Showing posts with label law. Show all posts
Showing posts with label law. Show all posts

judg(e)ment

At some point in my American education, I learned that judgment was an American spelling and judgement was the preferred British spelling. Ditto acknowledgment and acknowledgementBut then I moved to England and grew up (possibly in that order) and reali{s/z}ed that nothing is ever that simple. (Though I see some poor souls [read: schools] on the internet are happy to promulgate the simplification.)

The e-ful versions of these words show up as 'more British than American' in the GloWbE corpus, but it's pretty clear from the numbers that it's not a straightforward difference. Here are the raw numbers:


with the E
without the E


And here, more readably, are the proportions. BrE does prefer the e-ful versions, but not absolutely. AmE has completely mixed feelings about acknowledgement and while it mostly prefers judgment without that e, it still has 25% e-ful judgement. (Yes, I know that there's still an e in the version I'm not calling e-ful. Don't be difficult. You know what I mean.)

acknowledgement AmE 56% BrE 77%, judgement AmE 25% BrE 63%
(includes singular and plural)


Now, you might look at this kind of thing and think: it's those Americans getting rid of letters again. Noah Webster, to whom many attribute American spelling habits, was not a fan of 'silent e' and tried to get rid of it elsewhere. (For example, he wanted to spell improve as improov.) But judgment is no Websterian Americanism. The Oxford English Dictionary tells us that though judgement had an e early on (coming, as it did, from French jugement), the e had started to drop out by the 16th century, and judgment was the prevailing spelling in by the end of the 17th century. Both judgment and acknowledgment are e-less in Samuel Johnson's 1755 dictionary

It was only in the 19th century that the e-ful judgement regained popularity in British contexts—I assume acknowledg(e)ment followed suit, but the OED has less info about that word. It's not surprising that the e gained traction, since using the e before the -ment suffix does some helpful things: 
  • it keeps the spelling of the root word (judge, acknowledge) intact
  • it signals the 'softness' of the g before the suffix ('soft' g's typically only go before e, i or y)
  • it avoids a weird letter combination: dgm
But you'd never know that judgement is "British English" if you looked in some places. Here's what the spelling is like in the UK Parliamentary record. Pretty darned e-less.


That's because legal language tends to be more conservative. In British law, judgment has no e.

This makes judg(e)ment just one more British word that has a spelling/form variation depending on professional context:

Some of those splits in BrE spelling are due to the influence of AmE, but in the case of judg(e)ment, we have (non-legal) BrE innovating while AmE mostly didn't change. If either variety is influencing the other, it might be BrE's allowance of those e's in judgment and acknoweledgement that's causing AmE to be more tolerant of the longer spellings. 

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leave

I have left my leave. In the spring of 2020 I was on university-funded leave. Then I took unpaid leave to go be an NEH Public Scholar for six months. Now I'm returning to my university job six weeks early so that someone else can go on sick leave. (Then I'll go back on unpaid leave in April and finish off the NEH grant.) That leaves me thinking about leave, and how Americans sometimes ask me to explain some BrE uses of it. 

Leave, a noun meaning 'time off from work/service' is general English, but it's used for more kinds of time off in BrE than in AmE. The leave in all of these expressions is not "I'm leaving! Bye-bye!", but that you have been given leave (permission) to go. And so...

Leave of absence is used in both places, but more in North America—and I am guessing that's because using leave on its own is less clear to those who use it less:

To be on leave is general English. The OED says that Americans can also be on a leave, but the corpus data I can find shows that as being more common in Canada than in the US. (On a leave of absence is much more common than on a leave on its own.)

In employment   

Several modifications of ___ leave seem to be used in both countries:

  • paid/unpaid leave
  • sick/medical leave
  • maternity/parental/paternity leave

...though you find all the parental leave expressions above, plus adoption leave much more in the UK because there's just much more of it to be had over here. Maternity leave also pops up as mat leave (and in Canada too) because familiarity breeds abbreviation.

Some BrE kinds of leave that aren't expressed that way in AmE are:

  • annual leave: one's annual (BrE) holiday / (AmE) vacation allowance. It's not uncommon in the UK to get out-of-office email messages that say "I'm on annual leave until [date] and will not be checking my email during this time".  
  • compassionate leave [thanks for reminding me, Biochemist]: time off to deal with some personal crisis, often a bereavement (bereavement leave also shows up in the corpus) or a family illness.
  • research leave: what those in US universities call sabbatical. (Sometimes in the UK, one runs across sabbatical leave.)
  • study leave: time off to do some training or education. I don't know of a US equivalent for this. Is there one?
  • garden(ing) leave: a euphemistic way of talking about some kind of paid suspension of work, often to keep someone out of trouble before they exit a job. This has come up before in this old post and was also an item in one of my Untranslatable Octobers.

Some or many of them might come from the military (see below) via the civil service. 

Some of kinds of leave in the UK might be threatened by post-Brexit degradation of working conditions. (Maternity leave looks ok for the time being, but holiday/vacation pay is a worry. See here.)  

The only ___ leave I can find that is used more in AmE than in BrE is administrative leave. In the news, it's what you see happening to police who shoot people while the shooting is being investigated.  American police do a whole lot more shooting people than (the mostly un-firearmed) British police. It's also used for other kinds of "we can't fire you yet" or "we don't want to fire you, but we need to look like we're doing something". In one British article (about doping in competitive cycling), administrative leave is followed by "sometimes called garden leave". While garden leave might hint at an impropriety, the hint is not as strong as it is for administrative leave. (E.g. some examples of garden leave seem to be about preventing employees from having access to company secrets before they move to another company.)

 In military service

Shore leave is general (military) English. I'd presume most of the military leaves are common to both. Furlough (my 2020 US>UK Word of the Year) is another military term for leave, with more meanings in AmE than BrE.

The military term absent without leave goes back to the 17th century, but the OED also marks it as "U.S. Military" in two senses: the offen{c/s}e of being absent without permission, and a person who is absent without permission. The acronym AWOL is originally AmE in all its senses.

 In immigration

As well as getting permission to go, you can get permission to stay. A BrE phrase every UK immigrant knows well is leave to remain. That is, permission to stay in the country. BrE indefinite leave to remain is equivalent to the AmE green card or general English permanent residence. Leave to remain can also be  temporary or limited (which are not the same thing), and discretionary, which is used in extraordinary circumstances (as for asylum seekers).

