‘Came to her dressed in mans cloaths’: transgender histories and queer approaches to the family in eighteenth-century Ireland

ABSTRACT This article engages with queer and trans scholarship to produce a methodological think-piece on how to queer the Irish family. It draws on a case study of alleged crossdressing and attempted intimacy that was recorded in the Kirk Session (church court) minute book of the Irish Presbyterian congregation of Templepatrick, County Antrim. In March 1706, a woman named Margaret McCal appeared before Templepatrick Kirk Session and lodged a complaint against a fellow church member. Margaret alleged that an individual known to her as Elizabeth McIlroy had approached her ‘Dressed in mans cloaths’, called themselves ‘David Campbell’ and ‘pretend[ed] courtship to her’. How do we understand this case? What can Margaret’s story tell us about gender, sex, and relationships in eighteenth century Ireland? Moving beyond a reading of the Templepatrick case as a simple instance of crossdressing, this article opens up new discursive pathways in histories of gender and the Irish family by situating it within a trans historical framework. In response to the calls of trans and queer scholars to ‘denaturalise the cisgender turn’, the article begins by interrogating the Presbyterian archive as a cisnormative and heteronormative construction. Next, it offers a trans reading of the case and situates David Campbell, not simply as a woman dressed in men’s clothing but as an individual who moved through the world at particular points in time as a man. Finally, the article ends by queering our understanding of female desire by unsettling the relationship between sex and gender in the pursuit of its fulfilment. Albeit based on one case-study, the story of David and Margaret captures an extraordinary – yet, as I will argue, very ordinary, intimate encounter that has important implications for our understanding of the family in Ireland.

been naughte with her'. 2 The Kirk Session resolved to proceed in the 'ordinaire method' and initiated an investigation, directing an elder to speak to the two alleged witnesses.A citation was also dispatched to Elizabeth to come to the Session when called.Appearing the following month, Elizabeth challenged Margaret to 'prove yt she came to her in mans cloaths by way of courtship '. 3 This Margaret could not do because the two men to whom Elizabeth had allegedly bragged of their intimacies claimed to know nothing of Elizabeth either dressing as a man, nor of the encounter with Margaret.After a period of deliberation, the Kirk Session ruled that there was 'nothing worth time to debate upon', and urged the pair to resolve their differences.At this point, Elizabeth said 'sorry for what she hath don[e]' and expressed sorrow for provoking God and the 'injury' done to Margaret.For this, they were 'seriously rebuked'. 4The Kirk Session then encouraged Margaret to 'forgive' Elizabeth and for the pair to be reconciled -a direction to which they 'both seemingly' complied. 5Albeit brief, amounting to no more than 300 words and two separate entries in the Kirk Session minute book, this case reinvigorates our understanding of the family and its relationships in eighteenth century Ireland.The case not only shines a light on the rich diversity of Irish relationships in the past, but it also underscores the inability of binary approaches to capture the messy realities of Irish family life.As an exercise in uncovering queer lives and in queering historical practice, this article engages with trans studies and scholarship on queer families to form a methodological think-piece for how to queer the Irish family.
Recognising that history is a political act, I want to begin by stating my aims and objectives. 6First, I want to participate in, and contribute to, the writing of histories that have important meanings for individuals who identify as queer, non-binary, and transgender.Today in Ireland, and indeed across many other parts of the world, the trans community is subject to attack. 7Marked out as a 'new invention' of the modern world or as a passing 'fad', the existence of transgendered individuals is often disputed on the grounds of historical evidence.(Heyam,p. 23).An emerging body of scholarship is doing much to challenge this assumption.Studies of transgender lives and queer experiences have blossomed, creating a rich body of exciting and politically-engaged scholarship that challenges fixed and binary approaches to the writing of gender history.From Kit Heyam's masterful long durée study of transgendered histories, to in-depth case-studies of trans individuals who lived in places and times as varied as medieval London, nineteenth-century Australia, and Nazi Germany, our knowledge of trans experiences has been considerably enriched (Boyd & Karras, 1995;Bychowski, 2021;Chesser, 2009;Heyam, 2022;Manion, 2021;Nunn, 2022).The exclusion of a trans reading is therefore not only analytically unsound, it is also harmful.A number of scholars have pointed out how the dismissal of trans explanations undermines the existence of transgender people both in the past and today (Bychowski, 2021).As Gina Watts shrewdly observed in her essay on the queer archive, 'not existing in the archive can seem like not existing at all' (Watts, 2018, p. 105).
Similar approaches have yet to be extensively applied in an Irish context.While much historical focus has been paid to the gay rights movement in Ireland and its political campaigns (Egan, 2016;McDonagh, 2019McDonagh, , 2020McDonagh, , 2021)), the everyday lives of members of the LGBTQ+ community has received comparatively little attention.As Tom Hulme observed in his essay on masculinity and same-sex desire in twentieth-century Belfast, queer histories in Ireland have been more focused on 'politics than experiences' (Hulme, 2021, p. 239).Queer Irish histories are limited in other ways too.Save a few notable exceptions (Connolly, 2000;McAuliffe, 2008;Ó Siocháin, 2017), much historical research on queer lives in Ireland is focused on the period from the late nineteenth-century onwards.This trend owes much to the dearth of primary source materials for the earlier period. 8Irish historians do not have access to the same quantity and quality of source material as their counterparts in Britain and Europe -a want that owes much to the destruction of the Public Records Office in 1922 (O'Dowd, 2018, p. 298).Whereas historians outside of Ireland have been able to partly reconstruct the experiences of individuals through the records of ecclesiastical and secular courts, Irish historians face considerable challenges to do similar work.Moreover, while there have been a number of studies dedicated to individuals whose bodies and behaviours defied neat categorisation, such individuals have yet to be analysed within a trans historical framework. 9By engaging with international scholarship, this article aims to bring Ireland into the scholarly conversation.
