Milton V. Anastos
Constantinople and Rome
A Survey of the Relations between the Byzantine and the Roman Churches.
M. Anastos, Aspects of the Mind of Byzantium (Political Theory, Theology, and Ecclesiastical Relations with the See of Rome), Ashgate Publications, Variorum Collected Studies Series, 2001. ISBN: 0 86078 840 7.
6. The rise of the see of Constantinople and the origin of the conflict between Constantinople and Rome in 381 and 451
In view of the great differences in language (the Romans spoke Latin, the Byzantines, Greek), temperament, traditions, liturgy, and theological subtlety (in which the Greeks outstripped the Latins), it is not difficult to understand why friction arose between them. Although Rome and the Eastern Church had had a number of disputes in the early centuries, major difficulty developed because of the rank assigned to the see of Constantinople in 381 by the Second
Oecumenical Council (which met in the Byzantine capital) and in 451 by the Fourth Oecumenical Council (that of Chalcedon). In the third canon of the Council of 381(55) it was provided that "the bishop of Constantinople has the privileges of honour after the bishop of Rome, because it is New Rome." This ecclesiastical ordinance marked an important step in the rise of the Church of Constantinople, and was intended primarily to safeguard the rights of the imperial Church of the capital city, which the emperors quite understandably expected to have a position of authority and influence commensurate with its location in the centre of imperial power.
In translating its wishes into ecclesiastical law in this way, the imperial government was merely adhering to the practice of the day, by which the Church as a whole had adopted the territorial divisions and administrative organization of the Empire as the model for the organization of its own hierarchy.(56) According to this system of arrangements, each church held a rank in the ecclesiastical structure corresponding in general to the relative prominence of the city in which it was located. That is, the most important cities would have the most powerful churches. Actually, as Byzantine theologians subsequently maintained, this criterion had applied from the very beginning to the West as well as to the East. The East acquiesced in this principle without question.
The Roman popes, however, always refused to recognize that it was of any effect or consequence, despite their own obligations to it, because they preferred to ascribe their eminent position in Christendom, not to geography and politics, but to their special connection with St. Peter as first bishop of Rome, whose successors they claimed to be. This relationship to Peter gave them a unique position in the West, since no other church in that part of the Empire claimed to have been founded by an Apostle. Hence, the see of Rome rapidly rose to dominion over all other churches in the West not only because it was joined to the seat of the imperial government, but also because it was able to invest itself with very special attributes, which raised it above all other western bishoprics, by insisting upon the extraordinary prerogatives appertaining to it as an apostolic foundation.
In the East, on the other hand, a multitude of churches had been established by the Apostles, and Peter had visited Antioch, Jerusalem, and may other places as well. Here, apostolic lineage had little significance, and the great sees of Antioch and Alexandria owed their high rank in the Eastern Church, not to their apostolic derivation, which was securely established in ecclesiastical tradition, but to the strategic and political importance of the cities to which they were attached.(57)
In conformity with these principles of ecclesiastical administration, the thin canon liberated the see of Constantinople from subservience to lesser cities specifically, we may assume, from dependence upon the bishopric of Heracleia(58) in Thrace to which it had long been subject. The Chronicon Paschal ("Easter Chronicle"), which was written around the middle of the seventh century, says that Constantine had already freed Constantinople from the jurisdiction of Heracleia. But since the bishops of Heracleia clung tenaciously to their ancient right to supervise the election of the bishops of Constantinople, it was apparently deemed necessary formally to rescind their authority in this regard, which was intolerable for the Church of the capital city. Heracleia was thus removed from its position at the head of the ecclesiastical diocese of Thrace, and replaced by Constantinople. Nevertheless, in recognition of the privileges he had formerly exercised, the bishop of Heracleia was permitted to preside at the coronation of the bishop of Constantinople.(59)
Moreover, there can be little doubt that, in issuing this canon, the Council of Constantinople was also striking a blow at the Church of Alexandria, which had gained great prestige during the Arian controversy through the vigorous leadership of Bishop Athanasius (328-73), and was determined to maintain its ascendancy in the East. It had intervened aggressively in the affairs of the Church of Antioch, and, just before the Council of Constantinople, had taken steps to gain control over the bishopric of the capital city. In pursuit of this goal, Bishop Peter II of Alexandria (373-80/81) sent a group of Egyptian bishops to Constantinople under the escort of a mob of Alexandrian sailors, and commissioned them to elect a creature of his own, named Maximus the Cynic, to the Constantinopolitan bishopric.(60) Peter hoped in this way to eject the amiable and scholarly Gregory of Nazianzus, who then was bishop of Constantinople (379-81), and thus establish hegemony over the whole of the Eastern Church. Peter's scheme failed because of the firmness of the people of the capital and of the Emperor Theodosius Ι, who ruled, as we can see in the fourth canon of the Council of Constantinople, that Maximus had never been bishop, and that all his acts were null and void. The fourth canon, in turn, was a specific application of the second of the same Council, which forbade bishops to interfere in the business of churches outside their own dioceses, and commanded the bishop of Alexandria to confine his activity to the church of Egypt.
