Hybristophilia

Hybristophilia (Pronounced hi-bris-a-fil-ee-uh)

An attraction to an individual who has committed a crime.

1986: The construct was the Ancient Greek ὑβρίζειν (hubrízein) (to commit an outrage against someone), +‎ -philia.  The -philia suffix was from the Ancient Greek φιλία (philía) (fraternal) love).  It was used to form nouns conveying a liking or love for something and in clinical use was applied often to an abnormal or obsessive interest, especially if it came to interfere with other aspects of life (the general term is paraphilia).  The companion suffix is the antonym -phobia. The related forms are the prefixes phil- & philo- and the suffixes -philiac, -philic, -phile & -phily.  One who exhibits hybristophilia is a hybristophile.  Hybristophilia & hybristophile are nouns; the noun plural is hybristophiles.

Brought to you by Cosmo which interviewed Dr Money for the December 1990 edition.

Although never explicitly mentioned in the American Psychiatric Association's (APA) Diagnostic and Statistical Manual of Mental Disorders (DSM), the phenomenon has long been noted and in popular culture is better known as “Bonnie & Clyde syndrome”.  In the mental health community, hybristophilia is (now sometimes) regarded as a paraphilia (a class of mental disorder characterized by a preference for or obsession with unusual (some still treated as “abnormal”) sexual practices) and the word “hybristophila” was in 1986 introduced by Johns Hopkins University professor Dr John Money (1921–2006), a New Zealand-born psychologist and sexologist with an untypical background whose work on human sexuality and gender remains controversial.  Dr Money’s had an academic interest in those who exhibited a sexual attraction towards individuals who committed serious crimes.

In the literature, it’s clear most hybristophiles are female, something not unexpected given the extent to which crime is a male-dominated business; most of the academic work in the field seems to have focused on women who have developed strong affectionate or romantic feelings towards individuals incarcerated for serious crimes and it’s been studied both in psychiatry and criminology.  Over the decades, the understanding of hybristophilia has evolved and there’s now a greater appreciation of the nuances which can extend to the political and although the original definition was restricted to sexual attraction (conventionally defined), aspects such as “thrill-seeking”, “sympathy”, “celebrity status hunting” (including deals for interviews and such) and a desire to “nurture or reform” have all been identified as factors which may influence the behaviour while some sources claim an alleged increased frequency of instances may be related to the rise in volume of “true crime” material on the internet and streaming services.  Of interest too is the role of the media in “romanticising” criminals and the rise (indeed the standardization) of the methods used by on-line dating apps: the response generated by the publication of a “hot” police mug-shot, the behaviour is not greatly different from “swiping right” on Tinder.

There has been criticism of the profession’s approach to hybristophilia, usually on the grounds of the definition being too broad and prone to the generation of ambiguities, some arguing the term may pathologize normal variations of human attraction, while others question the empirical evidence supporting its classification as a paraphilia.  Of course, the editors of the DSM have never listed it as a paraphilia and it is others who have made the link which at least implies a degree of disapprobation, the phenomenon perceived seemingly as a form of self-harm from which women need to be protected, an attitude with something of a history in psychiatry and medicine generally.  The matter of hybristophilia is emblematic of the general problem of the DSM’s category of paraphilic disorders being thought of as a sort of dumping ground for sexual behaviour thought unusual and when the fifth edition (DSM-5) was published in 2013, the editors acknowledged this by differentiating between (1) atypical human sexual behavior and (2) behavior either causing mental distress to a patient or which makes the them a threat to the psychological or physical well-being of others.  Although it’s clear legal implications played a part in the editorial committee’s discussions about revising diagnostic criteria, the goal really was to update the disorders in the category in a way which would reflect the outcomes for patients and those with whom they interacted rather than abstractions about the behaviour itself.

Lindsay Lohan and her lawyer in court, Los Angeles, December 2011.

What emerged was a change in the defined characteristics of paraphilic disorders, a recognition most people with atypical (as opposed to “abnormal”) sexual interests do not have a mental disorder requiring treatment.  After the DSM-5, to be diagnosed with a paraphilic disorder, a patient must either (1) feel personal distress about their interest (not merely a distress resulting from society’s disapproval) or (2) have a sexual desire or behavior that involves another person’s psychological distress, injury, or death or (3) have a desire to indulge in sexual behaviors involving unwilling persons or persons unable to give legal, informed consent.  There was also a process of re-naming conditions to delineate between an atypical sexual interest and a defined disorder, a process which essentially differentiated between the behavior and the disorder stemming from that behaviour; the APA was giving its imprimatur for folk to engage in consensual atypical sexual behavior without inappropriately being labeled with a mental disorder. With this revision, the DSM-5 distinguished between atypical sexual interests and mental disorders involving these desires or behaviors.  That hybristophilia is not specifically mentioned in any edition of the DSM is thus not an omission as such and the DSM-5 did include the diagnostic category called “Other Specified Paraphilic Disorders” (OSPD) which was created to encompass atypical sexual interests causing significant distress or impairment but not fulfilling the criteria for any of the listed specific paraphilic disorders.  In other words, OSPD was there as a kind of clearing house for clinicians who identified a problem and that might include a hybristophile if the behaviour is causing personal distress or impairment (or consequent problems for others with whom they have some relationship).

Baldur von Schirach in the dock, where he told some lies and some partial truths, Palace of Justice, Nuremberg, May, 1946.

