CARDOZO LAW REVIEW
Dr. Leo Stone’s 1954 lamentation that “scholarly information
about this important word is remarkable for its scarcity” remains true
The first recorded use is disputed.
Some sources point to the
poem Flen flyys—a Latin and English mix satirizing the Carmelite friars
of Cambridge composed before 1500.
Others claim the first known
use of fuck is in a Scottish poem by William Dunbar, Ane Brash of
Wowing, in 1503.
However, it took nearly another century for fuck to
make its lexicographic debut in John Florio’s 1598 Italian-English
Not surprisingly, the etymology of fuck is unclear. Some
etymologists trace fuck to Germanic languages with an original meaning
of “to knock” and cognates such as Old Dutch ficken , Middle High
German vicken, and German ficken .
This widely accepted derivation,
Stone, supra note 3, at 31.
The quest for the earliest recorded use is an example of historical lexicography. Historical
lexicography is the study of the etymology, chronology, and meaning of words by means of an
historical method that traces the meaning of the word back to its earliest appearance in print. All
later developments in the word’s usage are then illustrated by dated and documented quotations
using the word. See Fred R. Shapiro, The Politically Correct United States Supreme Court and
the Motherfucking Texas Court of Criminal Appeals: Using Legal Databases to Trace the Origins
of Words and Quotations, in L
ANGUAGE AND THE
ROCEEDINGS OF A
368 (Marlyn Robinson ed., 2003).
See, e.g., T
117 (Jesse Sheidlower ed., 2d ed. 1999) (noting the initial citation
as the poem attacking the Carmelite Friars of Ely and dating it as early as 1450-1475). The poem
is named from the first line, “Flen, flyys, and freris,” or “fleas, flies, and friars.” The line
containing fuck is: “Non sunt in coeli, quia gxddbov xxkxzt pg ifmk.” The Latin phrase “Non
sunt in coeli, quia,” means “they are not in heaven, since.” Then the encoded phrase “gxddbov
xxkxzt pg ifmk” is translated by substituting the preceding letter in the alphabet, while being
mindful that i was then used for both i and j, v was used for both u and v, and vv was used for w.
In the end, this leaves “fvccant vvivys of heli.” The translated line reads: “They are not in heaven
because they fuck the wives of Ely.” Wikipedia: The Free Encyclopedia, Fuck,
http://en.wikipedia.org/wiki/Fuck (last visited Jan. 14, 2007) [hereinafter Fuck Definition]; see
also Dictionary.com, Fuck, http://dictionary.reference.com/search?q=fuck, (last visited Aug. 29,
2006) (word history).
See, e.g., Read, supra note 2, at 268; Stone, supra note 3, at 31. The line is: “Yit be his
feiris he wald haue fukkit:/Ye brek my hairt, my bony ane.” Fuck Definition, supra note 24.
The word “fucke” appears in the definition of fottere along with jape, sard, swive, and
occupy. See Stone, supra note 3, at 31.
See Read, supra note 2, at 267-68; see also Jesse Sheidlower, Introduction to T
supra note 24, at xx, xxv (“Fuck is a word of Germanic origin.”); D
supra note 3,
at 32 (noting probable German origin). According to Read, the Latin cognates are pungo (to
prick) and pugil (boxer) which comes from the root pug- (to thrust). See Read, supra note 2, at
267-68. But see Stone, supra note 3, at 32 (noting Read’s etymology and that his “strong opinion
about a unilateral etymology is stated somewhat arbitrarily, without documentation of
intermediate sources”). Germanic origin, however, is also seen from an Indo-European
etymology. See William Whallon, Wicked Cognates, in 12 M
, at 25, 25 (Reinhold
Aman ed., 1996) (explaining Indo-European etymology of fuck using Grimm’s Law). The sound
however, has its critics.
Another possible etymology is through the
French foutre and Latin futuere ,
but there are similar doubts and an
absence of lineage for this derivation as well.
Possibly there is a
hybrid derivation where foutre participated with ficken to produce
Still other etymologies suggest a Celtic derivation.
particular interest to the lawyer-lexicographer is the suggestion of an
Egyptian root petcha (to copulate).
During the last Egyptian
dynasties, legal documents were sealed with the phrase, “As for him
who shall disregard it, may he be fucked by a donkey.” The
hieroglyphic for the phrase—two large erect penises—makes the
Understanding the etymology of fuck is hampered because the
word did not appear in any widely-read English dictionary from 1795 to
The exclusion of fuck from the leading dictionaries illustrates a
deliberate attempt to cleanse the language of this word.
