<\/p>\n
It is tempting to adopt a certain fatalistic, nihilistic hedonism in the face of a dying world. Law professors can do little as the legal system that they have dedicated their lives to enters its death throes, armed only with articles that are worth considerably less than the paper that they are printed on. In this essay, I argue that the path out of these destructive thought patterns is to begin to embrace their logical conclusion- willful absurdity. I do this through the lens of this fatalism\u2019s most successful pop culture champion, Batman\u2019s nemesis Joker. By recognizing these temptations as those of a misguided villain, it becomes easier to combat them. But Joker and Batman are hugely important to one another, each giving the other a reason to exist and the strength and energy that their respective missions can drain from them. I argue that by embracing the low status of the law professor\u2019s art form, the law review article, and being a little bit silly, authors both gain the energy to move forward in more productive ways and possibly even change things in a way that legal reason alone cannot. Even if this hope is so detached from reality that it is delusional, the delusion seems like one worth embracing and sharing- a folie a deux, if you will.<\/p>\n
Contents<\/p>\n
I. Joker<\/a><\/p>\n II. Devil\u2019s Advocate<\/a><\/p>\n III. The Man Who Laughs<\/a><\/p>\n IV.\u00a0 A Serious House on Serious Earth<\/a><\/p>\n V. The Dark Knight<\/a><\/p>\n VI. The Killing Joke<\/a><\/p>\n Joker is a popular comic book supervillain who serves as the primary antagonist to popular comic book superhero Batman. A fixture of Batman comics since his appearance as the first Batman villain in Batman #1, the clown prince of crime is known for his flamboyant personality, twisted sense of humor, and outlandish thematic weapons. While Joker began his fictional life as a villain in comic books for children, he has gone on to enjoy broad mainstream appeal. For example, two different actors have won Academy Awards for their portrayal of the character.[1]<\/a> One of those actors, Heath Ledger, won said award after his death by fatal drug overdose, further adding to the character\u2019s power over the public consciousness.[2]<\/a><\/p>\n The second of those actors, Joaquin Phoenix, won the award for his performance in Joker<\/em>, a 2019 film that removes the character from his fantastical weapons and relationship with Batman.[3]<\/a> Joker <\/em>tells the story of Arthur Fleck, a mentally ill man who is eventually driven to adopt the persona of a murderous clown after experiencing numerous indignities at the hands of the wealthy, his role model, public services, his mother- society<\/em>, with an emphasis on class and institutional failure.[4]<\/a><\/p>\n While the film was financially successful (becoming the first R-rated movie to make over one billion dollars)[5]<\/a> and an awards favorite (it received 11 Academy Award nominations, winning for Phoenix\u2019 performance and Hildur Guonadottir\u2019s score)[6]<\/a>, the film was critically divisive. Review aggregator Rotten Tomatoes reports that 68% of critic reviews were positive[7]<\/a>– still \u201cfresh,\u201d but decidedly low for such a runaway awards darling.[8]<\/a> Critics noted, among other things, the film\u2019s somewhat unfocused critiques of society.[9]<\/a> The film was about <\/em>class and institutional failure, but it failed to make any interesting or even terribly coherent points about either. [10]<\/a><\/p>\n Many of these critiques came from the online left,[11]<\/a> which eventually lead to the development of the somewhat niche slang \u201cjokerfy\u201d to express a real sentiment with an undercurrent of contempt or dismissiveness towards that sentiment. Urban Dictionary, a crowd-sourced, online slang dictionary, defines \u201cJokerfied\u201d as \u201c\u2026the quality or condition of being disillusioned with society and those who actively engage in it without questioning established norms.[12]<\/a> Urban Dictionary further says that \u201cJokerfication is a joke among leftists\u201d that \u201crefers to\u2026 a reaction to the betrayal of electoralism, manufacturing consent (see the book of the same name) and the seemingly impossibility to affect positive change through the proper means that we should instead embrace absurdism (the belief that human being[s] exist in a purposeless, chaotic universe) or in simplistic terms become like the Joker in the film \u2018Joker \u2013 2019\u2019.\u201d[13]<\/a><\/p>\n In this essay, I discuss what I see as the jokerfication of law. I have wanted to write something like this for a while, but the term that I have used to express this feeling in the past- legal nihilism- does not convey the reality that while I do feel many of the sentiments associated with jokerfication, I also know that it is bad that I think this and want to stop. I begin by making the case for whatever one chooses to call my affliction- doomerism, legal nihilism, jokerfication- and how I choose to express it. I go on to explain the role of Joker in fiction, including why I know the promise of fatalistic absurdity is an empty one. I then show how those who have not embraced this same nihilism reflect a far deeper contempt for the work that they and I have dedicated our lives to than I could even imagine. From there I consider the Joker\u2019s unique relationship with Batman, and how their seeming oppositeness reflects how close they are to one another. I conclude by saying why I do what I do in the face of such despair, hopefully making the case for having more fun, doing something, and, quite possibly, saving the world. It’s going to be a bumpy ride.[14]<\/a><\/p>\n The world is dying.[15]<\/a> Year after year the world continues to blow past carbon emissions targets that were already set far too high to meaningfully avert the impending climate disaster.[16]<\/a> We are beginning to experience the near-constant environmental disasters that threaten to make large sections of the world uninhabitable, from hurricanes to unseasonal fires.[17]<\/a> Many in the global south who are disproportionately effected by the decaying climate have begun to seek refuge in more hospitable environs, where the result has been a rise in heartless nativism rather than any real effort to resolve the problems causing this increase in migration.[18]<\/a><\/p>\n Fears of the impending climate crisis and humanity\u2019s combination of unwillingness and inability to address the issue have only been compounded by one of its many symptoms, the COVID-19 pandemic.[19]<\/a> In many ways, the pandemic served as a trial run of the societal response to climate change.[20]<\/a> The results were not just a categorical failure, but a failure in ways that even the most pessimistic could scarcely imagine.[21]<\/a> Mild inconveniences were treated as unimaginable crimes.[22]<\/a> Prominent public figures, including political leaders and our most influential entertainers, denied the severity and even existence of the pandemic.[23]<\/a> Prior local-level bonds of fellowship irrevocably broke as family and neighbors fell into conspiratorial thought.[24]<\/a> The shift in public sentiment against vaccination that exploded during the role-out of the vaccine that nominally ended the pandemic[25]<\/a> has led to a sharp increase in illnesses kept in check through vaccination efforts, such as Whooping Cough[26]<\/a> and measles.[27]<\/a><\/p>\n In theory, the situation is not hopeless.