paid and they are free from any condemnation the moment Christ died—if Owen’s understanding is correct. But the Bible speaks in no such terms. It urges all men without exception to turn, repent and believe, to flee from the coming wrath.
This gets to the true nature of the atonement, as Hodge points out, of a judicial satisfaction. And it is here where case law provides a pertinent illustration. In 1830, George Wilson was convicted of robbing the US mail, and was sentenced to death. Through the influence of a friend, President Andrew Jackson pardoned Wilson, but Wilson refused the pardon. The case went to the Supreme Court, which ruled in 1833:
“A pardon is a deed, to the validity of which delivery is essential, and delivery is not complete without acceptance. It may then be rejected by the person to whom it is tendered; and if it be rejected, we have discovered no power in a court to force it on him.”
In other words, acceptance of the pardon is essential to it. The parallel to the atonement is plain. Acceptance by faith of the Lord Jesus and his death in payment for one’s guilt is essential. Apart from this acceptance, the pardon for sins is not in force. The New Testament everywhere enjoins faith as a requirement for pardon. One can see how judicial satisfaction is far more reflective of the biblical data than a commercial or monetary view.
This question did in fact emerge again in US history. In 1915, George Burdick v United States deliberated largely the same question. Burdick did not want to accept the pardon offered, because it carried an admission of guilt. In citing the earlier case, the court noted the prior pardon was conditional, that is, limited to the crime of robbing the mail that Wilson committed. The pardon from Woodrow Wilson for Burdick’s case said that he, as president, grants “unto the said George Burdick a full and unconditional pardon for all offenses against the United States which he, the said George Burdick, has committed or may have committed.” Did the fact that Burdick’s pardon was explicitly unconditional mean it differed from Wilson’s? It did not. United States v. George Burdick upheld the principle of United States v George Wilson: the pardon must be accepted to be in effect.
One can see how this principle sets aside the “double payment” argument. The New Testament does not present the death of Christ as immediately procuring the pardon of anyone and everyone, but only those who come by faith to Christ. The double payment argument is a category confusion, bringing monetary parallels where they are not appropriate. The judicial nature of the atonement means that the pardon must be accepted.
 John Owen, The Death of Death in the Death of Christ (Edinburgh/Carlisle, Banner of Truth, 1967), 153.
 Owen, 161.
 Charles Hodge, Systematic Theology, Vol 2. (New York, Charles Scribners,& Sons, 1872), 554-555.
 Cornell Law School, Legal Information Institute, “United States vs. George Wilson” (https://www.law.cornell.edu/supremecourt/text/32/150)
 Justitia, U.S. Supreme Court, Burdick v. United States, 236 U.S. 79 (1915) (https://supreme.justia.com/cases/federal/us/236/79/#89-90)