An Elegy for the Hereditary Peers

          “This bill, drafted in Brussels, is treason” was the Earl of Burford’s verdict on the soon-to-be-passed House of Lords Act 1999. “Stand up for your Queen and country,” he thundered while standing on the Woolsack in the House of Lords chamber, “and vote this bill down.”¹

          Burford spoke as the heir apparent to a dukedom, which would have once entitled him to a seat in the House of Lords upon the death of his father. But that entitlement vanished with the passage of the Act against which he railed. “No-one,” its text declares, “shall be a member of the House of Lords by virtue of a hereditary peerage.”² The Act excepted from its rule the Earl Marshal, the Lord Great Chamberlain, and ninety other hereditary peers,³ but sent the remaining 658 packing.⁴

           The just-passed Hereditary Peers Act 2026⁵ picked up where the 1999 Act left off, expelling the remaining ninety-two hereditary peers.⁶ “Treason” those Acts are not. But they are a tragedy in that they bring to ultimate fruition a long and steady campaign to divest the hereditary nobility of its formal role in the U.K. government.

Divestiture

           That campaign proceeded in four stages. First, hereditary nobles were deprived of their ability to control the composition of the House of Commons. Second, the hereditary nobility’s beachhead—the House of Lords—was made largely impotent. Third, hereditary nobles were “swamped” within the House of Lords. Finally, hereditary nobles were altogether expelled from their chamber.

           First came the deprivation of the hereditary nobility’s ability to dominate the House of Commons. From the early days of the Commons onward, “the status and wealth of upper house members enabled them to significantly influence who was chosen to serve in the Commons.”⁷ Peers controlled “the election of as many as 354 MPs, or 54% of the Commons,”⁸ by 1832, with “many Commons seats . . . held by the eldest sons of peers.”⁹ That hereditary control of the Commons largely came to a halt with the Reform Act 1832,¹⁰ which abolished ancient seats controlled by hereditary peers, broadened the franchise, and created seats in the Commons for urban areas not susceptible to the wiles of the landed class.¹¹

           The second step in the elimination of the hereditary nobility’s formal role in the British state was the weakening of its beachhead, the House of Lords, vis-à-vis the House of Commons.

           Even in the late eighteenth century, the House of Lords was still “extremely important.”¹² “[M]ost ministers continued to be drawn from the Lords rather than the Commons,” and “the seniority of the Commons in the making and breaking of governments . . . was not yet unequivocally established.”¹³ And, throughout the nineteenth century and the beginning of the twentieth, the Lords frequently resisted the Commons’ initiatives.¹⁴ The 1893–1895 period saw “the Tory majority in the Lords . . . alter or reject almost every major Liberal bill,”¹⁵ and the Liberal government in the Commons “was defeated in the [Lords] 113 times” between 1906 and 1910.¹⁶

           Thus, the House of Commons divested the Lords of much of its power of resistance. The Parliament Act 1911, passed after the Lords voted down the Commons’ Finance Bill 1909, barred the Lords from rejecting money bills and from holding up any other species of legislation for more than two years.¹⁷ After the House of Lords did not yield in its efforts to block the Commons’ initiatives,¹⁸ the Commons forced through the Parliament Act 1949. That legislation further defanged the Lords by reducing to one year the period it could hold up a bill from the Commons.¹⁹

           Third came the “swamping” of hereditary nobles within the House of Lords. The means by which this was accomplished was the Life Peerages Act 1958, “a simple measure just to allow life peers to be created and to sit.”²⁰ Notwithstanding the seeming inoffensiveness of this Act, which was “generally welcomed by peers,”²¹ it flew in the face of half a millennium of precedent.²² And it proved consequential: By the time of the House of Lords Act 1999, life peers made up almost forty-three percent of the House of Lords.²³

           The fourth and final step in dispossessing hereditary nobles of their formal political power was the passage of the House of Lords Act 1999 and the Hereditary Peers Act 2026, which banished them from the House of Lords. The basis for these Acts was political and ideological—political in that Labour governments were “always . . . defeated more often than Conservative governments in the House of Lords, due to the chamber’s peculiar composition,”²⁴ and ideological because they rebuked the idea that political power should be some’s birthright.²⁵ In that latter respect, the battle lines were drawn back in 1911. That year’s Parliament Act stated that “it is intended to substitute for the House of Lords as it presently exists a Second Chamber constituted on a popular instead of hereditary basis, but such substitution cannot be immediately brought into operation.”²⁶

A Tragedy

           For three reasons, I mourn the success of the campaign to dispossess the United Kingdom’s hereditary nobility of its formal political power.