Not that kind of leave

And as long as I'm talking about noun uses of leave, take leave of (someone) is general (maybe a bit old-fashioned?) English, but take leave of one's senses ('stop thinking normally') seems rather BrE:


 

What have I forgotten? Let us know in the comments:

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The fourth 'Untranslatables' month summary

This was the fourth year that I declared October Untranslatables Month on my Twitter feed. (Here's 2011 , 2012, and 2013.) Instead of offering a 'Difference of the Day', I offered an 'Untranslatable of the Day' every weekday.  Last year, I swore that I wasn't going to do it again. In part I doubted that I could find another month's worth, but also in part, I was tired out from people arguing with me online about elements of the project. You can probably guess their complaints from the defensive bullet points that appear below. 

About my Untranslatables:
  • I'm only talking about the relationship between British and American English here (as is my theme). These expressions may well have equivalents in other languages or dialects.  
  • By Untranslatable I mean that there is no lexicali{z/s}ed equivalent in the other dialect. And by lexicali{z/s}ed I mean that the expression is a word or an idiom--something that language users learn through hearing others say it, rather than something that has been made up anew.
    One can translate things by making up new sentences or phrases that describe the same thing, sure. But it's special when a language has lexicali{z/s}ed an  expression for something--it tells us something about the culture that invented and uses that expression.
  • Many of these have started to be borrowed between the dialects--and that's natural. If it's a useful expression and the other dialect doesn't have it, it's a prime candidate for international migration.
  • If you have not heard of the word before (even though I've said it comes from your country), this is not cause for complaint. It is cause for celebration that you have this opportunity to enrich your vocabulary! 
That all said, I wasn't given much of a hard time this year. And I certainly was not subject to abusive rants, as happened for a while last year. (Phew.)

My rules for choosing the untranslatables are:
  • They can't repeat items from the previous Untranslatables Months.
  • It should be the expression that's missing from the other country, rather than the thing. So, for instance Page 3 Girl was suggested, but there is no American newspaper that puts topless young women on page three every day (thank goodness). There's no word for it in the US only because there's nothing for it to refer to in the US, so it doesn't belong in this particular list.
  • I try to alternate American and British expressions (but that doesn't always work out).

With the words below, I've given the content of the Untranslatable of the Day tweet, expanded and re-formatted from the necessary abbreviations of 140 characters. If I've discussed the expressions before on this blog, I provide links to those posts. I also include here the links I provided with the tweets and I try to give credit to those who suggested them as untranslatables. Here we go.

  • BrE snug: a small, comfy room in a pub. Occasionally  extended to other comfy personal (orig. ScotE) hidey-holes. Here's a Wikipedia description. [I learned this during the year while reading an article that I now can't find. I had to look the word up, and then spent the rest of the year waiting for untranslatables month to come round again.]
  • AmE to jaywalk: to cross the street/road against the light or where there's no crossing. Thanks to @SimonKoppel for the suggestion. As I noted in a later tweet, this word is known by many in the UK, but generally only used to refer to people doing it in the US. Some British twitterers objected that this couldn't count because the thing doesn't exist in the UK. They were under the impression that one cannot jaywalk in the UK because it's not illegal to cross in the middle of the (orig. AmE) block here.  But notice that there's nothing about legality in the definition I've given. I grew up in a place where (I was told, I've never actually checked) jaywalking wasn't illegal. But we still called it jaywalking. (Remember: laws--including many traffic laws--vary by state in the US.)
  • BrE Billy No-Mates: a friendless person. Here's a history of the phrase. (Can't find who suggested it, but thanks!) Several people sent variations on this like Johnny No-mates, Norma No-Mates and Norman No-Mates, but Billy seems to be the original (and the one I hear most--the others may be a bit more spread around the anglophone world).
  • AmE backwash: saliva/mouth contents that go back into a bottle that's been swigged from. (Urban Dictionary's take on it.) Several Brits told me they knew this from childhood, but it's still not (in my experience) widespread in the UK. Of course, the word-form is used in both dialects for other kinds of washing-back in rivers and plumbing.
  • BrE garden(ing) leave: Explained in this old post.  Thanks again to @SimonKoppel.
  • BrE to plump for: to choose suddenly after much dithering. Thanks for the suggestion to @rwmg.
  • AmE will call: [of tickets] to be collected at the box office. Wikipedia says COBO ('care of box office') is the BrE equivalent, but it's not in general use. In a US theat{er/re} you might have to go to the will-call desk/counter/box office to get the tickets. COBO isn't used like that. Yet another one suggested by @SimonKoppel. I might have to put him in charge of Untranslatables month next October.
  • BrE to decant: to transfer people temporarily to another location. See sense 1.1 in Oxford Dictionaries Online. Thanks to Diane Benjamin for this suggestion.
  • AmE to stop on a dime: to come to a halt quickly and neatly in exactly the right spot. Many complained that this has a BrE equivalent in stop on a sixpence. Fair enough. Though I will note that turn on a sixpence seems to be more common than stop on...
  • BrE three-line whip: Party instruction to Members of Parliament that they must vote with the party on some matter. (Here's more explanation from a Stack Exchange.) There is a question here whether it should count: is there an equivalent three-level structure of whips in the US? Well, there could be, so I gave it the benefit of the doubt. Thanks to @JanetNorCal for the suggestion.
  • AmE loaded for bear: well prepared (and probably eager) for a forthcoming confrontation. Thanks to @sethadelman for the suggestion.
  • BrE gazunder: [for a buyer] to reduce an agreed-upon price for a house/property just prior to signing contract.  Here's Word Spy on it.  
  • BrE gazump. To obtain a property by offering more for it than an already-accepted offer. Here's Oxford Dictionaries Online on it.
  • AmE layaway (= AusE lay-by). Instal(l)ment purchasing, where the item's not received until it's paid off. There was some discussion about whether this should count because it's unclear that the equivalent exists in the UK. British hire-purchase is the equivalent of AmE rent-to-own or rental-purchase, in which case you take the thing home and make payments on it. I allowed it because I think one could argue that certain Christmas schemes in the UK (like this one) are kind of like layaway. Thanks to @smylers2 for the suggestion.
  • BrE U and non-U: (Non)-upper class, with particular reference to words that "should" or "shouldn't" be used. Here's the Wikipedia article on it. And here are places where the distinction has been mentioned on this blog.
  • AmE charley horse. A cramp in the leg. Here is Merriam-Webster's definition. Thanks to @meringutan for the suggestion. There were some suggestions for British-dialectal equivalents of this. Hard to tell if they're really equivalent. You can discuss amongst yourselves in the comments.
  • BrE WAGs: wives and/or girlfriends of (BrE) footballers as a type of celebrity. Discussed on this blog here. Thanks to @meringutan.
  • AmE snow day: a day when schools and businesses are closed due to snow. (Longman definition). Sometimes heard in UK now, but no local lexical equivalent. Thanks for the suggestion, @laurelspeth.
  • BrE chav. This is a word for a stereotyped type of person. Here's Wikipedia's take on it. Suggested by @kearsycormier (thanks!). This one I was most uneasy about including, because I think it is the case of it being more the referent (in this case people rather than things) rather than the word that the US lacks. It's all about the UK social class system, which operates in different ways, with different emblems, than the US class system.  Many years ago I wrote about an attempt to import chav to the US. It hasn't worked.
  • AmE family-style: adjective or adverb describing the serving of food at restaurant in dishes that are to be passed (a)round and taken from, like at home. (Oxford's definition)
  • BrE scrumping: stealing apples from an orchard. Thanks to @beardynoise for the suggestion.
  • AmE palimony: (humorous) alimony-style payments made after the break-up of a non-marital relationship. 
  • BrE dodgy: with its many shades of meaning, it's hard to think of an exact equivalent: Here's Oxford Dictionaries Online on it. Once one learns this word, it soon becomes a necessary part of one's vocabulary, so it's not surprising that there are US sightings of it. Thanks to  @tonythorne007 for the suggestion.
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'the newspaper' and more on the written word

