Definition
CRE appears in Burrill's Law Dictionary as an abbreviated form of the Latin term "recreant" (verbum recreantis, or the word of the recreant), not as a standalone legal term. In that context, it functions as a scribal or editorial shorthand pointing to the entry for RECREANT — the formal declaration of defeat and surrender in trial by combat.
In modern legal usage, CRE is not an established term of art. It appears occasionally as an initialism in specialized regulatory and public health law contexts, most commonly as an abbreviation for carbapenem-resistant Enterobacteriaceae, a class of drug-resistant bacteria subject to reporting requirements under state and federal public health statutes. This usage is administrative and epidemiological rather than doctrinal.
Common Language
Modern common usage (Wiktionary): (1) Initialism of carbapenem-resistant Enterobacteriaceae. (2) Initialism of cutaneous rabbit effect (a perceptual phenomenon studied in neuroscience and psychology).
Historical common usage: No entry in Webster's 1913. The abbreviation had no established common English meaning at that time.
The gap between Burrill's legal usage and any modern meaning is significant: Burrill uses "CRE" purely as a truncation mid-entry, directing the reader to the full discussion of RECREANT. It is not a defined term in its own right. The modern public health initialism developed entirely independently and carries no connection to the historical legal usage.
Common Confusion
CRE as it appears in Burrill is not itself an entry — it is a fragment of the word "recreantis" caught at a page break or abbreviation point, functioning as a cross-reference handle. Researchers who encounter "CRE" in historical legal materials should not treat it as a defined legal concept but should follow it to RECREANT. Conflating this historical shorthand with the modern public health abbreviation would be an error with no basis in either tradition.
Why It Matters in Research
Researchers working in the Law Mind corpus should treat CRE as a navigational artifact rather than a substantive term. When encountered in Burrill or similar historical digests, it signals proximity to the doctrine of RECREANT — the formal consequence of defeat in trial by combat, which carried devastating legal consequences including loss of frank-law, infamy, and exclusion from juries and witness testimony.
The historical legal consequences attached to the cry of recreant are significant for understanding medieval English procedure and its echoes in later common law concepts of competency and credibility. Any research into witness disqualification, compurgation, wager of law, or the abolition of trial by combat in English law (formally abolished by statute in 1819) should engage the RECREANT doctrine directly.
For researchers encountering CRE in modern administrative law materials — particularly hospital regulations, infection control standards, or public health reporting frameworks — the term functions as a technical abbreviation with no legal-doctrinal content of its own. Its significance lies in the underlying regulatory scheme governing infectious disease reporting, not in any common law tradition.
Historical Dictionary Support
Burrill's Law Dictionary does not give CRE an independent entry. The appearance of CRE in the corpus is a page-fragment or abbreviation pointing toward RECREANT and the phrase verbum recreantis. Burrill's full treatment of RECREANT, citing Blackstone's Commentaries (3 Bl. Com. 340; 4 Bl. Com. 348) and Stephen's Commentaries (4 Steph. Com. 415), describes the legal consequences of crying recreant in detail: the defeated party was condemned to amittere liberam legem — to lose his frank-law — becoming infamous and legally degraded, incapable of serving on a jury or giving testimony. Blackstone treated this as one of the more severe forms of civil death available under English law.
No other historical dictionary in the Law Mind shelf addresses CRE as an independent term. The absence is expected: it was never a term of art, only a typographical convenience.
Encyclopedia Cross-Reference
See RECREANT for the substantive doctrine to which this abbreviation points.
See TRIAL BY COMBAT for the procedural context in which the cry of recreant operated.
See FRANK-LAW and COMPETENCY (WITNESS) for the downstream legal consequences.