Mixed Race Studies

Individualism, Success, and American Identity in The Autobiography of an Ex-Colored Man

African American Review
Volume 30, Number 3 (Autumn, 1996)  
pages 403-419

Kathleen Pfeiffer, Professor of English
Oakland University, Rochester, Michigan

The title character in James Weldon Johnson’s The Autobiography of an Ex-Colored Man embodies the paradox of race and color because he is both legally black and visibly white. The Ex-Colored Man’s response to this paradox defies his audience’s expectations: He believes that it’s possible for blacks to aspire and succeed in America, yet he decides to seize his own opportunity for success by passing as white. Passing in general and the Ex-Colored Man’s narrative in particular have long been viewed as instances of racial self-hatred or disloyalty. Both are predicated, so the argument goes, on renouncing blackness—an “authentic” identity—in favor of whiteness, an “opportunistic” one. These previous interpretations have insisted on a “racially correct” way of reading the text. However, such readings try to categorize a character who often resists categories. Must the Ex-Colored Man’s embrace of the potential for success to which his white skin avails him be seen simply as his co-optation by a culture founded on “white” values? Must passing necessarily indicate a denial of “blackness,” or racial self-hatred and nothing more?

When we look at the Ex-Colored Man as a person who values individualism, who is idiosyncratic, undisciplined, and inclined towards improvisation, we invite a much richer and more complex reading. When we recognize that the Ex-Colored Man demonstrates ambivalence about whiteness as well as blackness, we avail ourselves of the novel’s more complicated nuances. Not strictly fiction, yet not entirely autobiographical, The Autobiography of an Ex-Colored Man reveals the instability of generic distinctions in much the same way that the Ex-Colored Man’s passing reveals the instability of racial distinctions. A textual changeling, the book is taxonomically slippery, encoding into its very pages the sort of disarray and ambivalence which passing evokes; the book’s own stubborn resistance to easy categorization thus suggests the constructed nature of distinctions separating texts as well as races. The Autobiography of an Ex-Colored Man, like the ideology of segregation, incorporates fundamentally contradictory attitudes. In turn, the Ex-Colored Man demonstrates the degree to which this segregation logic permeates our most deeply embedded beliefs about identity, race, and the U.S.A.

Because the book first appeared anonymously in 1912, The Autobiography of an Ex-Colored Man was, understandably, construed by its initial readers as the genuine autobiography of a light-skinned black man who had successfully passed into white society. It was, in fact, a fictional account written by James Weldon Johnson. The narrative’s opening paragraphs offer contradictory motives for the document that follows. At once a divulger of secrets, a confidence man, a trickster figure, and a confes-…

Constitutionality Of Miscegenation Statutes: McLaughlin v. Florida

Maryland Law Review
Volume 25, Issue 1 (1965)
pages 41-48

Lee M. Miller

The appellants, a Negro man and a white woman, were convicted of violating a Florida statute which proscribed cohabitation between Negro and white persons who are not married to each other. The Florida Supreme Court upheld the conviction. On appeal to the Supreme Court of the United States, the appellants claimed: (1) The statute was invalid as a denial of equal protection of the laws since it applied only to members of certain races, and (2) they were denied due process and equal protection of the laws because a Florida law prohibiting interracial marriage prevented them from establishing the defense of common law marriage. The appellants thus hoped to reach the issue of whether the state’s prohibition of interracial marriage contravened the fourteenth amendment. The Supreme Court, basing its decision on the single issue of equal protection (appellants’ first claim), set aside the conviction and invalidated the cohabitation statute. Finding this claim to be dispositive of the case, the Court refrained from expressing any view as to the constitutionality of the law prohibiting interracial marriages.

The provisions of state statutes banning interracial marriage, often called miscegenation statutes, vary considerably, but today all states which have such statutes ban Negro-white marriages, and all declare the proscribed interracial marriages void. Most statutes provide criminal penalties, thus making race an element of a crime. The Maryland statute, for example, proscribes Negro-white and Malay-white marriages and has a mandatory penitentiary sentence.