Baldur von Schirach (1907-1974; head of the Hitlerjugend (Hitler Youth) 1931-1940 & Gauleiter (district party leader) and Reichsstatthalter (Governor) of Vienna 1940-1945) would in 1946 have been hanged had some of the material relating to his time as governor of Vienna been brought before the court at the first Nuremberg Trial (1945-1946) but he instead received a 20 year sentence for which he should have been more grateful than ever he was.  In 1965, he was found to be suffering a detached retina and, after some objections from the Soviets, he was sent to the British military hospital in Berlin for surgery.  While under guard in his room on the second floor, the guards noticed movement in the tree next to the window and upon investigation, found a woman climbing the trunk.  She said he name was Karin Stein and told her interrogators she’d had always been “desperately in love” with their prisoner and had for years been sending him letters, cards and flowers (none of which he’d ever been allowed to receive).  She was escorted from the hospital and released but later returned, disguised as a nurse and managed to reach the door to his room before being stopped.  This hybristophile was a good stalker and turned up outside Spandau Prison when, at the stroke of midnight, he was released on 1 October 1966.  She would haunt him for some years.

“Sexy Sadie” mug shot, 1969.

Other notorious criminals who have married while serving long sentences include (1) Charles Manson (1934-2017) who at the age of 80 married the 26 year old who administered his social media sites; (2) Masson family member Susan “Sexy Sadie” Atkins (1948–2009) who in 1981 married someone who had convinced her was a multi-millionaire (she had the marriage annulled when she learned he was poor and had 35 prior marriages) before in 1987 marrying a law student to whom she remained married until her death; (3) Manson family member Charles Denton "Tex" Watson (b 1945) who, after becoming a born again Christian in 1975, married an admirer in 1979 and became an ordained minister, going on to father four children before the California Department of Corrections and Rehabilitation banned conjugal visits for those serving life sentences (the couple divorced in 2003); (4) In custody, confessed serial killer, rapist and necrophile, Ted Bundy (1946-1989) married a twice-divorced mother of two who'd dated him before his arrest and in 1982 she gave birth to a daughter in 1982, naming Bundy as the father; (5) Serial killer Richard Ramirez (1960–2013, dubbed “The Night Stalker” by the press) received his death sentence for, inter alia, 13 murders, five attempted murders and 11 sexual assaults. Seven years into his time on death row, he married a freelance magazine editor who had been in correspondence with him for some years, telling CNN in 1997: “He's kind, he's funny, he's charming, I just believe in him completely.  In my opinion, there was far more evidence to convict O.J. Simpson, and we all know how that turned out."  (6) Both the  Menendez brothers (Lyle (b 1968) & Erik (born 1970), the pair now back in the news) attracted hybristophiles.  Lyle married twice, firstly to a former model (who divorced him after she found out he was writing to another woman) and subsequently to a magazine editor who has since become an attorney although tabloid revelations that about Lyle leading a “double life” in prison as a gay man can’t have made for marital bliss.  Erik married just the once and the couple are still together; (7) There is also apparently (although undocumented) the condition “hybristophile rebound”: serial killer, kidnapper, and rapist Kenneth Bianchi (b 1951) married a woman with whom he’d been corresponding; earlier she had tried woo Ted Bundy before focusing her sights on Bianchi.

Brian Thompson (1974–2024; chief executive officer (CEO) of UnitedHealthcare 2021-2024, left) and Free Luigi hoodie from Chill Guy (right).

Hybristophilia need not of necessity be a matter of sexual attraction although it’s those cases which attract the most publicity.  Somewhat different is the widespread acclaim expressed towards Luigi Mangione (b 1998) who stands accused of the execution-style murder of Brian Thompson.  Mr Thompson was CEO of a health insurance company which had become notorious for its practices of “deny, delay & defend” (there are alliterative variations to that string) to avoid paying out against claims and the popularity of Mr Mangione is more a case of becoming a “folk hero” with his alleged victim being emblematic of corporate greed and the misuse of power in the US.  Still, it’s inevitable Mr Mangione will attract proposals of marriage; even among those not drawn to his single-handed attack on the excesses of capitalism, some will have noted his good-looking mug shot.  Not even 24 hours passed between the news of Mr Mangione’s arrest and the appearance on-line of “Free Luigi” merchandise.

Mr Ghosn (left) and Mr Putin (Vladimir Vladimirovich Putin; b 1952; president or prime minister of Russia since 1999, right), the Kremlin, Moscow, 2006.

Another who became an instant folk hero (among certain groups) was the Brazilian born Carlos Ghosn (b 1954) of Lebanese descent.  While in Japan serving as CEO of Nissan and chairman of Mitsubishi Motors, Mr Ghosn was arrested on suspicion of financial misconduct at Nissan involving millions of dollars and, possibly noting the 99% conviction rate of the famously efficient Japanese criminal justice system, while under house arrest awaiting trial, he arranged to have himself enclosed in a large freight box which was flown out of the country on a private jet.  Upon landing at Lebanon’s Beirut–Rafic Hariri International Airport, the fugitive was greeted by cheering crowds, a reaction which played into the prejudices many hold about the Lebanese national character.  There is no extradition treaty between Japan and Lebanon.

Continuity

Continuity (pronounced kon-tn-oo-i-tee or kon-tn-yoo-i-tee)

(1) The state or quality of being continuous; logical sequence, cohesion or connection; lack of interruption.

(2) A continuous or connected whole.

(3) In political science, as “continuity theory”, an approach to twentieth century German historiography which focuses on structural and sociological continuities between eras (including pre-twentieth century influences and traditions).

(4) In narratology, a narrative device in episodic fiction where previous and/or future events in a series of stories are accounted for in present stories.

(5) As bicontinuity (the sate of being bicontinuous), (1) in topology: homeomorphic (a continuous bijection from one topological space to another, with continuous inverse) and (2) in physics, chemistry (of a liquid mixture), being a continuous phase composed of two immiscible liquids interacting through rapidly changing hydrogen bonds.

(6) In film production, as “continuity girl” (the now archaic title in film production (now called “continuity supervisor” or “script supervisor”)) for the person responsible for ensuring the details in each scene conform to the continuity of the narrative.

(7) In film production, the scenario (in the industry jargon a synonym of “continuity”) of script, scenes, camera angles, details of verisimilitude etc, in the sequence in which they should appear in the final cut.

