SOURCE: “Female Heroism and Legal Discourse in Lady Mary Wortley Montagu's ‘Epistle from Mrs. Y[onge] to Her Husband’,” in ELH, Vol. XXXIV, No. 4, June 1997, pp. 10-22.

[In this essay, Snyder maintains that in “Epistle from Mrs. Y[onge] to Her Husband” Montagu defines an “alternative heroine” by “subtly manipulating the meanings of various forms of the legal term ‘submission’ until they characterize a speaker who possesses a powerful and authoritative, and thus traditionally masculine, capacity for judgment.”]

In the January 24, 1738 edition of her political journal The Nonsense of Common-Sense, Lady Mary Wortley Montagu insists that people of all ranks in society, and of both sexes, must be judged, and more importantly, must judge themselves, not according to their gender or social rank, but to their merit. For Lady Mary, this active self-reflection characterizes a new heroic ideal for both women and men. She qualifies the ideal for women, however, even as she insists that women may behave as heroically as men. Women are especially heroic, she argues, because they spend their lives yielding to male authority. In their very “submission” to male power, they may, in fact, be paragons who possess a virtue as great as that of Cato or Socrates:

… as much greatness of Mind may be shewn in submission as in command, and some Women have suffer'd a Life of Hardships with as much Philosophy as Cato travers'd the Desarts of Affrica. … [But a woman's] virtue must only shine to her own recollection, and loses that name when it is ostentatiously expos'd to the World. …¹

In this essay, however, Lady Mary speaks through a male persona and praises a woman who “submits” in the conventional sense, a woman “who has perform'd her Duty as a Daughter, a Wife, and a Mother” without questioning the grounds of such submission, and who indeed may “shine” only in the context of that submission.² Lady Mary would seem to agree with Clarissa in Pope's The Rape of the Lock that a certain heroism resides in the good-humored acceptance of one's lot in such a situation.³ In a poem written fourteen years earlier, however, the “Epistle from Mrs. Y[onge] to her Husband,” Lady Mary expands upon this publicly acceptable definition of female heroism.⁴ The poem's speaker, Mrs. Yonge, certainly does not perform her proper duty by good-naturedly “submitting” to her husband, yet she is the protagonist of a heroic epistle anyway; she is a “heroine.” And Lady Mary defines this alternative heroine within the poem by subtly manipulating the meanings of various forms of the legal term “submission” until they characterize a speaker who possesses a powerful and authoritative, and thus traditionally masculine, capacity for judgment.

The “Epistle” is based upon a contemporary scandal. In 1724, William Yonge, an infamous rake and adulterer who was legally separated from his wife, hired spies to obtain evidence that Mrs. Yonge, too, was committing adultery. He then sued her lover for damages in the Court of Common Pleas. He eventually succeeded in having both houses of Parliament debate and pass a Bill of divorcement. As a result, Mrs. Yonge was publicly disgraced and forced to cede her entire dowry and a large part of her fortune to her husband, except for a comparatively small yearly allowance.⁵ According to a contemporary newspaper account, during the debate in Parliament, when the Comptroller asked whether Mrs. Yonge “had consented to the said Allowance,” a Mr. Onslow replied:

that her Consent was not material. … That since she had forfeited all by Law, the taking away half of her Fortune, was not sufficient Satisfaction for her Husband's Sufferings and that, as to her Allowance, since she had not thought fit to oppose the Bill in either House, her Silence gave Consent.⁶

In her poem, Lady Mary gives a voice to the silent Mary Yonge, constructing her as a speaking subject who argues that women's silence implies not consent but forced submission to a conventional ideal of courtship and marriage that has been codified in custom and law. Lady Mary transforms Mrs. Yonge into an active judge of herself and of those by whom she has been judged. In contrast to the progress of the actual case in court and Parliament, in the “Epistle,” Mrs. Yonge assumes control of the interpretation of her own narrative.⁷ The poem implies that such an active self-assessment and self-interpretation constitute the criteria that qualify Mrs. Yonge as a “heroine.”

