Saturday, February 17, 2018

#36 the average and reasonable person




Good morning.

            Two concepts that have interested me for a long time are the "average man" and the "man on the Clapham omnibus," a.k.a. the "reasonable man."  (Both phrases evolved in the 19th century and of course began as "man," not "person," but that solecism has been remedied in more recent scientific and legal literature.  I will use the 19th-century phrasing where appropriate.  I trust that those who read my messages will understand that I would not otherwise use those terms.)  I want to be clear that my meanderings on average and reasonable people doesn't really go anywhere.  You may also find it a snoozer.

The average man is the product of the work of Adolphe Quetelet, starting in 1835; the reasonable man is a fictional person used by the courts in tort law beginning in 1903. 

            In English law, the "prudent man" appeared in 1837 in Vaughan v. Menlove:

The care taken by a prudent man has always been the rule laid down; and as to the supposed difficulty of applying it, a jury has always been able to say, whether, taking that rule as their guide, there has been negligence on the occasion in question.  Instead, therefore, of saying that the liability for negligence should be co-extensive with the judgment of each individual, which would be as variable as the length of the foot of each individual, we ought rather to adhere to the rule which requires in all cases a regard to caution such as a man of ordinary prudence would observe.

            In 1856 the prudent man became the reasonable man, in Blyth v. Company Proprietors of the Birmingham Water Works.

Negligence is the omission to do something which a reasonable man, guided upon those considerations which ordinarily regulate the conduct of human affairs, would do, or doing something which a prudent and reasonable man would not do.

            Later in the 19th century, the reasonable man became "the man on the Clapham omnibus":  "a hypothetical ordinary and reasonable person, used by the courts in English law where it is necessary to decide whether a party has acted as a reasonable person would. . . .  The man on the Clapham omnibus is a reasonably educated, intelligent but nondescript person, against whom the defendant's conduct can be measured."  The phrase formally entered English law in 1903, in an opinion in which the jurist, Sir Richard Henn Collins, in a libel case, cited a judge in an 1871 case.  Lord Bowen in 1871 apparently wrote or said that "'We must ask ourselves what the man on the Clapham omnibus would think.'  Quite why he singled out that particular route we shall never know."  A commentator on the phrase explained Clapham:

When it was first used, Clapham was a lower middle class (in modern terms) area of London in commuting distance to the city (financial district) so users of the omnibus would mainly be clerks, junior office workers, etc.  So the test was actually pretty specific to somebody who was somewhat educated, could read and write but wasn't a professional lawyer/accountant/stockbroker.

A lawyer/historian friend concurred.  "A nondescript commuter suburb seen to represent 'ordinary' London."

The phrase itself is scattered through English literature beginning early in the 19th century.

            The man in the Clapham omnibus remains in English law up to the present.  In a 2014 opinion from the Supreme Court of the United Kingdom, Justice Reed wrote that

1.  The Clapham omnibus has many passengers.  The most venerable is the reasonable man, who was born during the reign of Victoria but remains in vigorous health.  Amongst the other passengers are the right-thinking member of society, familiar from the law of defamation, the officious bystander, the reasonable parent, the reasonable landlord, and the fair-minded and informed observer, all of whom have had season tickets for many years.

2. The horse-drawn bus between Knightsbridge and Clapham, which Lord Bowen is thought to have had in mind, was real enough.  But its most famous passenger, and the others I have mentioned, are legal fictions.  They belong to an intellectual tradition of defining a legal standard by reference to a hypothetical person. . . .

3. It follows from the nature of the reasonable man, as a means of describing a standard applied by the court, that it would be misconceived for a party to seek to lead evidence from actual passengers on the Clapham omnibus as to how they would have acted in a given situation or what they would have foreseen, in order to establish how the reasonable man would have acted or what he would have foreseen. . . .  The behaviour of the reasonable man is not established by the evidence of witnesses, but by the application of a legal standard by the court.

4. In recent times, some additional passengers from the European Union have boarded the Clapham omnibus.  (Given the Brexit vote, those passengers may be getting off the bus in the near future.)