Tonight (22:00/10pm) people in the UK (and maybe abroad?) will be able to hear a new instal(l)ment of The Verb "Radio 3's cabaret of the word". [It's downloadable for the next 7 days.]  I was invited to talk about a piece I'd written a few months ago about American attitudes to dictionaries and, by extension, the written word. And it was a lovely time. The other guests were Nathaniel Mann (with his collaborator, violinist Daniel Merrill) and Nicholson Baker, whose writing I've long admired (and who was contributing over the phone from Maine; as a friend of mine pointed out, I was on the phone with the inventor of phone sex). The host, Ian McMillan, is not only a great radio host and performer, but also a great actual host, as were the rest of the staff there. Who knew we'd get apples before and cake after?

But, of course, one prepares for such events and then one is a bit disappointed when one misses the opportunities to say every fascinating (to oneself, at least) thing that one's thought of. In particular, that I've thought of. So, I'm typing this on the train back from the recording. L'esprit de railway.

The original essay and the radio piece both make a big thing out of what may be a very little thing: some evidence of differences in attitude to the written word in the US and UK. My contention is that Americans like written authorities, while the British tend not to turn to the written word as authority as much. On the program(me) I talk about dictionaries, the Bible, supreme courts, and constitutions, as I did in the original essay. In the course of it, I get a Winston Churchill quotation wrong (he actually said: "The English never draw a line without blurring it.") and miss the opportunity to point out a couple of things I had enjoyed discovering this week. So I'll tell you about them now.

The Supreme Court strikes (some dictionaries) again!
On the topic of U.S. Supreme Court use of dictionaries, a particular example of it arose this week. The case, Bond v. United States, involved the question of whether a wife putting caustic powders on her husband's pregnant lover's doorknobs could be prosecutable under the Chemical Weapons Convention Implementation Act. The Court unanimously said 'no', and the opinion, written by Chief Justice Roberts, cites seven different dictionaries — from Johnson's to the 3rd edition of the American Heritage Dictionary (why not the 4th or the 5th?) — in defining weapon and treaty. The two cited definitions of weapon define them as instruments of combat, and Roberts then shifts from dictionary evidence to evidently out-of-his-hat proclamations about "natural parlance", i.e. 'But no speaker in natural parlance would describe Bond's feud-driven act of spreading irritating chemicals on Haynes's door knob and mailbox as "combat."' American Heritage (4th edn) defines combat as 'To oppose in battle; fight against.'. Was Bond fighting against Haynes? Does this mean that, say, the Sarin was not a chemical weapon when it was used in a Tokyo train because the passengers weren't in a battle? Heck, does it mean that a gun used in domestic violence is not a weapon? We can see that court usage of dictionary definitions is a bit wobbly. Or scary, if you prefer. I'm not saying that the use of a rash-inducing caustic powder in a domestic dispute should be subject to international treaties about chemical weapons. But I am saying that if you're going to use a dictionary to support your opinion, you shouldn't hop back and forth between using it and ignoring it. And you probably shouldn't be using it that much at all. (By the way, Slate magazine hails the Chief Justice's "comic stylings" in this case. Yes, Americans can do irony.)

the newspaper?
While thinking further about how we talk about the dictionary even though there are many dictionaries, I wondered about use of the newspaper.  People say things like I read the newspaper every day or I read about that in the newspaper. But, of course, it's a particular newspaper title that they read every day, and it was a particular issue of a particular title that they read a particular fact in. (There's a reason why newspaper is the word that I use to teach first-year students about polysemy.) Saying the newspaper in these contexts, like when people say the dictionary, gives the impression that it's immaterial whether there is more than one possible newspaper that you could be referring to, since it is the news they're telling you. (In contrast, people don't talk generically about how to read the book or say that they read a fact in the book, unless it's clear from context which book they're talking about.) I wondered: do we see a difference in this use of the in AmE and BrE?  Well, I wouldn't be feeling the need to tell you about it if we didn't.

Using the Corpus of Global Web-Based English again, I looked at various newspaper phrases. British websites were about as apt as the American to have the phrases read a newspaper and read in a newspaper. But when we put a the in there, the scale(s) tip(s) to the American, with 106 American instances of read the newspaper to 45 British ones, and 23 American read in the newspaper to 9 British.  (I also didn't get to note that fellow-guest Nicholson Baker has an essay called 'Reading the paper' about newspaper-reading [in his case the New York Times] in his collection The Way the World Works.) This difference is probably much to do with the fact that American newspapers are meant to be 'objective' and 'impartial', while British ones wear their political positions more obviously.  If one believes that all the news is impartially reported in all the newspapers, then, the thinking might go, the news in the papers is interchangeable. (The fact that any news above the local level is likely to be coming from a wire service makes this almost true in some cases.) The American ideal of impartial print media (and until Fox News, broadcast media were held to the same standards) seems tied up with the value of the printed word in American culture.

