The Naming of the Triple Crown

By Bennett Liebman
Government Lawyer in Residence[1]

Now that American Pharoah has won the Triple Crown, it is time to try to make some better sense of how the Kentucky Derby, Preakness Stakes, and the Belmont Stakes became known as the Triple Crown races. There is a conventional wisdom view concerning the naming of the Triple Crown by racing writer Charles Hatton. While there will always be uncertainty as to the phrase’s origin, there is one thing that should be very clear. The conventional wisdom on the origin of the phrase is wrong.

The Conventional Wisdom and Charles Hatton

The conventional wisdom on the Triple Crown can be simply stated. Charles Hatton, a longtime writer and columnist for the Daily Racing Form, is said to have originated the term in the 1930’s.  Hatton had started writing for the Daily Racing Form and its companion paper the Morning Telegraph in the early 1930’s. When he died in 1975 at age 69, his obituary in Newsday read, “Hatton coined the term Triple Crown in referring to the Kentucky Derby, Preakness, and Belmont Stakes.”[2] The New York Times wrote that Hatton “was credited with coining the term ‘Triple Crown.’”[3]  The credit given to Hatton for originating the term continues to this day.[4] As has been stated, “Hatton is the man who invented the American Triple Crown.”[5]

The Varied Stories on How Hatton Originated the Triple Crown

A good part of the problem involving crediting Hatton with the creation of the phrase “Triple Crown” centers on the fact that there is no clear timeline on when he created the phrase.[6] The most likely date for Hatton’s first involvement is 1935, when Omaha became the third Triple Crown winner.[7]

Nonetheless, there are claims that the Hatton term dates from 1930, 1941, and even generally sometime in the 1930’s. Some of the writers who have written on this subject have themselves used a variety of dates in describing the timing of Hatton’s creation. Hatton himself mentioned the 1930’s in general, but seemed to focus on the year 1935. The other problem in determining the date of origin of the term is that nobody in the general media seemed to give credit to Hatton for devising the phrase until the 1960’s.

The principal evidence for the 1935 date comes from Hatton himself. In an interview with Chicago Tribune racing columnist Neil Milbert, Hatton said, “I found it journalistically clumsy to keep referring to these races by name. And I had always felt that we should have a Triple Crown as they did in England. . . .  So I took those three races and called them the Triple Crown. It got me off the composition hook and before long it came to mean something to other writers and ultimately to people in racing.”[8] Hatton added, “So I just decided on the three in the spring. The terminology seemed to catch on in 1935 when Omaha won all three. In those days, I had the good fortune of being the only nationally syndicated racing columnist so I had a captive audience. There was nobody to get up and say ‘This is a lot of nonsense.’”[9]

Support for the 1935 date also comes from Newsday columnist Ed Comerford. In 1969, Comerford wrote that the phrase “was borrowed from a series of English races in 1935 by Charles Hatton.” Don Clippinger, writing for the Philadelphia Inquirer, wrote in 1985, “Racing historians have traced the first reference to the Triple Crown to Charles Hatton, chief columnist for the Daily Racing Form. The year was 1935, when Omaha won the derby, the Preakness and the Belmont Stakes.”[11] Finally, Peter Chew used the 1935 date in his book, “The Kentucky Derby: The First 100 Years.”[12]

Many sportswriters have used the 1930 date. This may be due, in part, to the fact that the Kentucky Derby Media Guide cites 1930 as the date that Hatton invented the term.[13] The writers using the 1930 date have included Andrew Beyer,[14] Neil Milbert,[15] John Eisenberg,[16] Bob Summers,[17] Bill Finley,[18] John Jeremiah Sullivan,[19] John Pricci,[20] Steve Davidowitz,[21] Frederick Klein,[22] Ed Schuyler,[23] Mal Florence,[24] and Dave Joseph.[25] Steven Crist at the New York Times wrote, “After Gallant Fox won the Kentucky Derby, the Preakness and the Belmont Stakes in 1930, the Daily Racing Form columnist Charles Hatton dubbed the victories a ‘Triple Crown.’”[26] Bill Christine at the Los Angeles Times has written, “It wasn’t until 1930 that Charles Hatton, searching for a catch phrase to blanket the three races in his Daily Racing Form columns, came up with ‛Triple Crown.’”[27] Even the magazine Baseball Digest has suggested that Hatton coined the term in 1930.[28]

