Serbonian Bog relates to the lake of Serbonis

Lake Bardawil

Lake Bardawil is a large, very saline lake in Egypt on the north coast of the Sinai Peninsula. The lagoon is shallow and is separated from the Mediterranean Sea by a narrow sandbar. It has Ramsar Convention protected wetlands.Lake Bardawil is about long, and wide...

 (Sirbonis or Serbon) in Egypt

Egypt

Egypt , officially the Arab Republic of Egypt, Arabic: , is a country mainly in North Africa, with the Sinai Peninsula forming a land bridge in Southwest Asia. Egypt is thus a transcontinental country, and a major power in Africa, the Mediterranean Basin, the Middle East and the Muslim world...

. Because sand blew onto it, the Serbonian Bog had a deceptive appearance of being solid land, but was a bog

Bog

A bog, quagmire or mire is a wetland that accumulates acidic peat, a deposit of dead plant material—often mosses or, in Arctic climates, lichens....

. The term is metaphorically applied to any situation in which one is entangled from which extrication is difficult.

The Serbonian Bog is identified as Sabkhat al Bardawil, one of the string of "Bitter Lakes" to the east of the Nile

Nile

The Nile is a major north-flowing river in North Africa, generally regarded as the longest river in the world. It is long. It runs through the ten countries of Sudan, South Sudan, Burundi, Rwanda, Democratic Republic of the Congo, Tanzania, Kenya, Ethiopia, Uganda and Egypt.The Nile has two major...

's right branch. It was described in ancient times as a quagmire

Quagmire

Quagmire may refer to:* Water infused earth or a bog. Solid ground may turn to quagmire following substantial rainfall.* By extension, a situation that is difficult to get out of.* A tactical defense made when defending a territory close to a river...

 in which armies were fabled to be swallowed up and lost.

Uses

Milton's description was quoted as the epigraph

Epigraph (literature)

In literature, an epigraph is a phrase, quotation, or poem that is set at the beginning of a document or component. The epigraph may serve as a preface, as a summary, as a counter-example, or to link the work to a wider literary canon, either to invite comparison or to enlist a conventional...

 to the chapter "Markets with non-convex preferences and production" presenting in .

Justice Cardozo used it in a dissenting opinion, stating: "The attempted distinction between accidental results and accidental means will plunge this branch of the law into a Serbonian Bog."

Justice O'Connor

Sandra Day O'Connor

Sandra Day O'Connor is an American jurist who was the first female member of the Supreme Court of the United States. She served as an Associate Justice from 1981 until her retirement from the Court in 2006. O'Connor was appointed by President Ronald Reagan in 1981...

 said:

We recognise that any standard requiring Courts to distinguish causes that are "accidents" from causes that are "occurrences" requires drawing a line, and we realise that "reasonable [people] may differ widely as to the place where the line should fall"... We draw this line today only because the language of Article 17 and 18 requires it, and not because of any desire to plunge into the "Serbonian Bog" that accompanies attempts to distinguish between causes that are accidents and injuries that are accidents... Until Article 17 of the Warsaw Convention

Warsaw Convention

The Warsaw Convention is an international convention which regulates liability for international carriage of persons, luggage or goods performed by aircraft for reward....

 is changed by the signatories, it cannot be stretched to impose carrier liability for injuries that are not caused by accidents.

US District Court Judge Joseph E Irenas stated:

Tipping the scales at nearly 157 pages, the complaint hardly comports with the principles of brevity......In addition to being overly long, the complaint is inconsistent and confusing, causing this Court to expend much valuable time in an effort to discern its meaning......There is a strong argument that portions of the complaint fail to comply with the strictures of Fed. R. Civ. and might afford this Court a sufficient basis for dismissal. However, a dismissal without prejudice under Fed. R. Civ. P. 8(a) would only lead to a new filing and needlessly increase the amount of time and money already expended. Thus, the Court will plunge into the complaint's "Serbonian Bog" and deal with the pending Fed. R. Civ. P. 12(b)(6) motions on the merits.

Justice Breyer used it in a dissenting opinion in Texas v. Cobb, 532 U.S. 162, 186 (2001).

Judge William H. Pauley III (2004): "This court declines the City's invitation to wander into a Serbonian bog before a state court has had the opportunity to illuminate the path."

Justice Dimmick used it in his dissenting opinion in State v. Cameron, 674 P.2d 650 (Wash. 1983).
"In Crenshaw we began the odyssey. Today's majority opinion now leads us further into the Serbonian bog.

In his published opinion in In re Dow, 213 F. 355 (E.D.S.C. 1914), Judge Smith wrote regarding judicial interpretations of the racial prerequisite in the early U.S. naturalization statute: "All of which foregoing discussion may seem wholly out of place in a reasoned legal opinion as to the construction of a statute, except as illustrating the Serbonian bog into which a court or judge will plunge that attempts to make the words 'white persons' conform to any racial classification."