The Watcher Cat

The Watcher Cat

Monday, December 31, 2018

Don't Dwell on What Has Past Away, Or What is Yet To Be....

We are in a liminal moment.
Neither here nor there.
2018, with its joys, woes, losses, gains, pains and joys, and everything else--
its time is drawing to a close,
and with it, a new year, as yet unformed, uncharacterized, awaits,
its blank pages inviting our words and deeds to fill them.
It's all up to you, and me, all of us where we go from here.

So hear some wisdom from Leonard Cohen:

You can add up the parts
You won't have the sum
You can strike up the march
There is no drum
Every heart, every heart to love will come
But like a refugee

And one more, from the Bard:

Not a whit; We defy augury.
There’s a special providence in the fall of a sparrow.
If it be now, ’tis not to come.
If it be not to come, it will be now.
If it be not now, yet it will come—the readiness is all.

And one last, again from the late Mr. Cohen:

Ring the bells that still can ring
Forget your perfect offering
There is a crack, a crack in everything (there is a crack in everything)
That's how the light gets in

May 2019 find you ready, ready to love and forgive--including yourselves. Happy New Year; thanks for coming on the prowl with me in 2018.

"Bunnies! Bunnies, It Must Be Bunnies!": Return to Watership Down

Er, no. Sorry, Anya. Let's try again:

Rather, I was thinking of the late Richard Adams's Watership Down, adapted by Netflix and BBC 1 recently in a splendidly dark, faithful manner (with, admittedly, a little nip here, a little tuck there). None of the changes are terribly plot-altering, although one rabbit who survived in the original gets a heroic death in the adaptation.

Now, if you were, as I was, a child in the 1970s, and had, as I did, a passion for books, odds are that you read Watership Down before you were ready for it. Or, if you were a little bit younger, you were traumatized by the 1978 animated movie. (Oddly,I missed the film, even though Watership was a favorite book. Still haven't seen it.) I remember the suspense, and the need to see what happened next driving me on, and on--even when the legends of El-ahrairah and Rabscuttle broke the momentum. From Fiver's first prophetic vision, until the bittersweet ending, I was stuck to this book until I finished it. Like Dracula and The Three Musketeers, Watership Down transported me into a bigger world than a Long Island boyhood would lead you to imagine. Throw in T.H. White and Mark Twain, and you have a portrait of the Anglocat as young, er, boy, actually.

So, as you can imagine, I watched this adaptation with considerable interest.

I'm going to start by emphasizing the wonderful work done by the script and the cast--distilling Adams's long novel into four hour long episodes and keeping almost all of it intact is a remarkable feat. The storyline doesn't skip any of the major set-pieces, and the cast build the relationships between our heroes (and our villains) swiftly. Nicholas Hoult (Fiver), James McEvoy (Hazel, his older brother), and John Boyega (Bigwig) are the three stalwarts who do the main lifting among the Sandleford rabbits, though the ingenious Blackberry (a very good Miles Jupp), and the inimitable Olivia Coleman as Strawberry also shine. At first, Hazel and Bigwig are in tension over who should lead, with Bigwig thinking the notion of "Hazel-rah" to be ridiculous--until Bigwig's distrust in Fiver, and thus in Hazel, nearly leads to his death. From then on, these three very different characters form a mutually loyal troika, determined to protect the members of their new warren.

As a fan of Peter Capaldi (of course as the Doctor, but check out The Thick of It, or even more compellingly, The Hour), I was delighted to see him as the irascible, but ultimately friendly gull Kehaar. Yes, Capaldi's Scottishness is a long way from Kehaar's Eastern European accent in the novel--but Capaldi captures the defensiveness, the vulnerability of the injured bird with comedic brio, and ultimately, his affection for his furry friends. At the beginning of the last episode, Kehaar gets his "crowning moment of awesome" when he swoops down on General Woundwort to remind him of just why rabbits fear birds, especially large angry ones.

Speaking of Woundwort, Ben Kingsley does a fine job with our Mad Efrafan leader, and brings a complexity and a rage to the part that is truly formidable. Bigwig's climactic battle with Woundwort, and our last glimpse of the General are. . . perfect.

Fiver is not given what Adams gave as his climactic moment--eerily expressing sorrow for Vervain's and the invader's imminent death, and drive them to retreat or surrender by his calm certainty--but a variant on Hazel's big moment. Any more would spoil a lovely moment so...go watch it yourselves.