            Wikipedia summarizes the modern-day version of the chap on the Clapham omnibus:

[Per Judge Learned Hand in 1932] The reasonable person standard is by no means democratic in its scope; it is, contrary to popular conception, intentionally distinct from that of the "average person," who is not necessarily guaranteed to always be reasonable.  The reasonable person will weigh all of the following factors before acting:
          the foreseeable risk of harm his actions create versus the utility of his actions;
          the extent of the risk so created;
          the likelihood such risk will actually cause harm to others;
          any alternatives of lesser risk, and the costs of those alternatives.

Taking such actions requires the reasonable person to be appropriately informed, capable, aware of the law, and fair-minded.  Such a person might do something extraordinary in certain circumstances, but whatever that person does or thinks, it is always reasonable.

From A. P. Herbert (1932), "Misleading Cases in the Common Law":

He is an ideal, a standard, the embodiment of all those qualities which we demand of the good citizen. . . .  [He] invariably looks where he is going, . . .  is careful to examine the immediate foreground before he executes a leap or bound; . . . neither stargazes nor is lost in meditation when approaching trapdoors or the margins of a dock; . . . never mounts a moving [bus] and does not alight from any car while the train is in motion, . . . uses nothing except in moderation, and even flogs his child in meditating only on the golden mean.

English legal scholar Percy Henry Winfield summarized much of the literature by observing that:

[H]e has not the courage of Achilles, the wisdom of Ulysses or the strength of Hercules, nor has he the prophetic vision of a clairvoyant.  He will not anticipate folly in all its forms but he never puts out of consideration the teachings of experience and so will guard against negligence of others when experience shows such negligence to be common.  He is a reasonable man but not a perfect citizen, nor a "paragon of circumspection. . . ."

The point of using the man on the Clapham omnibus is that "individual, personal quirks inadvertently injuring the persons or property of others are no less damaging than intentional acts.  For society to function, [wrote Justice Oliver Wendell Holmes] 'a certain average of conduct, a sacrifice of individual peculiarities going beyond a certain point, is necessary to the general welfare.'"

The reasonable person has been called an "excellent but odious character."  The reasonable person can be the reasonable woman, the reasonable disabled person, the reasonable something, in the context of a case.  (The late Justice Scalia dismissed the use of the reasonable woman in cases of sexual harassment, but at least some courts have adopted it.)

            I could be a man on the Clapham omnibus, certainly!  I don't want to be considered odious, although I otherwise qualify because I don't have Achilles' courage, Ulysses' strength, nor am I clairvoyant.  I can't tell to what extent I might be a "paragon of introspection."  Probably more than is healthy.

            Let me turn now to the "average man."  The true "average person" must be bi-gendered, inasmuch as we need to "average" men and women together to get the "average" human being.  Or perhaps, in the term now being used, "non-binary."  (http://gender.wikia.com/wiki/Bigender:  "Bigender is a gender identity which can be literally translated as 'two genders' or 'double gender'.  Bigender people experience exactly two gender identities, either simultaneously or varying between the two.  These two gender identities could be male and female but could also include non-binary identities.")

            As I noted earlier, the idea of the average man was first articulated by Adolphe Quetelet in 1835 ("l'homme moyen").  This guy was clearly a "Renaissance man," a doctorate in mathematics, he produced original and noteworthy work in multiple fields (including "meteorology, astronomy, mathematics, statistics, demography, sociology, criminology and history of science"); he was also an artist and a musician.  Most of us would know him through the body-mass index, which he developed (originally the "Quetelet Index," it was given the name body mass index by Ancel Keyes, a world-famous University of Minnesota physiologist).  Quetelet was, however, primarily a statistician—after he realized he could bring the methods of astronomy to data on human beings.  He was one of the first to make use of data on larger populations to make generalized statements about humans and he's considered the—or certainly one of the—founders of the social sciences (which did not split into different fields—sociology, political science, psychology, etc., until the early 20th century).

            Quetelet began his statistical observations with physical characteristics such as height and weight (hence the development of the body mass index).  He later went on to consider the motivation of behavior in society.  "His principal work, 'A Treatise of Man and the development of his faculties' published in 1835 is considered 'one of the greatest books of the 19th century.'" 

