Understanding the Magisterium By Michael Lofton, M.A.

 

Introduction

In an age when documents of the magisterium (the church’s teaching authority) have been widely disseminated, one can read about church teachings and easily become confused about their meaning or value. Much like a young boy who makes his way to the cockpit of an airplane and obliviously strikes random buttons, untrained readers of magisterial teachings often manhandle the teachings of the church. This is because an understanding of how to interpret the magisterium is not nearly as pervasive as its content.

Hoping to help correct this, the following material is offered. A consideration will be made of the various categories of the magisterium, as this will help the reader to understand the different teaching organs of the church. Then, an examination of the different levels of the magisterium will be made, in order to establish gradation in theological teachings. This will be followed by an analysis of reform in relation to the magisterium. Lastly, establishing infallibility in church documents and weighing the magisterial content of church teachings will be discussed. Having explored such material, the reader will be better equipped for basic engagement of the magisterium’s content.

I. Categories of the Magisterium

Much like a chef who has multiple ways to cook the same meal, the church has multiple ways in which it can teach. Various theologians may offer different terms for each of the church’s teaching organs, but the following will help bring out the distinctives of each. There is the extraordinary infallible papal magisterium, extraordinary conciliar magisterium, the ordinary and universal magisterium (i.e. ordinary infallible papal magisterium) and the authentic ordinary magisterium (i.e. ordinary fallible magisterium). Each will be considered in order.

A. Extraordinary Infallible Papal Magisterium (Ex Cathedra)

In order to understand the extraordinary infallible papal magisterium, also known as ex cathedra teachings, it is important to review what it is not. First, it is not anything the pope says in an interview or in a private conversation. It is not his opinion on what is the best song of the year or who will win the Superbowl. It is also not new revelation, as the First Vatican Council states:

“For the Holy Spirit was promised to the successors of Peter not so that they might, by his revelation, make known some new doctrine, but that, by his assistance, they might religiously guard and faithfully expound the revelation or deposit of faith transmitted by the apostles.”[1]

What then is it? An ex cathedra teaching is when the Pope “in the exercise of his office as shepherd and teacher of all Christians, in virtue of his supreme apostolic authority… defines a doctrine concerning faith or morals to be held by the whole Church.”[2] In other words, there are multiple conditions the teaching of the pope must meet before it could be considered ex cathedra. This means most papal teachings do not fall under this category. In fact, the following is a list of the generally agreed upon instances of this rare magisterium:

  1. The Tome of Leo
  2. The letter of Pope Agatho on dyothelitism
  3. Unam Sanctam
  4. Benedictus Deus
  5. Exurge Domine
  6. Cum occasione
  7. Caelestis pastor
  8. Cum alias
  9. Unigenitus
  10. Auctorem fidei
  11. Ineffabilis Deus
  12. Quanta cura
  13. Munificentissimus deus

B. Extraordinary Conciliar Magisterium (Definitions of Ecumenical Councils)

In addition to extraordinary infallible papal teachings, an ecumenical council may also teach with the extraordinary infallible magisterium. This occurs when the body of bishops, as members of the body of Christ, assemble in union with their visible head, the pope, and infallibly and defines a matter of faith and morals in a solemn proclamation. There have been 21 Ecumenical Councils in the history of the Catholic Church and the majority of them offered definitive teachings These councils are as follows:

  1. The First General Council of Nicaea, 325
  2. The First General Council of Constantinople, 381
  3. The General Council of Ephesus, 431
  4. The General Council of Chalcedon, 451
  5. The Second General Council of Constantinople, 553
  6. The Third General Council of Constantinople, 680-681
  7. The Second General Council of Nicaea, 787
  8. The Fourth General Council of Constantinople, 869-870
  9. The First General Council of the Lateran, 1123
  10. The Second General Council of the Lateran, 1139
  11. The Third General Council of the Lateran, 1179
  12. The Fourth General Council of the Lateran, 1215
  13. The First General Council of Lyons, 1245
  14. The Second General Council of Lyons, 1274
  15. The General Council of Vienne, 1311-12
  16. The General Council of Constance, 1414-18
  17. The General Council of Basel-Ferrara-Florence, 1431-45
  18. The Fifth General Council of the Lateran, 1512-17
  19. The General Council of Trent, 1545-63
  20. The First General Council of the Vatican, 1869-70
  21. Vatican II – 1962-1965

C. Ordinary and Universal Magisterium (Ordinary Infallible Papal Magisterium)

The ordinary and universal magisterium (i.e. ordinary infallible papal magisterium, the ordinary universal magisterium, the ordinary magisterium)[3] can be exercised by a pope and the bishops scattered throughout the world when they agree a teaching is to be held definitively.[4] This can take place outside of an ex cathedra document or an ecumenical council. As an organ of the magisterium, it is often overlooked in discussions about church teachings.

In order to illustrate this organ better, there are examples of this magisterium to consider. For instance, the teachings concerning the “communion of saints, the resurrection of the body and the life everlasting”[5] are all instances of this category. These have never been solemnly defined by the extraordinary magisterium, but they are still dogmatic because the popes and bishops have often expressed these teachings as definitive. Sometimes this organ of the magisterium is made manifest through the teachings of the pope when he expresses the constant and universal teaching of the church. This is why this organ has also been called the ordinary infallible papal magisterium.[6] Some examples are Humanae vitae and Ordinatio sacerdotalis. In the case of the former, there are no instances of an ex cathedra teaching or an ecumenical council on the prohibition of artificial contraception, but this teaching is still considered definitive because the pope simply gave expression to the teaching of the ordinary and universal magisterium.

D. Authentic Ordinary Magisterium (Ordinary Fallible Magisterium)

The authentic magisterium (i.e. authentic ordinary magisterium, ordinary fallible magisterium or the ordinary magisterium) is when a “an ecumenical council, a pope, a regional or national council, a Roman congregation, an episcopal conference, or a local bishop”[7] teach something that is not proposed as definitive, which means it could be fallible and reformable. Teachings in this category are often found in encyclicals and homilies. It also should be noted, in older documents the term “authentic magisterium” or “ordinary magisterium” may or may not have referred to the ordinary and universal Magisterium. For this reason, caution should be used, especially when one comes across this term in documents prior to the First Vatican Council. In such cases, context will serve as key to determine how the term was used.