[28]<\/a> But any solution would involve international mobilization at a level not seen since World War II, and governments that would need to play a key role in such mobilization, such as the United States, have been taken over by leaders and factions who are not only disinterested in such collaboration, but hostile to the notion of doing anything to address the crisis.[29]<\/a> In fact, the only solace many effected by such dubious leadership can take is its complete incompetence.[30]<\/a> This is cold comfort at a time when unprecedented competence is necessary.<\/p>\n The utter failure of the United States government warrants further mention as it spills into the dissolution of the rule of law. A once promising vision of the future (a \u201cshining city on a hill\u201d)[31]<\/a> has decayed over decades of institutional neglect into a rotting husk.[32]<\/a> The ultimate manifestation of that decay is its current inhabitant,[33]<\/a> a chaotic-evil[34]<\/a> bard.[35]<\/a> Legislative action has become basically nonexistent at a time when large-scale legislative action is more necessary than it has ever been.[36]<\/a> This has left most of the work of lawmaking to agencies subject to the whims of the executive, at a time when any positive action towards greater equity faces fierce opposition from the judiciary.[37]<\/a> The judiciary is similarly in total decline, with the Supreme Court at the top of it demonstrating open corruption[38]<\/a> and little interest in doing anything beyond enabling the illegal whims of the United States\u2019 first convicted criminal president.[39]<\/a><\/p>\n The situation would be so much better if this total failure were not so understandable. I wish that I could share my colleagues\u2019 confusion over how an openly racist and misogynist convicted criminal could sweep into power after attempting a coup, but instead I consider it a small miracle that he did not win by greater margins.[40]<\/a> Then-President Joe Biden rose to power promising a return to normalcy, to return to stability after the tumultuous first four Trump years.[41]<\/a> Instead, he governed for four years that felt endlessly chaotic. Some of this was not Biden\u2019s fault. Inflation, which was undeniably a core concern for many voters, would have hampered any president, a fact President Trump acknowledged basically as soon as he had won the election.[42]<\/a> But rather than acknowledge this pain and at least pay lip service to the notion that policy might help ease the burden, Biden and the Democrats effectively told the people that there was no problem and that they were imagining things.[43]<\/a> Further, some of the chaos was very much Biden and the Democratic Party\u2019s fault, including support for Israel in its invasion of Gaza that many consider a genocide.[44]<\/a> While Democrats bought themselves some opportunity to separate themselves from the failures of the Biden administration when they ran his vice president Kamala Harris as their candidate instead of him, her campaign instead went out of his way to not differentiate her from Biden and put on performances with universally reviled former vice president Dick Cheney and his family, embracing a status quo that had not only clearly failed, but had been repeatedly rejected.[45]<\/a> The self-appointed \u201cadults in the room\u201d have repeatedly proven themselves no more adept, and considerably less responsive to the needs and concerns of those they govern, than the rowdiest children.<\/p>\n This unresponsiveness merits further discussion, since it is a major contributing factor to this despair. When I share these concerns with people, I do so out of hope that someone will give me a reason to doubt them. Instead, I get banal, unactionable platitudes. I am fully aware that constant despair is unhealthy and counterproductive, I am trying to talk myself out of it for exactly that reason, so being told once again that it is unhealthy and counterproductive serves no real role other than giving me another worthless emotion, guilt, for worthless emotions that I already feel. Then these same people who insist that my pessimistic predictions are farfetched act surprised when things not only happen more or less exactly as I predicted but somehow wind up being even worse.<\/p>\n Against this backdrop, it has become a common grim joke that law schools and lawyers will be out of work since the law does not mean anything anymore.[46]<\/a> I do think this overstates the case somewhat. There will always be a role for lawyers or someone like them to resolve disputes within civil society. The first days of the second Trump administration have already inspired a flurry of legal activity.[47]<\/a> This activity will likely only continue to increase as many of the judiciary\u2019s moves to empower the executive branch have ultimately expanded the judiciary\u2019s already considerable role in the lawmaking process.[48]<\/a> But this is the trade school argument for the law.[49]<\/a> The law might be a noble trade. The first Trump administration saw a significant increase in law school enrollment, and there is some reason to think that trend will repeat itself in his second.[50]<\/a> Much of the pushback against the unpopular promises of the new administration will come from legal challenges to executive actions.[51]<\/a> But with a judiciary as willing to break all norms and precedent in order to accomplish policy objectives as this one is, all that these battles are good for is buying time, putting sand in the gears of a machine that will still inevitably crush those it targets.[52]<\/a><\/p>\n While the law\u2019s uselessness might be a new experience for many practitioners, legal academics should already be accustomed to the utter meaninglessness of their more high-minded academic efforts. It has been a common refrain for years at this point that nobody reads law review articles.[53]<\/a> Entire doctrines have completely vanished with nary a mention of decades of scholarship surrounding them.[54]<\/a><\/p>\n To use a recent example, my essay Dissecting the Frog<\/em> is successful by the metrics of legal scholarship.[55]<\/a> The essay got a good placement.[56]<\/a> It spent several months at the top of SSRN\u2019s Young Scholars Law eJournal Top 10 Download List.[57]<\/a> I know multiple prominent legal scholars have at least read it, and started conversations based on it.[58]<\/a> Paul Caron shared it on his popular TaxProf blog.[59]<\/a> The piece is a perfect calling card for my scholarly persona, and I am proud of it.<\/p>\n For all of Frog\u2019s<\/em> minor virality, it has been downloaded 185 times.[60]<\/a><\/p>\n Yet despite their total irrelevance beyond small pockets of the small profession, law review articles remain the currency of the realm.[61]<\/a> One must become a prolific, unique scholar in order to move forward in their career path.[62]<\/a> Fortunately, once a school has hired a professor, tenure is far more likely than it is in other disciplines.[63]<\/a> Unfortunately, this simply front-loads the publication requirement, creating a steeper barrier to entry for new voices from less traditional law faculty backgrounds.[64]<\/a> Going up for a tenure-track position without multiple publications is often an exercise in futility.[65]<\/a> We deal exclusively in an irrelevant currency, and in doing so we reinforce our own disconnection from reality and irrelevance.<\/p>\n Faced with this demand that I produce scholarly work for an audience best measured in dozens, I write. There are respectable ways to characterize what I write about. For instance, one could say that I write about the tools of legal trade and those tools\u2019 relationships with those who use them.