Secondly, I aim to queer the history of the Irish family by exposing the limitations of historical approaches that cling to static models for understanding family life.Outside of Ireland, queer histories of the family and marriage have flourished, revealing the myriad ways that people in the past 'did' family life.These approaches extend beyond recovering queer lives in the archives, considering instead how a queer analytic lens can unsettle the very conceptual grounds on how we understand family and the relationships that give rise to it (Berry, 2012;Fish et al., 2018;Goldhill, 2016;Roulston, 2013).For example, Joanne Begiato's article (2023) on eighteenth-century wives has drawn attention to the conceptual possibilities of queering 'wife' as a category.As Begiato notes, women were involved in a 'variety of relationships that were akin to marriage' but did not conform to its legal or social conventions (Begiato, 2023, p. 14).Others, such as Matt Cook and Sharon Marcus have restored stories of queer individuals and their families to broader narratives of kinship, demonstrating how same-sex couplings were intrinsic to normative ideas of family life (Cook, 2010;Marcus, 2007).To paraphrase Marcus, it is only once we suspend our preconception with 'strict divisions' and binaries of male-female, or homosexualheterosexual, that the rich diversity of 'families' and their many different 'social formations swim into focus' (Marcus, 2007, p. 12).
Although not parsed as such, Irish historians have engaged in the process of queering fixed narratives of Irish family life.Focusing on how women and men in Ireland 'did' family, as opposed to how their families mapped (or did not) onto 'ideal' models of family life, a number of studies have pushed understandings of the family beyond the normative/antinormative dichotomy.Studies of Irish (heterosexual) marriage have refined the image of Ireland as a morally chaste and sexually repressed nation that restricted sexual activity to the marriage bed.Maria Luddy and Mary O'Dowd's ground-breaking study of Irish marriage drew attention to the flexibility of marriage as a concept, casting light on the diversity of relationships and methods that gave rise to its celebration (Luddy & O'Dowd, 2020).Likewise, my own work has highlighted the colourful spectrum of sexual relationships that existed in the space between the licit and illicit, disentangling the creation of the family from histories of marriage (Calvert, 2018(Calvert, , 2022a(Calvert, , 2022c(Calvert, , 2023)).Other historians, such as Clodagh Tait, have shown how family life could be performed from beyond the grave, noting how the act of 'mothering' transcended the boundaries between the living and the dead (Tait, 2020).The 'work' of family in relation to companionship, mothering, and economic support could also take place in contexts that were seemingly distant from 'normal' patterns of family life -a theme evidenced in Elaine Farrell's study of women in the Irish convict prison (Farrell, 2020).The 'queering' work of Irish historians continues.As the other articles in this special issue evidence, Irish historians are now actively employed in the practice of 'Queering the family' in order to disrupt taken for granted suppositions about how Irish families were made, sustained, and functioned.Whereas Tom Hulme's essay unsettles the assumption that individuals who engaged in same-sex encounters were excluded from family support networks, Mo Moulton's piece queers the biological boundaries of the family, demonstrating how family ties extended to the non-human.
The following article contributes to this queering tradition by exploring the interpretative possibilities of the case of David Campbell that is archived in the records of Templepatrick Presbyterian church.In response to the calls of trans and queer scholars to 'denaturalise the cisgender turn', the article begins by interrogating the Presbyterian archive as a cisnormative and heteronormative construction.Next, it offers a trans reading of the case and situates David Campbell, not simply as a woman dressed in men's clothing, but as an individual who moved through the world at particular points in time as a man.Finally, it considers the case from the perspective of Margaret and queers our understanding of female desire by unsettling the relationship between sex and gender in the pursuit of its fulfilment.Albeit based on one case-study, their story captures an extraordinary -yet, as I will argue, very ordinary, intimate encounter that has important implications for our understanding of the family in Ireland.
Before moving on to discuss the case in hand, I want to pause and reflect on the use of names and gendered pronouns.This article chose to begin by retelling the case of David Campbell and Margaret McCal verbatim, retaining the original language and spelling used in the minute book.Consequently, David is initially presented to the reader as both male and female, as David Campbell and as Elizabeth McIlroy.These slippages are important in situating David within a trans framework.As I will argue, it is precisely these ambiguities that make David's case such a powerful case-study of Irish family life.Following this initial introduction, the article makes two further decisions in its telling of David's story.Firstly, this article makes the conscious choice to use the name David throughout so as not to participate in, and perpetuate, their 'un-naming' (Bychowski, 2021, p. 104).While the clerk who recorded the case continued to assign them the name Elizabeth, it is important that they called themselves David in the moment they met with Margaret.This article attempts to 'do justice' to David and their story, and respects their right to self-name in that context (Butler, 2004, p. 68).Secondly, this article elects to use gender-neutral pronouns in its discussion of the case and refers, in various places, to the femaleness and maleness of David's presentation.The minutes suggest that not only did David move between gender performances, but they were recognised by those around them as both male and female in specific contexts.While they appeared to Margaret (and the two alleged witnesses) as male, they presented to the Kirk Session as female.Following the lead of Kit Heyam, the article employs they/them pronouns out of a recognition that David embodied 'multiple gendered possibilities at once' (Heyam, 2022, pp. 29-30).

De-coding the Presbyterian archive
To acknowledge that history is not impartial and the archives that facilitate the writing of history are not neutral, is neither a radical nor a new statement to make.It is, however, necessary to repeat.Much has been written about the constructed nature of the archive and its impact on the stories that we write (Burton, 2005;Tortorici, 2018).As Saidiya Haartman astutely pointed out, the archive 'dictates what can be said about the past and the kinds of stories that can be told about the persons' who appear within it (Haartman, 2007, p. 15).Whereas some stories are privileged and easier to reconstruct, many others are pushed to the margins, dismissed as impossible on the grounds of scant evidence, distorted beyond recognition, or at worst, omitted altogether.Take for example the historicised account of the massacre of forty Indigenous individuals at Quarequa, colonial Spain, who were put to death (according to historical accounts and retellings of the event) for engaging in sodomy while dressed as women.In an article on the events at Quarequa, Jamey Jesperson has drawn attention to how the episode has been 'disremembered by colonisation and misread by historians over time' (Jesperson, 2023, pp. 4-5).As a result of a series of 'mistranslations, egregious embellishments and historiographical oversights', the events at Quarequa have been misinscribed in the historical record (and in popular consciousness) as a mass execution for sodomy (Jesperson,p. 3).As Jesperson reveals, the charge of sodomy is 'at best, a speculation, and at that, retrospective' (Jesperson,p. 3).In an effort to push back against a 'colonial trans misogyny' that archives the story to histories of sexuality, Jesperson compellingly argues for the recentring of the 'trans femininity' of those massacred to their story.(Jesperson,.The archive has an important bearing on the stories we write. Historians have also reflected on their entanglements with the archive and the extent to which it is possible, or even methodologically sound, to ignore one's subjectivity in the writing of history (Barclay, 2018;Burton, 2005;Robinson, 2010).Being aware of our inherent biases is also quite powerful.In an intriguing viewpoint piece, Stanley (2018) reflected on how her reading of a sexual assault case from nineteenth-century Japan changed in the wake of the #MeToo movement.Stanley initially read the claims of rape made by Tsuneno, the subject of her research, as the efforts of a woman who 'seize [d] upon "cultural narratives" about seduction and coercion to explain themselves' (Stanley, 2018).As Stanley admits, her 'own social conditioning' and training as a historian had informed her 'reading of the source' (Stanley, 2018).It was only once she reckoned with her inherent biases, asking herself what story she would write if she believed the woman's account, did Stanley begin to explore other stories that could be written about Tsuneno, stories that were 'equally plausible' but which she had 'never considered' (Stanley, 2018).The point is, historians may cling to the notion of objectivity; yet, in reality, the narratives they weave reflect their own interactions with the world and the ways that they move most easily through it.