(8) In fiction (especially in television series but also in film and literature), as “continuity nod”, a reference, to part of the plot of a previous series, volume, episode etc.

(9) In audio & visual production (radio, podcasts, television, internet et al), the spoken part of a script that which provides introductory, transitional or concluding material in non-dramatic (documentaries and such) programmes (some production houses include in their staff establishment the position “continuity announcer”).

(10) In film projection, the continuous projection of a film, using automatic rewind.

(11) In mathematics, a characteristic property of a continuous function.

(12) In mathematics, as semicontinuity (of a function), the state of being semicontinuous (that it is continuous almost everywhere, except at certain points at which it is either upper semi-continuous or lower semi-continuous).

(13) In mathematics, as equicontinuity, (of a family of functions), the state of being equicontinuous (such that all members are continuous, with equal variation in a given neighborhood).  The Lipschitz continuity was named after German mathematician Rudolf Lipschitz (1832–1903); the Scott continuity was named after US logician Dana Scott (b 1932).

(14) In mathematics, as hemicontinuity, the state of being hemicontinuous (having the property that if a sequence of points in the domain of a function converges to a point L, then either the sequence of sets that are the images of those points contains a sequence that converges to a point that is in the image of L, or, alternatively, for every element in the image of L, there will be a sub-sequence in the domain whose image contains a convergent sequence to that element.

(15) In marketing, in the plural, as “continuities”, sets of merchandise, given away for free or sold cheaply as promotional tool (the idea being the continuity of the customers returning).

1375–1425: From the late Middle English continuite (uninterrupted connection of parts in space or time), from the Old & Middle French continuité, from the Latin continuitatem (nominative continuitās) (a connected series (the construct being continu(us) (continuous) + -itās (equivalent to the English continu(e) +‎ -ity), from continuus (joining, connecting with something; following one after another) from the intransitive verb continere (to be uninterrupted (literally “to hang together”).  The –ity suffix was from the French -ité, from the Middle French -ité, from the Old French –ete & -eteit (-ity), from the Latin -itātem, from -itās, from the primitive Indo-European suffix –it.  It was cognate with the Gothic –iþa (-th), the Old High German -ida (-th) and the Old English -þo, -þu & -þ (-th).  It was used to form nouns from adjectives (especially abstract nouns), thus most often associated with nouns referring to the state, property, or quality of conforming to the adjective's description.  Continuity is a noun, continuance, & continuousness are nouns, continue is a verb, continuous & continual are adjectives and continually is an adverb; the noun plural is continuities.

The adjective continuous (characterized by continuity, not affected by disconnection or interruption) dates from the 1640s and was from either the French continueus or directly from the Latin continuus.  The verb continue (was in use by at least the mid-fourteenth century) in the form contynuen (maintain, sustain, preserve) which by the late 1300s has assumed the meaning “go forward or onward; persevere in”.  It was from the thirteenth century Old French continuer and directly from Latin continuare (join together in uninterrupted succession, make or be continuous, do successively one after another), from continuus.  The sense of “to carry on from the point of suspension” emerged early in the fifteenth century while the meaning “to remain in a state, place, or office” dates from the early 1400s, the transitive sense of “to extend from one point to another” was first documented in the 1660s.  The word entered the legal lexicon with the meaning “to postpone a hearing or trial” in the mid fifteenth century.

The noun continuation (act or fact of continuing or prolonging; extension in time or space) dates from the late 1300s, from the thirteenth century Old French continuation and directly from the Latin continuationem (nominative continuatio) (a following of one thing after another), a noun of action from past-participle stem of continuare.  The adjective continual was from the early fourteenth century continuell (proceeding without interruption or cessation; often repeated, very frequent), from the twelfth century Old French continuel and directly from the Latin continuus.  The noun continuance (perseverance, a keeping up, a going on) dates from the mid-fourteenth century, from the thirteenth century Old French continuance, from continuer.  Continuance seems to have been the first of the family to appear in the terminology of legal proceedings, used since the late fourteenth century in the sense of “a holding on or remaining in a particular state”, in courts this by the early fifteenth had extended to “the deferring of a trial or hearing to a future date” and in some jurisdictions lawyers to this day still file an “application for continuation”.  The now widely used discontinuation (of legal proceedings; of a product range etc) has existed since at least the 1610s in the sense of “interruption of continuity, separation of parts which form a connected series” and was from the fourteenth century French discontinuation, from the Medieval Latin discontinuationem (nominative discontinuatio), noun of action from past-participle stem of discontinuare.

Page 1 of IMDb's (Internet Movie Database) listing of discontinuities in Mean Girls (2004).

A discontinuity: In Mean Girls, a donut (doughnut) appeared with a large bite taken from it while a few seconds later it had endured just a nibble.

In film production, the job title “continuity girl” seems to have been retired in favor of “continuity supervisor” or “script supervisor”, one of the terms culled in the process of gender neutrality which also claimed most of the “best boys” (they’re now styled with titles such as “assistant chief lighting technician” or “second lighting technician”.  Whether myth or not, the industry legend is the “best boy” job title really did begin with the request “give me your best boy” although that wasn’t something as ominous as now it may sound.  The first known reference to a continuity girl in a film’s credits was in the US 1918 and the job involved ensuring the “continuity” (in the industry “scenario” is synonymous) of the final cut appeared as a seamless narrative.  The job was required because although a single scene in a film might appear to be a contiguous few minutes, the parts assembled in the editing process to produce it may be made up of takes shot days or even months weeks and possibly in different places.  Among a myriad of tasks, what a continuity girl had to do was maintain a database with the details of each piece of film (vital for the editing process) and ensure the details of each shot (clothes, haircuts, props (including their exact placement) and environment (climate, time of day etc) are in accordance with the previous footage.  The detail can be as simple as the time displayed on a wall clock and it matters because there’s a minor industry of film buffs who go through things frame-by-frame looking for discontinuities, all of which gleefully they’ll catalogue on various internet sites.