The 1941 date draws its support from certain sports columnists. In 1961, longtime turf columnist John I. Day wrote that it “wasn’t until 1941 when Calumet Farm’s longtailed hero, Whirlawayturned the trick that Charles Hatton, writing in the Daily Racing Form, dubbed it the Triple Crown.”[29] Seymour Smith at the Baltimore Sun wrote that the victories of Whirlaway in 1941 ‟inspired Charlie Hatton a writer for the Daily Racing Form to coin the phrase ‛The Triple Crown.’”[30] Jerry Nason at the Boston Globe wrote that it wasn’t until 1941 when, inspired by Whirlaway’s wins, that Hatton coined the phrase “Triple Crown.”[31] Andrew Beyer noted that when Whirlaway completed a sweep in 1941, he was the first horse universally hailed as a Triple Crown winner.”[32]

The generic 1930’s date has received support from some sportswriters. Dick Jerardi of the Philadelphia Inquirer said that Hatton came up with the phrase in the 1930’s.[33] Also using a general 1930’s date was Ed McNamara of Newsday,[34] Reid Cherner of USA Today,[35] Bill Christine[37] Steven Crist, who had earlier utilized the 1930 date, wrote to “credit Charles Hatton, a Daily Racing Form columnist, with popularizing it. It was in common usage by the time Gallant Fox’s son Omaha became the third Triple Crown winner in 1935.”[38]

The Hatton Skeptics

A selected number of writers have been skeptical of the claim that Charles Hatton was the sole creator of the Triple Crown phrase.

Some have suggested that Bryan Field[39] of the New York Times deserves his share of the credit for devising the term. Among these writers was Bill Nack, who gave joint credit to both Field and Hatton for naming the Triple Crown. [40]

Other writers have credited Field rather than Hatton with the creation of the term. Gerald Strine of the Washington Post found that Field had used the term in June of 1930 before Hatton.[41] So did Dale Austin at the Baltimore Sun[42] and Mike Kane at the Louisville Courier-Journal.[43] Kane reviewed the New York Times and the Daily Racing Form from 1930 and found that Field’s use of the term antedated any mention of that term that year in the Daily Racing Form.

The “Triple Crown” in the 1920’s

So what does the record show for the creation of the phrase, Triple Crown? There were actually sporadic references to the Triple Crown of the Kentucky Derby, Preakness and Belmont in the 1920’s, well before Charles Hatton began working for the Daily Racing Form. But while there were references to the Triple Crown as we know it, there was no regularity to these references.

The New York Times first used the term “Triple Crown” to describe the Derby, Preakness, and Belmont in 1923 at a time when Hatton was at most 17 years old. The Times, in a year where the Preakness preceded the Derby, wrote, “Thomas J. Healey had Walter J. Salmon’s Preakness winner, Vigil, and his owner wired today that he would be here [Louisville] Friday to see his colt try to capture his second classic in the triple crown of the American turf.”[44]

The turf writer Peter Burnaugh also referred to the Triple Crown in an article in 1923. Burnaugh was a significant turf writer who unfortunately died at the age of 35 in 1927. He was a prolific writer and covered horse racing for a variety of newspapers in New York City in the 1920’s. Burnaugh wrote, “The record of Sir Barton, therefore, stands alone as an American “Triple Crown” winner, he having captured all three events.”[45] Nonetheless, Burnaugh later in the same year, in praising the race record of Zev, claimed that Zev has beaten older handicap stars in three of his stakes, and he has won the American “triple crown”–the Derby, the Belmont Stakes and the Realization.[46]

W. C. Vreeland, the turf writer for the Brooklyn Eagle, in 1924 stated in passing in an article, “But the triple crown, as our English cousins would say, of the American turf is comprised of the Preakness, the Kentucky Derby and the Belmont.”[47]

The Associated Press even made mention of the Triple Crown in 1927, stating that Sir Barton was the only three-year-old to win the “triple crown” in America.[48] Similarly, the Daily Racing Form did mention the Triple Crown in 1927. The paper stated, “The Belmont, Kentucky Derby and Preakness could readily be considered the triple crown for three-year-olds in this country.”[49] The article concluded by stating that “the fact remains that Sir Barton stands alone as winner of a Belmont, Kentucky Derby and Preakness and in all of his racing career he proved himself one of the great American thoroughbreds.”[50]