These methodological issues have an acute importance in trans studies and queer scholarship.As Greta LaFleur, Masha Raskolnikov and Anna Klosowskai have argued, 'The archaeology of knowledge production is central to transgender studies' as a field, which is itself 'uniquely structur[ed]' by 'archival silences, gaps, and erasures' (LaFleur, Raskolnikov and Klosowskai,2021, p. 2).Although made in relation to transgender studies, their point is instructive for historians more broadly, and for historians of the Irish family more particularly.Queer and trans scholars have repeatedly pointed out the dangers of uncritically accepting the cisnormativity of the archive and the lives that it records (Heyam, 2022, p. 19).M.W. Bychowski, for example, has pointed to the cisgendered biases of historical scholarship, critiquing the 'compulsive' decision of historians to 'assign cisgender assumptions to people and texts without stopping to consider trans potentials' (Bychowski, 2021, pp. 96-7).Drawing on the medieval example of Eleanor Rykener, a sex worker in medieval London, Bychowski interrogated the cisnormative construction of their archived story, teasing apart the roles played by Rykener's client Britby and the scribe who recorded the case.In a similar vein to Stanley, Bychowski's essay underscores the interpretative possibilities that emerge from the archive when we listen to the voices of our subjects, tell their stories 'on their own terms' and hold our scholarship 'accountable' (Bychowski,pp 96,110).With these points in mind, how might we then approach the Presbyterian archive and the case of David Campbell?
Let us begin with the minute book itself.The record of the encounter between David and Margaret was inscribed in the minute book belonging to the Presbyterian Kirk Session of Templepatrick, which was situated in a rural parish in County Antrim, Ireland.Presbyterians were a religious minority in Ireland, who were imported to the island as a result of successive waves of emigration from Scotland.Beginning with the arrival of Scottish settlers in the seventeenth-century, the Presbyterian population swelled over the following centuries, establishing a strong foothold in the north-eastern counties of the island.Although Presbyterians emerged as the dominant religious grouping in the province of Ulster, they constituted a minority in Ireland as a whole (Calvert, 2023;Connolly, 1985;Holmes, 2006;MacRaild & Smith, 2013;McBride, 1994).The largest religious grouping in Ireland were Roman Catholics, who made up between three-quarters and four-fifths of the population in the early eighteenth-century (Connolly, 1992(Connolly, , 2008)).Numbers, however, did not equate to political power.Until the mid-nineteenth-century, Ireland was a confessional state in which access to political and civil rights was dependent on adherence to the Established Church of Ireland, which was Anglican.Those who dissented, such as Presbyterians and Roman Catholics, suffered various forms of discrimination as a result. 10 The Presbyterian church exercised control over its adherents through its system of church courts.These courts were hierarchical in their arrangement and included (in descending order of power): the Synod or General Assembly, the Presbytery, and the Kirk Session.While each of these courts were involved in the operation of church discipline, the bulk of their business was dealt with in the lowest court: the Kirk Session.
Acting at a local level, the Kirk Session was made up of the minister of the congregation and a body of elected male representatives, known as elders.Members of the community who breached (or who reported to have breached) church standards were called to appear before this court and account for their behaviour.The types of misbehaviours that warranted church interference can be split into three broadly defined categories: breaches of marital norms, such as bigamy and irregular marriage; social offences, such as intoxication, brawling, and slander; and sexual offences, like fornication and adultery.The latter category constituted the majority of church business dealt with by the Kirk Session (Calvert, 2018(Calvert, , 2022b)).
Community members who were found guilty had to undergo church discipline.Presbyterians in Ireland largely followed the guidance on discipline published in a document by the Church of Scotland known as the Form of Process (Church of  Scotland, 1755). 11An adapted version of this guide was published in Ireland in 1825 known as the Code. 12The purpose of discipline was not merely punitive; rather, it was designed to reclaim and reform the sinner (Holmes, 2006, p. 169).For this reason, the method of discipline was directed to be in line with the gravity of the offence committed.Whereas some sins, like undutifulness to parents, could be handled by the Kirk Session in the form of a private admonition or rebuke, others, such as fornication, merited an immediate suspension from the church privileges of infant baptism and communion.After a period of introspection and under the spiritual guidance of the Kirk Session, offenders were required to stand publicly before the congregation three times before being absolved.Importantly, while the Presbyterian church courts claimed the right to exercise authority over its members, they had no ability to compel them to submit to discipline.As a religious minority in a confessional state, the Presbyterian church had no legal mandate.That the majority of the community did, however, is significant and evidences the important place and power of the church in the lives of its adherents.
The record of the exchange between David and Margaret survives because the proceedings of Templepatrick Kirk Session were recorded in a minute book.Kirk Session minute books were kept to ensure that the courts were following church practice consistently, and they were periodically sent to the Presbytery for approval.It should be noted, however, that church minute books do not survive for every Presbyterian congregation in Ireland.There are less than twenty such minute books in existence for the period before 1800 -Templepatrick being one of them.Whereas some minute books may have been lost over time, it is also possible that some communities did not keep records because they did not practise discipline (Calvert, 2023).The relative survival of these minute books, however, in no way diminishes their importance as sources.Our understanding of the sexual and social worlds of Irish women and men have been greatly enriched by studies that employ the Presbyterian archive (Calvert, 2018(Calvert, , 2022a(Calvert, , 2022c(Calvert, , 2023;;Luddy, 2018;Norman, 2022;O'Dowd, 2004, Luddy andO'Dowd, 2020;O'Dowd, 2017).