[66]<\/a> But even that charitable interpretation must account for the fact that Dissecting the Frog<\/em>, for example, is mostly about a meme and arguably includes a dick joke on the first page.[67]<\/a> My work on artificial intelligence displays another trend where I make a modestly relevant observation and couch it in thousands of words explaining pop culture of dubious relevance.[68]<\/a> When I deign to make a doctrinal point, it is about such hot-button issues as cannibalism[69]<\/a> and sandwiches.[70]<\/a> Even with my willfully irrelevant scholarship, my voice and point is compromised. Authorship by Omission <\/em>began its life trying to use its point to illustrate the political disconnect from the legal world to the rest of the political world, trying to fix the problems I have merely complained about here.[71]<\/a> While I believe the article is undeniably superior in its current form- it makes a clearer point in a more compelling way- its current form is a concession to the forces it sought to illuminate.<\/p>\n As questionable as my scholarship may be, I do love all my pieces, and that affection makes it easier for me to write the next one. So it makes me sad when I see people treat this task for a nonexistent audience as drudgery. A lot of this takes the form of students seeing their first project as I did, as a burden to be overcome rather than an opportunity to explore the details of law that reaffirm their love for it and find their own voice. I use my projects to show that the barrier to entry is nowhere near as high as they think it is, and I have found breaking this barrier makes students appreciate law school and their projects more.<\/p>\n But I also see it among my colleagues. The pursuit of meaningless placement in journals whose decisions often feel arbitrary has them writing on what they feel they should <\/em>write about rather than what they want to write about. Days of their lives, thousands of their words, the purest distillation of their academic interest\u2026 all for a piece that they do not like and would just as soon forget. Often, this pursuit of respectability brings no higher engagement or placement than my nonsense. To these people, I simply must ask:<\/p>\n Why so serious?[72]<\/a><\/p>\n Joker gets his namesake from his primary character and visual inspiration, the Joker trading card that comes in a standard deck of cards.[73]<\/a> The character is defined by his perpetual mirthless smile, a trait that is often portrayed as a permanent physical disfigurement forced upon him.[74]<\/a> His villainy often emphasizes forcing this same mirthless grin upon people. From his first appearance, Joker\u2019s primary weapon has been \u201cJoker venom,\u201d a toxin that kills people and leaves their faces with grotesque smiles.[75]<\/a> While the character has gone through periods of being more or less lethal as the demands of selling comic books to children required, his venom has remained his primary tool, forcing laughter and joyless smiles upon his unwilling victims.[76]<\/a> Even the most grounded interpretations of the character have him trying to \u201cput a smile on that face.\u201d[77]<\/a><\/p>\n In keeping with his role in shaping the world to his image, a central element of The Joker\u2019s character, and arguably his greatest threat, is corruption. While Joker is willing and able to force people to adopt his appearance, he has repeatedly shown greater interest in convincing people to adopt his worldview willingly. His longtime sidekick (who has since grown out of her ex\u2019s long shadow) Harley Quinn was originally Harleen Quinzel, a psychiatrist who he manipulated into becoming his accomplice and lover.[78]<\/a><\/p>\n In Alan Moore\u2019s The Killing Joke<\/em>, Joker attempts to drive police commissioner Jim Gordon insane by torturing him and paralyzing his daughter Barbara Gordon.[79]<\/a> This parallels the story\u2019s own offered origin story for The Joker (which the book takes pains to illustrate as one of several possible origin stories but has nonetheless largely been treated as canon in subsequent comics) of a failed comedian whose pregnant wife dies in a household accident shortly before he participates in a chemical factory heist that ends with him falling into a vat of chemicals that disfigures him.[80]<\/a> The Joker\u2019s point is that the world is \u201ca black, awful joke\u201d and that even the sanest person is just \u201cone bad day\u201d away from madness.[81]<\/a><\/p>\n The 2008 film The Dark Knight<\/em> features The Joker attempting to make a similar point. Throughout the film, Joker asserts that people are \u201conly as good as the world allows them to be.\u201d[82]<\/a> Over the course of the film he reveals deep institutional rot within all levels of Gotham society and eventually succeeds in corrupting district attorney Harvey Dent.[83]<\/a> In the film\u2019s third act, Joker attempts to prove \u201c[t]hat deep down, everyone [is] as ugly as [him]\u201d by creating a scenario where a boat full of allegedly respectable Gotham citizens and a boat full of incarcerated criminals both have the opportunity to save themselves by destroying the other boat.[84]<\/a><\/p>\n While Joker seemingly prefers to get people to see the world as he does, his corruption more often comes in inspiring others to take violent action against him. The character is arguably the metatextual reason for Batman\u2019s \u201cno kill\u201d rule, as original Batman creator Bill Finger\u2019s decision to kill off the character in order to prevent Batman from seeming incompetent was overruled by editor Whitney Ellsworth.[85]<\/a> This editorial dispute, along with changing norms in comic publication, transformed into Batman\u2019s strict policy to never kill.[86]<\/a> Appropriately given his role as its origin, Joker is also the character who most frequently tempts Batman to break that rule. The severity of his crimes, paired with society\u2019s inability to hold him to justice, represents the criminal element that Batman has dedicated his life to defeating and his inability to ever achieve victory.<\/p>\n Other characters do not have Batman\u2019s or Gordon\u2019s same resolve. The Joker killed one of Batman\u2019s young wards (known as Robin, a role that has been fulfilled by several different individuals), Jason Todd,[87]<\/a> only for Todd to come back from the dead with the help of multidimensional chicanery and a Lazarus Pit[88]<\/a> and seek to end crime in Gotham by using violent means against the city\u2019s criminal element.[89]<\/a> Todd\u2019s ultimate move is to force Batman to either kill The Joker or kill Todd in order to stop him from murdering the clown, an ultimatum that Batman ultimately thwarts.[90]<\/a> The climax of the film Batman: Mask of the Phantasm<\/em> features Batman trying to stop his former love interest Andrea Beaumont from killing The Joker, who murdered her father.[91]<\/a> Andrea ultimately seemingly succeeds, ending Andrea\u2019s relationship with Bruce (and both of their last chances of happiness) forever.[92]<\/a><\/p>\n These two threads converge in the Batman: The Animated Series <\/em>version of the characters\u2019 death. In Batman Beyond: Return of the Joker<\/em>, we learn that Joker kidnapped that series\u2019 second Robin, Tim Drake, mutilating and torturing him until he became a maniacal mirror image of Joker. [93]<\/a> Having successfully stolen Batman\u2019s surrogate son and adopted Tim as his own, Joker attempts to complete his victory by having Tim shoot Batman. Tim ultimately struggles, then fires the gun at Joker, killing him. [94]<\/a> Joker is surprised and unamused by this turn of events, unlike his prior apparent death in Mask of the Phantasm<\/em>. \u201cThat\u2019s not funny. That\u2019s not funny at all.