Three covers used for Leah McLaren’s The Continuity Girl (2007, left); not all Chick lit titles used vibrant or pastel shades in the cover art.  The Continuity Girl (2018, right) by Dr Patrick Kincaid (b 1966) is an unrelated title.

The Continuity Girl (2007) was the debut novel of Canadian journalist Leah McLaren (b 1975), the protagonist being a continuity girl named Meredith Moore.  A classic piece of Chick lit (the construct being chick (slang for “a young woman” + lit(erature)), a now unfashionable term describing novels focused on women and their feelings) the plotline involves Ms Moore’s biological clock tick-tocking to the psychological moment on her 35^th birthday: she wakes up feeling a sudden acute yearning for a baby.  In a Chick lit sort of way, her solution was to leave her predictably pleasant Canadian life and head for London where she plans to select a man on the basis of her assessment of his genetic suitability for breeding, seduce him and, in the way these things happen, fall pregnant.  Things of course don’t work out quite that effortlessly but, being Chick lit, there’s much self-realization, self-discovery and self-expression on the path to a happy ending.

In political science, “continuity theory” is an approach (in two aspects) to twentieth century German historiography which focuses on structural and sociological continuities between eras (including pre-twentieth century influences and traditions).  The first aspect was the notion there existed “continuity” in the persistent influence of long-term social, political, cultural, and institutional developments in German history, dating at least from the time of Martin Luther (1483–1546) contributed to the particular nature of Imperial Germany (1871-1918), the failure of the Weimar Republic (1918-1933) and the Führerprinzip (Leader Principle) which, structurally, was the distinguishing feature of the Third Reich (1933-1945).  This idea has underpinned a number of major historical studies but has always been contested because another faction (which has at times included a significant proportion of the German population) which argues that Nazism was uniquely radical and an aberration in the nation’s history.  Most controversially, some proponents of continuity theory extend the application to the post war years, examining how former Nazis, neo-Nazis and their ideologies persisted (and at times have flourished) both in the FRG (Federal Republic of Germany; the old West Germany (1949-1990)) and the unified state formed 1990 after the FRG absorbed the GDR (German Democratic Republic (the old East Germany)).

Adolf Hitler (left) looking at Ernst Röhm (right), Nürnberg, 3 September 1933.  Some nine months later, Hitler would order Röhm's discontinuation (murder).  Photograph from the Bundesarchiv (Federal Archives), Bild (picture) 146-1982-159-22A.

The theory’s other aspect was structural and was essentially an analysis of the extent to which the Nazi state operated under the constitutional and administrative arrangements inherited from the Weimar Republic, the state which Adolf Hitler (1889-1945; Führer (leader) and German head of government 1933-1945 & head of state 1934-1945) claimed “his” National Socialist revolution had overthrown.  The indisputable fact that the Nazi dictatorship was fundamentally different from Weimar at the time obscured the continuity but maintaining the Weimar constitution was hardly unique.  Hitler choose also to adapt the existing mixed economic model, something which upset some of the more idealistic souls in his movement who had taken seriously the “socialist” bit in “National Socialism” and led to the infamous Nacht der langen Messer (Night of the Long Knives), also called Unternehmen Kolbri (Operation Hummingbird) a purge executed between 30 June-2 July 1934, when the regime carried out a number of extrajudicial executions, ostensibly to crush what was referred to as “the Röhm Putsch” (Ernst Röhm (1887–1934; chief of the Sturmabteilung (the stormtroopers (the SA)), head of the four-million strong SA had certainly in the past hinted at one but there’s no doubt no such thing was imminent).

The USGS’s (US Geological Survey (1879)) depiction of the Mohorovičić discontinuity (the Moho).

The Mohorovičić discontinuity (which geologists tend to call “the Moho”) is the boundary between the Earth's crust and mantle, the extent defined by the distinct change in velocity of seismic waves as they pass through changing densities of rock.  The phenomenon is named after Croatian geophysicist Andrija Mohorovičić (1857–1936; one of the seminar figures in modern seismology), who first published his findings (based on seismographic observations of shallow-focus earthquakes) in 1909.

Consecutive

Consecutive (pronounced kuhn-sek-yuh-tiv)

(1) Following one another in uninterrupted succession or order; successive without interruption.

(2) Marked or characterized by logical sequence (such as chronological, alphabetical or numerical sequence).

(3) In grammar & linguistics, as “consecutive clause”, a linguistic form that implies or describes an event that follows temporally from another (expressing consequence or result).

(4) In musical composition, a sequence of notes or chords which results from repeated shifts in pitch of the same interval (an alternative term for “parallel”).

1605-1615: From the sixteenth century French consécutif, from the Medieval Latin cōnsecūtīvus, from the Latin cōnsecūtus (follow up; having followed), from consequī (to pursue) & cōnsequor (to travel).  The construct was consecut(ion) + -ive.  Consecution dates from the early fifteenth century and by the 1530s was used in the sense of “proceeding in argument from one proposition to another in logical sequence”.  It was from the Middle English consecucioun (attainment), from the Latin consecutionem (nominative consecution), noun of action from the past-participle stem of consequi (to follow after), from an assimilated form of com (in the sense of “with, together”) + sequi (to follow (from the primitive Indo-European root sekw- (to follow).  The meaning “any succession or sequence” emerged by the 1650s.  The Latin cōnsecūtiō (to follow after) was from the past participle of cōnsequor (to follow, result, reach).  The –ive suffix was from the Anglo-Norman -if (feminine -ive), from the Latin -ivus.  Until the fourteenth century, all Middle English loanwords from the Anglo-Norman ended in -if (actif, natif, sensitif, pensif et al) and, under the influence of literary Neolatin, both languages introduced the form -ive.  Those forms that have not been replaced were subsequently changed to end in -y (hasty, from hastif, jolly, from jolif etc).  The antonyms are inconsecutive & unconsecutive but (except in some specialized fields of mathematics) “non-sequential” usually conveys the same meaning.  Like the Latin suffix -io (genitive -ionis), the Latin suffix -ivus is appended to the perfect passive participle to form an adjective of action.  Consecutive is a noun & adjective, consecutiveness is a noun and consecutively is an adverb; the noun plural is consecutives.