Thus, it may be seen that the third canon of Constantinople was designed in the first instance to strengthen the position of the imperial Church, to protect it against its closest rivals, and to give it primacy in the East, which even Bishop Timothy Ι (381-85) of Alexandria was forced to recognize when he appended his signature to the proceedings of the Council.(61)
The Church of Rome had not been represented at the Council of 381, and the decisions of that body were concerned primarily with questions of jurisdiction that arose in the Eastern Church. Nevertheless, they were far from being purely local in effect. In all likelihood, they were not originally anti-Roman in intention. But there is no doubt that they adversely affected the interests of the Roman Church since any aggrandizement of the Constantinopolitan
see inevitably diminished the prestige of Rome.
Still, the popes made no immediate objection to this new definition of the authority of the Constantinopolitan Church. They did protest against it at the Council of Chalcedon in 451, but the Patriarch Photius (858-67, 877-86) alleges that Pope Damasus Ι (366-84) approved the results of the Second Oecumenical Council. Although this allegation, which is attested also by the later Latin tradition, is not verifiable from sources of the fourth century, Pope Vigilius (537-55) says that he and his Church endorsed all four of the Oecumenical Councils which had been held before his own day in all things, and the third canon of Constantinople was confirmed by the weightiest Latin authorities, including the great Latin canonist Gratian (ca. 1150) in his Decretum.(62)
Notwithstanding the formal but reluctant adherence of Timothy Ι of Alexandria to the canons of 381, the Church of Alexandria did not abandon its aggressive pursuit of power. Hardly a generation after the Council of 381, Bishop Theophilus of Alexandria (385-412) succeeded in humbling John Chrysostom the eloquent and fearless Bishop of Constantinople (398-404, d. 407), whom he drove into exile (403). Pope Innocent Ι (402-17) of Rome intervened in Chrysostom's behalf but was unable to save him from his enemies. Α few years later, however, Pope Celestinus Ι (422-32) was won over by Cyril (412-44), Theophilus's nephew and successor as bishop of Alexandria, and helped him bring about the downfall of the Constantinopolitan theologian Nestorius who had been bishop of the capital city only three years (428-31) before his condemnation.
Then, in 449, Bishop Dioscorus of Alexandria presided over what had been intended as another oecumenical council at Ephesus, and humiliated Constantinople once more in the person of the Bishop of that city, Flavian by name (447-49), whom he caused to be deposed, and who died shortly afterwards as a result of injuries said by some sources of dubious lineage to have been inflicted upon him by his theological opponents. The proceedings of this Ephesian synod were so irregular and attended by so much disorder that it is known in history as the Robber Council (Synodos lestrike, Latrocinium). This time Alexandria again defied Rome, which had supported Flavian.(63)
Pope Leo Ι of Rome (440-61) and many others urged the Emperor Theodosius II (408-50)
to convoke a new gathering of bishops to repair the damage done by the Robber Council, which, among other things, had pronounced in favour of monophysitism. Theodosius ignored their pleas. But after his death, his sister, Pulcheria, and her husband, the new Emperor, Marcian (450-57 summoned an Oecumenical Council (the fourth) to meet in Chalcedon in 451, although Leo by this time would have preferred to have an Italian council or none at all. This assemblage of bishops is relevant in the present context because of its twenty-eighth canon,(64) which confirmed and extended the third of Constantinople.