\u201d[95]<\/a> Even when by all accounts Joker should have won, his ward rejected his worldview in favor of that of his nemesis.<\/p>\n However appealing Joker\u2019s corruption might be, he frequently loses, and he loses because his assessment of the world is wrong. Often those Joker believed he could corrupt remain innocent. Jim Gordon comes out of his ordeal in The Killing Joke <\/em>as sane as he was at its beginning, insisting on doing things \u201cby the book\u201d to prove to him that \u201c[their] way works.\u201d[96]<\/a> In The Dark Knight, <\/em>Joker is proven wrong when neither boat decides to destroy the other.[97]<\/a> The Joker is (seemingly) alone in his madness and susceptibility to corruption.[98]<\/a><\/p>\n Even when he successfully corrupts people, those who gave in to temptation found it unsatisfying and made efforts to escape. Joker is regularly portrayed as an abusive partner to Harley Quinn, who stepped out of his shadow in part by developing a more fulfilling relationship with eco-terrorist Poison Ivy.[99]<\/a> Contemporary portrayals of Jason Todd have shifted him to more of an anti-heroic role than a villainous one, with his stories often revolving around re-finding the purpose and community that his death, rebirth, and heel-turn have taken from him.[100]<\/a> The final exchange of Mask of the Phantasm <\/em>involves a party-goer asking Andrea if she wants to be alone, to which she replies, \u201cI am.\u201d[101]<\/a> As alluring as Joker\u2019s promises might be, there is no reward for those who succumb to them.<\/p>\n Joker\u2019s promises are so unfulfilling because they were always a lie. Joker is no happier and fulfilled under his forced smile than the victims he forces similar grins onto. For all his affected nihilism, Joker keeps trying to convince people that they\u2019re just like him because he cares deeply about proving to himself and others that he is not alone in his madness. For all of Joker\u2019s talk of chaos and unpredictability, his schemes are often thoroughly planned out and a little repetitive. Joker uses the same tool repeatedly, a tool that he seemingly spent years developing and perfecting in private because he also cares deeply about his craft and how he presents it to his audience. However appealing Joker\u2019s promises of freedom, he is every bit as trapped by social norms, other people, and his own neuroses as the rest of us. He, like all of us \u201clive[s] in a society.\u201d[102]<\/a><\/p>\n One peculiar feature of writing academic articles that you love but that you do not think matter in any cosmic sense about law that you think is meaningless is that you come to realize just how little respect for either thing most of those who celebrate their value and meaning have for them. While this is a grotesque oversimplification, it sometimes feels that the more seriously a legal mind takes the legal project, the less they think of the law and its consequences.<\/p>\n There are almost too many examples to count of practitioners and judges showing complete dissatisfaction for the law and its practice. Ours may be a noble profession, but it is also a famously miserable one.[103]<\/a> Substance abuse and mental health issues our common.[104]<\/a> Job retention is low for a profession with such a high barrier to entry.[105]<\/a> Many of the law\u2019s greatest ambassadors, such as popular legal thriller author John Grisham, are former attorneys who left the practice and frequently reflect a pretty dire view of it.[106]<\/a><\/p>\n However, for my example I point to the very top, as I believe much of this misery comes from the top down. Chief Justice of the United States Supreme Court John Roberts has long enjoyed a reputation as the judge\u2019s judge, a center-right institutionalist who simply \u201ccalls balls and strikes.\u201d[107]<\/a> While he has consistently lead an undeniably right-leaning Supreme Court, he repeatedly demonstrated an ability to compromise and build consensus in high-profile cases such as National Federation of Independent Business v. Sebelius<\/em>, upholding the Individual Mandate of the Patient Protection and Affordable Care Act.[108]<\/a> Even as the Court took a sharp rightward turn following President Donald Trump\u2019s appointment of three conservative justices over the course of his first term, Roberts enjoyed some reputation even among his ideological adversaries for curbing the worst impulses of his fellow conservatives.[109]<\/a><\/p>\n That reputation vanished almost entirely over the course of 2024, due in large part to multiple high-profile rulings showing a total disregard for precedent and foundational principles of the American legal system in order to protect Donald Trump from consequences of his attempted coup following his electoral defeat by Joe Biden.[110]<\/a> The capstone of these cases was Trump v. United States<\/em>, a sweeping decision giving former presidents absolute immunity from criminal prosecution for official acts with presidential authority, with presumptive immunity for broadly defined \u201cofficial acts.\u201d[111]<\/a><\/p>\n Trump v. United States<\/em> is a decision so bad that it would be embarrassing if its implications were not so horrifying.[112]<\/a> I make an effort to cite the case at every possible opportunity as an explicit embrace of a foundational pillar of my legal nihilism- that the law simply does not apply to the people most capable of doing harm due to their vast institutional power, precisely because of the vast institutional power that they hold. As compelling as it is to talk about the decision\u2019s numerous follies, from its needlessly expansive reach to its one-sided reasoning to its unclarity on issues clearly presented to the Court for review to its pretensions of eloquence draped in aggressive and willful misapprehensions of quotes from founding fathers such as Alexander Hamilton, I leave that analysis to more erudite scholars with a deeper knowledge of the topic and a less vested interest in talking about Batman villains.[113]<\/a><\/p>\n Instead, I want to focus on the man who wrote the decision and the incredible delusion and disdain for the legal system and the public it governs that his work reveals. The obvious terribleness of the Trump v. United States <\/em>majority opinion becomes even more horrifying when one considers how Roberts saw the ruling prior to its release.<\/p>\n In his writings on the immunity case, the chief justice seemed confident that his arguments would soar above politics, persuade the public, and \u00a0stand the test of time. His opinion cited \u201cenduring principles,\u201d quoted Alexander Hamilton\u2019s endorsement of a vigorous presidency, and asserted it would be a mistake to dwell too much on Mr. Trump\u2019s actions. \u201cIn a case like this one, focusing on \u2018transient results\u2019 may have profound consequences for the separation of powers and for the future of our Republic,\u201d he wrote. \u201cOur perspective must be more farsighted.[114]<\/a><\/p>\n This position is, quite frankly, completely absurd and delusional. At a foundational level, Roberts seemed to think that his expansive view of executive power was an apolitical position, even though the nature of executive power is a hotly contested one, often along political lines.