Writer J. B. Snodgrass in the New York Post mentioned the three races and the Triple Crown in an article in 1928, but he forgot that Sir Barton had won the crown. He wrote, “It will probably never be the good fortune of one horse to win the triple crown of America—the Preakness, the Kentucky Derby and |the Belmont—but as Sir Barton won the Preakness and the Derby, so it is entirely within the reach of Reigh Count to win the Derby and the Belmont.”[51]

Along Comes Gallant Fox

The success of Gallant Fox in winning the Derby, Preakness and Belmont in 1930 brought forth the first consistent use of the term Triple Crown in America. The principal user of the term “Triple Crown” was the New York Times and its turf writer, Bryan Field.

When Gallant Fox won the Belmont, the New York Times headline proclaimed, “Woodward’s Preakness Derby winner ties Sir Barton as Triple Crown hero.”[52] Jockey Earl Sande “gave all the credit to his mount which by winning the Preakness, Kentucky Derby, and Belmont had equaled the feat of Sir Barton. These two horses are the only ones to win the ‘triple crown.’”[53] In a separate article accompanying the story of the win of Gallant Fox in the Belmont, the New York Times (most assuredly through Field) wrote, “In America, the idea of the Triple Crown being duplicated came when the Preakness, the Kentucky Derby, and the Belmont Stakes reached such prominence as to overshadow all other Spring 3-year-old events in this country. And as in England, to win the Triple Crown in America carries with it the utmost that can be won on our race courses.”[54]

Later in the year, after the decision was made to retire Gallant Fox after his victory in the Jockey Club Gold Cup, Field again referred to the Triple Crown. He wrote, “He is the second horse to win the Triple Crown of the Preakness, Kentucky Derby and Belmont Stakes.”[55]

Finally, the sports editor of the New York Times in summarizing the sports season noted that Gallant Fox was the “second American Triple Crown winner.” Thus, the New York Times cited the American Triple Crown four times in 1930.[57]

After the Times’ reference to the Triple Crown, other newspapers began referring to the crown. On the Monday after Gallant Fox’s win in the Belmont Stakes, J. B. Snodgrass in the New York Post wrote, “The “Triple Crown” championship for 1930 three-year-olds fell as lightly and gracefully on William Woodward’s Gallant Fox Saturday as this combined honor that goes with victories in the Preakness, the Kentucky Derby and the Belmont Stakes ever descended on a horse after a race in which there was the semblance of a contest.[58] The Atlanta Constitution referred to Gallant Fox as the “triple crown winner of the Preakness, Kentucky Derby and Belmont Stakes.”[59] The Buffalo Courier-Express noted that “Gallant Fox completed his triple crown in the Belmont Stakes.”[60]

In the summer of 1930, in what is likely to have been a wire service article, numerous newspapers wrote, “Gallant Fox and Sir Barton are the only thoroughbreds to win the triple crown in the United States, an honor signifying championships in the Kentucky Derby, the Preakness and the Belmont Stakes.”[61]

Easily the longest, and perhaps the most significant, reference to the Triple Crown came in an article at the conclusion of the New York racing season which ran under the byline of “Sunny Jim” Fitzsimmons, the trainer of Gallant Fox. In the three-page article, he referred to the Preakness, Kentucky Derby and Belmont Stakes and wrote, “Those great stakes make up the ‘Triple Crown’ of American racing.”[62] The subtitle of the article adds that Gallant Fox was the first horse to win the ‘Triple Crown’ of racing since 1919.”

The Daily Racing Form’s Past Performances on the “Triple Crown”

With the New York Times, and significant parts of the media referring to the Triple Crown in 1930, what was happening with the Daily Racing Form’s coverage of the Triple Crown? Thanks to the digitalization of many of the back issues of the Racing Form,[63] it is possible to review the Form’s coverage of the spring classic races in the 1930’s.[64] For the spring of 1930, the digitization includes the entire months of April, May and June.