Iain in the comments mentions 'in the papers" (note: I did newspaper rather than  paper because of the ambiguity of the latter--both are used in AmE & BrE). The plural there acknowledges that there is not a single paper, so more use of the plural would go along with the claim I'm making above (which, I must underscore, is a thought-experiment, like the original dictionary piece. I'm seeing how far I can go with it. And then I might go somewhere else with it!).  Looking at GloBWE again, each country (US, CA, UK, IE, AU, NZ) has only one instance of read it in the newspapers.  But for read the newspapers there are 33 US and 63 UK examples, making it reasonably more frequent in BrE. So the plural form doesn't undermine the thought-experiment.  But keep experimenting!
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redundant

David C wrote this week to ask:

I know the English use 'redundant' where we USns would say 'laid off' but the question came up whether they would use 'redundant' where we would say 'obsolete' in reference to, say, a 5-year old computer.

Let's back up a bit and discuss what David's taken for granted. In AmE a company can lay off its employees but in BrE a company (or a university!) makes its employees redundant. What's a little confusing is that you can be laid off in the UK too, but it means something different. According to this site (among others) a lay-off is expected to be temporary, as opposed to a redundancy in which you really, really lose your job. But this is not the understanding in AmE, where being laid off is the equivalent of BrE redundancy.

In answer to David's question, objects can also be made redundant in BrE--if they've been made worthless, particularly because they've been superseded by something else. Both Better Half and I feel like this is not quite the same thing as obsolete, but we're a bit hard-pressed to explain exactly why. Do others have this intuition?
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partner

I looked at my collection of e-mails from readers that request coverage of this or that Americanism or Briticism. The collection contains just those that I've not blogged about yet and that I think have at least a little potential to be an interesting post. At my current rate of one post a week, it'll take me a year to get through them--that is, if each e-mail has only one request in it. Maybe a year and a half, then. And they just keep coming in! If you ever thought I'd be out of bloggable ideas by the third year in, you were wrong. (And we're not even counting the topics on my own lists of questions I want answered, gripes I want to air, and little jigs I want to dance on your computer.)

With such a backlog (the ones that I consider answerable go back a year now), it seems a bit unfair that I'm going to write about the one that arrived today. Blame my mother. Whenever my brother didn't get into trouble when any reasonable person could see he was guilty as sin (He really was on my side of the car seat! And besides, HE'S LOOKING AT ME FUNNY!), my mother would explain "Life isn't fair." I took logic (AmE) in college/(BrE) at university, so I figure/reckon: Life isn't fair, and I'm alive, so I don't need to be fair. Right?

Regular reader/requester Jackie wrote today to request coverage of the BrE use of partner (since some of the requests I'm ignoring in order to do this one are hers, it's not that unfair, is it?) . She sums up the situation:
When I lived in London I was forever getting confused by people referring to their heterosexual partners as their partner. In the U.S., when someone refers to his or her "partner," it usually means the other person is the same gender. Or that they are in business together, a source of frequent confusion here. I don't know if it's worth discussing, but do you know how the words acquired the narrower meaning in the U.S. (or the broader reading in the U.K.)?
I am going to come out of the closet and tell you that I LOVE partner! In the UK, it is the unmarked--which is to say normal, usual-- way to refer to the person you share your life with (but usually aren't married to). It's gender-free, works as well for gay and straight relationships, doesn't infantali{s/z}e either party. It's wonderful. In fact, I love it so much, that it's still how I refer to Better Half, even though the law has intervened and I could call him my husband now. It's just such a grown-up, practical word, and I feel grown-up saying it. (I think I'll be at least 70 before I stop getting a kick out of being an adult.)

Jackie asks how it came to be this way. How? Hard to tell without a lot of etymological research, which I haven't the wherewithal to do now. But I can tell you this: the OED has examples of partner meaning 'spouse' going back to Milton (17th century). The business sense goes back a to the 15th century. In between, the word was extended to include dancing partners and bridge partners, etc. The OED comments:

Now increasingly used in legal and contractual contexts to refer to a member of a couple in a long-standing relationship of any kind, so as to give equal recognition to marriage, cohabitation, same-sex relationships, etc.
But it doesn't say when that 'now' started. Milton notwithstanding, it does have the feeling of a modern use. I've heard older BrE speakers expressing discomfort with the term ("that's what they all call it nowadays, isn't it?"), although I think the real discomfort isn't the word partner but the fact that their children are (chiefly AmE) shacking up instead of getting married.

Why don't Americans use it so generally? Probably because gay and lesbian folk started using it, and no one wanted to be mistaken for gay/lesbian, so they avoid it--though the official story is that it 'sounds too business-y'. What do Americans use instead? All sorts of things--there just isn't an unproblematic and widely accepted equivalent. They use boyfriend/girlfriend, significant other, lover and write articles like this.

The fact that it sounds 'business-y' is part of its appeal to me. It doesn't traipse into the emotional or bedroom details of your relationship. It acknowledges that you have to work together with anyone who's such a deep part of your life, that you share goals and assets and responsibilities. And I suspect that is a reason it's found popularity in the UK--it talks about a personal part of your life without getting into the private details. That and the fact that co-habiting relationships (including same-sex relationships) are treated with more seriousness and respect in British law these days, so they require a term that can be used in officialdom as well as by someone wanting to mention the person who picks their dirty socks up off the floor (with only the pleasure of self-satisfied eye-rolling as payment).

Generally (in BrE), if your refer to someone as your partner, people will assume that you live together. But I can think of at least two committed pairs I know who don't live together but who use the term for each other. That's how I can tell when my friends have become serious about the people they're seeing--they start calling him/her 'my partner'.

By the way, I'm retiring the Canadian Count. I've had a few lately, but I've lost count and I think it was only amusing me--and less and less so.
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johns, punters and ponces

Grover and I went out for a lovely lunch with our friend Maverick the other day, and now I find that her pseudonym creates a linkage problem. Do I link to her blog (as is my usual courtesy to people-I-mention-who-have-blogs) or to our previous discussion of AmE/BrE differences in the use of the word maverick? The solution of course is to make a roundabout way of doing both, as I have in this paragraph, but I'll have to (chiefly AmE) figure out a less verbose way of doing it before she points out something else to blog about...