In addition to their origins, we also need to consider how these sources were constructed.It is important to note that Kirk Session minute books are authored sources that filter the experiences of those they record through the pen of the clerk.The words of offenders, complainants, witnesses, and indeed the resolutions of the Kirk Session itself, were transferred onto the page by the person who did the note taking.While some statements made before the Kirk Session were transcribed verbatim (or as close to verbatim as possible) and sometimes signified by means of speech marks, more often, the clerk paraphrased what was said and cases were transcribed in the third person.Clerks sometimes made additions to the remarks of an alleged offender to indicate the Session's suspicions that they were being untruthful or that their claims were subjective.For example, when Ann Giles was called to appear before Templepatrick Session in 1703 to answer a report 'that the man she cal[led] her husband' was already married, the clerk emphasised the dubiousness of her claim to marriage.Ann's assertion that her husband was a 'soldier overseas' was preceded by the bracketed qualifier '(so she sayes)'.Similar qualifiers were employed when Ann was 'asked to provide the names of the persons (who she pretends) were present at her marriage'. 13Such doubts were not just reserved for the testimonies of women.The clerk explicitly noted in 1713 that the Session 'doubt[ed] the truth' of Samuel Telford's claim that he could not appear publicly because 'he came under an oath many years ago, that he would never appear before a congregation to confess any sin'. 14 The methodological challenges of using the records of courts, whether ecclesiastical or secular, to access the intimate and subjective lives of individuals is well recognised by historians.On the one hand, scholars have been attendant to the problems of reconstructing intimate histories with archives that were created for the purpose of regulating the deviant and the disorderly.As Julie Hardwick pointed out, the constructed nature of the archive can distort our view, highlighting 'the problematic rather than the ordinary' (Hardwick, 2020, p. 8).This is particularly important to bear in mind when writing histories of the LGBTQ+ community.As Rictor Norton observed in his essay on recovering 'gay histories' from the Old Bailey, we must tread carefully with sources in which individuals 'become visible almost solely through the records of crime and scandal' if we want to produce a history of homosexual experience as opposed to a history of homophobia (Norton, 2005, p. 41, 44).
On the other hand, scholars must also confront the challenge of accessing the 'authentic voices' of individuals who appeared before the courts (Stretton, 2019).Testimonies delivered in court were not only carefully crafted to secure the best outcome for the person who spoke, but they were shaped by wider social and cultural values. 15The voices that appear in court records were thus multi-authored.In addition to the scribes who wrote down and edited the words of those who spoke in court, the content of that speech was also shaped by the advice of lawyers, friends, and family members.Historians are now encouraged to consider the sources produced before these courts as collaborative documents that provide a larger window into the society and people that shaped them.As Frances Dolan has argued, 'To acknowledge the clerk is not to replace the deponent with the clerk; it is to start to think in a different way about the venue of the church court and the genre of the deposition' (Dolan, 2013, p. 122).Indeed, Tim Stretton has suggested that it is precisely by paying attention to the collaborative context of sources that we can find new meaning in the 'amendments' that were made to them (Stretton, 2019, p. 698).I argue that it is by thinking through the collaborative and constructed nature of the Kirk Session minute book that we may take the first step in deconstructing the Presbyterian archive -and the relationships that it uncovers, as a cisnormative creation.Working both with and against the archive, we can thread together the overlapping fictive truths of the moments captured in the minute books to make sense of the messy spaces between what Margaret alleged, what David said, and what the clerk transcribed.
Let us now turn our attention to the recording of the encounter between David and Margaret.As with other western Christian traditions, Presbyterian teaching on sex was rooted in heteronormative understandings of the family.Families were created, sustained, and performed through heterosexual marriage.The Westminster Confession of Faith (1646) -a document that outlined the main beliefs and practices of the church, made this explicit.According to chapter twenty-four on 'Marriage and Divorce', marriage was a contract between 'one man and one woman' and it served three main ends: 'the mutual Help of Husband and Wife', 'the Increase of Mankind with a Legitimate Issue', and it prevented 'Uncleanness'. 16Sexual intercourse was therefore not only ideally restricted to the heterosexual marriage bed, its overall purpose was procreative.Further guidance was provided on how to choose an appropriate marriage partner.In addition to the restrictions that were placed on marriage with close kin, church members were encouraged to choose a partner with whom they shared religious parity. 17The Confession advised that believers should 'Marry only in the Lord' and not enter unions with 'Infidels, Papists or other Idolaters'. 18Such advice was geared towards creating stable family units that would nourish future generations of Presbyterian believers.As the Irish Presbyterian minister John McBride expounded in his Vindication of Marriage (McBride, 1702), those who married without taking 'notice of vertuous Qualifications in their choice' would 'suffer the Miseries of unholy and unequal Yoking'. 19 The special place of sexual intercourse within the marriage contract was also emphasised in church teachings on divorce.According to the Confession, adultery committed after marriage was grounds for the breaking of the marriage tie. 20Moreover, marriages could technically be dissolved if it was later discovered that an offending spouse had committed adultery or fornication before the marriage was celebrated. 21In both of these cases, the 'innocent' party was free to marry again 'as if the offending Party were dead'. 22 These rules reflected the importance that was placed on heterosexual marriage as the foundation of a godly society.Indeed, this was captured in the words of McBride when he listed the destructive effects of adultery.Extra-marital sex not only threatened the 'Common-wealths [that] arise from, and are preserved by Marriages', it 'shakes their Foundations [and] converts conjugal Love into mutual Hatred'. 23The unhappiness that adultery caused in the household could then bleed out into the community, and fill 'whole Houses . . .with Reproaches and Feuds' resulting in 'publick Miseries and Destruction'. 24Marriage, defined as a spiritual union between a heterosexual couple, was marked out as the glue that held society together.
These heteronormative frameworks shaped how the Presbyterian Kirk Session of Templepatrick understood the intimate exchange between David Campbell and Margaret McCal.The encounter between the pair was at once understood, and yet rendered impossible, through the performance of a heteronormative courtship script.We can interrogate this idea further by drawing on what scholars have termed the 'discourse of impossibility' -the idea that something is made or acknowledged as real through the denial of its existence (Braunschneider, 2004;Hope;Cleves, 2015).For example, Rachel Hope Cleves's work on same-sex marriage in nineteenth-century America notes how individuals of the same-sex were described as being in relationships 'like marriage' or how they 'lived as if husband and wife' (Hope Cleves, 2015Cleves, , pp. 1057-59)-59).The qualifiers 'as if' and 'like' were imbued with interpretative ambiguity that acknowledged the existence of these marriages while simultaneously denying their very possibility.A similar process was at work in the Templepatrick case.
