The following is an excerpt from
The MacArthur New Testament Commentary on Jude 9.
Yet in the same way these men, also by dreaming, defile the flesh, and reject authority, and revile angelic majesties. But Michael the archangel, when he disputed with the devil and argued about the body of Moses, did not dare pronounce against him a railing judgment, but said, “The Lord rebuke you!” (Jude 8–9)
Jude demonstrated the seriousness of the apostates’ irreverence by contrasting their behavior with that of Michael the archangel. As God’s most powerful angel and the protector of God’s people (cf. Dan. 10:13–21; 12:1), Michael did not demonstrate irreverence when he disputed with the devil and argued about the body of Moses. Michael knew that God could grant him power over Satan (cf. Rev. 12:7–9), yet he also understood that he was not to act beyond God’s prescribed limits. Out of respect for Satan’s status and power as the highest created being, Michael did not dare pronounce against him (Satan) a railing judgment as if he possessed sovereign dominion overhim. In fact, he did nothing more than utter the words, “The Lord rebuke you!”
Michael’s response anticipated the example of the Angel of the Lord in Zechariah 3:2: “The Lord said to Satan, ‘The Lord rebuke you, Satan! Indeed, the Lord who has chosen Jerusalem rebuke you! Is this not a brand plucked from the fire?’”In the prophet Zechariah’s vision, Joshua the high priest—who along with Zerubbabel led the first group of Jews back from Babylonian captivity—was standing in heaven before the Angel of the Lord. The devil was also there, at the right hand of Joshua, accusing Joshua and the nation of Israel whom he represented.
Satan’s argument, based on Israel’s sinfulness, was that God should break His covenant promises (cf. Gen. 12:3, 7; 26:3–4; 28:14; Deut. 5:1–21; 2 Sam. 7:12; Ps. 89:3–4; cf. Rom. 9:4; Gal. 3:16). In response, the Angel of the Lord (the preincarnate Christ) defended Israel by deferring to God the Father and asking Him to rebuke Satan (cf. 1 John 2:1). And the Father honored the preincarnate Son. Instead of breaking His covenant with His chosen people, God reaffirmed His commitment to Israel’s future justification, promising to forgive Israel’s sin and clothe her with garments of righteousness (Zech. 3:3–5).
When Michael contended for the body of Moses, he did just what the Angel of the Lord did. His appeal to the Lord as sovereign apparently ended the dispute with Satan. Interestingly, this is the only place Scripture mentions this incident; the Old Testament provides no details about Moses’ death other than to say, “So Moses the servant of the Lord died there in the land of Moab, according to the word of the Lord. And He buried him in the valley in the land of Moab, opposite Beth-peor; but no man knows his burial place to this day” (Deut. 34:5–6). Because God did not want anyone to preserve Moses’ body and venerate it, He gave Michael the responsibility of burying it where no one—including Satan—could find it. False teachers exercise no such restraint but pretend to have personal power over Satan and angelic beings.