[115]<\/a> He also seemed to think that the public would ever read his meandering prose and pretentious misapprehensions of foundational documents, rather than those already embroiled in the legal profession (maybe) and future law students (if he is lucky, they will probably just find the brief on Quimbee).[116]<\/a> This delusional insistence that anyone cares what he wrote exacerbates his needless abstraction of the issue. In a climate as sharply divided as contemporary American politics, even a clear, concise, and well-written opinion would still be invisible in the face of a sweeping ruling protecting an unpopular former president from the consequences of an attempted coup.[117]<\/a> Roberts tried to read the facts out of a case where the facts themselves posed a foundational problem to the constitutional order.<\/p>\n So, how does someone get where Justice Roberts found himself? I am not a mind reader, and do not have any insight into the machinations of the Supreme Court. But based on what we do know, it seems that Roberts perceived his action as necessary to protect against massive institutional failure. Donald Trump\u2019s various legal battles rarely turned in his favor, with his eventual success in the legal system due to prosecutors\u2019 excessive caution and judicial interference by partisan hacks.[118]<\/a> Despite this, Roberts\u2019 reasoning reflects a complete distrust in the judiciary to resolve the issue fairly and impartially, treating the prosecution of obvious and democracy-threatening crimes as political persecution. This is consistent with reporting that Roberts completely froze out Court\u2019s liberal justices when making his decision, responding to their concerns with an exceedingly defensive five pages that amount to little more than calling their dire predictions of future actions enabled by the decision foolish because they had not happened yet.[119]<\/a> In addition to once again displaying Roberts\u2019 commitment to far-sighted perspective, this section also displays a complete distrust in politically opposed justice\u2019 ability to approach the subject rationally. To get to a point where you write an opinion as tragically bad as Trump v. United States<\/em>, you must believe anyone who rejects it is incompetent.<\/p>\n While Trump v. United States<\/em> is a particularly abhorrent and visible sign of a deep contempt for the legal system and those it governs, the truth is that it fits cleanly within longer-standing trends in Roberts\u2019 behavior. Roberts has been strongly opposed to any attempt to regulate judicial conduct, using his year-end report on the state of the judiciary at a time of historically low trust in the judicial system by waving away massive, widely reported ethical issues within the judiciary[120]<\/a> and comparing people being mean on Twitter to hate crimes.[121]<\/a> When he has used the address for any purpose other than condescendingly dismissing widespread criticism, he has used his platform to discuss the history of typewriters.[122]<\/a> One might expect Roberts to lay off his contemptuous condescension when addressing another branch of government in a legal opinion, but one would be disappointed. Roberts\u2019 holding in Shelby v. Holder <\/em>effectively gutted the Voting Rights Act following the compelling argument that a list of governed states that had been positively affirmed repeatedly over several decades was invalid because the legislature had not thought about it hard enough.[123]<\/a><\/p>\n While Roberts\u2019 open contempt for anyone beyond a narrow band of conservative jurists is well on its way to destroying American democracy, at least it is obvious in his writings and actions. In the realm of legal scholarship, the contempt that many law professors appear to have for their own work product comes through in the overwhelming celebration of generative artificial intelligence. These tools, popularized with the emergence of ChatGPT in late 2022, are effectively word calculators that use existing data to create new content.[124]<\/a> For a variety of reasons, these novel products have become a prolific presence across the internet.[125]<\/a><\/p>\n But also, the content that generative artificial intelligence produces is bad, and not in terribly interesting ways. The problem that has come up the most often in the legal space is AI\u2019s tendency to constantly share wrong information confidently.[126]<\/a> The infamous case Mata v. Avianca <\/em>put this tendency front and center in the legal world, when attorneys repeatedly swore by cases supporting an incorrect legal point that ChatGPT has \u201challucinated,\u201d or effectively made up.[127]<\/a> Google\u2019s \u201cAI Overview\u201d is the first thing that comes up when performing a Google search at this point, a product that gives an extremely basic overview of the topic in question and frequently gives wrong (or misleadingly correct) information.[128]<\/a> Even when the content AI produces is correct, features inherent to the technology\u2019s role as a word calculator make the content that it produces generic, formulaic, and repetitive.[129]<\/a> I do not want to dedicate too much time to the nature of AI\u2019s folly, but I will say that while these products undeniably have their adherents, the market has spoken: for any number of reasons, most people do not want what those proselytizing AI are selling.[130]<\/a><\/p>\n So naturally, the legal community has embraced artificial intelligence with open arms.<\/p>\n AI has been a fixation of the legal community since the technology first emerged. Artificial intelligence was one of the 25 \u201cmost-used keywords for articles accepted via Scholastica in 2024,\u201d[131]<\/a> as well as 2023, 2022, and 2021.[132]<\/a> Much of this embrace has taken the form of buying into the apocalyptic rhetoric of those encouraging the adoption and financing of AI, like ChatGPT CEO Sam Altman.[133]<\/a> The legal community has been all too willing to embrace the technology as an inevitable future that lawyers must embrace if they and their profession are to survive.[134]<\/a><\/p>\n I should acknowledge that even as something of an AI skeptic, it is easy to see the technology\u2019s appeal. Industry-focused products such as Lexis+ AI and Westlaw AI show at least some potential for giving attorneys a basic introduction (complete with solid, if imperfect, initial sources) introducing to topics that they were previously unfamiliar with.[135]<\/a> Furthermore, much of the work product of attorneys is generic, formulaic, and repetitive.[136]<\/a> That is why so much of the work of being a lawyer is plagiarism.[137]<\/a> Attorney work is so repetitive that massive libraries of template documents exist for attorneys to use and modify as similar-but-slightly-different situations present themselves. In a world where attorney workload has skyrocketed while attorney income has remained stagnant, technological shortcuts such as AI have obvious value.[138]<\/a><\/p>\n Where even these respectable shortcuts lose me is when they present themselves in legal academic work. Multiple scholars have openly used generative artificial intelligence to write their articles.[139]<\/a> Michael Smith\u2019s review is sufficient for my purposes: \u201cChat GPT\u2019s output is shallow, vague, repetitive, and meandering.\u201d[140]<\/a> Brian Frye\u2019s review from his own piece using AI is similarly cutting: \u201c[I]f an AI text generator can compete with your scholarship, then you are [a] superficial thinker.