Some have criticized the animation. I am tempted to reply with Bigwig's response to Woundwort in the Honeycomb, but will simply say: Seriously? Yes, it's imperfect, but it works, and the script, the vocal talents of superb actors, and the storytelling had me 15 minutes in.

But then, the book has held me much longer.

Sunday, December 23, 2018

What Reason Have You to Be Merry? A Sermon on Luke 1: 46-56

[Delivered at St. Bartholomew's Church, New York City
December 23, 2018.

What right have you to be merry?

What reason have you to be merry?

So asked Ebenezer Scrooge in A Christmas Carol, 175 years ago tomorrow, and maybe, just maybe it’s about time we took that question seriously.

After all, the story was published in 1843, and we’ve pretty much just assumed that it was bad-tempered spite on the part of old Ebenezer to ask it.

And maybe that’s true. He is, after all, the villain of the story as well as its protagonist, and his salvation takes the three spirits of Christmas some pretty heavy lifting.

On the other hand, villains often are the dark mirrors of ourselves, the part of us we reject as unworthy, the parts of our true selves that we repress because we can’t bear to acknowledge them. We all want to be our best selves, kind, brave, generous but prudent. We act the parts of the people we want to be, and mostly we try to live up to that image. But that image—the “Glittering Image” as Susan Howatch called it—isn’t our real self either, because it’s only a part of the whole that comprises each and every one of us.

This darker half of ourselves, the unacknowledged fears, desires, and thoughts, can have a kind of wisdom that we shut out of our minds.

After all, what reason does Scrooge’s nephew Fred have to be merry? As Scrooge points out, every Christmas for Fred is “but a time for paying bills without money; a time for finding yourself a year older, and not an hour richer; a time for balancing your books and having every item in 'em through a round dozen of months presented dead against” poor Fred.

For that matter, what reason does Scrooge’s clerk, Bob Cratchit, who applauds Fred’s defense of Christmas have to be merry? What reason do Cratchit’s wife and six children have to be merry? They are desperately poor, living on the slender salary Scrooge provides Bob. Mrs. Cratchit struggles to provide decent meals, sometimes even with meat, for her husband and her children, who are already becoming introduced to the life of the working poor in early Victorian London. Their lives are dirty, laborious, and their surroundings ramshackle. And her youngest son, Tiny Tim, is visibly failing, and very likely to die.

What right do Fred or the Cratchits have to be merry? What are they celebrating? Isn’t Scrooge right, when he caustically suggests that Fred’s celebration is simply driving him deeper in debt, allowing him to postpone the moment when he is forced to confront his failures and, at long last, set his house in order?

And we, here, today. Our Government is shut down, our politics are toxic, with the poisonous ooze of hatred coursing through the veins of the body politic. And we can’t pretend that because we’re in New York that this poison can’t effect us. Seventeen years ago, our skyline was changed forever, nearly 3,000 people died, and 6,000 were injured in an act of terrorism the reverberations of which are still vibrating through the fabric of our Nation.

And the tide of home grown hatred has lapped to the very doors of St. Barts. Two weeks ago, when I was standing on the steps greeting parishioners as they came inside for the 11:00 service, one of our ushers called me to the front door nearest to 51st Street. There, etched in the door in red pen, were two swastikas. Right outside. Right here. At St. Barts.

What right have we to be merry? What reason have we to be merry?

Mary and Elizabeth live in a time of terror, of ethnic hatred. The land of Israel occupied, Roman soldiery brutally enforcing the Emperor’s order, extorting whatever they wanted from the people living under occupation, and tax collectors doing the same. The religious establishment tainted and corrupt, complicit with the occupying forces, and life dependent on submission to brute force, with no real hope for justice.

Even Mary, Jesus’s mother, knew from her own experience the fear of death by execution. We are told in Matthew’s Gospel that when it became known that Mary was pregnant, that Joseph decided to save her life from a death by stoning by taking on himself the shame of what he believed was her crime.[1] Only after this remarkable act of mercy did he receive the illumination that led him to welcome her as his bride.

Her cousin Elizabeth was granted the gift of a child late in life, but at the time of Mary’s visit featured in today’s Gospel, her husband remained mute, from causes she did not know. The future of a widow—and Zechariah’s age and his new infirmity had to have her concerned for him—was extremely precarious, as was the future of Elizabeth’s child.

