Paradox of Self-Amendment by Peter Suber Liar's lie. But in law, the reversals only go as far as the human judges and jurors care to take them. The jury's verdict is stable, and appellate court's judgment is stable and, after a point, appeals come to an end. Jones has never been cited by another case or by commentators, as far as I or Lexis knows.[Note 8] C. Self-referring laws Self-reference is common in statutes and legal instruments such as contracts, wills, and treaties. Here is a small list of perfectly harmless examples to show that self-reference per se does not create paradox, incoherence, or meaninglessness. C.1. Statutes, constitutions, and legal instruments may contain language that explicitly refers to the section or whole of which it is a part, e.g. "Nothing herein shall be construed to prohibit...", "This statute shall be prominently displayed in every hotel room...", " Violation of this treaty shall be referred to arbitration..." C.2. Laws may apply to themselves without necessarily referring to themselves, e.g. the provisions in a state code on how the code is to be interpreted, any constitutional or contractual amending clause, and the entire Vienna Convention on the Law of Treaties (the "Treaty on Treaties"). C.3. Legal powers may apply to themselves to limit or augment themselves or their users, e.g. a parliament's power to bind itself and future parliaments by a present decision, a sovereign state's power to bind itself by a treaty or contract, a President's power to pardon himself, a legislature's power to delegate legislative power, a contract's power to declare its own integration, a majority's power to establish majority rule, a court's jurisdiction to declare the boundaries of its own jurisdiction. C.4. Statutes or sections of statutes may be caught in a circle of mutual reference, e.g. A refers to B and B to A, but neither refers to itself. This may lead the human researcher on a circuitous path, but an irreflexive rule of conduct or procedure may be articulated by the rules. The references may form a circle of any size: A refers to B, B to C, ..., Z to n, and n to A. Albert Einstein was probably referring to this phenomenon when he said that the United States Internal Revenue Code was more difficult to understand than the universe. Many complex statutes contain sections that do nothing but define terms. These sections implicitly refer the reader to dictionaries for the undefined terms used in the definitions, thus putting one indirectly on a very large circuitous path.[Note 9] C.5. Statutes may as a group inadvertently create vicious circles, e.g. circular liens (see Section 20.E, below) C.6. Self-reference in language outside law may lead to legal difficulties, e.g. Abbie Hoffman's book, Steal This Book, which was frequently stolen. D. The liar The best known reflexivity paradox is the Liar: "This statement is false." The statement is true if false, and false if true. Some variations occur in legal settings.[Note 10] The most direct is the "imperative liar": "Do not obey this law". Alf Ross discusses this variation briefly.[Note 11] In Section 14 I showed the sense in which sunset clauses in statutes and constitutions might be construed to say, after the expiration of the clause, "this law is no longer valid". The 16th century French courts had to decide how to interpret the testimony of women accused of being witches. According to the prevailing theology, witches were under the control of the devil, and consequently they either always lied or frequently lied. If they always lied, clever interrogation could disclose the truth. If they only lied sometimes, but with devilish ingenuity, then the truth could be hidden forever.[Note 12] When Urbain Grandier was on trial for invoking the receiving the aid of the devil, his judges had to obtain a ruling from Sorbonne theologians on the reliability of testimony given under oath by one who might be possessed by the devil.[Note 13] More recently, Melvin Weinberg, the swindler hired by the F.B.I. to devise the "Abscam" sting of members of Congress who accepted bribes, testified under oath that, yes, he did once say that he was the world's biggest liar, but at the time he had been lying.[Note 14] E. Circular liens and liabilities Cases often arise in which an estate or fund must be distributed among claimants when A's claim takes priority over B's, B's takes priority over C's, and C's takes priority over A's. The problem takes several, subtly different forms that have received inconsistent treatment from courts. This type of circularity has a surprisingly large literature.[Note 15] A similar problem arises when an insurance policy declares itself inapplicable to injuries or losses that are covered by other policies. If an injured person has two or more policies that each contain such provisions, then each would become inapplicable. But as soon as they were inapplicable, they would each trigger the other's applicability again, and so on. The policy-holder would either be entitled to nothing or to benefits from at least one policy, to be determined by an unending and indeterminable oscillation of liability. 134