\u201d[141]<\/a><\/p>\n Frye\u2019s comment brings up an important point: If legal scholarship is so wildly unpopular that an unambiguous success is lucky to crack 200 downloads, what is the point of writing it? More importantly, what is the point of making such unpopular work the primary barrier to entry into the hallowed halls of academia? One assumes that the point is to demonstrate a scholar\u2019s ability to grapple with a complex idea, to think about something for an extended period, to internalize material and express it in a way that is not only accurate, but insightful. A law review article is unlikely to move the needle on even the lowest level of court proceeding, but an instructor capable of writing a law review article is guaranteed to influence hundreds, if not thousands, of students\u2019 understanding of the law at a foundational level. If that skill can be easily replicated by a machine, what is even the point of developing it? Why on earth are we testing it, much less making it among the most important skills we consider when opening our doors to newcomers?<\/p>\n The good news is that I feel, and I think can demonstrate, that the skill is not so easily replicated by a machine. But then the question turns to those who think a machine has already demonstrated such capacity. If a seasoned law professor cannot see the obvious quality difference between a young professor making a novel point and a computer spewing word salad into the void, that says more about the perception of those young professors than it does the technology. This is to say nothing of our own work. Sure, an insightful subject matter expert is consistently going to be interested in the same things and be a little repetitive in their articles. I\u2019m still a pretty young scholar and I\u2019ve already managed to milk two different articles out of the question \u201cwhy do people like Lexis more than Westlaw.\u201d[142]<\/a> But those two pieces are different from one another, and it is clear that only I (or someone like me) could have written them. I am also biased, but I would argue they are both pretty good but demonstrate clear growth as a scholar over a short period. I encourage those convinced that AI is worthy competition to treat themselves and their work with a bit more respect.<\/p>\n The lack of thematic unity in a man who dresses like a bat\u2019s primary antagonist being a clown is a common joke among Batman fans.[143]<\/a> Several attributes that both Batman and Joker have developed over their lengthy publication histories help to square this asymmetry- Batman\u2019s order versus Joker\u2019s chaos, Batman having a plan for every contingency versus Joker being impossible to plan around, Batman\u2019s introspective seriousness versus Joker\u2019s externalized humor. However, at a more foundational level, consider Batman\u2019s common alias, \u201cThe Dark Knight.\u201d[144]<\/a> Bruce Wayne, the son of one of the founding and foundational families of Gotham who uses his wealth and privilege to protect those living in his realm from harm while living by a strict moral code, fits many of the archetypal features of a knight.[145]<\/a> A jester, on the other hand, played a vital role in many monarchies and noble houses across the world.[146]<\/a> This role is immortalized in the jester\u2019s (also known as a joker)\u2019s inclusion in the French-suited deck of playing cards, alongside nobility such as kings and queens.[147]<\/a> The Joker card is a more recent addition to such decks, introduced as a trump card whose role changes based on the needs of the game.[148]<\/a> As noted above, the Joker playing card eventually served as the inspiration for Joker, with the character often using the playing card as if it were a business card.[149]<\/a> While the joker and knight might not be obvious enemies, they are both clearly connected with one another.<\/p>\n While the role of the jester was primarily to entertain guests during royal court, this role entitled jokers to \u201cJester\u2019s privilege,\u201d or the ability and right to talk and mock freely without punishment.[150]<\/a> The cap and bells and marotte of the court jester symbolized the unique status and legal protection of the jester by mirroring the crown and scepter of a king.[151]<\/a> This freedom gave jesters the ability to give bad news to the nobles that they served without the fear of reprisal that might silence those of nominally higher stature.[152]<\/a> William Shakespeare captured this dynamic and spread it beyond courtly halls in works such as King Lear<\/em>, where the jester offers honest, insightful advice to a king otherwise incapable of receiving it.[153]<\/a> While distinct from the jester or joker, Shakespeare\u2019s fools are clever peasants or commoners who use their wits to outdo people of higher social standing, playing a similar role.[154]<\/a> These characters were frequently among Shakespeare\u2019s most popular characters, beloved by the lower-class \u201cgroundlings\u201d banished to the floor of the theater and the nobility alike.[155]<\/a><\/p>\n Joker is the jester to Batman\u2019s dark knight. The comics themselves have made this explicit, with recent iterations of the character abandoning clown aesthetics for the cap and bells associated with a jester.[156]<\/a> Joker often fills that role in a more foolish manner, a nobody who uses his wits to regularly get the upper hand on a more physically powerful, better-resourced adversary. But while Batman and Joker are adversaries, there is an undeniable camaraderie to their bond. In his chaos, nihilism, and low stature, Joker\u2019s existence allows Batman to indulge in whims he had otherwise denied to himself. Joker shows Batman truths about himself that nobody else can.<\/p>\n Batman and Joker also show surprisingly strong investment in the others\u2019 survival mirroring the king\u2019s protection of his jester. In the Batman: The Animated Series episode The Man Who Killed Batman<\/em>, a devastated Joker gives his nemesis a mournful eulogy before attempting to murder the petty criminal who seemingly murdered Batman.[157]<\/a> In Emperor Joker<\/em>, Joker gains near-godlike powers that he uses to kill and then revive Batman every day.[158]<\/a> Joker ultimately loses, though, when fellow superhero Superman realizes that Joker cannot allow the universe to end (which his continued superpowered existence makes inevitable) because it would mean stopping Batman from existing, a thing that Joker cannot allow to happen.[159]<\/a> \u201cI could never kill you\u2026 Where would the act be without my straight man?\u201d[160]<\/a><\/p>\n Joker and Batman\u2019s protection works both ways. By the end of Mask of the Phantasm<\/em>, Andrea has already killed several people whose crimes pale in comparison to Joker\u2019s, but Joker is the final bridge she cannot cross to maintain her relationship with Batman.[161]<\/a> When Joker dies at the end of the video game Arkham City <\/em>from a self-inflicted illness immediately after murdering Batman\u2019s former love interest (and in some continuities mother of his child) Talia al Ghul, it is Joker\u2019s corpse that Batman melodramatically carries out in mourning.