In sport, the most celebrated consecutive sequence seems to be things in three and that appears to first to have been institutionalized in cricket where for a bowler to take three wickets with three consecutive deliveries in the same match was first described in 1879 as a “hat trick”.  Because of the rules of cricket, there could be even days between these deliveries because a bowler might take a wicket with the last ball he delivered in the first innings and the first two he sent down in the second.  A hat trick however can happen only within a match; two in one match and one in another, even if consecutive, doesn’t count.  Why the rare feat came to be called “hat trick” isn’t certain, the alternative explanations being (1) an allusion to the magician’s popular stage trick of “pulling three rabbits out of the hat” (there had earlier also been a different trick involving three actions and a hat) or (2) the practice of awarding the successful bowler a hat as a prize; hats in the nineteenth century were an almost essential part of the male wardrobe and thus a welcome gift.  The “hat trick” terminology extended to other sports including rugby (a player scoring three tries in a match), football (soccer) & ice hockey (a player scoring three goals in a match) and motor racing (a driver securing pole position, setting the fastest lap time and winning a race).  It has become common in sport (and even politics (a kind of sport)) to use “hat trick” of anything in an uninterrupted sequence of three (winning championships, winning against the same opponent over three seasons etc) although “threepeat” (the construct being three + (re)peat) has become popular and to mark winning three long-established premium events (not always in the same season) there are “triple crowns).  Rugby’s triple crown is awarded to whichever of the “home countries” (England, Ireland, Scotland & Wales) wins all three matches that season; US Horse racing’s triple crown events are the Kentucky Derby, the Preakness Stakes and the Belmont Stakes.

Graham Hill (1929–1975) in BRM P57 with the famous (but fragile) open-stack exhausts, Monaco Grand Prix, 3 June 1962.  Hill is the only driver to have claimed motor-racing's classic Triple Crown.

The term is widely used in motorsport but the classic version is the earliest and consists of the Indianapolis 500, the 24 Hours of Le Mans and the Formula One (F1) World Drivers' Championship (only one driver ever winning all three) and there’s never been any requirement of “consecutiveness”; indeed, now that F1 drivers now rarely appear in other series while contracted, it’s less to happen.

Donald Trump, a third term and the 22^nd Amendment

Steve Bannon (left) and Donald Trump (right).

Although the MAGA (Make America Great Again) team studiously avoided raising the matter during the 2024 presidential election campaign, now Donald Trump (b 1946; US president 2017-2021) is President elect awaiting inauguration, Steve Bannon (b 1957 and a one the most prominent MAGAs) suggested there’s a legal theory (that term may be generous) which could be relevant in allowing him to run again in 2028, by-passing the “two-term limit” in the US Constitution.  Speaking on December 15 at the annual gala dinner of New York’s Young Republican Club’s (the breeding ground of the state’s right-wing fanatics), Mr Bannon tantalized the guests by saying “…maybe we do it again in 28?”, his notion of the possibility a third Trump term based on advice received from Mike Davis (1978, a lawyer who describes himself as Mr Trump’s “viceroy” and was spoken of in some circles as a potential contender for attorney general in a Trump administration).  Although the 22^nd Amendment to the constitution states: “No person shall be elected to the office of the President more than twice”, Mr Davis had noted it was at least arguable this applied only to “consecutive” terms so as Mr Bannon confirmed, there was hope.  Warming to the topic, Mr Bannon went on to say :“Donald John Trump is going to raise his hand on the King James Bible and take the oath of office, his third victory and his second term.” (the MAGA orthodoxy being he really “won” the 2020 election which was “stolen” from him by the corrupt “deep state”.

Legal scholars in the US have dismissed the idea the simple, unambiguous phrase in the 22^nd amendment could be interpreted in the way Mr Bannon & Mr Davis have suggested.  In the common law world, the classic case in the matter of how words in acts or statutes should be understood by courts is Bank of England v Vagliano Brothers (1891) AC 107, a bills of exchange case, decided by the House of Lords, then the UK’s final court of appeal.  Bank of England v Vagliano Brothers was a landmark case in the laws relating to negotiable instruments but of interest here is the way the Law Lords addressed significant principles regarding the interpretation of words in statutes, the conclusion being the primary goal of statutory interpretation is to ascertain the intention of Parliament as expressed in the statute and that intention must be derived from the language of the statute, interpreted in its natural and ordinary sense, unless the context or subject matter indicates otherwise.  What the judgment did was clarify that a statute may deliberately depart from or modify the common law and courts should not assume a statute is merely a restatement of common law principles unless the statute's language makes this clear.  The leading opinion was written by Lord Herschell (Farrer Herschell, 1837–1899; Lord High Chancellor of Great Britain 1886 & 1892-1895) who held that if the language of the statute is clear and unambiguous, it should be interpreted as it stands, without assuming it is subject to implicit common law principles; only if the language is ambiguous may courts look elsewhere for context and guidance.

So the guiding principle for courts is the words of a statute should be understood with what might be called their “plain, simple meaning” unless they’re not clear and unambiguous.  While the US Supreme Court recently has demonstrated it does not regard itself as bound even its own precedents and certainly not those of a now extinct UK court, few believe even the five most imaginative of the nine judges could somehow construe a constitutional amendment created for the explicit purpose of limiting presidents to two terms could be read down to the extent of “…more than twice…” being devalued to “…more than twice in a row…”.  Still, it was a juicy chunk of bleeding raw meat for Mr Bannon to throw to his hungry audience.

The ratification numbers: Ultimately, the legislatures of 41 of the then 48 states ratified the amendment with only Massachusetts and Oklahoma choosing to reject.  