At one time or another, over half the states had miscegenation statutes. Although these statutes have been repealed by twenty state legislatures, they remain in effect in nineteen other states. Six states have included miscegenation prohibitions in their state constitutions. The highest courts of only two states have held their miscegenationn statutes unconstitutional. Alabama declared its statute unconstitutional in 1872 but reversed itself five years later; California declared its statute unconstitutional in 1948. State courts and lower federal courts have upheld the constitutionality of such statutes. The Supreme Court of the United States has never ruled on the issue. In two cases reaching that Court in recent years, certiorari was denied in one and the issue bypassed in the other.”…

Read the entire article here.

2nd Annual: What Are You?

Brooklyn Historical Society
Crossing Borders, Bridging Generations
2012-10-04, 19:00 EDT (Local Time)

Let’s talk about race and ethnicity, and where we’re from (or where we’re from from); how we express our own multicultural identities, and how others perceive us. Panelists will start the conversation and we hope you’ll join in. We’ll discuss big questions like: How does our cultural background shape us? Can we see race? Is identity fixed or fluid?  #CBBGwhatru

Featuring:

• Jen Chau, founder of Swirl
• Erica Chito Childs, author of Fade to Black and White: Interracial Images in Popular Culture
• Heidi Durrow, co-host of Mixed Chicks Chat and author of The Girl Who Fell from the Sky
• Ken Tanabe, founder of Loving Day
• Angela Tucker, director of Black Folk Don’t

Co-sponsored by Swirl, a multi-ethnic, anti-racist organization that promotes cross-cultural dialogue

For more information, click here.

Tufts Hapa reaches out to mixed-race students

The Tufts Daily: The Independent student newspaper of Tufts University
Medford, Massachusetts
2012-10-03

Alexandria Chu

Among the more than 300 student organizations at Tufts, there are many geared toward specific ethnicities and cultures. Tufts Hapa, a new group on campus, is working to become the only one intended to represent mixed race students.

In 2000, the United States Census was changed to allow citizens to check multiple boxes of racial identification, and the 2010 Census showed a 28 percent increase in interracial households. Tufts Hapa hopes to reflect these changes on campus.

Tufts Hapa aims to create a community of mixed race peoples of part Asian descent, according to President Joseph Wat, a senior. The club is currently in the process of receiving recognition by the Tufts Community Union (TCU) and has the support of the Asian American Center.

Tufts Hapa executive board member and senior Stephanie Howell explained that the start of her involvement in Tufts Hapa stemmed from the instability of past multiracial organizations on campus…

…Tufts Hapa’s faculty support, Assistant Professor of Economics Arthur Chiang, commented on the difficulty of achieving the balance between maintaining pride in ethnicity and solely defining oneself by it, which is particularly tricky for people of a mixed-race heritage.

“I think the basis of [your] social life shouldn’t be based on your race … It’s certainly a concern, everyone just fracturing into their own little [ethnic] groups. Of course, at the same time, no matter what background you have, you should feel some pride in your culture,” Chiang said. “It’s a little bit harder if you’re mixed, so I think a good thing for this club is the celebration of Hapa culture. It’s not an exclusionary thing, but more about learning about our experiences.”…

…Professor of History Gary Leupp notes a feeling of alienation throughout the history of people of mixed-race descent. He gives an example of an epitaph written in 1680 by Pieter Hartsinck, the son of a Dutch merchant and a Japanese woman.

According to Leupp, the epitaph is in St. Jakob’s Church in Osterode, Lower Saxony, Germany, detailing that Hartsinck and his mother were born in the East and his father in Europe.

Leupp quoted Hartsinck, “My destiny varied from the beginning … I left my homeland early in life to find my father’s country. But I could not find my true home.” Leupp explained that Hartsinck accomplished much in his life, even translating Descartes’ work into Latin from French, but his identity struggles are evident in his epitaph…

Read the entire article here.

The Obamas and a (Post) Racial America?

Oxford University Press
January 2011
336 pages
6-1/8 x 9-1/4
Hardback ISBN13: 9780199735204; ISBN10: 0199735204

Edited by

Gregory Parks, Assistant Professor of Law
Wake Forest University, Winston Salem, North Carolina

Matthew Hughey, Associate Professor of Sociology
University of Connecticut

The United States has taken a long and winding road to racial equality, especially as it pertains to relations between blacks and whites. On November 4, 2008, when Barack Hussein Obama was elected as the forty-fourth President of the United States and first black person to occupy the highest office in the land, many wondered whether that road had finally come to an end. Do we now live in a post-racial nation?