And yet, the meeting of the two women is joyful. Not merely the happiness of two relatives meeting after a time of separation, either. No, this is a meeting marked with the solemn joy of those who see that history, which may be, as Nicholas Meyer wrote, “replete with turning points,” is at a turning point like no other, and that these marginalized women—Elizabeth, long thought barren, and Mary, whose child nearly cost her her life—are the catalysts for what is about to begin.

About to begin, I say, but in fact, Mary presents it as a fait accompli, a thing that is already accomplished. A destiny fulfilled. Hear her words:

My soul magnifies the Lord,
and my spirit rejoices in God my Savior,
for he has looked with favor on the lowliness of his servant.
Surely, from now on all generations will call me blessed;
for the Mighty One has done great things for me,
and holy is his name.
His mercy is for those who fear him
from generation to generation.
He has shown strength with his arm;
he has scattered the proud in the thoughts of their hearts.
He has brought down the powerful from their thrones,
and lifted up the lowly;
he has filled the hungry with good things,
and sent the rich away empty.
He has helped his servant Israel,
in remembrance of his mercy,
according to the promise he made to our ancestors,
to Abraham and to his descendants forever."

Mary is not speaking of things to come, but as things accomplished. She believes—no, she knows—that the intervention of God into the world through the birth of Jesus will by its very occurrence create the very changes she describes.

Elizabeth knows it too, as witnessed by the fact that the older woman defers to the younger, and forthrightly tells her that she is “blessed among women” because she “believed that there would be a fulfillment of what was spoken to her by the Lord.”

And, in fact, so it has been. Rome fell, but here we are in a national landmark that is in fact a sanctuary raised to honor the child borne by Mary, and I am speaking these words under a beautiful painting of her and her child. Yes, evil still exists. Yes, discord and strife tear at the world. But they are not normative, not what we consider the measure of right conduct. Nobody reveres Herod, Pontius Pilate, Annas or Caiaphas. They are only known at all by most people because of their roles in the story that begins tomorrow night.

The old brutal dreams of might makes right, of tribe and power defining what we call the good has been on the run ever since Jesus showed us a better way, since God so loved the world that She offered her only begotten Son to be with us, not to lead our tribe to supremacy, but to lead us all to the deeper wisdom of love. Not just a wishy-washy ethic of sentimentality, but a way of life. That Way, as the disciples and their direct successors called what the world terms Christianity, involves a commitment to seeing, every day, the beauty of a Child of God, in every person, even when we are divided by them. That Way has survived empires, wars, corruption of its so-called leaders, and still is going strong. It doesn’t need an army. It never has. It has you, each and every one of you, who is here, not out of compulsion or social pressure, but because you want to be. Because the Way speaks to your heart.

Scrooge had a kind of wisdom, but it was of the lower kind—pragmatic wisdom, how to survive in a hostile world. Fred and the Cratchits refused to accept that the world was by its nature hostile. Their wisdom was deeper than his.

What right have you be merry?

The right of a child of God, in the world created by God.

What reason have you to merry?

The best reason in the world: that we are here again together, about to celebrate the end of those old, dark ways, and to repel the dark with the Light of the World.

In the Name of the Father, and of the Son, and of the Holy Spirit.
[1] See John Wirenius, “The Man of Mercy,” (December 18, 2016).

Friday, December 7, 2018

Hat-Tip: Words and Music

I write to music. It can't be the music that can overwhelm you, and compel engrossment into itself alone. But it needs to resonate with my mood. Not something so powerful as to distract me, but something that jibes with the general emotional state I'm evoking in myself, and hope to share with my readers. Phineas at Bay was largely written to film scores, mostly John Barry, specifically his score to Mary, Queen of Scots (1971).

This year, this parlous year, in which division and distrust have increasingly marred the country I love, I have preached on those themes, and on love--not sentimental goop, but real love, that is, a fundamental commitment to the well-being of the other, however you describe that "other," as the only hope to heal our divisions, and our world.

Just as I have written books because I myself needed them to exist, so too I have preached, as I often do, the sermons I need to hear. I have made myself confront the sins to which I all too easily can fall prey--arrogance in my sense of rightness, self-certainty, and righteous indignation. I have sought to call myself, as well as those who hear me, to the better angels of my own nature.