           The first is that an institutional check on raw majority rule has been eliminated. If The Federalist is instructive of anything, it is that sound, just public policy arises not through mob rule “moderated” by empty procedure but through the clash of genuinely adverse interests. “Ambition must be made to counteract ambition,” wrote James Madison. “The interest of the man must be connected with the constitutional rights of the place.”²⁷

           And titled nobles have interests of their own to protect from taxation and legislation. They are among the United Kingdom’s wealthiest²⁸ and most prominent,²⁹ and they were once its ruling class. Representation for the hereditary nobility in the U.K. state ensured that the very real demands of the public for social services and political equality would clash with the very real, and deeply felt, interests of the hereditary nobility in the preservation of its estates and preeminence,³⁰ thereby producing evenhanded settlements conducive to the common good.

           Sentimentality is my second basis for mourning the exclusion of the hereditary nobility from modern-day decision-making. The Commons has cut the United Kingdom off from a core aspect of her constitutional tradition—that is, a seven-century-old practice of allowing peers to serve in the House of Lords by birthright.³¹ And it has deprived the chamber of living, breathing historical continuity in the form of peers whose titles date back to 1138.³²

           Edmund Burke once said, “To make us love our country, our country ought to be lovely.”³³ Here, the Commons has done precisely the opposite. It has surrendered, to quote Russell Kirk, “the ancient ideals of England . . . to the stock-jobber and the modern political economist,” “to the class of persons intent on denationalizing society, men who would dig up the charcoal foundations of the temple of Ephesus to burn as fuel for a steam-engine.”³⁴

           Third among my reasons for seeing the banishment of the hereditary peers as a tragedy: They are in some respects better equipped to govern than life peers³⁵ and popularly elected representatives.³⁶

           To quote the third Marquess of Salisbury, “They have the leisure for the task, and can give it the close attention and the preparatory study which it needs.”³⁷ “Fortune enables them to do it for the most part gratuitously,” he continued, “so that the struggles of ambition are not defiled by the taint of sordid greed.” “[T]hey have been brought up apart from temptations to the meaner kinds of crime”—and, even if they were so tempted, “they occupy a position of sufficient prominence among their neighbours to feel that their course is closely watched, and they belong to a class among whom a failure in honor is mercilessly dealt with.”³⁸

           Additionally, hereditary nobles have a strong incentive to legislate for the long run rather than for short-term expediency, as they have titles and estates that depend on the survival of the United Kingdom.³⁹ And neither hereditary nobles’ status nor that of their families turns on election results, meaning they can speak from principle even when doing so is politically unpopular.⁴⁰ John Adams made much the same observation in noting, “Mankind have not yet discovered any remedy against irresistable Corruption in Elections to Offices . . . but making them hereditary.”⁴¹

           None of this is to mention that, as Thomas Jefferson wrote, “the moral and physical qualities of man, whether good or evil, are transmissible in a certain degree from father to son.”⁴² Today’s hereditary peers are the descendants of statesmen, industrialists, diplomats, military heroes, and “various others at the top of their fields” whom monarchs thought fit to reward with a truly august honor.⁴³ Perhaps such descent alone should create a rebuttable presumption that each hereditary noble is qualified to govern.⁴⁴

           Certainly, the United Kingdom should not allow the hereditary nobility to rule the roost. “Aristocrats are always ambitious and avaricious,”⁴⁵ Adams wrote, and Salisbury added that “unlimited power would be as ill-bestowed upon them as upon any other set of men.”⁴⁶ But “the great Secret of Liberty,” Adams advised, is not to banish aristocrats from government, but “to find means to limit their Power and controul their Passions.” “Rome and Britain have done it best.”⁴⁷

           In a subsequent article for Notre Dame Journal of Law, Ethics & Public Policy: In Limine, I will write about a development in the United States parallel to the exclusion of the U.K. hereditary nobility from formal political power: the alienation of state governments from an active role in the U.S. government. My foil in this respect will be Joshua Katz’s recent argument that “whatever problems we have in this country, we have not yet moved to erase our cultural heritage to quite the extent that England and the rest of the United Kingdom have, where Parliament voted to remove the remaining hereditary peers from the House of Lords.”⁴⁸

