Shalom Holtz has clearly demonstrated that laments in the Psalms manifest multiple applications of ancient Near Eastern legal language and procedure, including the lamenter’s claim to proper standing in the divine courtroom. From the perspective of form criticism, Psalm 39 departs in noticeable ways from the typical psalm of lament, as one of the very few laments that does not close with some indication of a vow of praise. Instead, the psalm requests relief from the divine presence, which it bases in part on the speaker’s status as an alien and stranger (gēr wǝtôšāb). As is made clear by Abraham’s negotiations for a burial plot in Genesis 23, the status of alien and stranger has legal implications. Abraham, as an alien and stranger, cannot simply acquire property permanently as could a native citizen. Thus, in Psalm 39’s mode of praying legally, the status of alien and stranger represents a departure from the typical lamenters’ self-presentation as “devoted clients or subjects of God, their divine patron” (Holtz, Praying Legally, 43). Rather, by evoking the status of alien and stranger, the psalm adds force to the request for relief rather than for divine attention: as one estranged from the divine judge’s beneficence, the plaintiff requests divine inattention instead.