So, Maverick got some good deal on magazine subscriptions and has started reading Time magazine. Though she receives the European edition, she finds that it doesn't make much allowance for the fact that its readers won't necessarily be speakers of American English. So, she was confused by the following sentence (or one like it--not sure if the on-line edition is exactly the same) in an article about recently shamed New York governor Elliot Spitzer:
Just last year, Spitzer had signed a law that lengthened jail time for johns from three months to as much as a year.
Maverick had assumed that john meant 'pimp', and so she was led astray, as it actually means 'prostitute's client'. Now, I think this means that Maverick doesn't watch Law and Order or CSI or any of the other 'gritty' American murder mysteries that are on (UK) Channel Five all the time. The OED marks this meaning of john (there are many more that I don't want to get into here) as 'orig. U.S.', meaning that it has made inroads into BrE.

Maverick and later Better Half tried to think of a BrE word for a man who pays for sex and came up dry. I've heard (BrE) punter used in this way, and there are thousands of examples of it on the web, including:
Meanwhile, lads' magazines continue their assault on British women with articles that aggressively blur the line between girlfriend/boyfriend and prostitute/punter relationships. -- Katherine Viner in the Guardian

The trio all use a website where "punters" - the men who visit prostitutes - go to discuss their encounters. -- Finlo Rohrer in BBC News magazine

Better Half and Maverick both protested, "But punter really means 'gambler'." Yes, I've heard that before, but it's a tough word to (orig. AmE) get a handle on (especially as a newcomer to these isles) because its meanings slide all over the place. The first sense that the OED (draft revision Sept 2007) has for it, dating back to the 18th century, is 'A person who plays against the bank at baccarat, faro, etc.' It then was generali{s/z}ed (as early as the 19th century) to mean any type of gambler and from there to mean someone who pays for something, and particularly a man who pays for a prostitute's services. As a side note, in AmE punter is one who (AmE) punts (drop-kicks the ball) in (American) football, and in the UK another kind of punter is one who propels a punt (a kind of flat-bottomed boat) down a river. The latter kind of punter is not marked as BrE in dictionaries, but much more punting goes on in the UK than in the US.

Back to john, in the OED, it defines the prostitute-client sense as:
A ponce; the client of a prostitute. slang (orig. U.S.).
Now, ponce is another difficult word. But according to the self-same OED (draft revision Mar 2007), it means 'pimp', not 'client':
derogatory slang (chiefly Brit.).
1. A man who lives on money earned by another person (esp. a woman); a kept man. Also: a person (usually a man) who lives off a prostitute's earnings; a pimp.
But I've only heard it used to mean:
2. depreciative. An effeminate or affected man or boy; (also) a male homosexual.
Searching for ponce + prostitute on Google.co.uk, I can only find evidence of it meaning 'pimp', and not 'john/punter'. So, it looks to me like a bad AmE-to-BrE translation in the OED--they haven't got(ten) to the Js yet in the current revision--but I expect this will be changed!

Postscript (1 April--but not an April Fool's joke!): Here's another example of punter, and how easy it is for a newcomer to misinterpret it. It's from The Guide (The Guardian's entertainment listings section, 29 Mar-4 Apr 2008), in a listing for Lucy Porter's stand-up show:
As she said of one of her younger punters, "I want to rip his clothes off -- but only so I can wash and iron them."
Now, they are not claiming that Porter turns tricks, though I originally thought that it meant someone she'd taken home (since they'd just said that "her specialist subject is relationships"), but Better Half was quick to dispel this impression by explaining to me that the 'younger punter' is a member of her audience.
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institutional verbs

One thing that I like about British English is the range of verbs and phrasal verbs for various interactions with public welfare institutions. I don't know why I have such fondness for them--maybe it's just my fondness for the public welfare institutions. When asked by British folk what I like about living in England, my first two answers are: the National Health Service and the trains. They usually express shock or derision, but then I point out how much healthcare costs (and how unevenly it is distributed) in the US and the fact that in my last American place of residence (a city of about 125,000) the Amtrak passenger train came only TWICE A WEEK and even then you had to drive to a couple of towns away to catch it. After those explanations, my appreciation for what might not be the greatest health and transport services in the world seems a lot clearer. As a (smugly) non-car-owning person with chronic illness, I have very few complaints about the services, and tend to find that the loudest complaints come from healthy folk who drive everywhere. But maybe I should save my prejudices about healthy people for another forum. Some of my best friends are healthy. Well, one of them, at least.

(In case you're wondering what my third favo(u)rite thing about living in England/Britain is, it's: everyone seems to have a hobby or passion [besides sitting in front of the tv/(BrE) telly every night]. What fun! If only everyone in my family had a hobby--it would make Christmas shopping so much easier.)

But enough asides (or since they came first, should I call them atops?). Here are some of the BrE institutional verbs I love:
  • to sign on also known as to go on (BrE) the dole: to register to receive social benefits (AmE: welfare or unemployment insurance). I was going to link you to the episode of Spaced in which Daisy tries to sign on, but no one's uploaded that one to YouTube yet. Just when you start to think that you can depend on the Internet, it goes and disappoints you in a fundamental way.

    One can use sign off to mean 'go off benefits (because one has become employed)', but I'm more accustomed to hearing it used to mean:
  • to sign off: (for a medical doctor) to give a medical certificate (to someone), allowing them medical leave from work. This is usually done by one's (BrE) GP -- general practitioner (AmE: primary care physician [though that's (AmE) HMO-speak] or family doctor). This is often used in the passive--e.g. I've been signed off for the next five weeks. When it's used in the active form, the direct object comes between the verb and the particle: The doctor signed John off, not *The doctor signed off John.
Of course, no welfare system is without its cheats, and BrE supplies some interesting verbs for turning them in:
  • to shop (someone): to turn someone in for some misdeed. This isn't only used for fraud against the government, but it's certainly used for that a lot. The OED has it going back for centuries, but says it's now "only slang or dial". For example:
    Council [AmE: municipal government] launches 'shop your neighbour' dustbin [AmE: trash can] hotline (Daily Mail, 12 Oct 2006)
While it is slang-ish, newspapers and even the government use shop quite easily--although often in (AmE) quotation marks/(BrE) inverted commas in order to signal its 'slanginess'.
  • to grass (up) (someone): again, to inform the police/authorities about someone's misdoings. More likely than shop (in my experience) to be used for non-fraud kinds of crimes. There are also the nouns grass and supergrass, meaning a person who grasses. And once one learns that, the name of the band [warning: link makes noise] makes more sense. AmE alternatives that I can think of for this meaning, such as rat, are also found in BrE.
According to someone in this BBC article (which uses both grass and shop):
Most smokers are law-abiding citizens, and I can't believe people will want to shop smokers. It is not the British way.
That it is perceived as 'not the British way' might go a little way to explaining why (in my experience) British universities tend not to have Hono(u)r Codes, in the American sense. At many US universities, one must sign a document promising not to cheat and to report any cheating one knows about. At my UK university, students have to sign statements that they haven't cheated (when they take an exam or submit and assignment), but (as I found when someone grassed on a fellow student) there is no process in place to allow for the investigation of an accusation of cheating that comes from a student, rather than a faculty member.
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to table