We can locate the discourse of impossibility in how the minutes frame the encounter between David and Margaret as 'pretended courtship'.That phrase and its meanings would be immediately recognisable to the Kirk Session (and the community they represented) as signifying sexual activity between persons of the opposite sex.Courtship was understood to involve sexual activities that included kissing, caressing, petting, and touching, and were legitimate practices so long as they took place within the agreed 'parameters of appropriateness' (Calvert, 2018, p. 257;Hardwick, 2015, p. 647).As I have demonstrated elsewhere, such activities became most problematic when couples progressed to sexual intercourse itself, which the church ideally restricted to the marriage bed (Calvert, 2018(Calvert, , 2023)).The Session's decision to proceed 'in the ordinaire' way therefore evidences an acceptance that some form of sexual intimacy had passed between David and Margaret.Given that courtship was understood as a series of rituals that women and men participated in as they advanced towards marriage, the heteronormative framing of the encounter between David and Margaret is significant because it signalled an acknowledgement of David's male gender.Moreover, while the details of what the pair did in the name of courtship is never explicitly mentioned, it did not need to be.Drawing on the shared language of courtship -a vocabulary rooted in heteronormative understandings of sex, the encounter was made legible to the Kirk Session.
It is this same shared heteronormative understanding of sex that ruled out the possibility that anything resembling courtship had (or could have) passed between the pair.The Kirk employed the qualifier 'pretended' to describe the encounter between Margaret and David.This phrase was used by the Presbyterian church courts to describe sexual and intimate relationships that they judged to be inauthentic; or, in other words, those that mimicked the rituals of courtship but were unable to achieve its ultimate end: heterosexual marriage.For example, Cahans Kirk Session in County Monaghan, Ireland, censured a servant woman named Agnes Kirk for receiving (what they perceived to be) the disingenuous advances of a servant man who came to her bed 'pretending courtship'. 25The decision to describe the sexual intimacy shared by David and Margaret as 'pretended' is therefore highly significant because it illuminates how the cisnormative presumptions of the court forced a heteronormative reading of the encounter.Viewed by the court and the clerk who did the note-taking as Elizabeth -indicating an alignment between sex and performed gender, David's alleged encounter with Margaret was deemed unworthy of church debate. 26It is for this reason that the Session recommend that the pair reconcile: 'the session seeing nothing worth time to debate upon, but only to desire reconciliation'. 27The cisnormative outlook of the Kirk Session not only shaped the outcome of the case, but it left a lasting imprint in the archive itself too.This becomes apparent when we consider how the minutes refer to David.As outlined above, it is significant that the clerk continued to assign them the name of Elizabeth, despite the fact that they called themselves David.Indeed, the heteronormative framing of the encounter worked to strip David's transness of any agency in the historical record: 'if [they] had been a man, [they] could have been naughte' with Margaret.

David Campbell: a trans reading
The cisnormative coding of the case may be upended by considering it from David's perspective.To do so, we must think critically about the construction of their story.At first glance, David's voice appears to be absent from the narrative.The encounter between the pair was first inscribed into the Presbyterian archive through the words of Margaret.It was Margaret who made the complaint to the Kirk Session and it was she who established the narrative of what passed between them.When David was afforded an opportunity to speak at the Kirk Session in April 1706, their resulting words were mediated through the pen of the clerk, who not only summarised their response in the minutes, but recorded their testimony as Elizabeth. 28In the absence of voice, it is difficult to assign a motivation to David.Lots of questions remain open.Was Margaret the first woman to whom they paid courtship?How often did they move through the world as David?What did David hope to achieve in their pursuit of Margaret?
The lack of testimony from non-conforming individuals who 'transed' gender norms has led scholars to find ways of speaking on their behalf (Manion, 2021).Often, their actions are subsumed in histories of cross-dressing and gender inversion.The women who appear in these narratives donned men's clothing to achieve specific outcomes: to facilitate travel, to track down errant husbands, to enter professions, or to access the economic privileges afforded to men (Cressy, 1996;Füssel, 2018;Bennett and McSheffrey, 2014;Stoyle, 2018).The cross-dressing of other women has also been read as evidence of their queerness: as women who dressed as men in order to pursue sexual gratification with other women (Charland, 2016;Derry, 2017).These explanations are, however, problematic for two main reasons.On the one hand, these narratives leave no space for a trans reading.As Kit Heyam has noted, the lack of testimony from individuals explaining their motivations is often used to 'close off any possibility' of a trans narrative.Moreover, these explanations perpetuate the idea of transness as a binary and stable category and overlook the ways that individuals moved freely between gendered categories, obscuring the 'messy realities' of many trans lives (Heyam, 2022, pp. 11-14).In the Templepatrick case, it is important to remember that David moved between gender performances: while they appeared to Margaret as male during their encounter, they presented to the Kirk Session as female.On the other hand, readings that associate cross-dressing with the pursuit of sexual gratification are underpinned by the problematic assumption that gender defines sexual desire.As Jen Manion's work on female husbands has highlighted, the equation of gender nonconformity with homosexuality serves to reproduce (rather than interrogate) the heteronormative frameworks that they seek to question (Manion, 2020, pp 5-6;Berry, 2012).
We can gain a better understanding of David and their motivations by considering them as they appeared to Margaret in the moment of their encounter: as a man.It is important to remember that David never repudiated their male gender.While David's voice was reshaped by the clerk who took the minutes, we can read the source against the grain to make visible their male subjectivity (Henninsgen, 2019, p. 252).The Session minutes reveal that David never denied wearing men's clothes.Instead, they challenged Margaret 'to prove' that the encounter had happened. 29Presbyterian standards afforded church members the right to reply to charges made against them. 30Generally, when Presbyterian women and men were cited to appear before the church courts to answer charges of misbehaviour, those who claimed innocence were quick to defend themselves.Whereas some made emphatic denials of guilt, others produced the names of individuals who could corroborate their evidence.Neighbours, employers, friends, and family members were often called to testify to the characters and good behaviour of those accused in a bid to support their claims of innocence. 31It is therefore significant that David chose to place the burden of proof on Margaret; they never disavowed their appearance as a man.