Despite the care the framers of this canon took not to deny the priority and special honours appertaining to Rome as the elder of the two cities, they neglected to mention the Petrine character of the see of Rome, on which the whole dogma of Roman primacy rested. Whether this omission was accident or deliberate cannot now be determined. But the authors made it clear that their primary purpose was to exalt Constantinople as the equal of Rome in ecclesiastical authority. According to the third canon of 381, the bishop of Constantinople was to have the "privileges of honour after the bishop of Rome." This was ambiguous, and could mean that the Constantinopolitan Church was to be second in authority to Rome, and was to share with Rome nothing more than certain vague "privileges of honour." This time, in order to avoid ambiguity, the words of honour were omitted, and reference was made only to privileges or rights ( presbeia alone instead of presbeia tes times). The rights and privileges conferred upon Constantinople still remain undefined, as in 381, but they were now formally declared to be identical with those enjoyed by Rome. So as not to offend the sensibilities of the Pope, however, the Council added that the New Rome which was thus to be honoured came second after Rome.
The canon was very adroitly phrased, and some mediaeval interpreters, like the canon lawyer Aristenus (who flourished in the twelfth century), contend that what its sponsors meant to say was that Rome outranked Constantinople in age only, and not in any other respect. Actually, the language of the canon may, perhaps, be susceptible of this interpretation. But Aristenus's contemporaries, Balsamon and Zonaras, strongly argue on the basis of a Novel of Justinian (131.2: see § 8 below) that Constantinople was here definitely stated to be inferior to Rome, and not merely younger.(65)
Balsamon himself was of the opinion that the Second and Fourth Oecumenical Councils had bestowed upon the patriarch of Constantinople the privileges of the pope of Rome, and had ordained that the former be honoured exactly like the latter in all respects. However this may be, the canon obviously was intended to strengthen the position of the bishop of Constantinople since it formally authorized him to consecrate, as we know from other sources he had long been doing,(67) the metropolitans of the dioceses of Pontus, Asia, and Thrace, and certain other bishops as well.
The twenty-eighth canon was reinforced also by the ninth and seventeenth, both of which conferred appellate jurisdiction upon Constantinople in certain cases arising in eastern bishoprics.(68) The seventeenth, like the twenty-eighth, also enunciated the principle that ecclesiastical administrative units should be patterned upon those of the Empire. The Roman delegates at Chalcedon ignored these, and concentrated their fire upon the twenty-eighth, as did Pope Leo Ι himself although the text of this canon had been drawn up so skilfully that Leo found it difficult to attack directly the provisions to which he was most opposed.
For he could not with propriety protest against the references to the "most holy Constantinople," which occur several times, while his see is merely designated as the Elder Rome. Nor could he openly declare his disapproval of the assignment of identical privileges to both Churches, which in effect sharply curtailed whatever superiority was still vouchsafed to Rome. Still less could he complain about the great power assigned the bishop of Constantinople in the consecration of metropolitans and bishops, or give utterance to the uneasiness he felt in the face of a threat to the Roman primacy posed by a powerful
bishopric which enjoyed the support of the imperial government. Instead, he very adroitly based his critique of the offending measure upon technical considerations.
First of all,(69) he recognizes no basis for the honour and dignity of a church except the apostolicity of its foundation, and accordingly rejects the principle that there should be a correlation between the rank of a city in the civil administration and its place in the ecclesiastical hierarchy. Thus, according to his strictly non-political scheme of computation, Rome had the primacy in the Church solely because of its Petrine origin; Alexandria held second place because it was founded by Peter's disciple, John Mark; and the third place was assigned to Antioch because of Peter's association therewith and because the name of Christian arose there. But he deems Byzantium to be of no account in this select company, because it was not founded by an apostle.
Secondly,(70) he repudiates the twenty-eighth canon altogether because it was in conflict with the sixth canon of the Council of Nicaea (325), which established the only regulations concerning the privileges of the churches that he would accept. This Nicene ordinance was frequently cited by the popes against Constantinopolitan claims, because it does not mention Constantinople at all (which was, of course, not established as the capital of the Byzantine Empire until May 11, 330), and deals only with the jurisdiction of the sees of Rome, Alexandria, and Antioch.