The sole mention of the Triple Crown and Gallant Fox in the Daily Racing Form in these months found merely that the blood of English Triple Crown winner Gay Crusader was in Gallant Knight, who finished second in the Kentucky Derby in 1930.[65]

Nor was there much mention of the Triple Crown in the Daily Racing Form in 1931. In an article regarding the Preakness, the Form mentioned that one of the Preakness winners was “Sir Barton, winner of the ‘triple crown,’ the Preakness, Kentucky Derby, and Belmont.”[66] After the Triple Crown races had been run, the Racing Form suggested that bad racing luck prevented Twenty Grand “from winning the triple crown.”[67] So there is no record of the Daily Racing Form or Charles Hatton coining the phrase “Triple Crown” in 1930, and the phrase was barely utilized in the Racing Form in the subsequent 1931 racing season.

There is support for the notion that the Daily Racing Form helped popularize the Triple crown in 1935. Nine articles in the Racing Form from May and June of 1935 mentioned Triple Crown in the same article as Omaha, who won the three classic races in 1935.[68] Accordingly, while there is no basis for finding that Charles Hatton created or coined the phrase Triple Crown, he may have played a role in popularizing the phrase. On the other hand, the phrase Triple Crown was used in 1935 in many of the major newspapers in the country, including the New York Times, the Herald Tribune, the Chicago Tribune and the Associated Press. it is not possible to determine whether Hatton’s use of the phrase caused other media outlets to use the phrase.

There is obviously no basis in finding that the term Triple Crown originated in 1941. This claim is predicated on the notion that the term Triple Crown was not in general usage when War Admiral won the Triple Crown races in 1937.[69] That was not the case. The term was used in 1937 by, at a minimum, the Associated Press, United Press, Boston Globe, Los Angeles Times, Chicago Tribune, New York Times, New York Herald Tribune, Baltimore Sun, and Washington Post.

The Verdict on the “Triple Crown”

Despite the conventional wisdom on Charles Hatton’s coinage of the phrase “Triple Crown” for the Daily Racing Form, the record supporting this hypothesis rests more on legend than on reality.

What can be deduced about the Triple Crown naming is the following:

  1. The term was used sporadically in the 1920’s.
  2. It was first regularly used by Bryan Field of the New York Times in 1930.
  3. Bryan Field’s use of the term antedates any possible use of the term by Charles Hatton.
  4. Charles Hatton/Daily Racing Form did not begin to regularly use the “Triple Crown” terminology in 1935.
  5. The Hatton/Daily Racing Form use of the term arguably may have contributed to the term’s popular usage.
  6. The term was in regular use by the media in the mid 1930’s; there is no support for the notion that the term was originated in 1941.

Nonetheless, the story of Charles Hatton’s coining of the “Triple Crown” is now enshrined in racing folklore. It may just be that this story cannot be countered by factual data. It has become much like the famous saying in the 1962 John Ford movie, The Man Who Shot Liberty Valence: “When the legend becomes fact, print the legend.” The legend of Charles Hatton and the Triple Crown seems secure.

[1] More than a decade ago, I had explored this issue for Albany Law School in Bennett Liebman“Where Did the “Triple Crown” Come From?” http://www.albanylaw.edu/media/user/glc/racing_gaming/wheredidthetriplecrowncomefrom.pdf.

[2] Obituaries, Newsday, March 15, 1973. See also “Charles Hatton Dies, Associated Press, Hartford Courant, March 16, 1975.

[3] “Charles Hatton, 69, A Racing Columnist,” New York Times, March 16, 1975. Hatton was a well-regarded writer. Red Smith, the Pulitzer Prize-winning columnist said, “Charley Hatton is one of the last of the old-time, graceful sportswriters. I love it when he writes that a horse won a race con brio.” Frederick C. Klein, “Bettor’s Bible,” Wall Street Journal, June 28, 1974.

[4] Stu Whitney, “South Dakota’s Triple Crown Connection,” Argus Leader, June 4, 2015; Deidre Schipani, “Interesting Things to Imbibe Around Town,” Charleston Post & Courier, May 6, 2015.

[5] Neil Milbert, “Triple Crown: An Idea for All Time,” Chicago Tribune, June 7, 1989.

[6] This problem is heightened by the lack of a Hatton byline at the Daily Racing Form until the 1940’s, when he started writing “The Judge’s Stand” column for the Daily Racing Form.

[7] Sir Barton had won the three races in 1919, and Gallant Fox had won the races in 1930.

[8] Neil Milbert, “Here’s How Racing’s Triple Crown Got Its Name in ‘30s,” Chicago Tribune, June 9, 1973.

[9] Id.