What the 22^nd amendment did was limit the number of times someone could be elected president.  Proposed on 21 March 1947, the ratification process wasn’t completed until 27 February 1951, a time span of time span: 3 years, 343 days which is longer than all but one of the other 26, only the 27^th (delaying laws affecting Congressional salary from taking effect until after the next election of representatives) took longer, a remarkable 202 years, 223 days elapsing between the proposal on 25 September 1789 and the conclusion on 7 May 1992; by contrast, the speediest was the 26^th which lowered the voting age to 18, its journey absorbed only 100 days between 23 March-1 July 1971.  While not too much should be read into it, it’s of interest the 18^th Amendment (prohibiting the manufacturing or sale of alcohol within the US) required 1 year, 29 days (18 December 1917-16 January 1919) whereas the 21^st (repealing the 18^th) was done in 288 days; proposed on 20 February 1933, the process was completed on 5 December the same year.

The path to the 22^nd amendment began when George Washington (1732–1799; first president of the United States, 1789-1797) choose not to seek a third term, his reasons including (1) a commitment to republican principles which required the presidency not be perceived as a life-long or vaguely monarchical position, (2) the importance of a peaceful transition of power to demonstrate the presidency was a temporary public service, not a permanent entitlement and (3) a desire not to see any excessive concentration of power in one individual or office.  Historians have noted Washington’s decision not to seek a third term was a deliberate effort to establish a tradition of limited presidential tenure, reflecting his belief this would safeguard the republic from tyranny and ensure no individual indefinitely could dominate government.

AI (Artificial Intelligence) generated images by Stable Diffusion of Lindsay Lohan and Donald Trump having coffee in the Mar-a-Largo Coffee Shop. 

For more than a century, what Washington did (or declined to do) was regarded as a constitutional convention and no president sought more than two terms.  Theodore Roosevelt (TR, 1858–1919; US president 1901-1909), celebrating his re-election in 1904 appeared to be moved by the moment when, unprompted, he announced: “Under no circumstances will I be a candidate for or accept another nomination” and he stuck to the pledge, arranging for William Howard Taft (1857–1930; president of the United States 1909-1913 & chief justice of the United States 1921-1930) to be his successor, confident he’d continue to pursue a progressive programme.  Taft however proved disappointingly conservative and Roosevelt decided in 1912 to seek a third term.  To critics who quoted at him his earlier pledge, he explained that “…when a man at breakfast declines the third cup of coffee his wife has offered, it doesn’t mean he’ll never in his life have another cup.”  Throughout the 1912 campaign, comedians could get an easy laugh out of the line: “Have another cup of coffee”? and to those who objected to his violating Washington’s convention, he replied that what he was doing was “constitutional” which of course it was.

Puck magazine in 1908 (left) and 1912 (right) wasn't about to let Theodore Roosevelt forget what he'd promised in 1904.  The cartoon on the left was an example of accismus (an expression of feigned uninterest in something one actually desires).  Accismus was from the Latin accismus, from Ancient Greek ακκισμός (akkismós) (prudery).  Puck Magazine (1876-1918) was a weekly publication which combined humor with news & political satire; in its use of cartoons and caricatures it was something in the style of today's New Yorker but without quite the same tone of seriousness.

Roosevelt didn’t win the Republican nomination because the party bosses stitched thing up for Taft so he ran instead as a third-party candidate, splitting the GOP vote and thereby delivering the White House to the Democrats but he gained more than a quarter of the vote, out-polling Taft and remains the most successful third-party candidate ever so there was that.  His distant cousin Franklin Delano Roosevelt (FDR, 1882–1945, US president 1933-1945) was the one to prove the convention could be ignored and he gained not only a third term in 1940 but also a fourth in 1944.  FDR was not only a Democrat but also a most subversive one and when Lord Halifax (Edward Wood, 1881–1959; British Ambassador to the United States 1940-1946) arrived in Washington DC to serve as ambassador, he was surprised when one of a group of Republican senators with whom he was having dinner opened proceedings with: “Before you speak, Mr Ambassador, I want you to know that everyone in this room regards Mr Roosevelt as a bigger dictator than Hitler or Mussolini.  We believe he is taking this country to hell as quickly as he can.”  As a sentiment, it sounds very much like the discourse of the 2024 campaign.

"The Trump Dynasty has begun" four term coffee mugs (currently unavailable) created for the 2020 presidential campaign. 

The Republicans truly were appalled by Roosevelt’s third and fourth terms and as soon as they gained control of both houses of Congress began the process of adding an amendment to the constitution which would codify in that document the two-term limit Washington had made a convention.  It took longer than usual but the process was completed in 1951 when the 22^nd Amendment became part of the constitution and were Mr Trump to want to run again in 2028, it would have to be repealed, no easy task because such a thing requires not only the concurrence of two thirds of both the House of Representatives & Senate but also three quarters of the legislatures of the fifty states.  In other countries where presidential term limits have appeared tiresome to those who have no intention of leaving office the “work-arounds” are usually easier and Mr Trump may cast the odd envious eye overseas.  In Moscow, Mr Putin (Vladimir Vladimirovich Putin; b 1952; president or prime minister of Russia since 1999) solved the problem by deciding he and his prime-minister temporarily should swap jobs (though not authority) while he arranged a referendum to effect the necessary changes to the Russian Constitution.  The point about referendums in Russia was explained by Comrade Stalin (1878-1953; Soviet leader 1924-1953) who observed: “it matters not who votes, what matters is who gets to count the votes.”  Barring accidents or the visitation of the angel of death, Mr Putin is now set to remain as president until at least the mid-2030s.  

Some mutual matters of interest: Donald Trump (left) and Vladimir Putin (right).