There is no
consensus if fuck was ever acceptable or precisely when it became
However, by the late seventeenth century a
deliberate purge emerges that becomes well entrenched by the
By the late eighteenth century most dictionaries
of p in ancient Indo-European came to be pronounced f by Germanic tribes as in Greek pod with
English foot. The Indo-European g became pronounced k as in Greek gonu and English knee.
Thus the Indo-European pug becomes fuck . Id.
According to Dr. Stone, the general trends of vowel sound change in English fail to
account for the evolution of ficken to fuck. Stone, supra note 3, at 42; see also James M. Ogier,
Sex and Violence in the Indo-European Languages, in 12 M
, supra note 27, at 85, 86-
88 (describing the relationship between fuck and ficken as spurious).
Fuck Definition, supra note 24 (noting the possible connection to futuere and foutre).
Stephen Skinner’s 1671 Etymologicon Linguæ Anglicanæ is targeted as introducing etymological
confusion with derivation through the French foutre ultimately to Greek. See Read, supra note 2,
at 268-69 (noting and criticizing Skinner for “mistakenly trac[ing] the word through the French”).
See Sheidlower, supra note 27, at xxvi (“The relevance of structurally similar words in
more distantly related languages (Latin futuere, for example), is unlikely.”); Stone, supra note 3,
at 42 (expressing doubts concerning the vowel change); Fuck Definition, supra note 24
(“However, there is considerable doubt and no clear lineage for these derivations.”).
Stone, supra note 3, at 42 (describing the combination of foutre and ficken ).
Fuck Definition, supra note 24.
TvWiki: The Free Encyclopedia, Fuck, http://www.tvwiki.tv/wiki/Fuck (last visited Nov.
G. Legman, A Word for It!, in T
9, 12 (Reinhold Aman ed., 1987);
supra note 3, at 13.
Fuck Definition, supra note 24; see Read, supra note 2, at 268-74 (detailing the absence of
fuck from dictionaries). The absence of old citations to fuck makes the etymology hard to trace.
supra note 3, at 24.
supra note 3, at 18 (“Fuck was kept out of print and out of dictionaries for
hundreds of years for being the dirtiest, filthiest, nastiest word in the English language.”).
Fuck Definition, supra note 24 (describing some evidence of acceptability as late as the
seventeenth century and other evidence of vulgarity as early as the sixteenth century).
See Stone, supra note 3, at 31 (“[T]he attack on obscene words in literature began even in
Elizabethan times, and apparently increased in severity thereafter.”); Read, supra note 2, at 269
(describing the strong current against use of low terms which started in the Elizabethan period
CARDOZO LAW REVIEW
were being produced for use in schools; fuck was excluded over
concerns of corrupting young minds.
Not surprisingly, when Samuel
Johnson, Jr. published the first American dictionary in 1798, it omitted
fuck in order to inspire modesty, delicacy, and chastity of language.
Noah Webster’s crusade against vulgar words sealed fuck’s fate in
America: exclusion from his dictionaries of 1806, 1807, 1817, 1828,
This Websterian tradition was carried back across the
Atlantic when in 1898 the authoritative Oxford English Dictionary
(OED) deliberately excluded fuck .
Indeed, its first appearance in the
OED was not until 1972 where the entry gives the guarded “ulterior
Whatever its origins, fuck ’s longevity in English is surprising given
the condemnation and concerted efforts to stamp out its use that
continued throughout the twentieth century. It’s hard for me to believe
that fuck was barely tolerable in print until the 1960s.
The saga to
preserve access to D.H. Lawrence’s classic, Lady Chatterley’s Lover— a
novel banned on three continents until victory over obscenity charges—
illustrates this point.
The print media continues to agonize over the
appropriate use of the word today.
Similarly, most English-speaking
and how the “hold of speech taboo became firmer” in the eighteenth century).
Read, supra note 2, at 271.
Id. at 272-73.
Id. at 273.
Id. at 274. On this score, Read is particularly critical and labels it a “lasting shame” that
the editors would not be true to the scientific spirit of the project and “offset the remissness” of
the earlier lexicographers. Id.