II. Levels of Magisterial Teachings

There are also different levels to magisterial teachings. This may come as a surprise to those who are under the impression that anything a pope says whether it is during an interview on an airplane or a homily at Santa Marta, carries the same authority. The fact is, not all teachings of the magisterium carry the same force.

In order to better understand these levels, a consideration of a document from the Congregation for the Doctrine of the Faith[8] entitled Doctrinal Commentary on the Concluding Formula of the ‘Professio Fidei’ will be made. This document is invaluable as it provides commentary on a profession of faith released by St. Pope John Paul II, which has three concluding paragraphs that correspond to the three levels of the magisterium.

A. First Level Teachings

The doctrinal commentary begins by addressing first level teachings. It states:

“With firm faith, I also believe everything contained in the word of God, whether written or handed down in Tradition, which the Church, either by a solemn judgment or by the ordinary and universal magisterium, sets forth to be believed as divinely revealed.”[9]

These are teachings which are said to be “formally revealed and, as such…irreformable.”[10] This means teachings in this category are from Scripture or Sacred Tradition and are either solemnly defined by a pope when teaching ex cathedra or are taught definitively by an ecumenical council, or are non-solemnly proposed as definitive by the ordinary and universal magisterium. The key is to note that teachings in this paragraph find their source in Scripture and Tradition and the church defines them as revealed by God. As such, they are considered “dogmas” of the Catholic Church.

It should be stressed that teachings in this category are clearly infallible and are not able to be revoked or changed. Perhaps the church could later separate the doctrine itself from what may be considered the “changeable conceptions of a given epoch,”[11] such as the way the teaching was communicated; however, the meaning of the doctrine itself cannot change. Moreover, due to the divine origin of these teachings, one is required to assent to them with the “assent of theological faith.”[12] In other words, one is to respond with the same faith one would give to God’s words if He Himself were present teaching.

B. Second Level Teachings

Second level teachings come from the second concluding paragraph, which states: “I also firmly accept and hold each and everything definitively proposed by the Church regarding teaching on faith and morals.”[13] These are also teachings that are irreformable and therefore infallible, yet they are not formally revealed by God, as are first level teachings. Instead, they are teachings that are “necessary for faithfully keeping and expounding the deposit of faith”[14] and are “necessarily connected with revelation by virtue of an historical relationship.”[15] They are also teachings that are solemnly defined by a pope when teaching ex cathedra or taught definitively by an ecumenical council or are definitively proposed by the ordinary and universal magisterium.

The key to note here is that they are not directly revealed by God through Scripture or Tradition but are so intimately bound with what has been formally revealed that they are necessary to believe. For this reason, they are considered “dogmatic facts” instead of dogmas, per se. Due to their necessity, they are also teachings that may not be revoked. Consequently, teachings in this category are said “to be held definitively.”[16]

C. Third Level Teachings

There are also teachings that belong to a third category and are addressed in the third concluding paragraph of the Professio Fidei. The profession of faith describes them by saying:

“Moreover, I adhere with religious submission of will and intellect to the teachings which either the Roman Pontiff or the College of Bishops enunciate when they exercise their authentic Magisterium, even if they do not intend to proclaim these teachings by a definitive act.”[17]

And the Second Vatican Council offers further expansion, saying:

“This loyal submission of the will and intellect must be given, in a special way, to the authentic teaching authority of the Roman Pontiff, even when he does not speak ex cathedra in such wise, indeed, that his supreme teaching authority be acknowledged with respect, and that one sincerely adhere to the decisions made by him, conformably with his manifest mind and intention, which is made known principally either by the character of the documents in question, or by the frequency with which a certain doctrine is proposed, or by the manner in which the doctrine is formulated.”[18]

In other words, these are teachings which are not necessarily infallible or irreformable but are taught by the authentic ordinary magisterium. They may be given expression by a pope or an ecumenical council when they teach non-definitively. This is why the commentary by the Congregation for the Doctrine of the Faith says they could be, but not necessarily are, taught in a “non-definitive way.”[19]

Teachings in this category require one to assent with “religious submission of intellect and will.”[20] As such, one must consider the way in which the teaching is proposed, in order to determine the degree to which submission of the intellect and will is to be given. The commentary elaborates by saying:

“As examples of doctrines belonging to the third paragraph, one can point in general to teachings set forth by the authentic ordinary Magisterium in a non-definitive way, which require degrees of adherence differentiated according to the mind and the will manifested; this is shown especially by the nature of the documents, by the frequent repetition of the same doctrine, or by the tenor of the verbal expression.”[21]

Concerning third level teachings, we should also note there are different kinds of non-definitive interventions the church offers. Some relate to making revelation more explicit, others to defending the truthfulness of a claim and then others to defend the faith against error. The Congregation for the Doctrine of the Faith describes them as follows:

“When the Magisterium, not intending to act ‘definitively’, teaches a doctrine to aid a better understanding of Revelation and make explicit its contents, or to recall how some teaching is in conformity with the truths of faith, or finally to guard against ideas that are incompatible with these truths, the response called for is that of the religious submission of will and intellect.”[22]

Lastly, teachings in this category are especially eligible for doctrinal reformability since they are taught non-definitively However, most teachings in this category are true and likely won’t change. In fact, unless a theologian has extreme reasons to believe otherwise, the denial of a teaching in this category is labeled “erroneous or, in the case of teachings of the prudential order, as rash or dangerous.”[23] The withholding of assent from teachings of this level should be rare and only after a serious attempt to reconcile them with the rest of the magisterium’s teachings.

D. Theological Notes

A word should also be said about the theological notes. These are ways in which theologians express the degree of certainty that a teaching may carry. They range from teachings revealed by God to teachings that are merely opinion. Clearly, the former is definitive, and the latter is not. This means there are some teachings which are irreformable, while others are not, depending on their degree of certainty. Much can be said about the theological notes, but the following from Fr. John Hardon succinctly addresses them:

“Degrees of certainty in the acceptance of religious doctrine. In theology several grades of certitude are recognized. the highest degree of certitude is attached to immediately revealed truths. they are to be believed with divine faith (fides divina) and if they are also defined by the Church, then with defined divine faith (fides divina definita). If the Church defines a doctrine that is not immediately revealed, it is to be believed with ecclesiastical faith (fides ecclesiastica). A doctrine that theologians generally regard as a truth of revelation, but that has not been finally promulgated by the Church, is said to be proximate to faith (proxima fidei), and if such a truth is guaranteed as the logical conclusion from a revealed doctrine, it is called theologically certain (theologice certa). Below this level are many grades of certainty, ranging from common teaching (sententia communis), when Catholic theologians responsive to the Church’s authority agree on some historical event as having occurred through the miraculous intervention of God.”[24]