Thirdly,(71) he sweeps aside the third canon of 381, which the bishops of Chalcedon had cited as their primary authority, because it had never been confirmed
by the Roman see, thus conveniently forgetting that, if his contemporary Eusebius
of Dorylaeum can be believed, he had listened to a reading of this canon and had expressed his approval of it.(72)
In the end, however, Leo gave up(73) his polemic on this issue, for he needed the Emperor and Bishop Anatolius of Constantinople as allies against the resurging forces of monophysitism, and even described the Emperor Leo Ι (457-74) as an infallible and inspired guide in Christian doctrine (see note 237 below). Nevertheless, official promulgation of Canon 28 was delayed, and the latter was not included by Johannes Scholasticus in his Collection of fifty titles. But the emperors and patriarchs of Constantinople conducted themselves
as if it had been duly enacted into law. In 545, Justinian incorporated it into the Corpus iuris civilis (Novel 131.1), and the thirty-sixth canon of the Council in Trullo (692) formally introduced it into Byzantine canon law(74)
On the other hand, the Vatican itself did not recognize the twenty-eighth canon until the Fourth Lateran Council,(75) which was held in 1215, after the Latins, as a consequence of the Fourth Crusade, had installed a Latin patriarch on the throne of the Church of Constantinople. Before that, however, ca. 1150, the canonist Gratian, who, like many other Latin writers, deemed the Council in Τrullo to have been an authoritative continuation of the Sixth Oecumenical Council of 680-81 (see § 11 below), quoted approvingly, as emanating from the latter, the thirty-sixth Trullan canon, which summarized the twenty-eighth of Chalcedon. Actually, the chorus of Latin approval of the third canon of Constantinople (see note 62) extended, in effect, to the twenty-eighth of Chalcedon.
NOTES
55. - Mansi, Concilia 3, 560 CD; text, translation, and commentary in Hefele-Leclercq, Conciles , 2, 1 (Paris, 1908), 21 ff.; Beck, Kirche, 45; Dvornik, Apostolicity, 50 ff Cf. Ν.Q. King, «The 150 holy fathers of the Council of Constantinople 381,» Studia Patristica, 1 (TU, 63 [Berlin, 1957]), 635-41; Attanasio Mozzillo, «La convocazione del Concilio di Constantinopoli,» Labeo, 3 (1957), 60-71 (only the emperor can convoke a council); G. Bardy, «Alexandrie, Antioche, Constantinople (325-451),» in "1054-1954, L'église et les églises" (cited in note 1 above), 1, 183-207; Η. Marot, «Les conciles romains des IVe et Ve siècles et le développement de la primauté» ibid., 209-40; Gennadios [Arabazoglu], History of the oecumenical patriarchate (in Greek), 1 (Athens, 1953), 141-90; V Grumel, «Formations et variations des patriarcats orthodoxes,» Annuaire de l'école de législation religieuse (Paris, 1953), 17-27; Ε. Kurilas, "Patriarchal history" (in Greek) (Athens, 1951); Ν. Η. Baynes, «Alexandria and Constantinople: Α study in ecclesiastical diplomacy,» "Journal of Egyptian Archaeology", 12 (1926), 145-54.
56. - Κ. Lübeck, Reichseinteilung und kirchliche Hierarchie des Orients bis zum Ausgange des vierten Jahrhunderts (Kirchengeschichtliche Studien, 5, 4 [Münster i.W., 1901]); summarized by Dvornik, "Apostolicity, 3 ff. and passim; Beck, Kirche, 27 ff.
57. - Dvornik, Apostolicity, 3-22.
58. - On Heracleia, see "Chronicon paschale", 1, CSHB, 530.12-16; Balsamon, PG, 137, 321Β-324C; Michael Le Quien, Oriens Christianus, 1 (Paris, 1740, reprinted Graz, 1958), 1092-98. Cf. Pope Gelasius Ι, Εp. 95, "Collectio Avellana", CSEL, 35, 1, 376.4-13, 378.15-18.
59. - Nicephorus Gregoras, "Byzantina historia", 6, 1, 6, CSHB, 164.15-165.11. Louis Thomassin, Ancienne & nouvelle discipline de l'église, ed. Μ. André, 1 (Barle-Duc, 1864), 234, ignores this passage when he concludes that the metropolitan of Heracleia lost this right at the end of the twelfth century.
60. - Gregory of Nazianzus, Poems, 2, 1, 807-1029, PG, 37, 1085-1100; Sozomenus, HE, 7, 9, PG, 67, 1436C-1448 with note. Cf. Dvornik, Apostolicity, 52 f., 61 f.; F. Homes Dudden, The life and times of St. Ambrose", 1 (Oxford, 1935), 208-14; Kidd, Α history of the Church to A.D. 461, 2 (1922), 249 ff., 279 ff.
61. - Mansi, Concilia, 3, 56, 8Β; Eduard Schwartz, «Zur Kirchengeschichte des vierten Jahrhunderts,» ΖΝTW, 34 (1935), 203-5.
