Definition
XXIII is the Roman numeral representation of the number twenty-three. In legal and legislative contexts, it appears most commonly as an ordinal or sequential designator — identifying a specific congress, an article or section within a legal instrument, a volume in a series, or a numbered subdivision of a code or court rule. It carries no independent legal meaning apart from its function as a positional marker within a numbered sequence.
Why It Matters in Research
Roman numerals of this kind appear throughout historical legal materials in ways that can create navigational difficulty for researchers unfamiliar with the conventions of a given era or publication. Several practical points apply:
First, capitalization was not always consistent. The same numeral might appear as XXIII, xxiii, or a mixture (as seen in the Anderson source, which references both "XXIV" and "xxv" in the same entry). A full-text search for one form may not return results in the other, so researchers should query all variants when working in historical corpora.
Second, Roman numerals were the standard convention for numbering U.S. Congresses, volumes of session laws, and major legal treatise series well into the nineteenth and early twentieth centuries. A citation to "Vol. XXIII" or "the XXIIId Congress" requires translation to Arabic numerals to locate the correct physical or digital item in many modern finding systems.
Third, the Twenty-Third Congress of the United States sat from December 2, 1833 to March 3, 1835 — a period that falls within the Anderson source's cited range of "Dec. 1, 1823 to March 4, 1835." Researchers using Anderson's Dictionary of Law should be aware that the source's coverage span encompasses multiple congresses, and that the Roman numeral designation alone does not resolve which session, which act, or which volume is at issue without additional context.
Fourth, when XXIII appears in a constitutional or amendment context — for example, the Twenty-Third Amendment to the United States Constitution — the numeral designates a specific, substantive legal instrument. The Twenty-Third Amendment (ratified 1961) grants Electoral College representation to the District of Columbia. A researcher encountering "XXIII" in an amendment citation must distinguish this constitutional meaning from purely sequential or bibliographic uses in the same materials.
Historical Dictionary Support
Anderson's Dictionary of Law does not define XXIII as a legal term. The appearance of the numeral in Anderson's source material is purely bibliographic — it marks a position within a congressional or volume sequence. The entry as captured reflects Anderson's use of Roman numerals to identify congressional sessions and document ranges, consistent with standard nineteenth-century legal publishing practice.
Historical legal dictionaries of the period (Bouvier, Black's early editions, Burrill) do not carry entries for Roman numerals as such. Their presence in legal reference works is always functional and positional, not definitional. This is consistent with Anderson's treatment.
Researchers should note that historical sources are uneven in their use of uppercase versus lowercase Roman numerals for the same referent, and that no authoritative rule governed the choice in most private publishing contexts of the era.