Considered critically, David's response can actually be read as confirmation that they had transed gender norms (Manion, 2020).Margaret was not just asked to prove that David had dressed in men's clothing; rather, she was challenged to prove that they had 'came to her in mans cloaths by way of courtship'.The emphasis was placed on what David had done (and intended to do) while dressed as a man (i.e.whether they had dressed in men's clothing for the purposes of facilitating courtship) and not the wearing of men's clothing per se. 32The framing of David's response suggests that they while they may have been dressed as a man, they did not approach Margaret so dressed with the intention of pursuing courtship.Read in this way, David's riposte pushes some responsibility for their encounter back onto Margaret, raising the possibility that their sexual exchange was the result of a dynamic and mutually shared experience (a point discussed more fully below).Indeed, this reading reinforces the point that a clearer distinction needs to be made between gender and sexual desire: we should not assume that David's decision to dress in men's clothing was prompted by a wish for female company.
There is likewise evidence to suggest that David's maleness was recognised by members of their community, and that their place in the world as a man was reaffirmed by what Kadin Henningsen has termed the 'gender labour' of others (Henningsen, 2019, p. 250).The minutes reveal that others, specifically other men, co-produced David's gender through their participation in the rituals of male sociability that included gossip and talk.Margaret's complaint turned on the claim that David had told two men (Thomas McCapin and Henry McIlroy) that 'if [they] had been a man [they] could have been naughte with her'. 33In boasting of their alleged sexual successes, David was behaving like many other young men who bragged to their male friends about their relationships (whether real, imagined, or exaggerated) with women.As I have demonstrated elsewhere, it was not uncommon to find men, particularly young, single men, boasting of their sexual conquests in homosocial spaces (Calvert, 2023, p. 8).Such brags and boasts were engineered to win approval and admiration from male peers, and claims of being 'sexually irresistible' bolstered a claim to manhood (Capp, 1999, p. 71;Foyster, 1999, pp. 41-43).David's boasts of sexual prowess can therefore be read as their participation in the male world of sexual competition, equating manliness with sexual success.Moreover, we may even posit that David's brags evidence a belief that they were more successful than their friends in the pursuit of female affection.Whether egged on by Thomas McCapin and Henry McIlroy or not, the boastful story may have been a way of stating their manliness.Participating in the male world of talk, however, came with risks.Young men often got into trouble when their words were repeated outside of their friendship circles.Whereas some lost opportunities for apprenticeship or economic advancement, others found themselves marked as unsuitable matches on the marriage market (Calvert, 2023, p. 8).Given the risks involved, David's inclusion in the male world of talk is significant because it evidences the external validation of their male gender.It is possible that the two male witnesses denied knowledge of the whole event in an effort to maintain the integrity of their male social space.

Margaret: queering female desire
The case of David and Margaret challenges the heteronormative construction of the archive and the cisnormative framing of their encounter in other ways.Shifting our attention away from David and towards Margaret, the case enables us to queer our understanding of female desire.The female wives, partners, and companions who engaged in romantic and sexual relationships with gender passing and male-presenting partners are often overlooked and neglected as queer figures in the past.Substantially more effort has been paid to debating the 'lesbian-like' motivations of those who transed gender norms than the women with whom they shared intimacy (Manion, 2020).Women who loved and lived with 'female husbands' tend to be cast as victims of deception or as participants in sexless and passionless marriages.The evidence for this reading largely comes from the testimonies of women themselves.The stories of wives attracted great interest as the public questioned what these women really knew about their spouses (Chesser, 2009, p. 381).Marriage meant sex and while the newspapers that publicly discussed these marriages were bound by social and moral conventions of what they could print, the spectre of bodily and sexual intimacy loomed large.Stood before the courts (whether ecclesiastical or secular) and placed under the scrutiny of their neighbours, friends, and family members, the testimonies of many women were deliberately crafted to present themselves as unwitting victims of gender trespass.
Some wives denied that they shared much, if any, sexual intimacy with their husbands.For example, when James Allen died in a work accident in London in 1807 and their body was subsequently determined to be female, questions were raised about how much their wife, Abigail Naylor, knew of it.Abigail denied knowledge of her husband's female body, telling authorities that James was ill on the night of their wedding and that 'sexual intimacies' were not part of their marriage (Manion, 2021, pp. 117-19).In their analysis of the case, Jen Manion has argued that Abigail's denial was partly motivated by her desperation to recover her reputation, in addition to her financial struggles to cover the costs of the funeral and claim widows' benefits (Manion, 2021, pp. 115-19).The denials of other women made for sensational reading.When Irish emigrant Edward de Lacy Evans was revealed to have been assigned female at birth, their third wife, Julia Marquand, was placed in the awkward position of explaining the paternity of their child.In her essay on the couple, Lucy Chesser noted that Julia initially 'claimed total ignorance of the child's origins' and that she 'assume [d] that Evans had smuggled a "real man" into the house' the night it was conceived (Chesser, 2009, p. 381).As with the case for individuals who transed gender norms, the testimonies of wives also need to be treated critically and sensitively.To accept that all of these women, particularly those who were married or lived with their partners for long periods of time, were unaware that their husbands had been assigned female at birth, renders the emotional and sexual dimensions of their relationships invisible (Manion, 2021, p. 119).Moreover, it disavows the queer agency of these women more broadly.
How might we then understand Margaret?It is possible that Margaret, like the other wives of female-husbands, was attracted to David exactly for, or indeed in spite of, their femaleness.In her work on eighteenth-century female cross-dressers, Ula Klein has compellingly argued that in some cases it was the 'ambiguous gender performance' of the 'cross-dresser' to which women were attracted (Klein, 2016, p. 124).It was the smooth, beardless and beautiful faces of the cross-dresser that underscored their erotic appeal to women (Klein, 2016, pp. 120-25).While the case with which we are concerned provides no information on the bodily appearance of the parties concerned, the words they exchanged, or the touches and caresses they shared, it does raise the possibility of attraction and queer desire on the part of Margaret.