Lady Mary grants Mrs. Yonge such judgmental authority by manipulating contemporary English legal discourse for her own purposes. By the early eighteenth century, legal discourse had come to be characterized by certain shared assumptions about both the reliability of evidence and the credibility of witnesses in a court of law.⁸ This discourse differentiated the “credible,” or disinterested, from the merely “lawful,” or interested, witness, and jurors who were considering the evidence presented by each were told to place more weight upon that of the disinterested witness. The most “reliable witness[es]” and jurors were imagined to follow “the Baconian model of observation,” which “depended on empirical evidence and elevated personal experience and testimony above hearsay and opinion.” They were expected to value reason and fact above custom and gossip.⁹ A judge, too, was expected to be impartial, a “detached seeker of truth.”¹⁰ At the same time, part of the role of both a judge and a prosecutor (defense counsel were not allowed to argue to thejury until later in the century) was to summarize and interpret the evidence. And such a witness, impartial judge, and skilled interpreter was implicitly understood to be male.¹¹

Yet because Mrs. Yonge's case was literally played out in various courtrooms, it is natural for this female speaker to employ legal discourse to defend herself. Further, as Clare Brant has noted in a discussion of eighteenth-century women's autobiography, despite the close identification of legal discourse with male subjectivity, such “discourse seemed to provide subject positions less assailable by scandal.” When women employed such as idiom in a written defense, their “charges against socially more powerful men could win conviction in texts as they could not in courts.”¹² Lady Mary employs a similar tactic in her epistle. She empowers her speaker to act as credible witness and believable lawyer on her own behalf, and as a discerning judge of both her own behavior and that of her husband, by reversing both conventional generic and traditional social assumptions.She simultaneously depends upon and manipulates conventional expectations about the character of the female speaker in an heroic epistle. That reinvented speaker in turn challenges conventionally accepted standards within legal discourse, particularly those associated with “submission,” to influence a jury of readers to convict Mr. Yonge and to exonerate her.¹³ By manipulating the meaning of “submission,” the speaker ultimately feminizes her husband, and he becomes the one who, according to his own standards, deserves to be judged censoriously and who must in turn “submit” to his wife's judgment.

Lady Mary first questions contemporary formulations of the masculinely-gendered judging subject by challenging the generic conventions of the Ovidian heroic epistle, a strategy which allows her to redefine the criteria that characterize female heroism. Seventeenth-and eighteenth-century readers, as Jane Spencer argues, “associated women's writing with a heroine's writing” because many of the well-known female “voices” in literature (in the Heroides, and other works in epistolary form) were “the voice[s] of the heroine of a love-story.”¹⁴ Indeed, the term “heroine,” as Lawrence Lipking has noted, “derives from Ovid's Heroides.”¹⁵ By choosing to tell Mrs. Yonge's story in an epistolary genre, then, Lady Mary is assured that her readers will readily assume that her protagonist is a “heroine.” She is then free to recast the conventions of the genre to create new heroic criteria.¹⁶

Lady Mary greatly admired Ovid's works; her reading of the Metamorphoses as a teenager inspired her to teach herself Latin, and she wrote a number of juvenile imitations of Ovidian epistles.¹⁷ In the “Epistle from Mrs. Y[onge],” however, she diverges from Ovidian tradition in both subject matter and rhetoric. Most seventeenth- and early eighteenth-century heroic epistles, following Ovid's model, tend to be concerned with the loves of mythological or historical figures. The subjects of Michael Drayton's Englands Heroicall Epistles (1619), for example, are famed aristocratic figures in English history, and six of the epistles in David Crauford's Ovidius Britannicus (1703) concern “Persons of Quality.”¹⁸ The subjects of Pope's Eloisa to Abelard, too, would be well-known to an eighteenth-century reading audience. The protagonist of the “Epistle from Mrs. Y[onge]” also would be well-known, even notorious, but not because she was an aristocrat or historical figure. Rather, like the heroines of many popular biographies, she was known for her sexual transgressions; the Yonges' divorce and Mrs. Yonge's adultery were the subject of much gossip and newspaper reporting.¹⁹

