If this Harvard Law Record article is accurate, State Department legal adviser Harold Koh is touting “an emerging ‘Clinton-Obama’ doctrine of international engagement.” From the context, it would seem clear that the Clinton is Koh’s boss, Hillary Clinton, not former president Bill Clinton.

Off the top of my head, I can’t recall anyone in an Administration ever labeling an American policy (or “doctrine”) with a compound name in which a subordinate’s name precedes the president’s. (And, no, I don’t think that the “Marshall Plan”—which makes no mention of President Truman—is somehow less respectful of Truman than the “Marshall-Truman Plan” would be.)

I’d guess that we’re not going to have to worry about President Obama nominating Koh to the Supreme Court.