The notes can be analyzed more thoroughly in a work by Father Sixtus Cartechini S.J entitled On the Value of Theological Notes and the Criteria for Discerning Them. A translation of this work by John Daly may be found online.[25]

III. Reform in Relation to Dogma and Dogmatic Facts

Having considered the organs and levels of the magisterium, attention should be given to the possibility of reform. When one speaks about reforming magisterial teachings, it should be emphasized that it is the church alone that can authentically reform a teaching. In other words, a private theologian may not reform the teachings of the church; at best, they may suggest reforms or withhold assent in very extreme cases of non-definitive teachings, but their disposition should be one of docility. Having noted this, there are different kinds of reforms that take on different meanings, depending on the referent. For example, the word reform in relation to dogma would take on a completely different meaning than the same word in relation to non-definitive teachings. A consideration of the former will be provided first.

A. Definitive Ex Cathedra and Conciliar Teachings

Whatever reform may mean in relation to Papal and conciliar dogmas, it must first be affirmed that all dogmas have an immutable aspect. The First Vatican Council teaches concerning the immutability of dogmas as follows:

“Hence, too, that meaning of the sacred dogmas is ever to be maintained which has once been declared by holy mother church, and there must never be any abandonment of this sense under the pretext or in the name of a more profound understanding.”[26]

In other words, if one speaks about reform in relation to papal or conciliar dogmas, it cannot mean that the dogma changes in meaning. What constitutes a change in dogma? The Congregation for the Doctrine of the faith answers as it says:

“As for the meaning of dogmatic formulas, this remains ever true and constant in the Church, even when it is expressed with greater clarity or more developed. The faithful therefore must shun the opinion, first, that dogmatic formulas (or some category of them) cannot signify truth in a determinate way, but can only offer changeable approximations to it, which to a certain extent distort of alter it; secondly, that these formulas signify the truth only in an indeterminate way, this truth being like a goal that is constantly being sought by means of such approximations. Those who hold such an opinion do not avoid dogmatic relativism and they corrupt the concept of the Church’s infallibility relative to the truth to be taught or held in a determinate way.”[27]

However, true the immutability of the meaning of dogma may be, it does not mean that the terms in the dogma cannot undergo some reform. For example, let’s suppose the church dogmatically defined the following proposition: Jesus is fully human. It is one thing to define that Jesus is fully human and it is another matter to define what constitutes humanity. The dogma in this hypothetical instance just says that whatever humanity is, Jesus has it, but it does not expressly say what humanity is. Suppose when this dogma was defined, humanity was understood to be x but over time humanity came to be defined as x + y. This would mean the dogma underwent some reform, not because the definition was poorly expressed, untrue or even inaccurate, but because it did not define what each term in the definition meant. This is likely what the Congregation for the Doctrine of the Faith meant when it said:

“Moreover, it sometimes happens that some dogmatic truth is first expressed incompletely (but not falsely), and at a later date, when considered in a broader context of faith or human knowledge, it receives a fuller and more perfect expression.”[28]

To offer an historical example, we see such reform in the doctrine of usury. The Ecumenical Council of Vienne, which defined the sinfulness of usury, says:

“If indeed someone has fallen into the error of presuming to affirm pertinaciously that the practice of usury is not sinful, we decree that he is to be punished as a heretic; and we strictly enjoin on local ordinaries and inquisitors of heresy to proceed against those they find suspect of such error as they would against those suspected of heresy.”[29]

Note the use of the term “we decree” and the use of an anathema on anyone who teaches usury is not a sin. This is likely an extraordinary act of the magisterium (or at least a conciliar expression of the ordinary and universal magisterium) and should be considered definitive. It should be emphasized that it only defines the sinfulness of usury and does not define what constitutes usury. This is a key point to understand when considering reform in relation to this doctrine. At the time of this definition, usury was defined as the charging of any interest on loans,[30] although a small amount of interest was curiously permitted for Jews.[31] However, usury began to take on a different meaning in later centuries. Over time, money was no longer understood to be static and the definition of usury became the excessive charge of interest on loans. As a reformed understanding of what constituted usury took place, the papacy opened to the liceity of charging small amounts of interest. The old Catholic Encyclopedia addresses this new reception of taxes on loans by saying:

“The Holy See admits practically the lawfulness of interest on loans, even for ecclesiastical property, though it has not promulgated any doctrinal decree on the subject. See the replies of the Holy Office dated 18 August, 1830, 31 August, 1831, 17 January, 1838, 26 March, 1840, and 28 February, 1871; and that of the Sacred Penitentiary of 11 February, 1832. These replies will be found collected in ‘Collectio Lacensis’ (Acta et decreta s. conciliorum recentiorum), VI, col. 677, Appendix to the Council of Pondicherry; and in the ‘Enchiridion’ of Father Bucceroni.”[32]

In this case, we see a clear example of how the understanding of a definitive teaching can be reformed. This is not because the meaning of the definition changed, but because some of the terms in the definition underwent reform. In other words, the definition was originally “expressed incompletely (but not falsely),” to use the words of the Congregation for the Doctrine of the Faith.

B. Definitive Ordinary and Universal (Ordinary Infallible Papal) Teachings

Everything that is true of papal or conciliar dogmas is also true of the dogmas defined by the ordinary and universal magisterium. Likewise, teachings in this category can also undergo a level of reform. For example, prior to the First Vatican Council, the doctrine of papal infallibility was considered definitive, not by an ex cathedra definition or definitive conciliar act, but by the ordinary and universal magisterium.[33] Yet, there wasn’t agreement on how this doctrine was to be understood. Even during the debates at the First Vatican Council, there were minimalists and maximalists, who had different perspectives on how and when the pope was infallible. The First Vatican Council laid out conditions for ex cathedra definitions, which helped clarify the matter. Surely, the further development offered by the First Vatican Council, in specifying conditions for papal infallibility, would constitute a reform to how many understood this teaching. In other words, further acts of the magisterium can help qualify or explain things definitively settled by the ordinary and universal magisterium.