There have been many African presidents who have "arranged" for constitutional term limits to be "revised" but the most elegant in the handling of this was Pierre Nkurunziza (1964–2020; president of Burundi 2005-2020) who simply ignored the tiresome clause and announced he would be standing for a third term, tidying up loose ends by having Burundi's Constitutional Court declare the president was acting in accordance with the law.  It would seem the principle of statutory interpretation in Bank of England v Vagliano Brothers wasn't brought before the court (formerly part of the empire of Imperial Germany and later a Belgian-administered territory under a League of Nations mandate, Burundi follows the civil law tradition rather than the common law inheritance from the old British Empire) and shortly before the verdict was handed down, one judge fled into exile, claiming the government had applied "pressure" on the court to deliver a ruling favorable to the president. 

Bulla

Bulla (pronounced bool-uh or buhl-uh)

(1) A seal attached to an official document; in the Holy See, a leaden seal affixed to certain edicts issued by the papal chancellery (a papal bull), having a representation of the saints Peter and Paul on one side and the name of the reigning pope on the other.

(2) In archaeology, a clay envelope or hollow ball, typically with seal impressions or writing on its outside indicating its contents.

(3) In Ancient Rome, type of ornament worn, especially an amulet worn around the neck (as a pendant (or boss), usually by children of “the better classes” (mostly boys) as a protective charm).

(4) In medicine, a large vesicle; alternative name for blister.

(5) In pathology, the tympanic part of a temporal bone (having a bubble-like appearance); any of several hollow structures as features of bones.

(6) In zoology, a blister-like or bubble-like prominence of a bone, as that of the tympanic bone in the skull of certain mammals.

(7) In archaeology, a clay envelope or hollow ball, typically with seal impressions or writing on its outside indicating its contents.

(8) In archaeology and linguistics, a clay envelope, hollow ball or token used in ancient Mesopotamian record-keeping; the link being the rounded, bubble-like form of the objects.

(9) A rich Jamaican cake made with molasses and spiced with ginger and nutmeg.

(10) In surgical use, as bullectomy (a procedure in which small portions of the lung (known as bulla, large areas (>10 mm diameter) in the lung filled with oxygen-depleted air) and bullostomy (the making of a hole through a bulla).

Circa 1845: From the Latin bulla (round swelling, stud, boss, knob (literally “bubble”)), either from the Latin Latin bullire (to boil), or from the Gaulish, from the primitive Indo-European bew- or beu- (a swelling) or bhel- (to blow, inflate, swell) which may have formed a large group of words meaning “much, great, many” (and also words associated with swelling, bumps, blisters and such and the source also of the Lithuanian bulė "buttocks and the Middle Dutch puyl (bag); etymologists remain divided over any link with the Latin bucca (cheek).  In medieval times, it referred to the seal (or stamp) attached to official documents because of its rounded, blister-like shape, familiar from many uses.  The speculative link with the Latin bullire (to boil) was an allusion to the need for heat to be applied to melt or partially melt the material (gold, lead, wax etc) used in the making of seals (once thus softened, the impression was applied).  Historically, while wax seals wear the most common, official imperial seals were gold and papal seals of lead (although some were gold).  The use to describe certain documents issued by the papal chancellery is an adoption of Medieval Latin.  Although it was never an absolute rule (the seal with a representation of the saints Peter and Paul on one side and the name of the reigning pope on the other has appeared variously), its existence usually indicates a papal document is a bulla, a specific type of papal document distinguished by its formality, purpose, and its authentication.  Bulla is a noun; the noun plural is bullas (the Latin bullae used of the papal documents).

Seal of the appropriation of Ospringe Hospital (Headcorn Kent) by the Archbishop of Canterbury, Boniface of Savoy, in accord with a papal bull of 31 March 1267, to, Headcorn Kent. 1267.

Bulls begin with the phrase Episcopus Servus Servorum Dei (The Bishop, Servant of the Servants of God) and are written in a formal style.  The significance of a document being a bull is that technically it is a decree with enduring legal & doctrinal authority including ex cathedra pronouncements or administrative acts (which can be as procedural as creating religious orders or dioceses).  In this they differ from (1) encyclicals which are letters intended for broader purposes, addressed to bishops, clergy, and the faithful, often dealing with theological or social issues, (2) Apostolic Constitutions which usually deal with issues of governance, the promulgation of liturgical texts or matters pursuant to earlier bullae and (3) Motu Proprio (literally “on his own initiative”) which are edicts issued personally by the pope and these can be used for just about any purpose although they’re most associated with rulings which provide an “instant solution” to a troublesome or controversial matter on which it’s not been possible to find consensus; the Moto Proprio may thus be compared to a "royal decree".  Papal bulls were more common in the medieval and early modern periods when formal seals were the primary means of authentication but today they are rare, most communication from the Vatican in the form of apostolic letters or exhortations, not all with origins in the papal chancellery.

The last papal resignation but one

Red Bull Chuck Wagon Restaurant (No Bum Bull Served Here), Winnemucca, Nevada, USA, circa 1967.

Even when absolute monarchies were more common, kings usually took care to placate at least elite opinion and today, although the constitutional arrangements in Saudi Arabia, Brunei, Oman and Eswatini (the old Swaziland) remain, on paper, absolute monarchies, even there things are not done quite as once they were.  The Holy See remains an absolute monarchy and is now the only theocracy so structured although doubtlessly many popes have lamented their authority seems to exist more in the minds of canon lawyers than among the curia or his flock, something exacerbated now malcontents can no longer be burned at the stake (as far as is known) and Francis (b 1936; pope since 2013) may recall the words of a world-weary Benedict XIV (1675–1758; pope 1740-1758): “The pope commands, his cardinals do not obey, and the people do what they wish.”

Papal Bull issued by Urban VIII (1568–1644; pope 1623-1644).  By the mid-fifteenth century, papal bulls had ceased to be used for general public communications and were restricted to the more formal or solemn matters.  The papal lead seals (the spellings bulla & bolla both used) were attached to the vellum document by cords made of hemp or silk, looped through slits.