[10] Ed Comerford, “Horseracing’s Triple Crown Needs Polish,” Newsday, June 18, 1969.

[11] Don Clippinger, “Triple Crown May Be Losing Its Luster,”false Philadelphia Inquirer, May 12, 1985.

[12] Mike Kane, “Triple Crown; 10 Things to Know,” Louisville Courier-Journal, June 7, 2014.

[13] See http://www.kentuckyderby.com/media/reference.

[14] “Sir Barton,” Washington Post, June 7, 2008, quoting Beyer comments.

[15] Neil Milbert, “Preakness’ New Blood,” Chicago Tribune, May 14, 2008.

[16] John Eisenberg, “The ‘Lost’ Preaknesses,” Baltimore Sun, May 20, 2006.

[17] Robert Summers, “Belmont Park: The Cathedral of American Horse Racing,” Buffalo News, June 11, 2005.

[18] Bill Finley, “Belmont at 100,” New York Times, May 1, 2005.

[19] John Jeremiah Sullivan, “Fast Track to Oblivion,” New York Times, May 15, 2004.

[20] John Pricci, “Grand Slam Might Be Hit,” Newsday, June 1, 1986.

[21] Steve Davidowitz, “Secretariat’s Death Leaves Void,” Minneapolis Star Tribune, October 4, 1989.

[22] Frederick C. Klein, “Time to Retire the Triple Crown?,” falseWall Street Journal, June 8, 1998.

[23] Ed Schuyler, Jr., “Plenty of Tragedy and Success for 1900’s Horse Racing,” Associated Press, Los Angeles Times, January 2, 2000.

[24] Mal Florence “The Inside Track; Morning Briefing; Move Over, Raiders, Here Come the Ravens,”false Los Angeles Times, January 31, 2001.

[25] Dave Joseph, “Time Cannot Diminish the Crown’s Jewels,” Fort Lauderdale Sun Sentinel, June 9, 1989.

[26] Steven Crist, “A Rigorous Challenge for 3-Year-Olds,” New York Times, June 6, 1981. See to the same effect, S. Lee Kanner, “Question Box,” New York Times, July 20, 1981.

[27] Bill Christine, “Crowning Glory,” Los Angeles Times, June 4, 1997.

[28] “The Fans Speak Out,” Baseball Digest, September 1, 2007.

[29] John I. Day, “Off and Running, ‘First’ Triple Crown Winner,” Schenectady Gazette, July 13, 1961. Day used the 1941 date in other columns, including “English Are More Patient,” Amsterdam Recorder, September 9, 1969.

[30] Seymour S. Smith, “Nine Have Won the Triple Crown,” Baltimore Sun, June 6, 1977.  See also Seymour S. Smith, “First Triple Crown Winner Recalled as Derby Day Nears,” Baltimore Sun, May 4, 1977; Smith subsequently wrote that Hatton had devised the phrase in 1935. Seymour S. Smith, “Triple Crown Excitement Grows for Belmont Stakes,” Baltimore Sun, June 4, 1981.

[31] Jerry Nason, “Sir Barton Won Triple Before it Was Big Deal, “Boston Globe, June 3, 1973.

[32] Andrew Beyer, “Will History Repeat Itself?,”false Washington Post, June 2, 2003.

[33] Dick Jerardi, “Behind the Triple Crown Drought,” Philadelphia Inquirer, June 6, 2012.

[34] “Triple Crown Winners,” Newsday, June 3, 2004.

[35] Reid Cherner, “Belmont Bound; Alysheba – Mile and Half from History,” USA Today, May 18, 1987.

[36] Bill Christine, “Sir Barton / 1919: First Triple Crown Winner,” Los Angeles Times, May 27, 1998.

[37] Jennie Rees, “The Belmont Stakes; An Empire Breaker,” Louisville Courier-Journal, June 8, 2003.

[38] Steven Crist, “The Triple Crown; The Kings of the Sport,” New York Times, April 28, 1986.

[39] Field, who died in 1968, was a major part of the horse racing industry. He was the racing reporter for the New York Times for more than a decade, a race caller at the New York tracks, a national television and radio announcer of horse racing for decades, and the general manager of Delaware Park Racetrack. Given his prominent and very public positions in horse racing, it is surprising that Field has taken a back seat to Charles Hatton, a columnist for a trade publication, in the “Triple Crown” controversy. See “Bryan Field, Turf Official, Dies at 68, “New York Times, December 15, 1968; Red Smith, “Bryan Field Remodeled Race Tracks for People,” Boston Globe, December 19, 1968.