Further, the goals of Lady Mary's speaker differ from those of traditional Ovidian heroines. Gillian Beer has noted that the speaker-heroines of heroic epistles “are capable of excoriating analysis of their own needs and those of their longed-for lovers.”²⁰ Mrs. Yonge may analyze her own needs and those of her husband, but that husband is certainly not a longed-for lover. Further, for many of Ovid's heroines, Beer argues, and for Pope's Eloisa in particular, “‘come’ is the most important word (even, finally, the only important word) [in their respective epistles]”; Mrs. Yonge, however, explicitly orders her husband to “go”: “Go; Court the brittle Freindship of the Great, / Smile at his Board, or at his Levée wait / And when dismiss'd to Madam's Toilet fly …” (71-73).²¹ Rather than begging for the return of a lost lover, she argues for her right to seek love elsewhere yet still retain her reputation: “Weary'd at length, I from your sight remove, / And place my Future Hopes, in Secret Love … To Custom (thô unjust) so much is due, / I hide my Frailty, from the Public view” (40-41, 46-47). The speaker must challenge “Custom” and the “Public view” in order to redeem herself, for they represent conventional standards of judgment, the assumptions embedded in the minds of both her husband and (implicitly) her potentialjury of readers. Those assumptions automatically categorize her as a bad example rather than as a heroine.

Because her society depends upon “custom” to interpret her situation, Mrs. Yonge experiences both public disgrace and legal punishment. Yet she neither pleads for pity from her husband nor claims to repent of her adultery:

Think not this Paper comes with vain pretence
To move your Pity, or to mourn th'offence.
Too well I know that hard Obdurate Heart;
No soft'ning mercy there will take my part,
Nor can a Woman's Arguments prevail,
When even your Patron's wise Example fails,
But this last privelege I still retain,
Th'Oppress'd and Injur'd always may complain.

(1-8)

Her motive for writing is not to plead with her own personal victimizer, but to expose widespread female victimization. She simply reserves the right to plead her case and, in so doing, she associates her own personal “oppression” and “injury” with political injustices more widely perpetrated against women who are forced to “submit.”

The speaker employs “submission” in its adjectival form, and using its most conventional meaning, in the second stanza of the poem:

Too, too severely Laws of Honour bind
The Weak Submissive Sex of Woman-kind.
If sighs have gain'd or force compell'd our Hand,
Deceiv'd by Art, or urg'd by stern Command,
What ever Motive binds the fatal Tye,
The Judging World expects our Constancy.

(9-14) (emphasis mine)

In describing women as “submissive,” she invokes two subtly different meanings of the term, according to Johnson's 1755 Dictionary; first, women must subject themselves to the power of their husbands, and, second, they must acknowledge that dependence in their demeanor and actions.²² In this passage she does not argue with the contemporary assumption that women are weaker than men, but asserts that they are victims either of men's artful seduction (their “Sighs”) or of their overpowering physical force. She points to the fallacy at the heart of the conventional argument that paradoxically makes women both weaker than men and yet also fully responsible for all their transgressions. She thus undermines the very basis of the argument by which she has been judged guilty.

Furthermore, the legal presumption that women must always “submit” assumes some very ugly overtones in this passage. Mrs. Yonge describes a woman's social and legal ordeals in terms of overpowering male physical “force” and “deceit,” of sexual violation and victimization. She thus strongly associates the personal with the political, equating the rape of a woman with men's quest for power within the public world. As she accuses her husband in the fifth stanza: “Beneath the Shelter of the Law you stand, / And urge my Ruin with a Cruel Hand” (55-56) (emphasis mine). The “stand-Hand” end-rhyme in this couplet repeats the end-rhyme of the couplet from the second stanza quoted above: “If sighs have gain'd or force compell'd our Hand, / Deceiv'd by Art, or urged by stern command …” (11-12) (emphasis mine). By echoing that end-rhyme, Lady Mary associates the figurative “Cruel Hand” of a man acting within the legal system with the “stern Command” of a man who forces a woman into marriage and thus into a sexual, social, and legal relationshipthat she may not desire. Further, all of the end-rhymes in that second stanza of the poem—bind-womankind; hand-command; and the jarring and noticeable tye-constancy—anticipate in their diction the depiction of marriage as physical torture that appears at the end of the third stanza: “For Wives ill us'd no remedy remains, / To daily Racks condemn'd and to eternal Chains” (23-24). This diction and the repetition of end-rhymes imply a feminist analysis quite revolutionary for the time: that a woman can be raped by the legal or social system just as she can be raped in the bedroom.

As the poem proceeds, Lady Mary's speaker continues to manipulate the denotations of “submission” in order to remove women from the torturous marital bind into which the first use of “submission” implies that they are forced. By the third stanza, Mrs. Yonge has already begun to employ another meaning that allows her to remove herself rhetorically from such a vulnerable position with regard to her husband and to replace him in the position of authority and judgment:

Just Heaven! (for sure in Heaven does Justice reign
Thô Tricks below that sacred Name prophane)
To you appealing I submit my Cause,
Nor fear a Judgment from Impartial Laws.