237 (2d ed. 1989); TvWiki: The Free Encyclopedia,
Fuck, http://www.tvwiki.tv/wiki/Fuck (last visited Nov. 12, 2006). Fuck still does not appear in
most dictionaries or gets only an entry or two. D
supra note 3, at 20.
While Jesse Sheidlower recounts that the earliest openly printed use of fuck in the United
States was in 1926, a published 1846 case from the Supreme Court of Missouri states, “The
slanderous charge was carnal knowledge of a mare, and the word ‘fuck’ was used to convey the
imputation.” Shapiro, supra note 23, at 370; see Sheidlower, supra note 27, at xxi-xxii
(identifying first printed example of fuck in U.S. as 1926). Shapiro also notes the 1889 use of
“motherf——g” by the Texas Court of Appeals and the 1897 use of “mother-fucking” by the
Texas Court of Criminal Appeals. Shapiro, supra note 23, at 371.
Lady Chatterley’s Lover was originally published in Florence in 1928. Because of D.H.
Lawrence’s use of fuck, it was banned in the United Kingdom until 1960 when publisher Penguin
Books won an obscenity trial. In Australia, not only was the book banned, but even a book
describing the British obscenity trial was banned. See Wikipedia: The Free Encyclopedia, Lady
Chatterley’s Lover, http://en.wikipedia.org/wiki/Lady_Chatterley%27s_Lover (last visited Nov.
12, 2006). In the United States, Grove Press published the book in 1959. After confiscation by
the U.S. Post Office, the publisher successfully challenged the order and the Second Circuit held
that the work was not obscene. See Grove Press, Inc. v. Christenberry, 276 F.2d 433, 439 (2d Cir.
In June 2004, Vice President Dick Cheney told Senator Patrick Leahy to “fuck yourself”
during a heated exchange on the Senate floor. Helen Dewar & Dana Milbank, Cheney Dismisses
Critic with Obscenity, W
, June 25, 2004, at A04. While The Washington Post reported
the exact use of the phrase, The Washington Times avoided the word altogether by reporting that
Cheney “urg[ed] Mr. Leahy . . . to perform a sex act that’s anatomically impossible.” Amy Fagan,
countries still censor it on radio and television.
vitality is even more amazing when compared to the fate of its sixteenth
century synonyms: jape and sarde are virtually unknown; Chaucer’s
swive is archaic; and occupy returns to English with a nonsexual
Why then is fuck so resilient?
B. Modern Usage
Fuck is a highly varied word. While its first English form was
likely as a verb meaning to engage in heterosexual intercourse,
now has various verb uses,
not to mention utility as a noun, adjective,
adverb, and interjection.
Testimony to the varied nature of the word
fuck is Jesse Sheidlower’s dictionary, The F-Word, the definitive source
on its use.
Now in its second edition, the reference book is devoted
exclusively to uses of the word fuck and now spans 272 pages with
hundreds of entries from absofuckinglutely to zipless fuck.
Linguists studying fuck identify two distinctive words. Fuck
means literally “to copulate.”
It also encompasses figurative uses such
as “to deceive.”
, however, has no intrinsic meaning at all.
Rather, it is merely a word of offensive force that can be substituted in
oaths for other swearwords or in maledictions.
The fact that Fuck
Nation Inside Politics, W
, June 28, 2004, at A05; cf. Moore, supra note 3, at 14
(describing newspapers’ struggles with printing the word). But see Sheidlower, supra note 27, at
xx (contending that few publications still refuse to print fuck ).
Wikipedia: The Free Encyclopedia, History of the Word “Fuck,”
http://en.wikipedia.org/wiki/History_of_fuck (last visited Jan. 14, 2007) [hereinafter History of
the Word “Fuck”]; see Fuck Definition, supra note 24 (describing various FCC actions); see also
infra Part IV.B (detailing FCC censorship).
See Stone, supra note 3, at 35 (summarizing the fate of the early synonyms of fuck); see
also supra note 26 (listing synonyms).
See supra note 24 and accompanying text.
, supra note 24, at 117-33 (identifying fourteen different verb uses).
See id. at 105-12 (listing ten separate noun uses); id. at 116 (defining fuck the adjective as
“describing, depicting, or involving copulation; pornographic; erotic.—used before a noun”); id.
at 141 (showing use as interjection); id. at 168-70 (noting adjective use of fucking ); id. at 171-72
(noting the adverbial use as “exceedingly; damned”).