IV. Reform in Relation to Non-Dogmatic Teachings

 A. Non-Definitive Teachings in an Ex Cathedra Documents

Ineffabilis Deus is recognized as an instance of a document containing an ex cathedra definition, as it defined the doctrine of the Immaculate Conception of the Blessed Virgin Mary. Yet, this does not mean everything in the document is considered irreformable. Instead, everything in the document either ranges from the authentic ordinary magisterium to the extraordinary infallible magisterium, with the former potentially being reformable.

B. Non-Definitive Teachings at an Ecumenical Council

That the church can reform some aspects of ecumenical councils, even in reference to their non-definitive teachings, is not an optional view for Catholics. It is simply a fact that such reforms have occurred. For example, we see a reform in relation to an ecumenical council in the case of the matter of ordination. The Council of Florence says:

“The sixth is the sacrament of orders. Its matter is the object by whose handing over the order is conferred. So the priesthood is bestowed by the handing over of a chalice with wine and a paten with bread; the diaconate by the giving of the book of the gospels; the subdiaconate by the handing over of an empty chalice with an empty paten on it; and similarly for the other orders by allotting things connected with their ministry.”[34]

The council clearly taught the matter of ordination is the passing on of the chalice and paten. This was a teaching overturned by Pope Pius XII in the Apostolic Constitution Sacramentum Ordinis, which says:

“Wherefore, after invoking the divine light, We of Our Apostolic Authority and from certain knowledge declare, and as far as may be necessary decree and provide: that the matter, and the only matter, of the Sacred Orders of the Diaconate, the Priesthood, and the Episcopacy is the imposition of hands.”[35]

In other words, Pius XII changed the teaching on the matter of ordination to the imposition of hands. Another reform of a non-definitive teaching at an ecumenical council involves the case of Ibas of Edessa at the Council of Chalcedon. The bishops present read the Letter of Mari to Ibas and concluded it was orthodox. Yet, the Catholic Benedictine Dom Chapman priest and historian says concerning this letter:

“As for the letter of Ibas, it had been read at Chalcedon, and in spite of its partial defense of Nestorius and abuse of St. Cyril, it had not been condemned, whilst a Papal legate and a bishop had pronounced it satisfactory so far as the faith of the writer was concerned.”[36]

Clearly, the letter that was read by the council was less than orthodox, though it implicitly affirmed it as orthodox. The Roman Catholic priest and historian Fr. Richard Price substantiates this claim by offering the following words taken directly from the proceedings of Chalcedon:

“Ibas has been proved innocent, and from the reading of his letter we have found him to be orthodox…Anatolius the most devout bishop of Constantinople Rome said: ‘The good faith of the most God beloved bishops who sat in judgment and the reading of all the accompanying material prove the most devout Ibas innocent of the accusations brought against him’…Maximus the most devout bishop of the city of Antioch said: ‘the most devout Ibas is guiltless of everything charged against him…his writing has been seen to be orthodox.”[37]

Reforming the work of Chalcedon, the Council of Constantinople II said this letter was heretical. It tried to save face for Chalcedon by saying that the council fathers must have read a different letter than the Letter to Mari, which Constantinople II, through the emperor Justinian, says was not really written by Ibas. This can be seen in the words of the Council of Constantinople II, which records the following:

“For the same purpose they made use of those impious writings of Theodoret which were directed against the first Synod of Ephesus, against Cyril and his Twelve Chapters, and also the shameful letter which Ibas is said to have written. They maintain that this letter was accepted by the Synod of Chalcedon, and so would free from condemnation Nestorius and Theodore who were commended in the letter… Moreover we exhort you to examine the writing of Theodoret and the supposed letter of Ibas, in which the incarnation of the Word is denied, the expression Mother of God and the holy Synod of Ephesus rejected, Cyril called a heretic, and Theodore and Nestorius defended and praised. And as they say that the Council of Chalcedon has received this letter, you must compare the declarations of this Council relating to the faith with the contents of the impious letter.”[38]

It also says:

“And this we made manifest to all, that we did not have any intention of omitting the Fathers of the first and second interlocutions, which the followers of Theodore and Nestorius cited on their side, but these and all the others having been read and their contents examined, we found that the aforesaid Ibas was not allowed to be received without being compelled to anathematize Nestorius and his impious teachings, which were defended in that epistle. And this the rest of the religious bishops of the aforesaid holy Council did as well as those two whose interlocutions certain tried to use.”[39]

Fr. Richard Price examined all of the acts of Chalcedon and Constantinople II and does not think highly of Justinian’s attempt to argue that Chalcedon accepted another letter of Ibas as orthodox. After refuting all the ways in which Justinian attempted to explain the decision of Chalcedon on the letter, Price addresses the claim that it was another letter and states, “Modern commentators have no patience with this attempt to cast doubt on the authenticity of the letter”[40] Price also shows that nobody before Justinian believed it was a different letter. Clearly, there was some degree of reform between Chalcedon and Constantinople II on the Letter to Mari. Either Chalcedon judged it as orthodox and this was overturned by Constantinople II, or Chalcedon did not sufficiently express its judgment on the letter and Constantinople II finished the job. Regardless of which theory one adopts, some element of reform has to be conceded. This is why others such as the Eastern Orthodox bishop Hilarion Alfeyev says of Constantinople II:

“There is an opinion that the Church has no right to return to the acts of the Ecumenical Councils for reconsideration. Yet history indicates otherwise…The Horos of the fifth Ecumenical Council in turn reinterpreted that of the fourth Ecumenical Council using the “twelve chapters” of St Cyril, in which he spoke against Nestorius and his Christological terminology. Finally, the same fifth Ecumenical Council condemned the theological works by Theodoret of Cyrhus and Ibas of Edessa, which means that it reinterpreted the decision of the fourth Ecumenical Council concerning these theologians.”[41]

As evident from Chapman, Price and Hilarion and the words of both councils, there is clearly a degree of reformability concerning the Letter to Mari from Chalcedon to Constantinople II. Such reform is possible because Chalcedon had no intentions of defining the orthodoxy of the Letter to Mari as a matter of faith. If this is truly the same letter condemned by Constantinople II, then it ruled on the orthodoxy of the letter with authentic ordinary magisterium only. Thus, Constantinople II was free to overturn this.

C. Non-Definitive Teachings of the Authentic Ordinary (Ordinary Fallible) Magisterium

Suffice it to say, the latitude of reform addressed hitherto applies to the authentic ordinary magisterium. Moreover, with this level of teaching a change in the meaning or an outright overturning of previous teachings apply. In other words, the church is free to revise teachings of this level however it sees fit. Although, it is very unlikely teachings in this category would be overturned, as the church has an overall accurate track record for such teachings.

