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alf of the 8th century. This being granted, there is room for plentiful speculation as to where and why it was concocted. We may still hold the opinion of Dollinger that it was intended to impress the barbarian Pippin and justify in his eyes the Frank intervention in favour of the pope in Italy; or we may share the view of Loening (rejected by Brunner, _Rechtsgeschichte_) that the forgery was a pious fraud on the part of a cleric of the Curia, committed under Adrian I.,[4] with the idea of giving a legal basis to territorial dominion which that pope had succeeded in establishing in Italy. The donations of Pippin and Charlemagne established him as sovereign _de facto_; the donation of Constantine was to proclaim him as sovereign _de jure_. It is significant in this connexion that it was under Adrian (c. 774) that the papal chancery ceased to date by the regnal years of the Eastern emperor and substituted that of the pontificate. Dollinger's view is supported and carried a step further by H. Bohmer, who by an ingenious argument endeavours to prove that the _Constitutum_ was forged in 753, probably by the notary Christophorus, and was carried with him by Pope Stephen II. to the court of Pippin, in 754, with an eye to the acquisition of the Exarchate. In support of this argument it is to be noted that the forged document first appears at the abbey of St Denis, where Stephen spent the winter months of 754. E. Mayer, on the other hand, denies that the _Constitutum_ can have been forged before the news of the iconoclastic decrees of the council of Constantinople of 754 had reached Rome. He lays stress on the relation of the supposed confession of faith of Constantine, embodied in the forgery, to that issued by the emperor Constantine V., pointing out the efforts made by the Byzantines between 756 and the synod of Gentilly in 767 to detach Pippin from the cause of Rome and the holy images. The forgery thus had a double object: as a weapon against Byzantine heresy and as a defence of the papal patrimony. As the result of an exhaustive analysis of the text and of the political and religious events of the time, Mayer comes to the conclusion that the document was forged about 775, i.e. at the time when Charlemagne was beginning to reverse the policy by which in 774 he had confirmed the possession of the duchies of Spoleto and Benevento to the pope. BIBLIOGRAPHY.--See Dollinger, _Papstfabeln des Mittelalters_ (Munich, 1863; Eng
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