The phrase has come under criticism in both American and British courts. Judges have called it a "freakish fad", an "accuracy-destroying symbol", and "meaningless". In a Wisconsin Supreme Court opinion from 1935, Justice Fowler referred to it as "that befuddling, nameless thing, that Janus-faced verbal monstrosity, neither word nor phrase, the child of a brain of someone too lazy or too dull to know what he did mean". The Kentucky Supreme Court has said it was a "much-condemned conjunctive-disjunctive crutch of sloppy thinkers". Finally, the Florida Supreme Court has denounced the use of "and/or", stating