In this section, consideration has been given to the different ways in which reform may apply to magisterial teachings, although this has not been explored exhaustively. In fact, much more can be said concerning magisterial reforms. For further discussion on these parameters, it is recommended the reader examine the Declaration in Defense of the Catholic Doctrine on the Church Against Certain Errors of the Present Day by the Congregation for the Doctrine of the Faith.

V. Establishing Infallibility

As seen above, only teachings of a non-definitive level can be entirely overturned by the church. For this reason, it is important to examine what establishes a teaching as irreformable, and thus ineligible for such reform. It was noted previously, the Church can teach something infallibly in san ex cathedra definition, a definition by an ecumenical council or when the ordinary and universal magisterium teaches something definitively. How can one identify when these organs of infallibility have exercised this charism? Unfortunately, there is no magical formula that is used to determine this. Instead, there are general principles and indicators that will alert one to the activation of this charism.

Sometimes, these principles are clear in an intervention of the magisterium, such as Infeffabilis Deus, but not every definitive intervention is so easily established and the assumption is that something has not been taught infallibly, unless demonstrated otherwise. In fact, one should not consider a teaching of the church as infallible, unless it can be manifestly demonstrated to have been taught definitively, since the Code of Canon Law says, “No doctrine is understood as defined infallibly unless this is manifestly evident.”[42] Once again, this does not mean there are no signals that alert the reader to an infallible definition; rather, there are general principles, and these will be examined next.

A. Establishing Papal Infallibility

As it has been shown seen, the First Vatican Council stated a pope teaches ex cathedra when the pope “in the exercise of his office as shepherd and teacher of all Christians, in virtue of his supreme apostolic authority… defines a doctrine concerning faith or morals to be held by the whole Church.”[43] This is the highest exercise of the papal office and is infallible and irreformable, but note the four criteria given in this definition. He must (a) teach as the shepherd of all Christians, (b) in the name of his apostolic authority, (c) define a matter of faith and morals and (d) bind the entire Church to his decision. Unless these four criteria can be demonstrated to be present in a papal document, then one cannot claim the pope has taught something ex cathedra. In other words, the burden of proof is on the one who claims something has been taught ex cathedra.

How does one know the pope intends to define a matter of faith and morals? As a rule of thumb, the pope may use language such as term “we define” (diffinimus) to signal such an intention. However, caution should be used because this has not always enough to establish intent to define a matter of faith and morals, since some popes have used this term without such intent.[44] The same can be said of papal use of the term “we decree.” For example, Quo primum says:

We likewise declare and ordain that no one whosoever is forced or coerced to alter this Missal, and that this present document cannot be revoked or modified, but remain always valid and retain its full force notwithstanding the previous constitutions and decrees of the Holy See, as well as any general or special constitutions or edicts of provincial or synodal councils, and notwithstanding the practice and custom of the aforesaid churches, established by long and immemorial prescription – except, however, if more than two hundred years’ standing.”[45] (Emphasis mine.)

In this case, the pope uses the term “we likewise declare” to bind all Catholic priests to use the Tridentine Missal in perpetuity. Yet, Pope Saint Paul VI overturned this with his edition of the new Roman Missal, as he states:

“We wish that these Our decrees and prescriptions may be firm and effective now and in the future, notwithstanding, to the extent necessary, the apostolic constitutions and ordinances issued by Our predecessors, and other prescriptions, even those deserving particular mention and derogation.”[46]

In other words, terms like “we declare” or “we decree” or even “we define” are not necessarily signals of an infallible definition.

As further ways to discern the level of authority by a papal intervention, it would be helpful to list the kinds of documents used in papal teachings. These are by no means exhaustive, but they do show a hierarchy in the different types of papal documents. The following list was written by Hellen Hull Hitchcock[47] and it is as follows:

  1. Apostolic constitutions
  2. Apostolic exhortation
  3. Apostolic letter
  4. Declaration
  5. Decree
  6. Encyclical
  7. Instruction
  8. Institutio
  9. Motu proprio
  10. Promulgation
  11. Recognitio

The different kinds of seals for papal documents also show a hierarchy of authoritative weight.[48] For instance, the seals below are in descending order:

  1. Documents sealed with a lead seal
  2. Documents sealed with a waxed seal
  3. Documents stamped with ink.

Being mindful of the kind of document a papal teaching is in or the kind of seal he uses helps situate the level of authority the pope intends to use.

B. Establishing Conciliar Infallibility

Concerning the infallibility of ecumenical councils, they teach infallibly when they define a matter of faith and morals. But how does one determine the council has done this? To understand the answer, it is important to consider how ecumenical councils generally teach. Ecumenical councils often, though not always, teach with chapters and canons. Chapters usually contain longer exposition of the faith, whereas canons are short standards given by the church.[49] It should be remembered that the chapters of an ecumenical council are “authoritative, but non-definitive exposition[s] of Catholic doctrine.”[50] In other words, not everything in the chapter of an ecumenical council is infallible, but “only that part of the chapter to which the canon corresponds.”[51] The same applies to the rest of the content in an ecumenical council since an ecumenical councils can teach something authoritatively but with the ordinary fallible magisterium.[52]

Ecumenical Councils generally issue anathemas against those who deny the teachings of a canon. If an ecumenical council issues an anathema, in conjunction with a canon that teaches a matter of faith and morals, then this is a strong presumption the church has taught the matter definitively.[53] One would have to show serious reasons to doubt why the use of canons conjoined by an anathema on a matter of faith and morals is not to be considered definitive. In the same vein, if an ecumenical council teaches something on a matter of faith and morals and uses forceful language like “we define” and adds canons and anathemas to anyone who affirms the contrary, then it is extremely likely it is definitive, unless consensus has determined otherwise. How does one identify such consensus? It is especially seen in the writings of theologians, who are given the task to establish when the church has taught definitively. [54]

The use of the term “we define” could also be a signal the council is signaling its use of infallibility,[55] although, the term did not always have a definitively binding sense in some of the older documents of the church.[56] For example, some teachings at the Council of Florence used this language. It says:

“We define also that the explanation of those words “and from the Son” was licitly and reasonably added to the creed for the sake of declaring the truth and from imminent need.”[57]

Some have noted the Filioque clause was not inserted in to the creed for urgent causes, so it is unlikely the council intended to define this as a matter of faith.[58] In such cases, the term “we define” could be understood as “we insist.”[59] However, this is not a hard rule, so context should be considered to discern intent.