The moral regularities, the aggregates of individual choice, which Quetelet himself investigated included age-specific crime rates for men and (separately) for women.  [The 1835 work was] on the development of human faculties. . . .  Also arousing lively reaction was a term used in the book:  l'homme moyen, the demographically average man, the human being with his individual wishes and peculiarities canceled out, and thus entitled to represent the nation. . . .  [In the 1869 second edition] Quetelet added observed regularities in the number of suicides from year to year, and in the rate of marriage for each sex and age group. This "moral statistics" of Quetelet is the distant progenitor of the modern science of sociology.

Where Quetelet aroused controversy was in his conclusions about the statistics he had compiled.  "Quetelet did not find in these observed social regularities evidence of divine will, as some had done.  He attributed them to social conditions, which were themselves liable to change or be changed."  He identified two types of causes of behavior.  One is the usual package of constant factors that every researcher looks at:  age, sex, education, income, religion, etc.  (He looked at them in combinations, an approach that was forerunner to multivariate analysis now used widely in statistical analyses.)  The other was "free will," which Quetelet largely dismissed and said it was a random cause of behavior that tended to cancel out across large populations.  (Like flipping a coin:  "unpredictable, but tending to average out in the long run.")

Among the philosophical issues raised by Quetelet's theory of social regularity . . . are questions of individual free will, and, ultimately, of individual responsibility for crime.  In Quetelet's own formulation, "Society prepares the crime, and the guilty person is only the instrument by which it is executed." . . .  Equally controversial are questions of the effect, and the desirability, of legislation intended to improve social conditions.

            A few years after Quetelet published his 1835 volume, he followed up with the observation that physical characteristics of humans (such as height, weight, chest circumference) fell into a normal distribution, a bell curve.  There are extreme cases (people really short and really tall) but most of us cluster around the average.

This has philosophical import:  it assigns the human ideal not (say) to the most evolved extreme, the highest end of the distribution, as cultured persons had invariably done up to that time, but rather to the term in the middle, the least extreme, the value with the most examples in that population.

            Todd Rose, in the Atlantic, described what he believed Quetelet's perspective to be.

for Quetelet, the Average Man was perfection itself, an ideal that Nature aspired to, free from error.  He declared that the greatest men in history were closest to the Average Man of their place and time.

Eager to unmask the secret face of the Average Man, Quetelet began to compute the average of every human attribute he could get data on.  He calculated average stature, average weight, and average complexion.  He calculated the average age couples got married and the average age people died.  He calculated average annual births, average number of people in poverty, average annual incidents of crime, average types of crimes, the average amount of education, and even average annual suicide rates. . . . Each of these average values, claimed Quetelet, represented the hidden qualities of the Average Man.

As much as Quetelet admired the Average Man, he held an equal amount of antipathy toward those unfortunate individuals who deviated from the average.  "Everything differing from the Average Man's proportions and condition, would constitute deformity and disease," Quetelet asserted.  "Everything found dissimilar, not only as regarded proportion or form, but as exceeding the observed limits, would constitute a Monstrosity."  He also pronounced, "If an individual at any given epoch of society possessed all the qualities of the Average Man he would represent all that is great, good, or beautiful."

There really cannot be an "average" person, given the physical differences between men and women (that is, born male or female, irrespective of choices they may later make about their gender).   As we all know, the averages of such things as proportion of body fat, height, endurance, strength, and so on, differ between men and women.  The "average" person is thus an impossibility.  It's possible that a male somewhere might, on many measures, approximate the average male; the same is true for a female somewhere.  But the average person can't exist.




(From "Uplift Connect, a feed to my Facebook page)

Nor can the "reasonable" person, the man on the Clapham omnibus (or one of its many passengers), exist.  The courts have pointed out repeatedly that for legal purposes, whether the reasonable person actually exists in a community is irrelevant, because the concept is a legal fiction.

There you have it.  Two of the most widely-used avatars of human beings are imaginary.  How do you compare to the two?


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