           In the meantime, I will raise a glass for the efforts of various hereditary peers to save their class from its ultimate fate. Among them are the first Duke of Wellington,⁴⁹ the third Marquess of Salisbury,⁵⁰ the first Earl of Halsbury,⁵¹ the nineteenth Baron Willoughby de Broke,⁵² the seventh Baron Sudeley,⁵³ the third Viscount Monckton,⁵⁴ and the nineteenth Earl of Devon.⁵⁵ Constitutions are precious things, and those who work to save them from perdition warrant a toast.

 

Declan M. Hurley. J.D. candidate, Notre Dame Law School, 2027. Graduate of the University of Chicago with a B.A. in history with honors and in economics, magna cum laude. Editor-in-chief of the Notre Dame Journal of Law, Ethics & Public Policy, volume 41. Incoming law clerk to Judge Kyle Duncan of the U.S. Court of Appeals for the Fifth Circuit.

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1. Nicholas Watt, Treason: Last Cry of the Lords, Guardian (Oct. 26, 1999), https://www.theguardian.com/politics/1999/oct/27/lordreform.constitution5; see also Wood on Peers Appendix, The Earl of Burford Climbs Onto the Woolsack and Interrupts Proceedings, at 0:24 (YouTube, July 28, 2025), https://www.youtube.com/watch?v=2ivuRzAkoS8. ↩︎
2. House of Lords Act 1999, c. 34 (UK). ↩︎
3. Those ninety were to be chosen “in accordance with Standing Orders of the House.” They were to serve for life, with standing orders making “provision for filling vacancies among the people excepted.” Id. § 2. ↩︎
4. See Michael White & Lucy Ward, Suspicious Peers Back Reform, Guardian (May 11, 1999), https://www.theguardian.com/politics/1999/may/12/lordreform.constitution. ↩︎
5. House of Lords (Hereditary Peers) Act 2026, c. 12 (UK). ↩︎
6. Note, however, that “around 15 Conservative hereditary peers would secure life peerages.” Sam Tabahriti, UK Ends Centuries-Old Hereditary Seats in Parliament Upper Chamber, Reuters (Mar. 11, 2026), https://www.reuters.com/world/uk/uk-ends-centuries-old-hereditary-seats-parliament-upper-chamber-2026-03-11/. ↩︎
7. Meg Russell, The Contemporary House of Lords: Westminster Bicameralism Revisited 16 (2013); Philip Salmon, House of Lords Reform: A Victorian Perspective, Hist. Parliament (Aug. 14, 2025), https://historyofparliament.com/2025/08/14/lords-reform-a-victorian-perspective/. ↩︎
8. Russell, supra note 7, at 22. ↩︎
9. Id. at 18. This made “membership of the Commons . . . an apprenticeship for membership of the Lords.” Id. ↩︎
10. See id. at 22. ↩︎
11. See Philip Salmon, The 1832 Reform Act, Hist. Parliament (Oct. 5, 2025), https://historyofparliament.com/2025/10/05/the-1832-reform-act/; The Reform Act 1832, UK Parliament, https://www.parliament.uk/about/living-heritage/evolutionofparliament/houseofcommons/reformacts/overview/reformact1832/ (last visited Apr. 6, 2026). ↩︎
12. Russell, supra note 7, at 21. ↩︎
13. Id. Indeed, “the second chamber continued to be one from which many senior ministers—and even Prime Ministers—were drawn until the early 20th century.” Id. at 37. ↩︎
14. “[A]t second reading in the Lords,” the Reform Act 1832 “was defeated by 41 votes,” id. at 22, an impasse that was ultimately broken only by “a written agreement to create [new] peers . . . provided reluctantly by the king,” id. at 23. The House of Lords also resisted the Paper Duty Repeal Bill 1860 (an apparent challenge to “the Commons’ financial privilege”), id. at 25; the Established Church (Ireland) Bill 1868, id.; and the Reform Act 1884, see Declan M. Hurley, “Two Nations Who Understand Each Other Unfortunately So Well”: An Account of Lord Salisbury’s Dynamic Views on the United States 41 (Mar. 29, 2024) (B.A. thesis, University of Chicago) (on file with author). Indeed, the Lords defeated the Government of Ireland Bill 1893. See Russell, supra note 7, at 26; Hurley, supra, at 50. ↩︎
15. Russell, supra note 7, at 26. Much of the credit for this resistance belongs to the third Marquess of Salisbury, who “organiz[ed] a disorganized but receptive Conservative mass” in the House of Lords “into effective resistance against Gladstonian initiatives passed by the Commons—much like a magnifying glass channeling sunlight into a single, hyperintense point of light.” Hurley, supra note 14, at 36. ↩︎
