These theologians may offer variations on Osiander's theory, but in principle they all advocate a justification based on an analysis of what the believer is or is in process of becoming. John Henry Newman of the mid-nineteenth century was a brilliant scholar who desperately tried to make a synthesis between the Protestant and Catholic positions. But Newman argued that God's word is a potent word which creates what it declares. Newman used the analogy of the creation epic. So, concluded Newman, when God declares the sinner righteous, that mighty creative word makes him righteous.
Justification is therefore a declaring righteous which is also a making righteous.
Whereas Osiander said that God declares righteous as a result of making righteous, Newman said that God makes righteous as a result of declaring righteous. But both roads lead back to Rome because, in both instances, sanctification becomes confounded with justification. Every attack on the forensic nature of justification is represented by two men - Osiander and Newman. All arguments against forensic justification seem to echo either Osiander or Newman. Newman earnestly tried to find a way to satisfy both the Protestant and Catholic camps.