American Justice Oliver Wendell Holmes Jr. opined in 1891 that "It is hard to explain why a master is liable to the extent he is for the negligent acts of one who, at the time, really is his servant, acting within the general scope of his employment. Probably master and servant are 'feigned to be all one person' by a fiction". Justice Holmes was of the view that the doctrine was in opposition to common sense. In 1916, British attorney Thomas Baty wrote that the doctrine, which he called a "deep-pocket theory", was "derived from an inconsiderate use of precedents and a blind reliance on the slightest word of an eminent judge, and from the mistaken notion that his flights of imagination ... were actual decided cases".