See generally id. Jesse Sheidlower, who compiled the book, was the Principal Editor of the
OED’s North American Editorial Unit. See Shapiro, supra note 23, at 370.
For the curious, absofuckinglutely is an adverb meaning absolutely; zipless fuck is a noun
meaning an act of intercourse without an emotional connection. See T
, supra note
24, at 1, 272.
One of the most clever uses of fuck is found in Allan Sherman’s book, the Rape of the
A.P.E. Chapter two, entitled “Short Chapter, Long Footnote,” contains a single word—“Fuck.”
It is followed by a nine-page, single-spaced footnote. S
, supra note 15, at 19-27.
See Alan Crozier, Beyond the Metaphor: Cursing and Swearing in Ulster, in 10
115, 122 (1988-89).
Id. at 122-23. Fuck
as a distinct word also has various uses as a part of speech. It can be
CARDOZO LAW REVIEW
be substituted for either God or hell illustrates the lack of any intrinsic
This linguistic distinction is crucial. The legal treatment of
fuck is inconsistent due in part to the lack of recognition of this
Suffice it to say, fuck is everywhere.
As author Roy Blount, Jr.
puts it: “the f-word is a fact of life. It thrives.”
One recent Internet
search revealed that fuck “is a more commonly used word than mom,
baseball, hot dogs, apple pie, and Chevrolet.”
It is present in
and popular music.
used as a noun as in “you’re as lazy as fuck,” as a verb as in “I’m fucked if I know,” as an
adjective as in “This engine’s fucked ,” and as an adverb as in “You know fucking well what I
mean.” Id. at 123.
Id. at 124.
See, e.g., text accompanying infra note 228.
Some commentators believe that “verbal satiation”—where a taboo word heard often
enough loses its effect—is the fate of fuck. See, e.g., Hugh Kenner, What Ever Happened to
., Jan. 20, 1978, at 90, 91. The incidents described in the introduction of
this Article and that of Lorrie Heasley, infra notes 68-69 and accompanying text, lead me to
Roy Blount, Jr., Foreword to T
supra note 24, at xv. For more on Roy Blount,
Jr., see his self-penned biography at Roy Blount Jr., http://www.royblountjr.com (last visited Jan.
See Eric Vanatta, The F-Motion, 21
285, 288-89 (2004) (noting fuck
had 24.9 million search engine hits compared to baseball, its closest competitor, with only 13.6
The use of fuck in R-rated movies intended for adult audiences is now common. It found
exceptional use in S
(Universal Pictures 1983), B
(Metro Goldwin Meyer
1986), and P
(Miramax 1994). See History of the Word “Fuck,” supra note 47
(describing use of fuck in these films). The use of fuck is not limited to the dark side of cinema
either. Hugh Grant repeatedly uttered fuck in the comedy
EDDINGS AND A
(Gramercy Pictures 1994). See Moore, supra note 3 (noting Grant’s humorous use).
On November 10, 2006,
producer/director Steve Anderson released his new documentary,
(Mudflap Films 2006). The film examines the impact of the word fuck on our culture
through interviews, film and television clips, music, and original animation. See Fuck: Four
Letter Film, About the Film, http://www.fourletterfilm.com/film.html (last visited Jan. 14, 2007).
Anderson describes the difficulty inherent in producing a film where its very title is subject to a
All along I've wanted to call the movie just simply “Fuck”, because that is what the
film is about. It’s the center of the film. But just like the word itself, there’s been
much debate about what reaction the title would get. It’s obvious that you couldn’t
print the ads for a film entitled “Fuck” in newspapers like the LA Times or New York
Times. Some newspapers like LA Weekly might print it. How does it go on a
marquee at a festival? So my feeling is this: The title of the movie is “Fuck”. We'll
make a design with an asterisk or a symbol, but the distributors or whoever takes the
film, they’ll have their own ideas. They might use an asterisk. They might use two
asterisks. They might rename it for their purposes just like they do in the newspapers.
But when you go to the theater and you see it onscreen, or when you see it on DVD,
the name of the movie will be “Fuck”. So in an odd way that’s what the movie is all
about; people’s reaction to this word, the reaction to the title. The debate we’ve had as
filmmakers has reflected society’s debate about the word itself. Is it appropriate? Can
we get away with it? Is it a good thing? Is it a bad thing? I think the discussion over
the title of the film reflects exactly what the film is about, so I decided to stick with
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