Ooh, I'm cruising through the backlog of requests now. We're in June now, with Simon writing to request treatment of the verb table, an example of a Janus word in BrE and AmE meeting lingo.

In the US, meetings are often held according to Robert's Rules of Order, a popular guide to 'parliamentary procedure'. (We may not have a parliament, but we have the procedures! The Congress has its own set of rules.) In the parlance of Robert's and AmE generally, if a motion has been made and is up for discussion, it is on the floor, as in the following quotation from the Princeton Union Eagle:
After a few minutes, Weisenburger said to Girard, "There's a motion on the floor, it's been seconded. Do something."
If you want to remove the motion from the floor--that is, to postpone discussion of it until a later time, you can put it on the table, or table the motion. (You'd then say that the motion is or has been tabled.) So, a tabled motion is not on the floor--it cannot be debated. Here are some examples from the minutes of the 2002 Annual General Meeting of the International Thunderbird Class Association (which may be international, but they seem to be based in Washington state, and they use table in an AmE way):

There was considerable discussion on the issue of the mast weight. Most had to do with the question of whether the matter could be taken off the table and voted upon at the current AGM. It was concluded that it could not, due to the failure of proper notification of the membership about such an action.

If a member wishes to have this motion taken from the table it would require a majority vote of those at the AGM, assuming proper advance notification - distribution to the fleet captains as part of the agenda two months prior to the meeting date. [...]

Currently, the motion is on the table, sine dei. There is no specific date upon which it is to be brought back before the AGM.


In BrE (where parliamentary procedure--or Standing Orders--seems to differ depending on the type of bill being debated and in which House), a motion that is being discussed is on the table. So, you table a motion when you want to bring it up for debate. You can also table questions (bring them up for discussion), according to the House of Commons Standing Orders for Public Business:
Notices of questions shall be given by Members in writing to the Table Office in a form determined by the Speaker. [...] a Member may not table more than five such questions on any one day
Both systems speak of the floor, but it seems to me that there are some differences in its use. This guide to the business of the House of Lords makes the distinction between work done on the floor--i.e. in a House of Lords session, with all members able to examine and discuss the matter at hand, and off the floor--i.e. in committee. In my experience of American government, on the floor would be used in a similar way, but I wouldn't say that work in committee is off the floor, really...I'd limit my use of that phrase to describing more informal behind-the-scenes deal-making (or whatever). Perhaps insiders into either government can give us more insight.

Click on the tag below for more Janus words...including the somewhat related moot.
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fingertip search

I've had a couple of requests (from Dennis in May and Marc in June) for coverage of the BrE phrase fingertip search, and more specifically for the AmE equivalent of the term. It's a term that comes up a lot in the news and in one of the UK's great cultural exports, the murder mystery novel, and thus there are some other available discussions of it on the Internet, for example on Language Log and in this discussion forum for translators.

Let's start with the meaning. Fingertip search (or, more rarely, finger-tip search) is a search carried out by people (rather than technology, like a scanning device) for something that probably needs careful attention in order to be noticed. It is most often used to describe, the goings-on at a crime scene, especially a place where a corpse has been found. This leads to the question, is it a search for fingertips, or a search with the fingertips? The common assumption (in our household, at least!) is that it's the latter. This photo from a 2002 BBC story illustrates the point. It's captioned: 'A fingertip search took place in atrocious weather conditions'.

While/Whilst one mostly finds fingertip search in discussions of crime scene investigations, it's not exclusively used in such contexts. For instance, the Language Log post linked above has an example of a fingertip search for newts and other amphibians, as part of a conservation effort. It does, however, connote an official search. For example, you don't typically hear people saying that they conducted a fingertip search of the bedroom carpet for a lost contact lens, and if you do, it's probably meant to be a little humorous.

Finger(-)tip search
is not to be found in the OED at this point, but we shouldn't conclude too quickly that it's a new term. It's rarely explained in the BrE news contexts in which it is printed, which seems to indicate that the writers feel that they can assume BrE speakers' familiarity with the term. Using Google Book Search, I've found an example in Blackwell's Magazine from 1945.
I remember an age-long fingertip search of a vast sweep of recreation- ground ;
I remember finding a mine balanced weirdly and precariously on its nose
That's as much as I'm allowed to see via Google, but note that even back then, the term is used without explanation--so it must have been a somewhat familiar term by then. It also may not be a crime scene, but the scene of a bombing. (We could consider that a crime scene, I guess.)

As for the question of what the AmE equivalent is, I don't think there is a noun phrase that sums up this meaning in the same way. And there doesn't need to be, since the activity is very describable (e.g. the police searched the scene with a fine-tooth[ed] comb) without a specific noun phrase equivalent. While it's convenient, if you need to talk about something a lot, to have a specific lexicali{s/z}ed expression for a particular concept, there are always other possible ways to describe it too.
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posted, post and mail

On to April's queries--with the goal of getting through them before the term starts.

On a visit to Colorado, Chris was puzzled:
Lining the roads were expanses of trees, and every so often I'd see a sign nailed to a tree that said "Posted."

