Benjamin Sommer's ambitious attempt to reconcile biblical criticism with Conservative Judaism's "Torah as Midrash" theology ultimately fails to find adequate scriptural support. The theology posits that Torah represents human interpretations of a contentless divine revelation rather than direct divine dictation - a view that seeks to preserve Torah's sacred status while accepting critical scholarship's rejection of Mosaic authorship. Through critical analysis of Sommer's exegetical arguments regarding the Sinai pericope in Exodus and the Elijah narrative in 1 Kings 19, significant problems emerge in his integration attempt. While biblical sources may support the concept of contentless revelation, they do not substantiate the crucial element of "open command" - God's commanding presence without specific content. The theological framework, developed from Rosenzweig and Heschel through contemporary Conservative thought, faces particular challenges: pre-Israelite theophanic traditions underlying the biblical sources contain no commanding elements, and the paradigmatic nature of the Sinai revelation appears questionable given the prevalence of specific divine commands elsewhere in the Pentateuch. These findings suggest that "Torah as Midrash" theology must stand independently of biblical narrative rather than claiming ancient textual support for its contemporary formulation.