Murdoch has frequently been cited as the ‘‘catalyst’’ for Canadian familylaw reform. 5 As I will illustrate, there can be little doubt that Murdoch playedan integral role in family law reform in the 1970s, but to credit the case for‘‘spurring’’ or ‘‘galvanizing’’ legislative action is somewhat misleading. Each ofthese terms suggests a level of agency that the decision, by itself, simply did nothave.