Along that path, this year, I have written several sermons to the accompaniment of Murray Gold's "The Shepherd's Boy" above. Somehow this piece speaks to me in this year of discord. Perhaps because the long build, the deceptive gentleness of the theme, its reaching a crescendo long delayed, speaks to me of the rebuilding, the re-weaving of the fabric of a nation fraying in ways I never expected to see ours fray.

I won't deny that Steven Moffat's recent writing seems to me to be seeking to that same basic mission, with his repeated emphasis on the virtues of courage and kindness. Ultimately, they are what I think we need: the courage to see ourselves in the other, and the kindness to trade them as we would treat ourselves. It is not easy to forego the luxury of righteous indignation, and choose instead the harder path of love, but, oh, I am trying. And I have many companions on the way--not just my friends and colleagues at St, Barts and throughout the Episcopal Church, but also friends and family writ large. But to my surprise, fiction, storytellers--often authors whose work I haven't visited in many years have come to my aid--T. H. White has more to say to me in my fifties than he did when I was a child, and I learned much from him then. Mark Twain and Henry James, Jean Anouilh and Jean Giradoux, have flared back into relevance this year. They have been good companions on the journey.

So too have Gold and Moffat.

I have read less theology than usual, but more stories, more parables, and I have found in them the resources to do that which has been needful, if only to myself. Robertson Davies's reminder to "never overlook the charm of narrative for the human heart" has come true for me this year. And so being an English major has turned out to be eminently practical after all. As has a taste for music.

Tuesday, November 27, 2018

"This is a Story of the Triumph of Good Over Evil. It is, of Course, A Fantasy."

As Filmstruck is shutting down, I am watching some of its buried treasures. Tonight, The Madwoman of Challot.

The Madwoman of Challot is a peculiar play, a poetic fantasia I first encountered in a 1984 adaptation by Dave Davis at Fordham Lincoln Center.

The play, first performed after the death of author Jean Giraudoux, is heavily stylized, taking place mostly in a Parisian tabac, with the denizens of the tabac as participants in the action, and, sometimes, as a Greek chorus. The play depicts the dream-and-romance addled Countess Aurelia, who, upon discovering that greed and selfishness are eliminating spontaneity, happiness, freedom. The Countess, once awakened, knowing the weaknesses that greed brings with it, takes radical action to protect her City, her friends, and her belief in Romance (definitely, the R is capitalized). Before she does, she and her friends have a trial for these malefactors of great wealth (Hmmm..."male factors"? Most of Aurelia's friends are women; all of the conspirators are men). The defendants are represented by the Ragpicker of Challot, Aurelia prosecutes, her friend Constance sits as Judge, and her friends Gabrielle and Josephine--watch. As do our Greek chorus.

The play was filmed in 1969, with Katharine Hepburn as Aurelia, Danny Kaye as the Ragpicker, Richard Chamberlain and Nanette Newman as the young lovers, and, stellar among a variety of great baddies, Yul Brynner and Donald Pleasance.

The film manages to maintain much of the atmosphere of the play, and, 24 years after the production, the joins to the contemporary world of 1969 are less seamless than in the original (though time has smoothed those joins a little). Hepburn is superb--at moments tragic, frail, and at other times slashingly contemptuous of the evil she has been forced to see. At one point, her smile and bearing were pure Jo March. It's a marvelous performance.

But so too is that of Danny Kaye. After charming the jury, wooing them, he shouts a brutally honest answer when Aurelia asks him what he'll do if given access to unlimited oil under lying Paris in this fable. Here's just a short clip, his furious finale as representative of the forces of heedless capital answering the question:

I've seen Kaye in a lot of films, but never this angry, never this powerful. It's a side of him that is astonishingly watchable.

The film abandons (probably wisely) the play's Greek Chorus ending, and instead ends as it begins, with another morning walk wit Aurelia. This time she discards her 1919 newspaper, signaling her readiness (after Chamberlain briefly assumes the role of her lost lover from her youth). It's a strange movie, and an extraordinary one. But it was a pleasure to watch this rendition of a parable, a story of the victory of good over evil. As the film's first title card reminds us, "It is, of course, a fantasy."

Thursday, November 22, 2018

"Love Changes Everything": A Meditation on a Forum

I won't try to expand on Buddy Stallings's recent sermon at St. Barts, or on the great exchange between Buddy and Dean Wolfe, our Rector, who graciously invited Buddy to return, and engaged him in a thought-provoking dialogue.