But popes still have great powers not subject to checks & balances or constitutional review, the best known of which is “papal infallibility”.  The Roman Catholic Church’s dogma of papal infallibility holds that a pope’s rulings on matters of faith and doctrine are infallibility correct and cannot be questioned and when making such statements, a pope is said to be speaking ex cathedra (literally “from the chair” (of the Apostle St Peter, the first pope)).  Although ex cathedra pronouncements had been issued since medieval times, as a point of canon law, the doctrine was codified first at the First Ecumenical Council of the Vatican (Vatican I; 1869–1870) in the document Pastor aeternus (shepherd forever).  Since Vatican I, the only ex cathedra decree has been Munificentissimus Deus (The most bountiful God), issued by Pius XII (1876–1958; pope 1939-1958) in 1950, in which was declared the dogma of the Assumption; that the Virgin Mary "having completed the course of her earthly life, was assumed body and soul into heavenly glory".  Pius XII never made explicit whether the assumption preceded or followed earthly death, a point no pope has since discussed although it would seem of some theological significance.  Prior to the solemn definition of 1870, there had been decrees issued ex cathedra.  In Ineffabilis Deus (Ineffable God (1854)), Pius IX (1792–1878; pope 1846-1878) defined the dogma of the Immaculate Conception of the Blessed Virgin Mary, an important point because of the theological necessity of Christ being born free of sin, a notion built upon by later theologians as the perpetual virginity of Mary.  It asserts that Mary "always a virgin, before, during and after the birth of Jesus Christ", explaining the biblical references to brothers of Jesus either as children of Joseph from a previous marriage, cousins of Jesus, or just folk closely associated with the Holy Family.

Lindsay Lohan, posing with a can of Red Bull, photographed by Brian Adams (b 1959) for Harper’s Bazaar magazine, 2007.

Technically, papal infallibility may have been invoked only the once since codification but since the early post-war years, pontiffs have found ways to achieve the same effect, John Paul II (1920–2005; pope 1978-2005) & Benedict XVI (1927–2022; pope 2005-2013, pope emeritus 2013-2022) both adept at using what was in effect a personal decree a power available to one who sits at the apex of what is in constitutional terms an absolute theocracy.  Critics have called this phenomenon "creeping infallibility" and its intellectual underpinnings own much to the tireless efforts of Benedict XVI while he was head of the Inquisition (by then called the Congregation for the Doctrine of the Faith (CDF) and now renamed the Dicastery for the Doctrine of the Faith (DDF)) during the late twentieth century (the Holy See probably doesn't care but DDF is also the acronym, inter alia, for “drug & disease free” and (in gaming) “Doom definition file” and there's also the DDF Network which is an aggregator of pornography content).  So while not since 1950 formally invoked, popes have not been reluctant to “play the de facto infallibility card”, possibly thinking of the (probably apocryphal) remark attributed to John XXIII (1881-1963; pope 1958-1963): “When one is infallible, one has to be careful what one says.”

Bulla issued 17 July 1492 by Innocent VIII (1432–1492; pope 1484-1492) granting St Duthac’s Church (Tain) official permission to become a Collegiate Church.

But for a pope’s own purposes, a bulla can prove invaluable.  Pietro Angellerio (1215-1296) was for five months between July and December 1294 installed as Pope Celestine V.  Prior to his elevation, Celestine had for decades been a monk and hermit, living a anchorite existence in remote caves and subsisting on little more that wild vegetables, fruits, honey and the occasional locust, his unworldly background meaning he emerged as the ultimate compromise candidate, declared pope after a two-year deadlock in the church’s last non-conclave papal election.  The cardinals had been squabbling for all those two years which so upset the hermit in his cave that he wrote them a letter warning divine retribution would be visited upon them if they didn't soon elect a pope.  Realizing he was entirely un-political, without enemies and likely pliable, the cardinals promptly elected him by acclamation.

Lindsay Lohan mixing a Red Bull & mandarin juice while attending an event with former special friend Samantha Ronson (b 1977), Mandarin Oriental Hotel, London, February 2012.

Shocked, the hermit declined the appointment, only to have his own arguments turned on him, the cardinals insisting if he refused the office he would be defying God himself; trapped, he was crowned at Santa Maria di Collemaggio in Aquila, taking the name Celestine V.  The anchorite, lost in the world of power politics and low skulduggery was utterly unsuited to the role and within weeks expressed the wish to abdicate and return to his solitary cave in the Abruzzi Mountains.  The cardinals told him it wasn’t possible and only God could release him from the office (will all that implies) but they couldn’t stop him consulting the lawyers who drafted for him two bulls, the first codifying the regulations concerning a pope’s abdication and the second a sort of “enabling act”.  The second bull (Quia in futurum (for in the future)) restored the constitution (Ubi periculum (Where there lies danger)), and re-established the papal conclave (the constitution had been suspended by Adrian V (circa 1216-1276; pope 1276)).  The bulls having put in place the required mechanisms, while at Naples, Celestine V abdicated.

Brutum Fulmen issued by Pius V (1504–1572; pope 1566-1572), concerning the Damnation, Excommunication and Deposition of Elizabeth I (1533–1603; Queen of England & Ireland 1558-1603) by Thomas Barlow (circa 1608- 1691; Lord Bishop of Lincoln (1675–1691).

That done, he resigned, intending to return to his cave but his successor, Boniface VIII (circa 1231-1303; pope 1294-1303) had no wish to have such a puritanical loose cannon at large (he feared some dissidents might proclaim him antipope) and imprisoned him (in an agreeable circumstances) in the castle where ultimately he would die.   His resignation from the office was the last until Benedict XVI who in 2013 did rather better, retiring to a sort of papal granny flat in the Vatican where he lived (uniquely) as pope emeritus.  Celestine was canonized on 5 May 1313 by Clement V (circa 1265-1314; pope 1305-1314) and no subsequent pontiff has taken the name Celestine.