As usual, a simple glance at the Scriptural context reveals no such universal absolution. And as usual, a look at the context of the Lutheran Fathers reveals that they did not teach such a thing, either.
The following is a translation of the section from Johann Gerhard’s commentary on 1 Timothy dealing with the phrase “justified in the spirit” in 1 Tim. 3:16. It is the entire section that deals with that phrase, plus a translation of Gerhard's concluding analysis of the verse.
Annotations on St. Paul’s First Epistle to Timothy
by Johann Gerhard (1582-1637)
Ἐδικαιώθη ἐν πνεύματι (“He was justified in spirit”). (1) Theodoret, Primasius, Sedulius, Anselm, Thomas, Lyranus, Cajetan, Gagnaeus, Justininanus, etc., understand “spirit” as “Holy Spirit,” so that the sense is: Just as ὁ θεάνθρωπος (the God-Man) Christ Jesus was conceived by the Holy Spirit, so from the beginning of His conception by the Holy Spirit He was made righteous and holy in such a way that He never had nor did He commit any sin. But “to be justified” is never attributed anywhere to Christ in the sense of “to be made righteous.” Nor would it denote anything special in Christ, since it is common to all righteous men that they have been justified in the Spirit. (2) It is more correctly understood as the Deity of Christ, since whatever is beyond human in Christ is called “spirit.” Therefore, it says, “The Son of God was manifested in the flesh, justified by means of the spirit,” that is, His Deity, by the strength of which He performed miracles and raised Himself from the dead. Therefore, by means of His miracles, performed by the power of a holy spirit, but especially by means of the resurrection, He demonstrated Himself to be the Son of God against the calumnies of His enemies. (Rom. 1:4, 1 Pet. 3:18).
By means of the spirit He was shown to be righteous and true (Latin declaratus est justus et verax) in works and doctrine, and He was also set free (Latin absolutus - absolved) from all the calumnies of the Jews. This type of justification for God agrees with Ps. 51:6, Matt. 11:18, Luke 7:29.
“He was justified,” that is, He was shown to be righteous (Latin justus declaratus), since in and by means of the resurrection Christ was set free (Latin absolutus - absolved) from the sins of men that He took upon Himself as Guarantor in order to make satisfaction for them to the Father.
[commentary on the rest of the verse follows, concluding with the following:]
Observe the steps in the apostolic saying: (1) “God was manifested in flesh.” This is the incarnation. (2) “Justified in spirit.” This is the policy (politia) or the conduct (conversatio) of Christ on this earth, in which, by means of various miracles, He demonstrated Himself to be the Son of God. (3) “Seen by angels.” This is the resurrection. (4) “Preached among the nations.” This is the preaching of the Gospel, which some received by faith. (5) “Received in glory.” This is the ascension.
It is clear from his own exposition of 1 Tim. 3:16 that Johann Gerhard did not find in this verse a universal absolution of all men. What he found was that, through the miracles He performed on earth and especially through His greatest miracle of raising Himself from the dead, Christ demonstrated His Deity. Gerhard did not apply this “setting free” (“justification, vindication, absolution”) of Christ to all men. He explicitly explains “this type of justification for God” in a different sense than the Book of Concord describes the justification of sinners. In other words, Gerhard is not describing the article of justification in these words, nor is he referring at all to the “forensic (divine courtroom) justification,” either of Christ or of anyone else.
What Gerhard does say about Christ is the same thing we say about Christ who deny a universal absolution without faith. Namely, that Christ “took upon Himself the sins of men as Guarantor in order to make satisfaction for them to the Father.” Indeed, Christ bore the sins of all and made satisfaction for the sins of all. He served as Guarantor (or “Sponsor”) of all men. And He was “shown to be righteous” in being “set free”(“absolved”) from sin's penalty, which is death.
But to make satisfaction for the sins of all does not result in the justification of all. It is only through faith in Christ that His satisfaction is applied to sinners so that they are justified. And to serve as Guarantor of all men does not result in the justification of all men. It is only through faith in the Guarantor that His payment is applied to their account so that they are justified before God. And Christ's being “set free” from sin's penalty, namely, death, is not a reference to any announcement by God that all sinners have been “set free” (absolved) from their sins, since all unbelievers are and remain dead and condemned.
However, those who believe in Christ do share in His resurrection and His life and have already escaped from death through faith in Him, and thus, as Calov/Gerhard point out, God “has absolved us in Him” (nos in ipso absolvit) not at the time of Christ's resurrection, but at the time when we were incorporated into Christ, namely, through Holy Baptism, which is consistent with all the Scriptures and the entire Book of Concord.