Some may wonder what role reception plays in relation to ecumenical councils. It should be emphasized that there is a sense in which the definitive decisions of an ecumenical council need to be received by the church in order to know the teaching has been expressed definitively. This does not mean reception is what establishes the infallibility of the council’s decision. Rather, it means “the most effective witness” that something has been defined is whether it has been received as such.[60]

Another thing to remember is that the intent of an ecumenical council to define a matter on faith and morals can become clearer by examining the acta (proceedings) of the council.[61] It is true there may be a challenge in determining the intent of some councils, since there are no extant copies of the acta in some cases. In other cases, the acta is in Latin and has not been translated into modern languages.

Lastly, being mindful of the different documents an ecumenical council may issue helps situation the level of authority the council intends to express. The following are examples of different documents an ecumenical council may issue and are in descending order. They are by no means exhaustive:

  1. Constitutions
  2. Decrees
  3. Declarations

C. Establishing Ordinary and Universal Infallibility

The ordinary and universal magisterium is said to be operative when the pope and the bishops of the world, even when they are not assembled in a council, teach something is to be held definitively.[62] One of the ways to establish this organ of infallibility is by a consensus that is “universal” and “constant.”[63] This is, in fact, what Pope Pius IX taught in a letter to the archbishop of Munich Tuas libenter, which says:

“For even if it is a matter of that subjection which must be given in the act of divine faith, it must not be limited to those things which have been defined by the express decrees of councils or of the Roman pontiffs and of this apostolic see, but must also be extended to those things which are handed on by the ordinary magisterium [Ordinary and Universal Magisterium] of the whole church dispersed throughout the world as divinely revealed, and therefore are held by the universal and constant consensus of Catholic theologians to pertain to the faith.”[64]

In other words, universal and constant consensus is best seen through the consensus of Catholic theologians. It can also established through “universal custom or practice associated with dogma, the consensus or agreement of the Fathers”[65] and “the common or general understanding of the faithful.”[66] This means if there is consensus on a matter of faith and morals among the church fathers or the theologians or even the faithful (through the sensus fidelium), then there is good reason to believe it is definitive.

VI. Weighing Magisterial Documents

There are times when magisterial teachings may appear to clash with one another. If such a case were to arise, the theologian should consider the weight of each teaching. Some helpful principles to judge the weight of a teaching are worth noting:

  1. The teaching of multiple popes outweighs the teaching of fewer popes, unless the fewer popes taught something with greater authority.[67]
  2. A teaching expressed more frequently and with greater force carries greater weight than something with less frequency and force. This is what the Second Vatican Council established when it said the mind of the pope “is made known principally either by the character of the documents in question, or by the frequency with which a certain doctrine is proposed, or by the manner in which the doctrine is formulated.”[68]
  3. Newer non-infallible teachings that appear erroneous are to yield to what has been taught historically, although the benefit of the doubt should initially be given to the more recent teaching, unless there is serious reason to believe otherwise.[69] In other words, if what is in the proximate rule of faith (current teachings) seriously appears to contradict the remote rule of faith (Scripture and Tradition), then one can withhold assent to the proximate rule of faith, as long as what is taught in this rule is a non-definitive teaching. The initial disposition, however, should be to assent to the non-definitive teaching.
  4. A single magisterial document can have teachings with different theological weights. For example, Ineffabilis Deus is generally seen as an ex cathedra document, but not all the teachings expressed in this document carry the same theological weight.[70]
  5. Consideration should be given to the different kinds of documents issued by an ecumenical council or a pope, in order to determine the degree of weight the document carries. For example, a dogmatic constitution of an ecumenical council would outweigh a declaration of an ecumenical council. Similarly, a dogmatic constitution would outweigh a pastoral constitution.
  6. A teaching from a pope outweighs something taught by a bishop, curial member or congregation.[71]

These principles are by no means exhaustive, though they will help anyone who tries to judge the theological weight of ecclesial documents.

VII. Conciliar Fundamentalism

Lastly, a word should be said about conciliar fundamentalism, as it stands in contradiction to much of what has been said above. The term “Conciliar fundamentalism” is one used by historian Fr. Richard Price concerning those in the early church who believed “all the acts [of ecumenical councils] and not just the decrees were treated with exaggerated respect.”[72] This is a view that is also prevalent among some Roman Catholic and Eastern Orthodox Christians today. It was expressed in the early church by figures such as Ferrandus of Carthage, who said:

“if there is disapproval of any part of the Council of Chalcedon, the approval of the whole is in danger of becoming disapproval…But the whole Council of Chalcedon, since the whole of it is the Council of Chalcedon, is true; no part of it is open to criticism. Whatever we know to have been uttered, transacted decreed and confirmed there was worked by the ineffable and secret power of the Holy Spirit.”[73]

Ferrandus also went on to elaborate his view as follows:

“General councils, particularly those that have gained the assent of the Roman Church, hold a place of authority second only to the canonical books.”[74]

The problem with this view is that it lacks the proper distinctions to seriously engage magisterial documents. It is a fact that the church has undergone reform and development in its conciliar acts and teachings, as described in various instances above. Conciliar fundamentalism denies this under the guise of piety and prevents any serious discussion of the church’s teaching authority by an over-rigorous calcification of theology. However pious the intentions of adherents of this position may be, this perspective simply stifles the work of the Holy Spirit whose role is to lead the church into all truth (John 16:13). In the words of St. Vincent of Lerins, who recognized the importance of development in matters pertaining to theology:

“But some one will say, perhaps, Shall there, then, be no progress in Christ’s Church? Certainly; all possible progress. For what being is there, so envious of men, so full of hatred to God, who would seek to forbid it? Yet on condition that it be real progress, not alteration of the faith. For progress requires that the subject be enlarged in itself, alteration, that it be transformed into something else. The intelligence, then, the knowledge, the wisdom, as well of individuals as of all, as well of one man as of the whole Church, ought, in the course of ages and centuries, to increase and make much and vigorous progress; but yet only in its own kind; that is to say, in the same doctrine, in the same sense, and in the same meaning.”