The first piece of evidence for this supposition may be found in Margaret's own testimony.Margaret recalled that when she met David, they not only presented themselves as male through the use of the name 'David', they exhibited their maleness through the wearing of 'mans cloathes'.Exactly what David wore and the items they chose to present their manliness is not detailed.It is likely, however, that they were wearing breeches.In the period that the pair met, it was standard for Irishmen to wear a 'less voluminous' style of breeches, which were buttoned with an exposed flap.The breeches' legs narrowed at the knees, which were then covered by gartered stockings (Greene & McCrum, 1990, p. 138).Breeches worn by the lower sorts in Ireland in this period tended to be made from buckskin, a hardwearing fabric (Greene & McCrum, 1990, p. 164).It is possible that Margaret was attracted to David on account of how they looked in men's dress.In their study of medieval crossdressing, Judith Bennett and Shannon McSheffrey argued that male dress offered 'new salacious opportunities for cross-dressing women' because it enabled them to expose parts of their bodies usually hidden by female clothes (Bennett and McSheffrey, 2014, p. 4).Whereas codpieces emphasised the crotch, tights showed off the legs and hips (Bennett and McSheffrey, 2014, p. 4).It is for this reason that women who made a living through sex work sometimes wore men's clothing: dressing as men bolstered their erotic appeal to male clients (Bennett and McSheffrey, 2014, p. 13).We can argue that a similar erotic appeal applied in the case of Margaret and David.The appearance of David's legs in breeches and gartered stockings (if that is indeed what they wore) may have likewise looked attractive to Margaret, adding encouragement to their sexual encounter.
That Margaret was attracted to David on account of their dress enables us to further queer the manifestation of her female desire.Scholars of dress have drawn attention to the coded nature of clothing.In their study of dress and crime in nineteenth-century Ireland, Elaine Farrell and Eliza McKee demonstrated the ways that individuals 'read' bodies' through the medium of dress.Clothing conveyed messages about the wearer, including their gender, age, social position, and occupation (Farrell & McKee, 2022, pp. -126-28).Dress not only conveyed messages about the wearer, but it also acted as a medium upon which others projected values about the body of the person who wore it.Indeed, as Adam Geczy and Vicki Karaminas noted in their study of queer style, the ways that people chose to dress their bodies affected how others perceived them (Geczy & Karaminas, 2013, p. 123).Considered in this way, David's dress may have been employed to signal their maleness, but it was how their body wore it that drew the attention of Margaret.
Secondly, although Margaret's complaint was recapitulated through the pen of the clerk, we can locate a degree of queer agency in the account.Her testimony may have emphasised the role of David's desire in driving their encounter, but Margaret's description of what happened positioned her as a reciprocal actor.The minutes note that David had allegedly told others that 'if [they] had been a man, [they] could have been naughte with' Margaret. 34That phrasing is important for two reasons.Firstly, it suggests that the pair could (and perhaps would) have progressed further if David had not put a stop to their activities, and secondly, it makes Margaret visible as a consensual participant.Margaret was not just the object of desire, she was its co-author and co-participant.David's response to the Kirk Session also highlighted Margaret's role in (co)initiating their encounter.David hinted that they did not approach Margaret with courtship in mind; their sexual exchange was the result of mutually produced desire.That Margaret desired David and was attracted to them is likewise suggested by the wording of the complaint.Although the consummation of their desire was never achieved, this did not mean that the couple lacked the desire to be 'naughte'.The minutes are explicit on that point: 'if [they] had been a man [they] could have been naughte'.It is in the ambiguous spaces of 'if' and 'could' where Margaret's desire becomes visible.
Parallels may also be drawn between Margaret's complaint to the Kirk Session and the testimonies of other women who were revealed to be involved in relationships with individuals who transed gender norms.It is important to note that Margaret's complaint hinged not so much on David's presentation as a man, but that they had since bragged to others about what allegedly passed between them.It was the public nature of their alleged encounter that underpinned Margaret's appearance between the church court.As outlined above, women who were exposed as companions of 'female husbands' were placed at considerable financial and social risk.Whereas some women were castigated and harassed by their communities as 'frauds', others were mocked as 'stupid' and 'ignorant' in the press (Manion, 2021, p. 114).Margaret's decision to turn to the Kirk Session may evidence her desire to gain control over the force of public gossip.By drawing attention to the transness of David, Margaret distanced herself from allegations that she was cognisant of their female body.Moreover, considering that women who dressed as men were sometimes equated with prostitution and sexual licentiousness, Margaret may also have been motivated to dissociate herself from further aspersions made against her character (Bennett and McSheffrey, 2014 pp. 1-2;Heyam, 2022, pp. 75-76).Indeed, David themselves acknowledged the 'injury' that their boasts had caused Margaret. 35 A further parallel may also be drawn between Margaret and other women who attempted to take control of the narratives that were spun about their relationships.Jen Manion has noted how some wives took the 'unusual tactic' of using 'assigned sex to delegitimize' their marriages as null and void (Manion, 2021, p. 124).Ann Stoake, for example, 'outed' her husband Henry as 'female' in order to achieve a divorce on 'favorable terms' (Manion, 2021, pp. 123-24).Likewise, Helen Berry's study of the marriage between Dorothea Maunsell and 'the castratro' Guisto Ferdinando Tenducci revealed how the (il) legitimacy of their union was decided at various points with reference to the latter's body (Berry, 2012).It is possible that a similar motive underpinned the decision of Margaret to take her case to the Kirk Session.David's boasts and brags made Margaret's sexual reputation the subject of gossip.One weapon that she had at her disposal to deflect this gossip was the Kirk Session.As an arbiter of public opinion, the Kirk Session had the power to make, break, and restore reputation.Margaret's complaint may have been engineered to draw attention to the 'impossibility' of sexual intimacy with Elizabeth, weaponising the Session's heteronormative understanding of sexual relationships to invalidate David's gossip and safeguard her own reputation.In other words, Margaret's complaint drew attention to the femaleness of David in an effort to put to bed rumours of her sexual incontinence.

Conclusion
Drawing broad conclusions from one case study is problematic.The record of the intimate encounter between David Campbell and Margaret McCal is certainly unusual in that it is one of the only examples of queer intimacy captured in the Irish Presbyterian archive.It would be easy to consider the case as an elusive example of same-sex relationships in eighteenth-century Ireland.In fact, it would be even easier to dismiss the whole encounter as nothing more than an elaborate prank, designed to get one over on an unsuspecting neighbour.Yet, to do so would not only render the transness -i.e. the fluid movement, of the encounter invisible, it would do an injustice to the story.Indeed, more egregiously, taking the easy route would curtail the explanatory potential of the case.As Scott Larsen has argued, 'trans history is a history of gender in motion and variation and is not only about trans and gender-variant people' (Larson, 2021, p. 361).It is precisely within this 'variation' in which the power of the story lies.