[162]<\/a><\/p>\n If the dark knight extends his protection to his jester, what truths does the jester reveal to his noble benefactor? While there might be discrete examples, at their core the truth is their similarity. While The Joker is wrong about Jim Gordon\u2019s and the average person\u2019s tenuous connection to sanity, Batman is not an average person. Batman\u2019s origin also involved \u201cone bad day,\u201d with the young Bruce Wayne devoting his life and considerable fortune to the mission of dressing up as a bat to beat up criminals (particularly the mentally ill) rather than using that fortune to address the inequities of Gotham life that allow the city\u2019s criminal element to thrive after witnessing the murder of his parents.[163]<\/a> The Killing Joke<\/em> introduced the influential idea that Batman is as insane as the criminals he battles, with the book ending with The Joker and Batman sharing a laugh over The Joker\u2019s joke about two inmates who try to escape an asylum but both fail because of their individual delusions.[164]<\/a><\/p>\n This analysis has evolved in the decades since its introduction, most effectively represented in The Batman of Zur-en-Arrh<\/em>. In that multi-year story, Batman faces an enemy who attempts to take advantage of Batman\u2019s participation in an experimental procedure that he engaged with in order to figure out the motives of Joker.[165]<\/a> The fiend Dr. Simon Hurt systematically attacks Batman\u2019s reason to the point where Batman abandons it completely, adopting Joker\u2019s color scheme and aggressive tactics to defeat his enemy.[166]<\/a> \u201cThe point is clear: if the Batman of Zur-en-Arrh is Bruce Wayne without his reason, then Bruce Wayne without his reason is none other than Joker himself.\u201d[167]<\/a> \u201cJoker in a batman disguise\u2026 at once personifies Bruce Wayne\u2019s forbidden desire for the savage violence, vengeance, and unrestrained freedom that characterize Joker\u2019s madness and <\/em>illustrates just how quickly the scant distance between Joker\u2019s madness and Bruce Wayne\u2019s reason can be traversed.\u201d[168]<\/a> \u201c\u2026[R]ather than a mortal enemy, Joker is the secret, primal source of Batman\u2019s strength.\u201d[169]<\/a><\/p>\n Joker\u2019s joke that finally gets a laugh out of Batman at the end of The Killing Joke<\/em> immediately follows Batman expressing his desire to end things with Joker, acknowledging that they are interlocked on a path that will end in one or both of their deaths, and offering to help rehabilitate him. Joker refuses the offer, then makes his joke.<\/p>\n See, there were these two guys in a lunatic asylum\u2026 and one night, one night they don\u2019t like living in an asylum any more. They decide they\u2019re going to escape! So like, they get up onto the roof and there, just across this narrow gap, they see the rooftops of the town, stretching away in the moonlight\u2026 stretching away to freedom. Now, the first guy, he jumps right across with no problem. But his friend, his friend daredn\u2019t make the leap. Y\u2019see\u2026 Y\u2019ss, he\u2019s afraid of falling. So then, the first guy has an idea\u2026 He says \u201cHey! I have my Flashlight with me! I\u2019ll shine it across the gap between the buildings. You can walk along the beam and join me! B-but the second guy just shakes his head. He suh-says\u2026 \u201cYou\u2019d turn if off when I was half way across!\u201d[170]<\/a><\/p>\n Since it\u2019s all I\u2019m good for, let\u2019s dissect this frog.<\/p>\n Batman and Joker are the two inmates, who share a madness caused by their respective \u201cbad days.\u201d From there, things get a bit murkier. Is the asylum the likely fatal feud that they have found themselves in, or the society containing their shared madness from the rest of the world? Is Batman the first guy, offering a path forward to someone unwilling to take it, or the second, who Joker is trying to lure into madness but vouching for his own untrustworthiness? A reading is certainly possible that each sees themselves in different roles.<\/p>\n The second guy\u2019s distrust is key to a reading that jokerfication is desirable. Much of my fatalism around the state of the world has come from an increasingly dire view of humanity, informed by its decision to seemingly only make bad choices. The science mostly exists to save the world from humanity\u2019s threat to it, but my doubts come from how likely effective adoption of that science is. Once one understands how hopeless the whole situation is, one can at least enjoy what little time we have left, freed from anxieties of a future that will never come.<\/p>\n So, I write. When I write, I stop focusing on the inertia of a world in decaying orbit and instead focus on the energy inherent to creating something new. But creating something truly new is hard, if not impossible. I start with what I already have, and because I am a dubious legal scholar whose primary interests lie outside of my profession that starting point is often a seemingly irrelevant thing that I think illustrates a legal issue in a unique way. This act of taking disconnected elements of a dying world and forming them into a cohesive whole allows me to, however briefly, imagine a world and future that I cannot otherwise envision. Writing gives me energy when the gears of the world have burned me out. Freed from an audience or expectation, I give myself a break from my intellectualized fatalism and just\u2026 have fun.[171]<\/a><\/p>\n This process works so well for the same reason that my perception of the world so frequently drives me to need that energy. Much of the sense that the world\u2019s decay is inevitable comes from its interconnectedness, the fact that so many things so seemingly irrelevant to one another all come together into a tightly woven message to tell those paying attention the same thing. By writing, I get to pick and choose the threads that I see, and when I do I see a world that all of the other threads have made impossible. This means I see these threads on a level playing field. It is tempting to think, as I often do, that this demeans the law, by pointing out its meaninglessness by comparing it to more meaningless things.<\/p>\n The problem with this approach is that it says these threads all mean nothing when the point is the exact opposite. Each thread means everything. Each deserves to be celebrated for all its folly. The affectation of finding the law meaningless gives me the ability to once again find the beauty in this thing that I obviously care deeply about.<\/p>\n Returning to the killing joke, I prefer to think that Joker and Batman are on the same page, and know that Joker is the problem. The asylum is the situation Batman and Joker find themselves in. Batman is the first guy, who can quickly escape the situation on his own. Joker is the second inmate, who distrusts his fellow inmate but more importantly distrusts that he can be meaningfully free (or, as extended to Joker, redeemed). While the first guy\u2019s fate is not clear from the joke, when extended to Batman the delusion and his fate become more clear- he will not leave his friend, because Batman believes that anyone can be redeemed.<\/p>\n Batman is no less delusional than Joker, but he is the hero and Joker is the villain because Batman\u2019s is the better delusion to have. In the momentum I regain by having fun, I can at least briefly imagine that a better world is possible. The arguments that I make are, apparently, somewhat novel.[172]<\/a> But they are rooted in the elemental power of widely popular stories, from a deeply influential genre of fiction to memes to common foodstuffs to books and film intended for an audience of children. As they find even the modest success that my work finds, I see common threads that I had long thought severed re-formed. Maybe those new threads can force the weave driving me down to take a new shape to incorporate it. If my work helps even a few people recover their own lost fun, then I will have done something that makes me deeply proud. Maybe I can be the one with the light, the solution, not the problem.