Conclusion

It has been shown the church’s teaching authority has different categories that distinguish the ways organs by which it can teach. Consideration was also given to the various levels of magisterial teachings, in order to demonstrate there are degrees of authority expressed in the teachings of the church. Ways in which the magisterium can undergo reform were also addressed in order to account for some of the contemporary teachings of the church. How to establish that something has been infallibly taught and therefore limited in the ways it can be reformed was examined. It has also been shown there are certain principles that should be used in weighing the value and authority of a magisterial teaching against the value and authority of another. Lastly, a word was offered on conciliar fundamentalism and its impediment for serious theological discussions about the magisterium. Having examined these things, the reader should be equipped to engage the texts of the church in a responsible fashion.


[1] First Vatican Council, Dogmatic Constitution on the Church of Christ Pastor Aeternus, chapter IV, paragraph 6. Available online: https://www.ewtn.com/catholicism/teachings/vatican-is-dogmatic-constitution-pastor-aeternus-on-the-church-of-christ-243. Accessed 9 February 2020.

 

[2] First Vatican Council, Dogmatic Constitution on the Church of Christ Pastor Aeternus, chapter IV, paragraph 9. Available online: https://www.ewtn.com/catholicism/teachings/vatican-is-dogmatic-constitution-pastor-aeternus-on-the-church-of-christ-243. Accessed 9 February 2020.

 

[3] In older documents, prior to the First Vatican Council. After this council, what was called the ordinary magisterium became known as the ordinary and universal magisterium.

 

[4] See the Second Vatican Council, Dogmatic Constitution on the Church Lumen Gentium, 25b. Available Online: http://www.vatican.va/archive/hist_councils/ii_vatican_council/documents/vat-ii_const_19641121_lumen-gentium_en.html. Accessed 9 February 2020.

 

[5] Francis Sullivan, S.J., Creative Fidelity: Weighting and Interpreting Documents of the Magisterium (Eugene, Oregon: Wipf and Stock Publishers, 2003), 14.

 

[6] Many people are not aware of this category of papal teachings between ex cathedra teachings and teachings of the ordinary magisterium.

 

[7] Ibid., 141.

[8] The Congregation of the Doctrine of the Faith is a part of the Roman Curia that assists in the affairs of the Pope.

 

[9] Congregation for the Doctrine of the Faith, Profession of Faith, 2. Available Online: http://www.vatican.va/roman_curia/congregations/cfaith/documents/rc_con_cfaith_doc_1998_professio-fidei_en.html. Accessed 2 February 2020.

 

[10] Congregation for the Doctrine of the Faith, Doctrinal Commentary on the Concluding Formula of the “Professio fidei,” 5. Available Online: https://www.ewtn.com/catholicism/library/doctrinal-commentary-on-concluding-formula-of-professio-fidei-2038. Accessed 2 February, 2020.

 

[11] Congregation for the Doctrine of the Faith, Declaration in Defense of the Catholic Doctrine of the Church Against Certain Errors of the Present Day, 5. Available Online: http://www.vatican.va/roman_curia/congregations/cfaith/documents/rc_con_cfaith_doc_19730705_mysterium-ecclesiae_en.html. Accessed 2 February 2020.

 

[12] Congregation for the Doctrine of the Faith, Doctrinal Commentary on the Concluding Formula of the “Professio fidei,” 5. Available Online: https://www.ewtn.com/catholicism/library/doctrinal-commentary-on-concluding-formula-of-professio-fidei-2038. Accessed 2 February 2020.

 

[13] Congregation for the Doctrine of the Faith, Profession of Faith, 2. Available Online: http://www.vatican.va/roman_curia/congregations/cfaith/documents/rc_con_cfaith_doc_1998_professio-fidei_en.html. Accessed 3 February 2020.

 

[14] Congregation for the Doctrine of the Faith, Doctrinal Commentary on the Concluding Formula of the “Professio fidei,” 6. Available Online: https://www.ewtn.com/catholicism/library/doctrinal-commentary-on-concluding-formula-of-professio-fidei-2038. Accessed 2 February 2020.

 

[15] Ibid., 7

 

[16] Ibid., 8.

 

[17] Congregation for the Doctrine of the Faith, Profession of Faith, 10. Available Online: http://www.vatican.va/roman_curia/congregations/cfaith/documents/rc_con_cfaith_doc_1998_professio-fidei_en.html. Accessed 2 February 2020.

 

[18] Vatican II, Lumen Gentium, No. 25, Vatican II: The Conciliar and Post Conciliar Documents, Vol. I, edited by Austin Flannery, O.P. (Northport, New York: Costello Pub. Co., 1992), p. 379.

 

[19] Ibid., 11.

 

[20] Congregation for the Doctrine of the Faith, Doctrinal Commentary on the Concluding Formula of the “Professio fidei,” 10. Available Online: https://www.ewtn.com/catholicism/library/doctrinal-commentary-on-concluding-formula-of-professio-fidei-2038. Accessed 2 February 2020.

 

[21] Ibid.

 

[22] Congregation for the Doctrine of the Faith, Donum Veritatis Instruction on the Ecclesial Vocation of the Theologian, 23. Available Online: http://www.vatican.va/roman_curia/congregations/cfaith/documents/rc_con_cfaith_doc_19900524_theologian-vocation_en.html. Accessed 2 February 2020.

 

[23] Congregation for the Doctrine of the Faith, Doctrinal Commentary on the Concluding Formula of the “Professio fidei,” 10. Available Online: https://www.ewtn.com/catholicism/library/doctrinal-commentary-on-concluding-formula-of-professio-fidei-2038. Accessed 2 February 2020.

 

[24]  Fr. John Hardon, Modern Catholic Dictionary. Available Online: https://www.catholicculture.org/culture/library/dictionary/index.cfm?id=36835. Accessed 11 February 2020.

 

[25] See Father Sixtus Cartechini S.J, On the Value of Theological Notes and the Criteria for Discerning Them, trans. John Daly. Available Online: http://the-pope.com/theolnotes.html

[26] First Vatican Council, Session 3, Dogmatic constitution on the catholic faith, chapter 4, On faith and reason, 14 Available Online: https://www.papalencyclicals.net/councils/ecum20.htm. Accessed 12 February 2020.

 

[27] Congregation for the Doctrine of the Faith, Declaration in Defense of the Catholic Doctrine of the Church Against Certain Errors of the Present Day, 5. Available Online: http://www.vatican.va/roman_curia/congregations/cfaith/documents/rc_con_cfaith_doc_19730705_mysterium-ecclesiae_en.html. Accessed 12 February 2020.

 

[28] Ibid.