Nothing else.
We have signs like this in my native New York state, too, and many, if not most, other states--though whether they can get away with just saying Posted might vary. The longer form of the sign would say Posted: No Trespassing, and we could refer to the area of land with these signs at its borders as posted land. In other words, the sign is saying that the land is privately owned (or at least not open to the public) and that you are not allowed to be on the land without the owner's permission, and that because signs have been 'posted' you have been warned of this fact. These kinds of signs, in my experience, are particularly used in wooded areas of countryside. This is the landowner's way of keeping away hunters, anglers, dog-walkers, (AmE) hikers/(BrE) ramblers, (orig. N. Amer. E) snowmobilers, others' livestock, etc. This also gives rise to the transitive verb: to post land--that is, to declare it off-limits by posting signs at specific intervals, as specified by state law. When I was a child, I was told that landowners were allowed to shoot trespassers if they'd posted their land. This, of course, was not true (though it could well have been true a longer time ago). These days, the penalties are fines or short jail stints and/or loss of hunting/fishing licen{c/s}es, depending on the state and whether the trespasser has hunted or has previous convictions. Click for miscellaneous examples from Kansas, Florida and North Dakota.

The trend in (at least northern) Europe is toward public access to private land. The UK recently implemented the Countryside and Right of Way Act (2000), informally known as the right to roam, which allows anyone the right to (BrE) ramble/(AmE) hike on uncultivated land (but not to ride horses, camp, etc.). (Hunting privileges are another matter, about which I have no clue.) For other European countries, see this Wikipedia article.

The Posted signs are pretty opaque in their meaning in the first place, but probably even more foreign to BrE speakers, since the related adjectival meaning of posted is used less in the UK:
2. Set up or fixed in a prominent place; displayed so as to provide information; advertised, made public. Now chiefly N. Amer. [OED: Mar 2007 draft revision]
As in:
1975 N.Y. Times 29 Oct. 28/1 There was ample time to peruse the posted menu of the day's cuisine minceur.
In BrE, one might be more likely to interpret posted menu as a menu that had been sent through the (BrE-preferred) post /(AmE-preferred) mail. (Mailed menu sounds a little odd to me in AmE--I'd probably say menu that had been sent in the mail.) When I worked in South Africa, in the days before widespread e-mail availability, I lived for the post/mail, even though it largely consisted of recitations by my mother of who-ate-what when they went out to dinner last. All of my letters were sent to my work address, so every afternoon, I could be heard to be wondering whether the mail was here yet. One of my colleagues could always be counted on to offer himself as "the male". That trained me into saying post fairly quickly.

Of course, the organi{s/z}ation that delivers the (BrE) post in the UK is the Royal Mail, demonstrating that mail isn't an AmE word, but that the senses and usage of the word varies across the two places. In BrE, it's more likely to be the mail when it is in transit in large bunches, and more likely to be the post when it is on its way from the post office to your door. Hence this entry in the OED (2004 draft revision):
2. a. A bag or packet of letters or dispatches for conveyance by post (more fully [Obs.] mail of letters). In later use chiefly: the postal matter (or a quantity of letters, packages, etc.) conveyed in this manner; all that is conveyed by post on one occasion. With definite article or without article. Also (chiefly in N. Amer.) in pl., and (chiefly S. Asian) with indefinite article.
The plural use mentioned here for AmE, the mails isn't used all that much, and sounds fairly outdated to me. (Something that the Pony Express might deal in, but not the modern-day USPS.) But the 'In later use chiefly' bit in the above definition is more true of BrE than AmE, since the following use is equally dominant in AmE:
c. orig. U.S. The letters, packages, etc., delivered to or intended for one address or individual.
The OED goes on to note that mail in AmE and AusE is also used to refer to the 'system of delivery and conveyance of letters, etc., by post', and notes:
The term mail (as distinguished from post) is currently dominant in North America and Australia, both for the system itself and the material carried. New Zealand retains post for the postal system, but mail otherwise. Britain favours post in both contexts. However, this pattern is not necessarily maintained in historically fixed collocations, such as Royal Mail, Post Office, Canada Post, Australia Post, parcel post, junk mail, etc. In the United Kingdom the word was formerly limited in ordinary use to the dispatch of letters abroad, as the Indian mail, etc., or as short for mail-train.
And thus AmE speakers tend to talk about mailmen--or the less gendered letter carriers--while BrE speakers tend to talk about postmen--but I note that the Royal Mail jobs website uses postperson where space is at a premium, and postman/postwoman elsewhere. Postal worker is used more generically to include people who work in the post office or sorting office, as well as deliverers, and of course some high-profile cases of postal workers (orig. BrE, I think) going mental and shooting people resulted in the AmE colloquialism to go postal.

Of course, postman is also known and used in AmE, as evidenced by The Postman Always Rings Twice and The Postman. This sounds a little old-fashioned to me in AmE, and I think Costner used postman in his title because it sounds a little more exotic than mailman. J. Robert Lennon's book title Mailman, on the other hand, carries with it a more quotidian feel. (Is it perverse to use such an exotic word to mean 'everyday'?)

I suppose we can't leave this subject without touching on e(lectronic)-mail. Much of the history of e(-)mail is situated in US Department of Defense (= BrE Defence) projects, which is probably why we call it e(-)mail, rather than e-post. This, of course, led to the AmE coinage of snail mail, but in BrE, of course, one can distinguish between the two types of communication by referring to e(-)mail versus post.

And with that, I'll post this blog post!
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recuse

The spellchecker will out me. I was writing an e-mail about Examination Board procedures. (Exam boards are a blight on British academic life, and unheard of in the US. I've mentioned them before, here.) In doing so, I typed the word recuse, as in Anyone with a personal relationship with a student should recuse him/herself from discussions of that student. My mail program didn't like recuse. Thinking 'how am I spelling that wrong?', I went to the Oxford Dictionary of English (not to be confused with the Oxford English Dictionary!), where I found the word, spelt as I had spelt it, but with the note: Chiefly U.S. and South African (or something like that--I'm away from that particular dictionary now). I think "Aha! So that's why my British spellchecker didn't like it."* (Although it must be said that it's a pretty pathetic BrE spellchecker, since it insists on one 'l' in travelling.) The OED only lists it as Now rare, but it's not particularly rare in American legalistic settings. The American Heritage definition of it goes:
To disqualify or seek to disqualify from participation in a decision on grounds such as prejudice or personal involvement.
Wondering how one would say this in British English, I had a look in the University's Handbook for Examiners, where they simply instruct the interested party to "leave the meeting while the student in question is being considered." Of course, one could say disqualify in this setting (albeit a little awkwardly), as in I disqualified myself from the discussion of that student. But where's the fun in that?