<\/p>\n Unsurprisingly to anyone outside of most of the Supreme Court, the Trump v. United States <\/em>decision provoked instant, vociferous backlash.[173]<\/a> Even someone as disconnected from reality as the Chief Justice was incapable of missing the furious response. Multiple reports note that Roberts \u201cwas shaken by the adverse public reaction to his decision affording Trump substantial immunity from criminal prosecution.\u201d[174]<\/a> \u201cUnlike most of the justices, he made no public speeches over the summer. Colleagues and friends who saw him said he looked especially weary, as if carrying greater weight on his shoulders.\u201d[175]<\/a><\/p>\n I have a fantasy about Justice Roberts\u2019 summer, one that I know is as self-serving and delusional as Roberts\u2019 understanding of Trump v. U.S.. While mine was one of millions of voices denouncing a decision that he apparently considered his magnum opus, I think there is a chance that a man willing to waste a uniquely powerful platform as the head of an increasingly embattled judiciary to talk about typewriters might be interested in a fun, short, modestly successful essay comparing two of the most prominent tools of legal research and writing. In that piece I briefly cite to several high-profile Supreme Court decisions, including Trump v. U.S., as a potential reason for the dissolution of law\u2019s hierarchy.[176]<\/a> I like to think that Justice Roberts read the piece, maybe even found some parts of it interesting and insightful, and then saw that citation and it ruined his day. I like to imagine I am at least a small part of that extra weight bringing him down.<\/p>\n This fantasy is, admittedly, somewhat vindictive and even cruel. I like to think of it as opening the door for someone to rediscover a foundational truth that they have long forgotten by introducing something elemental and foundational in a novel way. I shine at least a small light for him to walk back his disastrous decision. I know that this is not terribly likely. But I have become the guy with the flashlight, not the one who doubts him.<\/p>\n However delusional every part of this fantasy might be, however much less realistic it is than my vision of a human race with no interest in the work of redemption driving the world to an early death, it is a much better delusion to have.<\/p>\n <\/p>\n Sam A. Williams is Reference and Instruction Librarian and Associate Professor of Law, University of Idaho, and a columnist at Hedgehogs and Foxes.<\/p>\n ________________________________________<\/p>\n <\/p>\n [1]<\/a> The 81st <\/sup>Academy Awards 2009<\/em>, Academy of Motion Picture Arts and Sciences (Feb. 22, 2009) https:\/\/www.oscars.org\/oscars\/ceremonies\/2009; The 92nd<\/sup> \u00a0<\/sup>Academy Awards 2020<\/em>, Academy of Motion Picture Arts and Sciences (Feb. 9, 2020) https:\/\/www.oscars.org\/oscars\/ceremonies\/2020.<\/p>\n [2]<\/a> HT Correspondent, The Real Story of Heath Ledger\u2019s \u2018Physically and Mentally Draining\u2019 Descent inot the Mind of the Joker <\/em>Hindustan Times (Apr. 14, 2020) https:\/\/www.hindustantimes.com\/hollywood\/the-real-story-of-heath-ledger-s-physically-and-mentally-draining-descent-into-the-mind-of-the-joker\/story-CyCwBI7t6x619PdhcCWr5K.html.<\/p>\n [3]<\/a> Joker (DC Studios 2019).<\/p>\n [4]<\/a> Id. <\/em><\/p>\n [5]<\/a> LaTesha Harris, \u2018Joker\u2019 Becomes First R-Rated Movie to Hit $1 Billion, <\/em>Variety (last visited Feb. 14, 2025). \u00a0https:\/\/variety.com\/video\/joker-first-1-billion-r-rated-movie-video\/.<\/p>\n [6]<\/a> The 92nd<\/sup> \u00a0<\/sup>Academy Awards 2020<\/em>, Academy of Motion Picture Arts and Sciences (Feb. 9, 2020) https:\/\/www.oscars.org\/oscars\/ceremonies\/2020.<\/p>\n [7]<\/a> Joker<\/em>, Rotten Tomatoes (last visited Feb. 14, 2025) https:\/\/www.rottentomatoes.com\/m\/joker_2019.<\/p>\n [8]<\/a> For comparison, Joker lost the award for Best Picture to Parasite<\/em>, a much better movie about class with 99% critic approval on Rotten Tomatoes. Parasite, <\/em>Rotten Tomatoes (last visited Feb. 14, 2025) https:\/\/www.rottentomatoes.com\/m\/parasite_2019.<\/p>\n [9]<\/a> See, e.g<\/em>., Adam Lubitow, Film Review: Joker<\/em>, City (Oct. 14, 2019) https:\/\/www.roccitymag.com\/movies\/film-review-joker-10926197 (\u201cHas nothing to say about the issues it raises, so they come across like mere window dressing to what\u2019s in the end a fairly conventional comic book supervillain origin story.\u201d); Mark Asch, Joker is a Thinly Veiled (and Thin) Take on \u201880s NYC, <\/em>Hyperallergic (Oct. 18, 2019) https:\/\/hyperallergic.com\/522952\/joker-review-joaquin-pheonix\/ (\u201c[I]t\u2019s disingenuous and pandering for Philips to root through a grab bag of resentments and pick out only the least problematic, like he\u2019s trying to find the last candy in the bag that isn\u2019t licorice.\u201d).<\/p>\n [10]<\/a> See, e.g<\/em>., Joker: The Tears of a Clown, <\/em>Film Frenzy (last visited Feb. 14, 2025) https:\/\/thefilmfrenzy.com\/2019\/10\/04\/joker-the-tears-of-a-clown\/ (\u201cThe actual movie is a shallow and sophomoric effort that isn\u2019t about a raging bull as much as it\u2019s merely raging bullshit.\u201d).<\/p>\n [11]<\/a> See. e.g<\/em>., Jenny Nicholson, Well, I didn\u2019t like Joker, <\/em>YouTube (Oct. 17, 2019) https:\/\/www.youtube.com\/watch?v=0tsdOo_wO44.<\/p>\n [12]<\/a> Jokerfied, Urban Dictionary (Apr. 22, 2020) https:\/\/www.urbandictionary.com\/define.php?term=jokerfied.<\/p>\n [13]<\/a> Jokerfication, Urban Dictionary (March 18, 2020) https:\/\/www.urbandictionary.com\/define.php?term=Jokerfication, (citing<\/em> Edward S. Herman & Noam Chomsky, Manufacturing Consent (1988) (the acceptance of government policies by people in the USA on the basis of the partial picture of issues offered by the mass media, denying them access to alternative views which would lead them to oppose such policies. They present this as a propaganda model in which the mass media select material in relation to the values of those in power.))<\/p>\n [14]<\/a> Batman: Mask of the Phantasm (Warner Bros. 1993).<\/p>\n [15]<\/a> Jonathan Franzen, What if We Stopped Pretending?<\/em>, The New Yorker (Sept. 8, 2019) https:\/\/www.newyorker.com\/culture\/cultural-comment\/what-if-we-stopped-pretending.<\/p>\n [16]<\/a> Emissions Gap Report 2024, <\/em>UN Environment Program (Oct. 24, 2024) https:\/\/www.unep.org\/resources\/emissions-gap-report-2024.<\/p>\n [17]<\/a> Adam B. Smith, 2024: An Active Year of U.S. Billion-Dollar Weather and Climate Disasters, <\/em>NOAA Climate.Gov (Jan. 10, 2025) https:\/\/www.climate.gov\/news-features\/blogs\/beyond-data\/2024-active-year-us-billion-dollar-weather-and-climate-disasters.<\/p>\n<\/h3>\n
<\/a>I.\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Joker<\/h3>\n
<\/a>II.\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Devil\u2019s Advocate<\/h3>\n
<\/a>III.\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 The Man Who Laughs<\/h3>\n
<\/a>IV.\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 A Serious House on Serious Earth<\/h3>\n
<\/a>V.\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 The Dark Knight<\/h3>\n
<\/a>VI.\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 The Killing Joke<\/h3>\n