(15-18) (emphasis mine)

In this passage, “submitting” is not associated with involuntarily yielding to the power of another, but (again I employ one of Johnson's 1755 definitions) with voluntarily leaving her “Cause” to someone else's discretion, legally referring to someone else's judgment, in this case that of God.²³ It is God, and not her husband or the corrupt legal system, she argues, who is truly qualified to pass judgment upon her, and this judgment will be based on “Impartial Laws” rather than accepted custom.

This is the same “Custom,” or conventional social judgment, to which the speaker paid heed when she hid her adultery from “public view” (see lines 46-47, quoted above). In English legal theory, of course, “custom” refers to unwritten law, law that is, according to Giles Jacob's New Law Dictionary, “established by long Usage.” Even long usage, however, Jacob notes, cannot “oblige a people without their Consent.”²⁴ He also quotes another legal scholar who states that one of the things that “good Custom must be grounded on” is “Reason.”²⁵ And “Reason” itself, according to Jacob's definition, “is the very Life of the Law; and that what is contrary to it is unlawful.”²⁶ Thus Lady Mary's speaker sounds much like a legal scholar or judge when she employs such legal discourse. She implies that women cannot be governed by conventional judgment, or “custom,” if they do not consent to it and if it does not follow the dictates of implicitly “impartial” reason, as God's does. By employing their own legal rhetoric against her judges, the speaker proves herself a more “impartial,” a more properly empirical, and therefore a better, witness and judge. This rhetoric, of course, is very much grounded in earthly rather than heavenly judgment; God does not need to be convinced by legal argument. By the end of the poem, in fact, we will discover that it is really her readers whom she is teaching to judge by such “impartial” standards and to whom she is truly “submitting” herself for judgment.

The adjective “submissive” appears again in the fifth stanza, but this time it describes the speaker's husband rather than “womankind.” As Mrs. Yonge taunts her husband: “While to my Fault thus rigidly severe, / Tamley Submissive to the Man you fear” (57-58) (emphasis mine). By employing the adjective for the second and only other time to describe her husband, the speaker implies that his deferential relationship to his patron, Sir Robert Walpole, parallels women's “submissive” relationships to their husbands. William Yonge “submits” to Walpole and then in turn forces his wife to “submit” to him. The repetition of the adjective reveals Yonge's hypocrisy and effectively feminizes him by transforming him from an active, and therefore masculine, judge into one who is, like the “weak, submissive sex,” passively judged.

In her final use of the term, once again in active verbal form, Mrs. Yonge once more argues that only God may ultimately render judgment upon her, yet she also readily admits what the opening stanza only implied, that the reader of the poem may be construed as judge and jury for her “Case”:

My hapless Case will surely Pity find
From every Just and reasonable Mind,
When to the final Sentence I submit,
The Lips condemn me, but their Souls acquit.

(65-68) (emphasis mine)

The verb “submit” is now laden with all of its previous denotations. On the one hand, the speaker refers to the “final sentence” or punishment decided by the court of law, that extension of her husband's “cruel hand” to whose corrupt judgment and force she must “submit” herself; but she also refers to her ultimate submission (read “deferral”) to God's more “impartial” judgment. And now, judicially empowered, she also appeals her “hapless Case” to a jury of “Just and reasonable” readers. It is those minds whose judgment she has been trying to influence throughout the poem, those minds her arguments are truly intended to sway. She has been trying to convince them to dismiss “custom” and the “public view,” which categorize her as an adultress while excusing her husband's parallel behavior, and to judge her by her integrity rather than her sexual transgressions. Although she knows that their “lips” will gossip about her scandal and depend upon “custom” to characterize her, she believes that her well-reasoned plea may still touch a deeply held sense of justice still present in some of her readers. She assumes a certain judicial authority by claiming reason rather than flawed custom as the basis for her assessments of her own behavior as well as her husband's, and she hopes that readers will be swayed by that authority into themselves becoming better judges of her “Cause,” better interpreters of her narrative.