According to this book’s contributors, a more nuanced and contemporary analysis and measurement of racial attitudes undercuts this assumption. They contend that despite the election of the first black President and rise of his family as possibly the most recognized family in the world, race remains a salient issue-particularly in the United States. Looking beyond public behaviors and how people describe their own attitudes, the contributors draw from the latest research to show how, despite the Obama family’s rapid rise to national prominence, many Americans continue to harbor unconscious, anti-black biases. But there are whispers of change. The Obama family’s position may yet undermine, at the unconscious level, anti-black attitudes in the United States and abroad. The prominence of the Obamas on the world stage and the image they project may hasten the day when America is indeed post-racial, even at the implicit level.

Features

• Draws on a growing body of scholarly literature on implicit racial bias.
• Discusses the implications of the entire First Family’s rise to prominence, not simply the President’s.

Contents

• Contributors
• Introduction
• Chapter 1: Measuring Racial Progress in America: The Tangled Path of Race – by Matthew W. Hughey (Commentary: Constraint and Freedom in the “Age of Obama” – by Kenneth Mack)
• Chapter 2: Implicit Bias: A Better Metric for Racial Progress? – Leslie Ashburn-Nardo, Robert Livingston and Joshua Waytz (Commentary: The Erasure of the Affirmative Action Debate in the Age of Obama – by Ian Ayres)
• Chapter 3: Black Man in the White House: Ideology and Implicit Racial Bias in the Age of Obama – by Kristin Lane and John Jost (Commentary: Black Man in the White House: A Commentary – Marc H. Morial)
• Chapter 4: Obama-nation?: Implicit Beliefs about American Nationality and the Possibility of Redefining Who Counts as “Truly” American – by Nilanjana Dasgupta and Kumar Yogeeswaran (Commentary: As American as Barack Obama – by Lawrence Bobo)
• Chapter 5: Does Black and Male Still = Threat in the Age of Obama? – by Jennifer A. Richeson and Meghan G. Bean (Commentary: Threat, Fantasy, and President Obama – by Eddie Glaude, Jr.)
• Chapter 6: Michelle Obama: Redefining Images of Black Women – by Shanette C. Porter and Gregory S. Parks (Commentary: First Lady Michelle Obama: Getting Past the Stereotypes – Julianne Malveaux)
• Chapter 7: Barack, Michelle and the Complexities of a Black “Love Supreme” – Clarenda M. Phillips, Tamara L. Brown and Gregory S. Parks (Commentary: The Obamas: Beyond Troubled Love – by Jenée Desmond-Harris)
• Chapter 8: Malia and Sasha: Re-envisioning Black Youth – by Valerie Purdie-Vaughns and Rachel Sumner (Commentary: Re-envisioning Black Youth: A Commentary by Marc Lamont Hill)
• Chapter 9: Obama and Global Change in Attitudes about Group Status – by George Ciccariello-Maher and Matthew Hughey (Commentary: Commentary on Obama and Group Change in Attitudes about Group Status – Michael Dawson)
• Chapter 10: The Role of Race in American Politics: Lessons Learned from the 2008 Presidential Election – by Thierry Devos (Commentary: The State of the Post-racial Union – by Farai Chideya)
• Chapter 11: Obama’s Potential to Transform the Racial Attitudes of White Americans – by Jack Dovidio, Samuel L. Gaertner, Tamar Saguy and Eric Hehman (Commentary: Black Behavior and Moral Dissonance: Missing Mechanisms in Theorizing the Obama Effect – by Richard O. Lempert)
• Chapter 12: New Bottle, Same Old Wine: The GOP and Race in the Age of Obama – by Russell J. Webster, Donald A. Saucier and Gregory S. Parks (Commentary: New Bottle, Same Old Wine: A Response – by Melissa Harris-Lacewell)
• About the Editors, Contributors, and Commentators
• Index

Newsletter Premiere!

National Association of Mixed Student Organizations (NAMSO)
Newsletter 1.1
October 2012

We are thrilled to be sending our first-ever bimonthly newsletter to you.  A new NAMSO initiative, this newsletter is intended to gather and broadcast a trove of updates related to the mixed heritage/multiracial/transracial adoptee community, with a focus on student organizations. 
 