*Eek! Spellchecking update! Blogger's (American--sort of) spellchecker doesn't like recuse either! Weird, weird, weird. I started to think that my vocabulary is too rarefied for spellchecking. So I googled recuse. It gets over a million hits. Ten times as many hits as uxorious, but the spellchecker has no problem with uxorious (a word that's not in my active vocabulary). Weird.
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moot

Someone some time ago asked about moot. This is a real source of miscommunication in BrE and AmE, as it has opposite meanings when used as an adjective, as in the phrase a moot point.

My first experiences of this word were in relation to moot court scenes in The Paper Chase (that [AmE] show/[BrE] programme was one of the early influences leading to my academic career). (Moot court is a trial practice exercise.) Then there was a sketch on Saturday Night Live that has stuck in my mind for 22 years now (I can't believe that I'm old enough to type that). In it, Jesse Jackson (the guest host, who was running for president at the time) was the host of a game show. He'd ask a contestant a question, and when s/he tried to answer it, he'd interrupt and say "The question is moot!" and then he'd embark on a diatribe about how it doesn't matter when Halley's Comet will appear (or whatever the question was about), because the Reagan administration is going to get us all killed in a nuclear war (etc.). You can see a video of it here.

As that example demonstrates, moot in North America is affected by its American legal sense:
An issue presenting no real controversy.
Moot refers to a subject for academic argument. It is an abstract question that does not arise from existing facts or rights. --Thomson-Gale Legal Dictionary (US)
You can see how this relates to the moot court experience--the exercise is academic and will have no real effect on the world. Meanwhile, in BrE, moot retains the sense 'debatable'. So, in BrE a moot point is one that can/should be debated, while in AmE it's one that isn't worth debating because the issue is already decided or out of our control.

The American Heritage Dictionary gives some context for this meaning variation in the following Usage Note:
The adjective moot is originally a legal term going back to the mid-16th century. It derives from the noun moot, in its sense of a hypothetical case argued as an exercise by law students. Consequently, a moot question is one that is arguable or open to debate. But in the mid-19th century people also began to look at the hypothetical side of moot as its essential meaning, and they started to use the word to mean “of no significance or relevance.” Thus, a moot point, however debatable, is one that has no practical value. A number of critics have objected to this use, but 59 percent of the Usage Panel accepts it in the sentence The nominee himself chastised the White House for failing to do more to support him, but his concerns became moot when a number of Republicans announced that they, too, would oppose the nomination. When using moot one should be sure that the context makes clear which sense is meant.
Whether there's anything that I can add to that is a moot point!
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outwith and diet (the Scottish factor)

As frequent commenters on this blog can tell you, I am not all that up on the details of English as it is spoken in Scotland, nor in the north of England (or Wales, or Northern Ireland...). I'm in the south, on the south coast. South south south. So most of the Scottish speakers I hear are on television (or, in pleasant but intense weekend bursts, Scrabble tournaments). For a while, I was hearing a fair amount of Scottish-accented speech on The Thick of It, a political satire in which the government's spin doctor is played by (*sigh*) Peter Capaldi (whom I still have a crush on due to Local Hero—undaunted by the many more/less savo(u)ry characters he's played since then). In/on the program(me), the Scots seem to run the government really, and it's generally felt that this was made to reflect real life. Sometimes I think it reflects my real life too, as I work at a university in southern England that has a Scottish Vice Chancellor and a history of Scottish people running various administrative departments.

Linguistically speaking, this means that sometimes the unfamiliar terms that come up in the university's administration-speak are Scottish imports. I'm not sure if we're the only university south of the border in which the year's exam diet is spoken of, but my colleagues who have come from other parts of England to work here find this term as foreign as I do. In Scottish law, a diet is a court session—and in academia it is the series of exams and examination boards (a feat of mind-wrenching bureaucracy necessitated by the classification of degrees) that happens at the end of the academic year—i.e. the examination 'season'.

I was reminded of this today when I was filling out a form concerning a new course. It said:
List all the programmes which will include this course. This should include ALL programmes within and outwith your school.
This was not the first time I'd encountered outwith where I would say outside or possibly (but only if I wanted to sound highfalutin in AmE) without. But this time, I was moved to investigate it, and (whaddya know?) it's marked in my dictionaries as Scottish. (My concise dictionaries say Sc(ottish), while the OED says Now chiefly Sc.) A little further investigation on the (AusE>BrE) uni website reveals that the author of the document is a graduate of the University of Aberdeen.

I wondered whether I should start to develop a paranoid theory about the Scottish conspiracy to run my life and drown me in paperwork (for all of my paranoia is deliberate), but then I thought about the fact that all the Scottish people I know are super-nice and very efficient. Contrary to popular stereotypes, they always seem willing to buy a round of drinks. (So what if my sample size is limited to less than a dozen Scots? They're buying!) If these people do have plans to run my life, well, maybe I should let them. Perhaps it'll turn out that all the drink-buying was a ruse, but it's a lot better than the other paranoid fantasies I have to choose from.
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Murphy's/Sod's Law

When I moved to South Africa in the 90s, I found that my American pronunciation of battery would not do when trying to buy batteries in shops. I learned to say, and somehow still say [bætri] instead of my flap-infested, three-syllable American version. Now I live in a place where the word has three syllables but no flap, yet I somehow made myself clear enough to succeed in buying a £7 battery for my watch on Saturday. Three days later, I hear a chink on the ground and it's my watch, which has irreparably broken in the place where the band is held to the watchy bit.

This is an illustration of Sod's law, which is the same law that Americans call Murphy's law ('anything that can go wrong will', etc.). The American name is older, having its origins in the first-half of the 20th century in the US military. (Stories of who the original Murphy was are best treated as apocryphal.) Sod's law came about in the 1970s, and is far more common on these shores than Murphy's law, which is nevertheless usually understood. It probably replaced Murphy's law because of the delicacy of Anglo-Irish relations. (Most Americans would claim that Murphy's law is not an anti-Irish gibe--but if your name is Murphy and you look Irish, you might have a different experience of this.)

Sod is short for sodomite and in this context is probably a play on God's law. It's commonly heard in poor sod--i.e., 'poor bastard' or in many of the places where a stronger vulgarity might be used--e.g. sod-all and sod off. As far as 'naughty' words go, this one is fairly mild these days, and I wouldn't be surprised if a lot of users of the word are unaware of its etymology.
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AmE = American English
BrE = British English
OED = Oxford English Dictionary (online)