Lawrence Lipking has argued that the female speaker of this poem simply “claim[s] a right to talk,” but “does not expect justice.”²⁷ While I agree that Lady Mary's heroine does not anticipate that her husband or his peers will grant her literal justice, her creator does grant her (and potential women readers) a figurative justice and a sense of integrity. By subverting the gender roles underlying the conventional legal discourse that defines women as the “weak Submissive sex,” Lady Mary implies that a woman may exhibit an heroic “greatness of Mind” not only in “submission,” as she later argued in The Nonsense of Common-Sense, but in the exercise of an active and discerning feminine judging subjectivity.

Notes

1. Lady Mary Wortley Montagu, The Nonsense of Common-Sense No. 6 (January 24, 1738), Essays and Poems and Simplicity, a Comedy, ed. Robert Halsband and Isobel Grundy (Oxford: Oxford UP, 1977) 133. For Lady Mary's praise of the great spirit and fortitude of Addison's Cato, as well as her admiration for the parallel “Greatnesse of Mind” exhibited by his daughter Marcia in private life, see her “[Critique of Cato] Wrote at the Desire of Mr. Wortley, suppress'd at the desire of Mr. Addison,” in the same volume, 62-68, esp. 64.

2. Montagu, Nonsense 133.

3. There is irony both in Lady Mary's adoption of a male persona to make these recommendations and in her failure to follow such advice in her own life. Posing as the male author of a political journal, she advises women to remove themselves from public and, by implication, political life, yet by producing her pro-ministerial journal, she enacts, albeit anonymously, the role of the public and political woman. Cynthia Lowenthal has noted that aristocratic women such as Lady Mary “were comfortable being the objects of others's gazes. Such visibility was essential for the maintenance of class status” (Lady Mary Wortley Montagu and the Eighteenth-Century Familiar Letter [Athens, Ga.: U of Georgia P, 1994] 132). By assuming a male persona, however, Lady Mary acknowledges both the unwritten rule urging aristocratic women to remain as invisible in commercial print culture as they remain visible in society and “the new cultural pressure urging women into the invisibility of the domestic world” (Lowenthal 132). Furthermore, by 1738, Lady Mary herself did not behave as though she believed that a certain heroism resided in acceptance of her situation. Having been alienated from her unaffectionate and dull husband since the 1720s, in 1736 she had fallen in love with an Italian writer, Francesco Algarotti, and would pursue him to the Continent the following year (Robert Halsband, The Life of Lady Mary Wortley Montagu [New York: Oxford UP, 1956] 124, 157-62, 176-78).

4. The poem was written in 1724 and may have been circulated in manuscript, but it remained unpublished until the 1970s. I will be referring to the text of the poem that appears in Lady Mary Wortley Montagu, Essays and Poems and Simplicity, a Comedy, ed. Robert Halsband and Isobel Grundy (Oxford: Oxford UP, 1977) 230-232. All citations to the poem will be by line number and will appear parenthetically in the text. As Lowenthal explains in the introduction to her book on Lady Mary's letters, Lady Mary's status as an aristocratic woman made it unacceptable for her to publish any of her works under her own name during her lifetime (6). Both The Nonsense of Common-Sense and an essay she contributed to The Spectator were published anonymously, but, as Halsband notes in his biography, she never permitted any of her poetry to appear in print (although in 1726 Edmund Curll managed to obtain and publish two of her town eclogues without her permission) (Halsband, Life 53).

5. Isobel Grundy, “Ovid and Eighteenth-Century Divorce: An Unpublished Poem by Lady Mary Wortley Montagu,” Review of English Studies ns 92 (1972): 422-23. The Eighteenth-Century Short Title Catalog lists the Bill number as 11 Geo I.c.1.