16. Russell, supra note 7, at 26. ↩︎
17. Id. at 26–27. “[W]hile some Conservative peers (the so-called ‘ditchers’) were prepared to risk” “the chamber’s ‘swamping’ with possibly hundreds of Liberal peers, . . . sufficient numbers abstained or voted with the government to allow the bill to pass.” Id. at 27. ↩︎
18. The Lords delayed the Government of Ireland Bill and Established Church (Wales) Bill, both of 1913, “until after the war.” Id. at 28. Between 1945–1951, when the Labour Party controlled the Commons despite having just sixteen seats in the Lords, “the government suffered 113 defeats” in the upper house. Id. at 30 (citation omitted). ↩︎
19. Id. at 31. Nevertheless, the House of Lords persisted in its resistance to the measures of the Commons during the period in which it was still under the control of hereditary peers. The Lords rejected a Rhodesia sanctions order in 1968, see Dana Adams Schmidt, House of Lords, in Defiant Vote, Rejects Sanctions for Rhodesia, N.Y. Times, June 19, 1968, at 1, a defeat that was final because “the Parliament Acts did not cover such legislation,” Russell, supra note 7, at 32. “The Labour governments of 1974–79 then suffered many more defeats, some of which ultimately proved fatal to bills.” Id. at 33 (citation omitted). Furthermore, the House of Lords “twice rejected” the War Crimes Bill 1990. Id. at 34. This capped off a decade of resistance against some Margaret Thatcher initiatives in the Lords, including the “abolition of the Greater London Council and . . . introduction of the so-called ‘poll tax.’” Id. ↩︎
20.  Russell, supra note 7, at 31. ↩︎
21. Life Peerages Act 1958, UK Parliament, https://www.parliament.uk/about/living-heritage/evolutionofparliament/houseoflords/parliamentacts/overview/lifepeeragesact/ (last visited Apr. 4, 2026). ↩︎
22. “[A]ll peerages had been hereditary” for the four hundred years leading up to the Appellate Jurisdiction Act 1876, a very narrow reform that allowed “a limited number of life peerages to be conferred specifically on senior lawyers to serve as Lords of Appeal.” Russell, supra note 7, at 23–24. ↩︎
23. See Hereditary Peers Removed, UK Parliament, https://www.parliament.uk/about/living-heritage/evolutionofparliament/houseoflords/parliamentacts/overview/hereditarypeersremoved/ (last visited Apr. 4, 2026). ↩︎
24. Meg Russell & Maria Sciara, Why Does the Government Get Defeated in the House of Lords?: The Lords, the Party System and British Politics, 2 British Pols. 299, 300 (2007). ↩︎
25. See Jill Lawless, Britain is Ejecting Hereditary Nobles from Parliament After 700 Years, PBS News (Mar. 11, 2026), https://www.pbs.org/newshour/world/britain-is-ejecting-hereditary-nobles-from-parliament-after-700-years (“Government minister Nick Thomas-Symonds said the [2026 Act] put an end to ‘an archaic and undemocratic principle.’ ‘Our parliament should . . . never be a . . . place where titles, many of which were handed out centuries ago, hold power over the will of the people.’”). ↩︎
26. Parliament Act 1911, 1 & 2 Geo. 5 c. 13, pmbl. (UK); see also Russell, supra note 7, at 29. ↩︎
27. The Federalist No. 51 (James Madison); see also The Federalist No. 48 (James Madison) (“Will it be sufficient to mark, with precision, the boundaries of these departments, in the constitution of the government, and to trust to these parchment barriers against the encroaching spirit of power? . . . [E]xperience assures us, that the efficacy of the provision has been greatly overrated; and that some more adequate defense is indispensably necessary for the more feeble, against the more powerful, members of the government.”). ↩︎
28. See Aristocrats Own Third of Land in England and Wales, Independent (Nov. 10, 2010), https://www.independent.co.uk/news/uk/home-news/aristocrats-own-third-of-land-in-england-and-wales-2130392.html. ↩︎