 

[29]   Council of Vienne, Decree 29. Available Online: https://www.papalencyclicals.net/councils/ecum15.htm. Accessed 12 February 2020.

 

[30] Francis Sullivan, S.J., Creative Fidelity: Weighting and Interpreting Documents of the Magisterium (Eugene, Oregon: Wipf and Stock Publishers, 2003), 53.

 

[31] Vermeersch, A. (1912). Usury. In The Catholic Encyclopedia. New York: Robert Appleton Company. Retrieved February 12, 2020 from New Advent: http://www.newadvent.org/cathen/15235c.htm

 

[32] Ibid.

 

[33] Congregation for the Doctrine of the Faith, Doctrinal Commentary on the Concluding Formula of the “Professio fidei,” 11. Available Online: https://www.ewtn.com/catholicism/library/doctrinal-commentary-on-concluding-formula-of-professio-fidei-2038. Accessed 12 February, 2020.

 

[34] Council of Florence, Session 8 22 November 1439 [Bull of union with the Armenians]. Available Online: https://www.papalencyclicals.net/councils/ecum17.htm. Accessed 12 February 2020.

[35]  Pope Pius XII, Apostolic Constitution Sacramentum Ordinis On the Sacrament of Order, 4. Available Online: https://www.papalencyclicals.net/pius12/p12sacrao.htm. Accessed 12 February 2020.

 

[36] Dom John Chapman, The First Eight General Councils and Papal Infallibility (London, Catholic Truth Society, 1906) 50.

 

[37] Richard Price, The Acts of the Council of Constantinople of 553: With Related Texts on the Three Chapters Controversy (Translated Texts for Historians LUP), vol 2 (Liverpool University Press, 2009) 91.

 

[38] Council of Constantinople II, Session I, The Emperor’s Letter (which was read to the Fathers). Available Online: http://www.newadvent.org/fathers/3812.htm. Accessed 11 February 2020.

[39] Council of Constantinople II, Session VII. Available Online: http://www.newadvent.org/fathers/3812.htm. Accessed 11 February 2020.

 

[40] Richard Price, The Acts of the Council of Constantinople of 553: With Related Texts on the Three Chapters Controversy (Translated Texts for Historians LUP), vol 2 (Liverpool University Press, 2009) 95.

 

[41] Hilarion Alfeyev, “The Reception of the Ecumenical Councils in the Early Church” St Vladimir’s Theological Quarterly 47:5-4 (2003): 424.

 

[42] Code of Canon Law, 749 §3. Available Online: http://www.vatican.va/archive/ENG1104/_P2H.HTM. Accessed 2 February 2020.

 

[43] The First Vatican Council’s Dogmatic Constitution on the Church of Christ, Pastor Aeternus, 9. Available Online: https://www.ewtn.com/catholicism/teachings/vatican-is-dogmatic-constitution-pastor-aeternus-on-the-church-of-christ-243. Accessed 2 February 2020.

 

[44] Francis Sullivan, S.J., Creative Fidelity: Weighting and Interpreting Documents of the Magisterium (Eugene, Oregon: Wipf and Stock Publishers, 2003), 82.

 

[45] Pope Pius V, Apostolic Constitution Quo Primum Promulgating the Tridentine Liturgy. Available Online: https://www.papalencyclicals.net/Pius05/p5quopri.htm. Accessed 12 February 2020.

 

[46] Pope Saint Paul VI, Apostolic Constitution Missale Romanum On the New Roman Missal, Available Online: http://www.vatican.va/content/paul-vi/en/apost_constitutions/documents/hf_p-vi_apc_19690403_missale-romanum.html. Accessed 12 February 2020.

 

[47]  Hellen Hull Hitchcock, “The Authority of Church Documents,” Adoremus 8, No. 6 (September 2002). Available Online: https://adoremus.org/2002/09/15/The-Authority-of-Church-Documents/. Accessed 10 February 2020. Quoted with permission. Emphasis mine.

 

[48] Francis Sullivan, S.J., Creative Fidelity: Weighting and Interpreting Documents of the Magisterium (Eugene, Oregon: Wipf and Stock Publishers, 2003) 21.

 

[49] See the Council of Trent for examples.

 

[50] Ibid., 48.

 

[51] Ibid.

 

[52] Ibid., 141.

 

[53] Ibid., 47.

 

[54] Ibid., 44.

 

[55] Ibid., 53.

 

[56] Ibid.

 

[57] Council of Florence, Session 6 6 July 1439 [Definition of the holy ecumenical synod of Florence]. Available Online: https://www.papalencyclicals.net/Councils/ecum17.htm. Accessed 12 February 2020.

[58] Francis Sullivan, S.J., Creative Fidelity: Weighting and Interpreting Documents of the Magisterium (Eugene, Oregon: Wipf and Stock Publishers, 2003), 53-54.

 

[59] Ibid., 54.

 

[60] Ibid., 85.

 

[61] Ibid., 45.

 

 

[62] Ibid., 103.

 

[63] Ibid., 104.

 

[64] Ibid., 99.

 

[65] Adolphe Tanquerey, A Manual of Dogmatic Theology, transl. by Rev. Msgr. John J. Byrnes (Desclee, New York, 1959), pp. 176-182.Available Online: http://www.catholicapologetics.info/modernproblems/vatican2/magisterium.htm Accessed 2 February 2020.

 

[66] Ibid.

 

[67] Fr. Chad Ripperger, Magisterial Authority (CreateSpace Independent Publishing Platform, 2014), 51.

 

[68] Vatican II, Lumen Gentium, No. 25, Vatican II: The Conciliar and Post Conciliar Documents, Vol. I, edited by Austin Flannery, O.P. (Northport, New York: Costello Pub. Co., 1992), p. 379.

 

[69] Fr. Chad Ripperger, Magisterial Authority (CreateSpace Independent Publishing Platform, 2014), 50.

[70] Francis Sullivan, S.J., Creative Fidelity: Weighting and Interpreting Documents of the Magisterium (Eugene, Oregon: Wipf and Stock Publishers, 2003), 84.

 

[71] Fr. Chad Ripperger, Magisterial Authority (CreateSpace Independent Publishing Platform, 2014), 51.

 

[72] Richard Price, The Acts of the Council of Constantinople of 553: With Related Texts on the Three Chapters Controversy (Translated Texts for Historians LUP), vol 2 (Liverpool University Press, 2009) 98.

 

[73] Ibid.

 

[74] Ibid.

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