6. Northampton Mercury, Dec. 21, 1724, quoted in Grundy 423-424.

7. The only other eighteenth-century poem I have discovered so far in which an adulterous wife addresses herself to her husband after a divorce trial is “A Poetical Epistle from Mrs. Elizabeth W—s to Mr. John W—s; With an Apology, in her particular Case, for Ad—t—y” (London: S. Bladon, 1783). The fifteen-page poem, which was published separately as a shilling pamphlet, was based upon a contemporary divorce trial (the transcript of which had recently been published) in which a “John Williams” accused his wife Elizabeth of committing adultery. It contains a voyeuristic and salacious first-person account of why Mrs. Williams chose to abandon her indifferent husband for her sexually talented lover. Although purportedly written by Elizabeth Williams, it is more likely a piece of hack work. A badly written and trite piece quite unlike Lady Mary's epistle, it does not empower its speaker as an individual subject nor reinterpret her story; instead, it objectifies her as the stereotype of the sexually insatiable woman. For the transcript of the original trial, see the anonymously authored The trial of Mrs. Elizabeth Williams, in the Arches Court of Canterbury, at Doctors Commons, for committing adultery with Joseph Peyton, Esq. captain of the Beaver Sloop. In which is given, the Whole of the Depositions of the Several Witnesses, fully describing the critical, amorous, and humorous scenes in that unparalleled Trial (London: M. Peate, 1782?). Copies of both the poem and the trial transcript are owned by the British Library and may be viewed on microfiche. See The Eighteenth Century (Woodbridge, CT: Research Publications, 1986), reels 3990 and 2320, respectively.

8. Barbara Shapiro, Probability and Certainty in Seventeenth-Century England: A Study of the Relationships between Natural Science, Religion, History, Law, and Literature (Princeton: Princeton UP, 1983) 168.

9. Susan Sage Heinzelman, “Legal Facts and Feminist Fictions: Laws of Evidence and Women's Writing 1688-1760,” Teaching the Eighteenth Century: Three Courses (Logan, UT: American Society for Eighteenth-Century Studies, 1993) 26.

10. Shapiro 190.

11. Heinzelman 26.

12. “Speaking of Women: Scandal and the Law in the Mid-Eighteenth Century,” Women, Texts and Histories 1575-1760, ed. Clare Brant and Diane Purkiss (London and New York: Routledge, 1992) 259, 261.

13. The duty of a wife to submit to her husband was made evident in contemporary English law, which, as Ian A. Bell observes, “seems to have created and authorised a very restricted typology of female possibility. … It seemed to recognise only two types of women. It valorised and encouraged the obedient, silent, chaste wife as a fit spouse for a male who could be as headstrong, noisy and lewd as he thought fit. In polar opposition to this image, the law stigmatised women who behaved as independent, sexual creatures, capable of self-government—such women were whores, and were not legally protected” (Literature and Crime in Augustan England [London and New York: Routledge, 1991] 101.).

14. Jane Spencer, The Rise of the Woman Novelist (New York: Basil Blackwell, 1986) 23.

15. Lawrence Lipking, “Sappho Descending: Eighteenth-Century Styles in Abandoned Women,” Eighteenth-Century Life 12, ns 2 (May 1988): 49.

16. Lady Mary is not the first woman poet to comment on the passivity of traditional Ovidian heroines. In 1688, Jane Barker published a poem entitled “To Ovid's Heroines in his Epistles,” in which she argues that self-possesssion and scorn for their lovers, rather than “lenity” and complaint, would better have become those heroines and, she implies, would have set better heroic standards for women (Poetical Recreations, Part I [London, 1688] 28-29.).

17. Isobel Grundy, “‘The Entire Works of Clarinda’: Unpublished Juvenile Verse by Lady Mary Wortley Montagu,” Yearbook of English Studies 7 (1977): 98-99.

18. Quoted in The Twickenham Edition of the Works of Alexander Pope, vol. 2: “The Rape of the Lock” and Other Poems, ed. Geoffrey Tillotson (New Haven: Yale UP, 1954) 276.

19. Grundy, “Ovid” 423.

20. Gillian Beer, “‘Our unnatural No-voice’: The Heroic Epistle, Pope, and Women's Gothic,” Yearbook of English Studies 12 (1982): 130.

21. Beer 131.

22. See “To submit,” v.n., and “submissive,” respectively, in Samuel Johnson, A Dictionary of the English Language, 1st ed. (London, 1755).

23. Johnson, “Submit,” v.a., definition no. 3. The Oxford English Dictionary clarifies the specifically legal meaning of the term “submission” during the eighteenth century (drawing examples from 1697-98 and 1765-8) that Lady Mary draws on here: “Agreement to abide by a decision or to obey an authority; reference to the decision or judgement of a (third) party …” (“Submission,” 1.a., 1989 ed.).

24. Giles Jacob, “Custom,” New Law Dictionary, 3rd ed. (London, 1736).

25. Jacob, “Custom.”

26. Jacob, “Reason,” New Law Dictionary, 3rd ed. (London, 1736).

27. Lawrence Lipking, Abandoned Women and Poetic Tradition (Chicago: U of Chicago P, 1988) 11.