There are so many new and revived student organizations dedicated to mixed identity emerging on campuses across the continent.  We recognize that many students and alums involved with mixed groups are seeking ways to stay connected to others who have shared interests, experiences, and goals.  NAMSO emerged out of a few student organizers’ realization that many of their efforts on campus were mirrored by those of student groups at other schools—but that they were unaware that those other groups even existed.  By shrinking the communication gap between mixed heritage/multiracial student groups at different schools, NAMSO aims to help strengthen, inform, and enable those groups to develop and run successful on-campus organizations focused on a rapidly growing demographic of self-identified mixed heritage students…

To read the entire newsletter, click here.

A.C.T.O.R. presents Dorothy Roberts

Busboys and Poets
14th & V Streets, NW
Washington, D.C.
Langston Room
2012-10-07, 17:00-19:00 EDT (Local Time)

Dorothy Roberts, George A. Weiss University Professor of Law and Sociology; Raymond Pace and Sadie Tanner Mossell Alexander Professor of Civil Rights
University of Pennsylvania

Dorothy Roberts is author of “Fatal Invention: How Science, Politics, and Big Business Re-create Race in the Twenty-First Century.”

A.C.T.O.R. A Continuing Talk on Race – Open discussion. The A.C.T.O.R series is hosted by Busboys and Poets as a community service. This discussion  series provides the opportunity for people to come together and speak openly and honestly about issues of race.  The intent is that each person walks away from the discussion feeling something: challenged, educated, uncomfortable, enlightened, refreshed, reassured and hopefully inspired and moved to action!  Regular discussions take place the first Sunday  of each  month a new topic is discussed, with Busboys and Poets sponsoring a facilitator.

For more information, click here.

The Color of Change: Voting Rights in the 21st Century and the California Voting Rights Act

Harvard Latino Law Review
Volume 15 (2012)
pages 184-231

Joanna E. Cuevas Ingram
University of California, Davis

Table of Contents

• INTRODUCTION
• I. THE VOTING RIGHTS ACT OF 1965 AND THE CALIFORNIA VOTING RIGHTS ACT
• II. U.S. SUPREME COURT DECISIONS ON FEDERAL VRA STANDARDS
  • A. Heightened Burdens of Proof for Potential Plaintiffs
  • B. Post-Racial Penumbras
  • C. The Politics of Containment: Post-Racial Opposition to Voting Rights Remedies
  • D. The Full Spectrum of Voter Discrimination: “Multiracial” Identities and Multiethnic Members of Protected Voting Rights Classes
• III. FEDERAL VRA STANDARDS: CIRCUIT COURT DECISIONS ADDRESSING MULTIETHNIC/MULTILINGUAL COALITIONS
  • A. The Majority View: Recognition of Coalition Plaintiffs
  • B. The Minority View: Non-Recognition of Coalition Plaintiffs
• IV. MULTIETHNIC/MULTILINGUAL COALITIONS IN CALIFORNIA AND THE CVRA
  • A. Multiethnic/Multilingual Coalition Voting Blocs in California
  • B. Impediments and Rewards for Compliance
• V. CONCLUSION

INTRODUCTION

“Once social change begins, it cannot be reversed. You cannot uneducate the person who has learned to read. You cannot humiliate the person who feels pride. You cannot oppress the people who are not afraid anymore. We have seen the future, and the future is ours.”

— César Chávez, Address to the Commonwealth Club of California (November 9, 1984).

In the twenty-first century, we have witnessed the rise of a post-racial national political narrative, particularly as the population in the United States has become increasingly multilingual and multiethnic. This narrative has been fashionably employed by cultural critics, media personalities, elected officials, attorneys, and even courts in an attempt to check the unprecedented surge in the political power of the diverse demographic, allowing these public figures and institutions to gloss over statistically sound cases of voter disenfranchisement in an attempt to dilute or contain what are fast becoming “minority-majority” voting districts.  Under Section 2 of the federal Voting Rights Act (“VRA”) of 1965, illegal vote dilution can be found where an electoral standard, practice, or procedure results in a denial or abridgement of the right to vote on account of race or color, including those instances where it can be demonstrated that the political processes leading to nomination or election in the state or political subdivision are not equally open to participation by members of a protected class of citizens under the VRA…

…D. The Full Spectrum of Voter Discrimination: “Multiracial” Identities and Multiethnic Members of Protected Voting Rights Classes

Opponents of minority coalition claims under Section 2 seem to make another secondary, and offensive, intimation: the idea that multiracial identity itself could frustrate the purpose and practical application of the VRA.