These are both great resources, and I will not pretend to add to them.

I will, however, touch on a few thoughts that being present for both raised in my own mind. So, if you've a mind to, tarry with the Anglocat for a bit. But don't miss Dean and Buddy.


Both in the sermon and in the forum, loving those with whom we disagree with, those who hurt us, was held up as the only cure for our divisive times. Neither Dean nor Buddy trivialized the sacrificial nature of such love, or denied the difficulty of loving those who hate us, torward whom we may feel a visceral anger--partially rooted, no doubt, in fear, fear that they will take away what we cherish. What is that "it" we fear losing? Safety, for many, simple physical safety, such as I, a middle class straight white male get to take for granted, almost all of the time (until I don't, that is. We all die, after all, and that includes me). Economic security, certainly. Others live lives that are far more menaced, far more in peril than do I, to the great shame of our society.

But to look at those across the divide, while they fear many of the the same things we do, the single greatest conservative concern seems to me to be a fear of the loss of Culture and Tradition--seeing these building blocks are seen by many as under siege, and that creates a different kind of fear. If you look at Rod Dreher's blog today, almost every post visible on the page relates to a fear of the loss of cultural hegemony, and a resulting extirpation at the hands of the militant left they so dread. I know, I know; the Right has the Presidency, the Judiciary, and, until January, both houses of Congress. But the fear is very real, nonetheless. Just read the posts.

How do we love across the divide?

Steven Moffat struggled with these very concerns in parable form in the last phase of his tenure on Doctor Who. As he wrote the Doctor, played by Peter Capaldi, the character underwent a character arc from a point where he described his companion Clara as his carer, adding "She cares so I don't have to," to his almost last words being "Hate is always foolish, and love is always wise." So I'm not ashamed to quote him. He offers the example of the show's definitive villain, trying to find a way back to her onetime friend:
DOCTOR: Nobody can have that power.
MISSY: You will, because you don't have a choice. There's only way you can stop these clouds from opening up and killing all your little pets down here. Conquer the universe, Mister President. Show a bad girl how it's done.
(Missy drops a deep curtsy. The Doctor rips the bracelet off.)
DOCTOR: Why are you doing this?
MISSY: I need you to know we're not so different. I need my friend back. Every battle, every war, every invasion. From now on, you decide the outcome. What's the matter, Mister President? Don't you trust yourself?


DOCTOR: Thank you. Thank you so much.
(He kisses Missy gently.)
DOCTOR: I really didn't know. I wasn't sure. You lose sight sometimes. Thank you! I am not a good man! I am not a bad man. I am not a hero. And I'm definitely not a president. And no, I'm not an officer. Do you know what I am? I am an idiot, with a box and a screwdriver. Just passing through, helping out, learning. I don't need an army. I never have, because I've got them. Always them. Because love, it's not an emotion. Love is a promise.
Two seasons later, Missy, without hope, without witness, without reward, will die trying to honor that promise.

Now, why did I inflict that sic-fi parable on you? Because we live in an age in which the culture of hatred in which we live has infected much of Christianity itself. If I simply refer you to the Gospels--with which this secular parable is absolutely consistent--if you are not an a Christian, or, worse, if you have encountered toxic Christianity, it may well be meaningless to you. And we need the non-Christians, not just the members of other faiths, either, because we aren't enough if we keep to our churchy enclaves.

Love is not an emotion; it's a promise. We aren't asked to not have feelings, but we are asked to not let those feelings corrupt us. We are asked--no, required, both by the Gospel, and by the torn and tearing fabric of the nation in which we live to forego the luxury of indulging the dubious (but very real) pleasures of self-righteous anger. And once again, I refer you to a non-religious source. Bernard Shaw, in his Nobel Prize-winning St. Joan, when the self-righteous Chaplain sees the burning of Joan, which he has egged on:
The Chaplain staggers in from the courtyard like a demented creature, his face streaming with tears, making the piteous sounds that Warwick has heard. He stumbles to the prisoner's stool, and throws himself upon it with heartrending sobs.

WARWICK [going to him and patting him on the shoulder] What is it, Master John? What is the matter?

THE CHAPLAIN [clutching at his hand] My lord, my lord: for Christ's sake pray for my wretched guilty soul.