62. Mansi, Concilia, 3, 596E-597Α (Photius, De synodis), cf. 597Ε, 600Β; ibid., 9, 413C (Vigilius); ibid., 16, 174Β (8th Council, the 4th of Constantinople, 869-70, can. 21; Hefel-Leclercq, "Conciles", 4, 1, 529; Μ. Jugie, DTC, 3, 2, 1291 f.f.); Mansi, Concilia, 11, 732Β (Pope Leo II's endorsement of the first five councils); ibid., 19, 663BC (Pope Leo ΙΧ's confirmation of the first four councils, including that of 381, which he says he venerates like the four Gospels, a notion derived from Isidore of Seville [d. 636], Etymologiarum sive originum libri ΧΧ", 6, 16, 1-7 [the four councils are like the four Gospels or the four rivers of Paradise], ed. W. Μ. Lindsay, 1 [Oxford, 1911]); ibid., 22, 989-91 (1215, can. 5; Hefele-Leclercq, Conciles, 5, 2, 1333 f.). Decretum magistri Gratiani, ed. Aemilius Friedberg, "Corpus iuris canοnici", 1 (Leipzig, 1879; reprinted Graz, 1959), 75, Distinctio 22, c. 2, n.: "Ηac auctoritate Alexandrina ecclesia secundum a prima locum habere censetur. Sed postea in Constantinopolitana sinodo ecclesia Constantinopolitana secundum a sede apostolica lοcum accepit. Unde in eadem Sinodo ... constitutum est ita: C. ΙΙΙ. Secundum a Romanο Pontifice Constantinopolitanus obtinet locum. Constantinopolitanae civitatis episcopum habere oportet primatus honorem post Romanum episcopum, propter quod sit nοva Roma." Cf. ibid., 76, Distinctio 22, c. 6: «Constantinopolitana ecclesia secundum a Romana obtinet locum. Item ex VI. Sinodo [cap. 36]. Renovantes sancti Constantinopolitani concilii decreta, petimus, ut Constantinopolitana sedes similia privilegia, que superior Roma habet, accipiat, non tamen ecclesiasticis rebus magnificetur, ut illa; ut hec secunda post illam existens, prius quam Alexandrina sedes numeretur; deinde Antiocena, et post eam Ierosolimitana. ..." On the great authority of Gratian, see, inter aliοs, Walter Holtzmann, «Die Benutzung Gratians in der päpstlichen Kanzlei im 12. Jahrhundert,» Studia Gratiana, 1 (Bologna, 1953), 323-49; cf. Ludwig Ott, «Gratian und das Konzil von Chalcedon,» ibίd., 31-50, who shows that Gratian cites all the canons of Chalcedon except 11 and 28 (cf "Distinctio" 16, c. 10, where Gratian mentions twenty-seven canons of Chalcedon); idem, «Das Konzil von Chalkedon in der Frühscholastik;» in "Das Κοnzil vοn Chalkedon", ed. Α. Grillmeier-Η. Bacht, 2 (Würzburg, 1953), 873-922. On other canonical collections, see Francis Dvornik, The Photian schism (Cambridge, Eng.,1948), 284 f., 289 f. For the Latin protests against the third canon of Constantinople in 451, see "ACO", 2, 3, 3, 101 f, 108-10; Mansi, Concilia, 7, 441 DE (summarized by Kidd, History of the Church, 3, 333 f.).
63. - For a review of the events summarized, see Kidd, History of the Church, 2, 439-44; 3, 209 ff, 303-7; and the other standard authorities, e.g., Ρ. de Labriolle et al., De la mort de Théodose a l'élection de Grégoire le Grand" (cited in note 14 above), 131-48, 163 ff., 220 ff. Α Latin list of the bribes used by Cyril has been published by Ρ. Batiffol, «Les présents de S. Cyrille à la cour de Constantinople,» in his Etudes de liturgie et d'archéologie chrétienne (Paris, 1919), 154-79. See Chrysostomos Ρapadopulos, History of the Church of Alexandria (in Greek) (Alexandria, 1935), 247 ff., 270, 313 ff, 377 ff; J. Faivre, "DHGE", 2 (1914), 322-28, 337 f.