Considered with a queer lens, the case of David and Margaret carries two important lessons for historians of the Irish family.Firstly, their example reminds us of the restrictions we impose upon ourselves (and the subjects we research) when we fail to appreciate the complicated and messy realities of lived experience.Situating David within a trans framework underscores the historical contingency and elasticity of gender as a concept.To borrow the words of Abdulhamit Arvas, figures like David 'blurred the binarized gender distinctions often taken for granted by modern readers' and they unsettle the idea that gender was 'fixed at dichotomous ends' (Arvas, 2019, pp. 116-117).As this article has revealed, David Campbell moved between gender performances and they were understood by those around them at different points in time as both male and female, as David and as Elizabeth.Similar to Greta LaFleur's reading of Deborah Sampson/Richard Shurtliff, an individual who lived openly as a man and a woman during their lifetime, to understand David, we must appreciate them 'in their uncertain complexity'. 36While we will never know how David understood their body or their gender, it would be analytically unsound to confine them to a history that inflects their experience through a gender binary, a binary to which they themselves would have been unfamiliar.As a lesson for historians of the Irish family, David teaches us that if we want to understand the family in Ireland, we need to move beyond the automatic ordering of its relationships into fixed categories that make sense to us today.Or, as Mo Moulton has pointed out, we need to recentre 'the strange-to-us category of unconventionality' (Moulton, 2013).Just as David reminds us that there were many ways of 'doing' gender in eighteenthcentury Ireland, so too were there were many ways of 'doing' family and its relationships.
Secondly, the case of David Campbell pushes Irish historians to radically confront the constructed biases of the archive and the histories that they subsequently write.In this article, I argued that the encounter between David and Margaret cannot be understood without first reckoning with the processes that led to its inscription in the Presbyterian archive.We must confront the role of the clerk and the space of the church court before we can begin to wrestle with the intricacies of the recorded encounter.As discussed throughout this article, this approach is well worn by scholars in trans studies.Historians of the Irish family can benefit from applying a similar practice in their work.In order to understand the Irish family in its historical complexity, just as in the case of David Campbell, we must step back from our sources, take pause, and reflect on the forces that led to their creation.It is useful here to borrow from Zeb Tortorici's queer approach to the colonial archive.Tortorici explained that in order to cast the archive queerly, we must 'apply pressure to our own preconceptions' of the past and interrogate the 'archival forms through which we inherit our understanding' of that past (Tortorici, 2018, p. 16).In a 2023 article, Lindsey Earner-Byrne teased this line of linking, when she astutely summed up the main problem faced by historians of the Irish family as one of definition.As she notes, 'the Irish family as a singular institution does not exist'; rather, the 'concept of "the family"' exists as an 'abstraction' that serves 'the interests of those who wish to deflect attention away from systemic inequality and injustice' (Earner-Byrne, 2023, p. 286).Recognising 'the Irish family' as an artificial construct, as a set of ideas made and remade over time and, responsive to hierarchies of power, is the first step we must take in our analytical journey.To write the history of the Irish family, we must also queer our very definition of what that family is, holding lightly our preconceptions about what constitutes family in the past and what it means to us today, and think critically about from where we grasp our sources.As Tortorici notes, what makes such a project queer 'is its focus on that which is "strange, odd, funny, not quite right, improper"' (Tortorici, 2018, p. 15).The Irish family we seek to write about may look nothing like what we expect.The story of David Campbell and Margaret McCal, then, captures an intimate encounter that is both extraordinary and yet, a very ordinary, example of Irish relationships in the eighteenth-century.

Notes
1. Public Record Office of Northern Ireland [PRONI], Templepatrick Kirk Session minutes, 10 March 1706, CR4/12/B/1.2. Ibid. 3. Ibid, 26 April 1706. 4. Ibid. 5. Ibid. 6.In this, I share the concern of Judith Bennett that the histories we write have real world consequences: 'As always, these questions have things at stake behind them, things that make their answers more than a mere academic exercise'.See, Bennett (2000), 'Lesbian-like' and the social history of lesbianisms, Journal of the History of Sexuality, 9 (1/2), p. 4. 7.An example is the polarisation of political and popular opinion concerning the rights of individuals to change their sex recorded on official documentation.This is now possible in Ireland, following the Gender Recognition Act (2015).This piece of legislation allows all individuals aged 18 years and over to self-declare their own gender identity and acquire a new birth certificate to reflect that change.Gender Recognition Act, 2015 https://www.oireachtas.ie/en/bills/bill/2014/116/;In the UK, trans people have had the right to legally change their gender since the Gender Recognition Act (2004); however, the process is subject to medical requirements and evidence that the person has lived in their acquired gender for at least two years.In 2022, the Scottish Parliament introduced and subsequently passed the Gender Recognition Reform (Scotland) Bill that streamlined the process for gender recognition.The bill was subsequently blocked by the UK Government.See, Scottish Government, 'LGBTI and gender recognition', https://www.gov.scot/policies/lgbti/gender-recognition/(accessed June 2023).8. Exceptions include, Connolly (2000); McAuliffe (2008); Ó Siocháin (2017);O'Halloran (2018).
Nineteenth-century examples include, Earls (2020Earls ( , 2019)).9. James Barry, a nineteenth-century Irish doctor, who lived as a man is one example.Barry is variously described as male, female, intersex, hermaphrodite, but not transgender.Bridget Hourican and Frances Clarke, 'James Barry (1792-1865)' in Dictionary of Irish Biography, https://doi.org/10.3318/dib.000442.v1(accessed 19 October 2022); Du Preez and Dronfield (2016); R. Holmes (2007); Kubba (2001).10.For a discussion of the discrimination faced by Presbyterians in relating to the celebration of marriage, see: Calvert (2018); Beckett (1948); Barkley (1993); Luddy and O'Dowd (2020).11.The Form of Process in the Judicatories of the Church of Scotland;with relation to Scandals and Censures . . . (Glasgow, 1763).12.The Presbyterian Church in Ireland, The constitution and discipline of the Presbyterian church: with a Directory for the celebration of ordinances, and the performance of ministerial duties, published by the authority of the General Synod of Ulster (Belfast, 1825) 13.PRONI, Templepatrick Kirk Session minutes, 3 November 1703, CR4/12/B/1.14. Ibid, 16 February 1713. 15.Rape cases are a good example.Garthine Walker, for example, has drawn attention to how women 'appropriated languages of sexual intercourse, of violence, and of law' in their