The Epistle of James probably was written shortly before the Jerusalem
Conference, most likely just before, that is, about A.D. 48 or 49. There
is no room here for an extended discussion of the proof of this
statement. In general I agree with the arguments of Mayor on this
point.[25] Plummer[26] is unable to decide between A.D. 49 and 59.
Writers like von Soden place it at the end of the century, and Bruckner
puts it in the second century. Spitta admits that Paul in Romans alludes
to the Epistle of James, but suggests that the present epistle is a
Christian adaptation of a Jewish book.
On the whole, the weight of the argument is toward the conclusion that
James wrote the epistle before the Conference and without reference to
the Judaizing controversy. Paul in Galatians and Romans may very well
have in mind a misuse of what James in chapter 2 says about faith and
works, which misapprehension he seeks to correct. The epistle must be
placed either between A.D. 40 and 50, before the Judaizing controversy
arose, or in the middle of the second century, after it had died
down.[27] The early date has the best of it, in my opinion.
If this date for the writing of the epistle is correct, we have no
difficulty in seeing how James could have written it so early. Already
about A.D. 44 we saw his leadership in the Jerusalem church (Acts
12:17). No man in the apostolic circles at this period had the ear of
the Jewish Christians as did James. This is seen further in the fact
that he is asked to preside over the Conference in Jerusalem to settle
the issues raised by the Judaizers against the work of Paul and Barnabas
among the Gentiles. The epistle, therefore, seems to come in at this
state of the career of James and is the chief expression left of his
mind and life.