29. See Aristocrats Have Increased Their Influence in Britain Over the Past 150 Years, Says Research, British Socio. Ass’n (Apr. 5, 2024), https://britsoc.co.uk/media-centre/press-releases/2024/april/aristocrats-have-increased-their-influence-in-britain-over-the-past-150-years-says-research/. ↩︎
30. This contest played out in full force when the Lords rejected the Finance Bill 1909, “which sought to fund new social provisions such as pensions through increased taxes, particularly on the wealthy.” Russell, supra note 7, at 27. ↩︎
31. See id. at 15. ↩︎
32. See Jonathan Spangler, The Howards: Premier Peer of the Realm as Duke of Norfolk and Earl Marshal, Dukes & Princes (May 6, 2023), https://dukesandprinces.org/2023/05/06/the-howards-premier-peer-of-the-realm-as-duke-of-norfolk-and-earl-marshal-catholic-champions/. ↩︎
33. 3 The Works of the Right Honorable Edmund Burke 334 (Boston, Little, Brown, & Co. 1865). ↩︎
34. Russell Kirk, The Conservative Mind 167–68 (3d ed. 1960) (writing of the Reform Act 1832, which he characterized as substituting for the old idea that men should be “represented in their corporate capacities” the “utilitarian and industrial concept” that people can “be represented upon a mathematical basis, in equal districts”). ↩︎
35. Charles Ross & Cormac Kehoe, Family Ties, Political Connections: What the Data Tells Us About Becoming a Life Peer, Prospect (Feb. 5, 2025), https://www.prospectmagazine.co.uk/politics/69163/what-the-data-tells-us-about-becoming-a-life-peer (“Since 2010, our analysis reveals that 59 per cent of the life peers appointed to the Lords are either ex-politicians, Spads or major donors.”). ↩︎
36. But see Nick Hallett, Out Go the Hereditary Peers—In Comes the Political Class, European Conservative (Mar. 12, 2026), https://europeanconservative.com/articles/commentary/uk-lords-hereditary-peers-reform-british-political-culture-restraining-power/ (“To an outsider, the reform may look obvious enough. Few modern democracies would design a legislature that includes lawmakers by birth.”). ↩︎
37. Robert Gascoyne-Cecil, The Confederate Struggle and Recognition, 112 Q. Rev. 535, 547 (1862). ↩︎
38. Id. ↩︎
39. For a similar argument from the nineteenth Earl of Devon, see Kate Whannel, Hereditary Lords Speak Out on Prospect of Leaving Parliament, BBC News (Apr. 19, 2025) (“He argues that, at a time of concern about the ‘rabid consumption of our natural world’ hereditaries offer a ‘long-term, multi-generational view’ and are less likely to be focused on short term political gains.”). For a more cynical—and theoretical—discussion of time preference in the context of monarchies, see Andrew Young, Freedom and Prosperity in Liechtenstein: A Hoppean Analysis, Mises Inst. (Feb. 18, 2020), https://mises.org/journal-libertarian-studies/freedom-and-prosperity-liechtenstein-hoppean-analysis-0 (“[A] royal family ‘owns’ the state, since the reigning monarch maintains control of the state until his death, passing ownership to his heir. . . . As a result, monarchs tend to have low time preferences and thus keep taxes low to maintain the capital value of their taxation monopoly.” “In a democracy, by contrast, . . . the president only controls the monopoly of taxation and jurisdiction for a short time,” so “his incentive is to exploit the state and its subjects as much as possible during his time in power.”). ↩︎
40. See Hallett, supra note 36 (“Hereditary peers have one important quality: they do not owe their seats to the favour of a recent prime minister. Once the House of Lords becomes entirely appointed, that independence inevitably shrinks.”). ↩︎
41. Letter from John Adams to Thomas Jefferson (Nov. 15, 1813), reprinted by Nat’l Archives: Founders Online, https://founders.archives.gov/documents/Adams/99-02-02-6198. “By corruption, here I mean a Sacrifice of every national Interest and honour, to private and party Objects.” Id. ↩︎
42. Letter from Thomas Jefferson to John Adams (Oct. 28, 1813), reprinted by Founders’ Const., https://press-pubs.uchicago.edu/founders/documents/v1ch15s61.html; see also Adams to Jefferson, supra note 41 (observing “moral intellectual and physical inequalities in Families, descents and Generations” and that even “in the most popular Governments, the Elections will generally go in favour of the most ancient families”). ↩︎