WARWICK [soothing him] Yes, yes: of course I will. Calmly, gently--

THE CHAPLAIN [blubbering miserably] I am not a bad man, my lord.

WARWICK. No, no: not at all.

THE CHAPLAIN. I meant no harm. I did not know what it would be like.

WARWICK [hardening] Oh! You saw it, then?

THE CHAPLAIN. I did not know what I was doing. I am a hotheaded fool; and I shall be damned to all eternity for it.

WARWICK. Nonsense! Very distressing, no doubt; but it was not your doing.

THE CHAPLAIN [lamentably] I let them do it. If I had known, I would have torn her from their hands. You don't know: you havnt seen: it is so easy to talk when you dont know. You madden yourself with words: you damn yourself because it feels grand to throw oil on the flaming hell of your own temper. But when it is brought home to you; when you see the thing you have done; when it is blinding your eyes, stifling your nostrils, tearing your heart, then--then--
Then, of course it is too late.

So, concretely, what do we do? Not give in to anger and hate, yes. But try to meet people in circumstances that promote relationships, not degrade them. I'm a member of The Anthony Powell Society, and many fellow enthusiasts are not of my political or other beliefs, but we laugh at the same jokes in Powell's books, enjoy the same eccentricities in society. We become friends, and differences matter less. Same in Anglicanism. My devotions have been greatly enriched by The Anglican Breviary.

Know thy enemy. S/he might someday cease to be one.

A "Local Crime" Across Multiple State lines: The Peculiar Preference for FGM

In a decision that is causing shock waves in the media, a federal District Court has found unconstitutional on federalism grounds a statute banning female genital mutilation ("FGM"). (I am uncomfortably reminded of the Supreme Court’s prior blithe dismissal of of an admittedly meritorious death penalty appeal with the blithely bloodless opening line, “This is a case about federalism”)

The District Court decision and Ilya Somin’s defense of it do not, to my mind, bear close scrutiny.

The federal government put forward two arguments for the constitutionality of the statute: first, that the statute fell within the scope of Congress's power under the Commerce Clause, and, second, that the statute was enacted in fulfillment of the ratified treaty, the International Covenant on Civil and Political Rights. Tellingly, the District Court admits "that it may invalidate a federal statute “only upon a plain showing that Congress has exceeded its constitutional bounds, and that the lack of constitutional authority to pass the act in question must be clearly demonstrated.” (Decision at 3, citations and Court's quotation and editing marks omitted).

The Somin post, like the decision, is based on the assumption that FGM is, as the District Court held, a purely local, intrastate crime, a factual assumption belied by the very facts of the case before the court, in which several of the the victims were brought across state lines to undergo the procedure.

Somin acknowledges that the court “potentially misses a key point. To the extent that FGM targets almost exclusively girls rather than boys, and the practice is the result of ingrained sexism in the societies that engage in it, it seems likely that banning really does help ensure that girls get the "measures of protection" needed by minors on par with boys [under the International Covenant on Civil and Political Rights]. The connection between FGM and gender-based discrimination against girls is much stronger than Judge Friedman suggests.” But he falls back on the District Court's false description of FGM as a “purely local crime” to find the treaty doesn’t apply, again due to federalism. Critically, the opinion itself notes that “The government alleges that four of the victims are residents of Michigan, three are residents of Illinois, and two are residents of Minnesota,” so one can hardly see how the "purely local crime" rationale applies to the facts of this case.

Moreover, the court makes no findings as to whether the clinic or doctors accepted a fee for performing the FGM, which is kind of critical in an interstate commerce determination where the interstate nature of the transaction is clear as to 5 of the 9 victims.

It is true that the Rehnquist Court did radically rewrite federalism limitations, and, as Roberts is a Rehnquist protege, he could push to do so even more. But my position is pretty simple: even if the statute’s constitutionality doesn’t extend to “purely local crimes,” (that is, violations purely within the geographical boundaries of one state) the interstate dimension of the case at bar would render that argument inapt as to this case.

Under the Court's and Somin's logic, the long-standing, Supreme Court-affirmed Mann Act would be unconstitutional. The Supreme Court held to the contrary in 1914, and that decision remains good law today.

One can hope that this decision is reversed, as it should be, under long-standing Supreme Court precedent, but if we've learned one thing about the Roberts Court, it's that consistency and stability in the law are not afforded a high value in its stochastic holdings.