[40] Bill Nack, “100th Running of Preakness Is Wide Open,” Newsday, May 15, 1975.

[41] Gerald Strine, “Some Day Somebody May Straighten Out Preakness Story,” Washington Post, May 13, 1975.

[42] Dale Austin, “Sunday Silence–the 12th Triple Crown?” Baltimore Sun, June 6, 1989. Austin referred to the same book on the Preakness as Gerald Strine had 14 years earlier at note 41. The book is Joseph J. Challmes, The Preakness: A History, Anaconda Publications (1975).

[43] Kane, supra at note 12.

[44] “Horses From East Arrive for Derby,” New York Times, May 15, 1923. There is a possibility that Bryan Field could have been responsible for this article. He worked for the Times from 1923-1944.

[45] Peter Burnaugh, “Zev, 3-Year-Old Champion, Ninth Among Turf Winners,” New York Evening Telegram, June 10, 1923.

[46] Peter Burnaugh, “Selection Of Zev Was Public’s Wish,” New York Evening Telegraph, October 6, 1923. The Morning Telegraph in 1922 referred to the Withers, the Belmont Stakes, and the Lawrence Realization as corresponding to the British Triple Crown. “Belmont Park To Have Great Day,” Morning Telegraph, June 4, 1922.

[47] W. C. Vreeland, “Where, Oh, Where, Are the Champion Race Horses 4, 3 and 2 Years Old?” Brooklyn Eagle, June 2, 1924.

[48] “Sir Barton Only Horse To Win ‘Triple Crown,’” Associated Press, Washington Post, May 8, 1927.

[49] “Here and There on the Turf,” Daily Racing Form, April 1, 1927.

[50] Id.

[51] J. B. Snodgrass, “Best 3-Year-Olds Meet in Belmont,” New York Post, May 28, 1928.

[52] Bryan Field, “Gallant Fox Beats Whichone 4 Lengths in $81,340 Belmont,” New York Times, June 8, 1930.

[53] Id.

[54] “English Turf Origin of the Triple Crown,” New York Times, June 8, 1930.

[55] Bryan Field, “Woodward Retires Noted Gallant Fox,New York Times, October 7, 1930.

[56] B. St. D. Thompson, “Season in Sports: Champions Three, a Man, a Boat and a Horse,” New York Times, October 12, 1930.

[57] Additionally, the New York Times’ featured sports columnist John Kieran referred to the focus on “Gallant Fox the Preakness, the Kentucky Derby and the Belmont Stakes” in a column on the 1899 English Triple Crown champion, Flying Fox. John Kieran, “Sports of the Times,” New York Times, June 6, 1930.

[58] J. B. Snodgrass, “Earl Sande Likely to Carry Gallant Fox to New Mark,” New York Post, June 19, 1930.

[59] George Daley, “Gallant Fox Seen as Easy Winner in Dwyer Stakes,” Atlanta Constitution, June 22, 1930.

[60] “Sport Day by Day,” Buffalo Courier-Express, June 13, 1930.

[61] See, e.g., “Just Two of Them,” Elmira Star-Gazette, July 24, 1930; Cortland Standard, July 26, 1930; “Just Two of Them,” Niagara Falls Gazette, August 4, 1930.

[62] James Fitzsimmons, “Gallant Fox—King of the Turf,” New York Herald Tribune, November 2, 1930.

[63] See http://athena.uky.edu/drf/.

[64] While the Racing Form’s archiving project is far from complete, there is considerable coverage in the 1930’s of the editions involving the Kentucky Derby, Preakness, and the Belmont Stakes. The available public archive generally covers the full editions during the period of the Triple Crown each year.

[65] “From Breeding Viewpoint,” Daily Racing Form, May 21, 1930.

[66] “Revive Preakness in 1909,” Daily Racing Form, May 4, 1931.

[67] “Twenty Grand May Start in Latonia Derby,” Daily Racing Form, June 22, 1931.

[68] The fact that Omaha was sired by prior Triple Crown winner Gallant Fox also provided an additional basis for using the phrase.

[69] See Austin supra at note 42.

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