43. Russell, supra note 7, at 26. ↩︎
44. In individual cases, that presumption is sometimes rebutted. But even a noble line that is down is not necessarily out. See Polly Dunbar, Not Such a Mad Marquess! How Millionaire Brother of Socialite Lady Victoria Hervey is Rebuilding His Family’s Fortune Brick by Brick After Inheriting Aristocracy’s Most Toxic Title from His Drug-Addled Brother, Daily Mail (Mar. 28, 2017), https://www.dailymail.co.uk/lifestyle/article-4349702/How-millionaire-rebuilding-family-s-fortune.html. ↩︎
45. Letter from John Adams to Benjamin Rush (Dec. 27, 1810), reprinted by Founders’ Const., https://founders.archives.gov/documents/Adams/99-02-02-5584. ↩︎
46. Salisbury, supra note 37, at 577. ↩︎
47. Adams to Rush, supra note 45. Philip J. Costopoulos, Jefferson, Adams, and the Natural Aristocracy, First Things (May 1, 1990), https://firstthings.com/jefferson-adams-and-the-natural-aristocracy/, summarizes Adams’ thought thus: “Mixed regimes offered the best security for liberty by luring the aristocrats into a gilded cage—the upper house of the legislature. There a strong executive and a jealous lower house could control them even while they, driven by their own ambition, could in turn check whichever other department of power appeared most overweening.” ↩︎
48. Joshua Katz, Badgering Churchill, New Criterion (Mar. 23, 2026), https://newcriterion.com/dispatch/badgering-churchill/. ↩︎
49. As a former Prime Minister, he vigorously opposed the Reform Act 1832. “[H]e felt [it] would ‘destroy the country, the House of Lords the first probably and all its Institutions’.” Letter from the Duke of Wellington to the Earl of Lucan on the Reform Bill, UK Parliament, https://www.parliament.uk/about/living-heritage/transformingsociety/private-lives/yourcountry/collections/waterlooexhibition/duke-of-wellington/letter-on-the-reform-bill/ (last visited Apr. 5, 2026). ↩︎
50. See supra note 15. ↩︎
51. “[D]uring the constitutional crisis of 1910–11 he was the figurehead around whom the die-hard ‘ditchers’ organized their opposition to the Parliament Bill; he . . . sent a circular letter to the peers in March 1910 urging them to reject . . . reform of the Lords. Halsbury’s simple faith led him to believe that it was constitutionally improper to interfere with the hereditary principle on which the House of Lords was hitherto based.” G. R. Rubin, Giffard, Hardinge Stanley, First Earl of Halsbury, Oxford Dict. Nat’l Biography (Jan. 3, 2008), https://doi.org/10.1093/ref:odnb/33395. ↩︎
52. In tandem with the first Earl of Halsbury, he led the all-out fight against the Parliament Act 1911. See Violet Bonham Carter, Winston Churchill: An Intimate Portrait 163 (1965). ↩︎
53. He “spoke out against the reform (or wrecking, as he called it) of the Lords,” citing “the wealth of governmental experience that the hereditary peers had accumulated from one generation to the next.” “[H]e wrote . . . a leading essay on ‘The Role of Heredity in Politics’”; a “Policy Paper against Lords Reform in December 1979”; and “a booklet titled, and arguing for, The Preservation of the House of Lords.” Obituary, the Lord Sudeley, 1939–2022, Traditional Britain President, Traditional Britain Grp., https://traditionalbritain.org/blog/obituary-the-lord-sudeley-1939-2022-traditional-britain-president/ (last visited Apr. 5, 2026) (citation modified). ↩︎
54. He “inherited his title after the passing of the House of Lords Act in 1999 which stripped hereditary peers from their automatic right to sit and vote in the chamber. But [he] claims the Act is flawed and unconstitutional and still refers to himself as a member of the upper house, though admittedly one ‘without the right to sit or vote’.” Britain’s Monckton Lordly About Title, Space Daily (July 20, 2011), https://spacedaily.com/britains-monckton-lordly-about-title-999/. ↩︎
55. See supra note 39. ↩︎