With Judge and Bull

The problem has long entertained lawyers, particularly those in whom a speculative turn of mind is allied with some proficiency in mathematics. Several exceedingly complex all-purpose theoretical solutions have been proposed. These have been ignored by the courts. A judge who finds himself face to face with a circular priority system typically reacts in the manner of a bull who has been goaded by the picadors: he paws the ground and roars with rage. The spectator can only sympathize with judge and bull.

Grant Gilmore, Circular Priority Systems, 71 Yale L.J. 53 (1961)