This argument rings hollow after the Bartlett decision, however, particularly given the fact that the U.S. Census Bureau had established clear guidelines in 2000 for data interpretation based on responses that included one or more, two or more, and four or more race/ethnicity selections. Over the last decade, the Census Bureau has developed some incredibly advanced digital statistics on racial demographics by census tract The Bureau continues to maintain relatively accurate analyses of voting patterns and polls for individual groups as well as aggregate groups; data that is readily available online to any inquiring mind.

While more young Americans today do identify as multiethnic, multiracial, or mixed race, self-identification alone does not mean that individuals who so identify believe that they live in a presently post-racial society, nor does it mean that multiethnic or multicultural individuals do not experience any discriminatory treatment. Furthermore, nor does it signify that they are no longer considered members of a protected class or minority group. In fact, many individuals who identify as multiethnic and multiracial speak to the diversity of experiences each person may encounter in equal access to employment, education, housing, health care, insurance, business loans, and other social indicators of discrimination, including access to the political franchise. Increasingly, several scholars who identify as multiethnic and multiracial have worked to craft a discourse of resistance, encouraging individuals, regardless of how they identify, to embrace the complexity of their experiences and heritage by challenging the dominant social, cultural, and political structures that perpetuate white supremacy and racial segregation.

Further, opponents’ arguments that the 2000 Census would complicate litigation projections for local jurisdictions ring hollow; the standards set forth by the Office of Management and Budget (“OMB”) in March 2000 established a coherent framework for the Department of Justice (“DOJ”) in evaluating claims for the purpose of the Voting Rights Act and other remedies designed to address both systemic racial discrimination and individual discriminatory treatment. The 2000 OMB standards, although arguably problematic in dealing with social constructs such as race, have sought to provide a clear framework to respond to systemic discrimination and to accommodate the groundbreaking transformation that the 2000 and 2010 Census have taken in allowing respondents to check more than one ethnicity/race. The rules set forth by the OMB and applied by the DOJ would in fact alleviate any perceived difficulties in meeting the Gingles requirements:

Pursuant to those rules, DOJ will allocate any multiple-race response in which “White” and one of the five other basic categories were checked to the minority race that was checked. Thus, the numbers for each minority race will consist of the total of (i) the single-race responses in which only that minority race was checked; and (ii) the multiple-race responses in which only that minority race and “White” were checked. DOJ will allocate the remaining multiple-race responses—those in which two or more minority races were checked, either along with “White” or without it—to a category called “Other Multiple-Race.” If it finds that a jurisdiction’s “Other Multiple-Race” category contains a significant number of responses that reflect a particular multiple-race combination, it will allocate those responses alternatively to each of the minority races in that combination.”

When it comes to the question of Hispanic or Latino identity, the DOJ has expressed its intention to continue to treat individuals who identify as Hispanic or Latino as members of a distinct minority group for the purpose of enforcing the Voting Rights Act. If the DOJ finds that a significant number of the individuals in the jurisdiction have identified as members of this ethnic category and one or more minority racial groups, it will allocate those responses alternatively to the Hispanic or Latino category and the minority race(s) checked. For example, if the DOJ finds that a significant number of responses checked both Hispanic or Latino and Black or African-American, it will allocate the first of those responses to the Hispanic or Latino category, the second to the Black or African-American category, and so on. While other scholars have confirmed that the DOJ will also have to use the OMB allocation rules in enforcing Section 2 of the Voting Rights Act, they have also posited that the courts are not bound to follow the guidelines as established by the executive branch…

Read the entire article here.

The Hafu Project: October Newsletter

The Hafu Project Newsletter
The Hafu Project
October 2012

The Hafu Project talking at a multicultural family workshop organized by TIPP in Meguro

We hope this email finds you well. This year the summer was harsh in Japan. We do hope you got to enjoy summer wherever you are in the world!

This volume of the newsletter features an interview with hafu writer, Sandra Häfelin, who recently published a book titled “Hafu ga bijin nante mousou desukara!!” (Translation: “It’s only a myth that hafus are beautiful!!”). Sandra was one of the many supporters who kindly participated in The Hafu Project in 2009 in Tokyo. Her website “Hafu wo kangaeyou” explores the topic of hafus through everyday experiences and stories. It is such a joy to read with plenty of real episodes, we highly reccommend her website!