64. - Mansi, "Concilia", 7, 428; "ACO", 2, 1, 3, 88 (447) f.; Hefele-Leclercq, "Conciles", 2, 2, 815 ff; Dvornik, Apostolicity, 82 ff; Thomas Ο. Martin, «The twenty-eighth canon of Chalcedon,» in Das Κοnzil vοn Chalkedon, 2 (cited in note 62 above), 433-58; Emil Herman, «Chalkedon and die Ausgestaltung des konstantinopolitanischen Primats,» ibid., 459-90; Anton Michel, "Der Kampf um das politische oder petrinische Prinzip der Kirchenführung,» ibid., 491-562; with full bibliography, ibid., 3, 825-65, by Α. Schönmetzer; V Monachino, «Genesi storica del canone 28o di Calcedonia,» "Gregorianum", 33 (1952), 261-91; idem, «Ιl canone 28o di Calcedonia e S. Leone Magno,» ibid., 531-65; Trevor Jalland, The life and times of St. Leo the Great (London, 1941), 276-85. Ι translate the canon as follows: Following the traditions of the holy fathers in all respects, and taking cognizance of the canon that has just been read of the 150 bishops beloved of God who assembled in the imperial city of Constantinople, the New Rome, during the reign of the Emperor Theodosius the Great of blessed memory [sc. at the council of 381], we decree and determine the same concerning the privileges of the most holy Church of the same Constantinople, the New Rome. For the fathers properly acknowledged the privileges of the Elder Rome because it was the capital city. With the same intention, the 150 bishops beloved of God granted the same rights to the most holy throne of the New Rome, rightly judging that the city which is honoured by the presence of the emperor and the senate, and which enjoys the same privileges as the imperial city, Elder Rome, should be honoured as the latter is in ecclesiastical affairs also, since [the New Rome] is second to her. Accordingly, the metropolitans of the dioceses of Pontus, Asia, and Thrace, and of these alone, as well as the bishops of the aforementioned dioceses whose sees are in barbarian territory, shall be consecrated by the aforementioned most holy throne of the most holy Church of Constantinople. That is, each metropolitan of the aforementioned dioceses shall consecrate the bishops of his province with the assistance of the bishops of the province, as has been provided by the holy canons. But the metropolitans of the aforementioned dioceses, as stated, are to be consecrated by the archbishop of Constantinople after a harmonious vote has been taken, according to custom, and has been transmitted to him.
65. - PG, 137, 321 ff., esp. 324Α ff.; cf. 484 ff.
66. - PG, 137, 1312C.
67. - Socrates, ΗΕ, 5, 8, PG, 67, 580; S. Vailhé, «Constantinople,» "DTC", 3, 2, 1322 ff. Cf. Joseph Hajjar, «Le synode permanent et le développement du siège byzantin de 381 à 451,» PrOC, 5 (1955), 216-39.
68. - For text and exegesis of these much-disputed provisions, see Hefel-Leclercq, "Conciles", 2, 2, 791 ff., 1805 f., later bibliography in Dvornik, Apostolicity, 92; cf. Beck, Kirche, 30-33 and passim.
69. - Dvornik, Apostolicity, 96 ff.; Jalland, "Life and times of St. Leo the Great", 323-27.
70. - On canon 6 of Nicaea, see Henry Chadwick, «Faith and order at the Council of Nicaea,» "HThR", 53 (1960), 180-95; Eduard Schwartz, "Der sechste nicaenische Κanon auf der Synode vοn Chalkedon,» Sitzungsberichte der Preussischen Akademie der Wissenschaften, Philos.-hist. Κl. 1930, no. 27 (Berlin, 1930); Hefele-Leclercq, "Conciles", 1, 1, 552 ff.
71. - Dvornik, Apostolicity, 51.
72. - Mansi, Concilia", 7, 449; "ACO", 2, 1, 3, 97 (456); Dvornik, Apostolicity, 89.
73. - Dvornik, Apostolicity, 102 ff.
74. - Canon 5 of 1215: Hefel-Leclercq, "Conciles", 2, 2, 857; 5, 2, 1333 f.
75. - Ibid., 2, 2, 856; Dvornik, Apostolicity, 102. On Leo's position, see Peter Stockmeier, Leo I des Grossen Beurteilung der kaiserlichen Religionspolitik (Münchener theologische Studien, Historische Abteilung", 14 [Munich, 1959]); Hans Μ. Klinkenberg, «Papsttum und Reichskirche bei Leo d. Gr.,» ΖSavΚan, 38 (1952), 37-112; and Jalland, op. cit. in note 64 above.
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