If you happen to live in Japan, you may have noticed a surge of media exposure of hafus. To start with, Nippon Television interviewed a dozen young hafu girls in Harajuku to discuss some of the unexpected cons of being a hafu in Japan (Zoom In Saturday, aired on Sep 15). Weekly magazine SPA also had a dedicated feature on hafus, which included the ins and outs of why hafus are often considered to be a “gaikokujin” (foreigner). In addition, Nagoya Television covered three hafu individuals with varying stories (UP!, aired on Sep 27). Each of these three media exposures had different approaches but certainly added to the current dialogue of being a hafu in Japan…

Read the entire newsletter here.

Void and Voidable Marriages in Maryland and Their Annulment

Maryland Law Review
Volume 2, Issue 3 (1938)
Article 2
pages 211-259

John S. Strahorn Jr., Professor of Law
University of Maryland

The essential task of this article will be to classify invalid or defective marriages in Maryland into those which are totally void and hence subject to collateral attack and those which are only voidable by appropriate steps of direct attack taken during the joint lifetime of the spouses. But, as investigation of this question requires a survey of all the local law concerning the requirements of and impediments to a valid marriage, and, as well, an inquiry into the procedural aspects of annulment, the article will be, in effect, one on the broader questions of validity of marriage and annulment in Maryland.

THE GENERAL DIFFERENCE BETWEEN TOTAL VOIDNESS AND VOIDABILITY

Terminology presents the first problem. The phrase “totally void” will be used herein to express the idea of a marriage’s possessing some defect rendering it susceptible to collateral attack, even after the death of one or both of the spouses. For such marriages no direct step or proceeding to annul is necessary, although the latter may be desirable. “Voidable” will be used to express the idea that the defect, at most, permits the validity of the marriage to be directly attacked by appropriate steps during the joint lifetime of the spouses, although without that the invalidity may not be asserted collaterally in any other proceeding. “Valid” and “completely valid” will be used interchangeably in the sense that the marriage meets all the requirements and encounters none of the impediments so that it can withstand both direct and collateral attack.

In addition to the question of total voidness or mere voidability, there must be considered whether, if the marriage be only voidable, it may be avoided by simple private act, or a judicial proceeding is necessary. Related to this is the matter of ratification, which is possible for some, though not all, voidable marriages and which is considered by some writers to be possible for certain marriages which are otherwise totally void. Whether such a latter class exists in Maryland law will be one of the inquiries of this article.’ A certain confusion exists between a marriage’s being totally void although capable of ratification, and its being voidable by private act without judicial proceeding…

…C. Race (Miscegenation).

White persons and Malayans are forbidden to intermarry and both are forbidden to marry Negroes or persons of Negro descent to the third generation. The statutory mode of expression to cover persons of mixed white and Negro blood is an awkward one and makes doubtful just what proportion of Negro blood will disqualify one from marrying a pure white person or Malayan. It is suggested that if the person in question has some non-Negro blood and that if all of his parents and grand-parents also had some, he is eligible for purposes of the statute, even though he is predominantly Negro.

Is a marriage which is definitely under the statutory ban totally void or only voidable? While no Maryland case has ever dealt directly with either the prohibition generally or the specific problem, a strong dictum in Jackson v. Jackson has indicated that such a marriage, forbidden by our statute, is so totally void that it cannot be recognized even when performed in a state sanctioning such marriages. As has been suggested, this should also determine the issue of total voidness or voidability for the purpose of internal law. This is particularly so in view of the fact that the Jackson case dictum put this type of marriage under the part of the exception to the conflicts rule for those marriages which “the local law making power has declared shall not have
any validity.

Granting such marriages to be totally void, what procedures are available for directly declaring that quality. The statutory procedure does not apply. No doubt, a divorce on the ground of marriage void ab initio could be procured. It is doubtful that an annulment under the general equity practice could be secured. A successful criminal prosecution for entering into the unlawful marriage (if the ceremony occurred in Maryland) or for illicit cohabitation s in Maryland under such an invalid marriage might accomplish the result of a judicial declaration of nullity, even though this does not come under the statutory method, which makes specific mention of criminal prosecution as an annulment device…

Read the entire article here.