Kanoon’s Sarange: Goodrich and the Non-Minor Jurisprudences of Law and Love

Abstract

This article uses three main global visual sites—the popular Korean drama Hometown Cha Cha Cha (2021), the Hindi-English movie, The Lunchbox (2013), and the British-American television series Ted Lasso (2020–2023) to engage with two main strains of Peter Goodrich’s scholarship: the interconnectedness between law, justice, and love; and the role of minor jurisprudences. Heeding Goodrich’s advice to consider media as an important node for legal analysis, it traces the course of aromantic amity and asexual kinship across these sites to deliberate new ways of considering the law’s liberal commitments to conjugality and dyadic partnership. By focusing on popular scripts seemingly unrelated to the law, I seek to both contemplate on new pulses in contemporary cultures and the tools they might offer to consider the literature on law and love. Kanoon is the word in Hindi for law and Sarange is the word in Korean for love. Translated loosely—and, intentionally with flaws and gaps in logic—as Law’s Love. To the extent we can reparatively imagine law from the perspective of these cultural prompts, I suggest that they offer new alterities from heteropatriarchy and utopic possibilities beyond the liberal queer rights regime.

I met Peter Goodrich eight years ago, almost to the month, over a photocopier between our two offices in an expertly landscaped Middle Eastern desert island. It could have as easily been a water cooler, but perhaps because it was not, ¹ our bond quickly moved beyond coworker sociality. Over the years, Peter ² and I have fashioned cortados of a certain consistency from our favorite baristas, unearthed unique pleasure in random epistemologies, shared students and drafts in progress, ignored each other’s recipes for making fish, drunk too much champagne, taken terrible photographs, delightfully lost our minds about new silent “p”s, ³ hated the same pretension in specific performance, and overall forged an asexual intimacy that mimics what I imagine—because he has offered me this framework for conjuring—we must have had if we were both young boys stuck in boarding school together. Despite what could be deemed to be deep lapses in similarity, ⁴ our nonetheless reciprocal ⁵ schoolboy friendship saw me through the pandemic as I lived a world away from my home and, over the years, his visits and postal missives of green and black chocolate (with attention to expiry date) have reminded me of how new bonds could be formed and nurtured over the course of one’s life. Unlike other connections, ⁶ our amity has been constructed by intuition and intention, not chance. If one of us passes first ⁷ —as we well might—I imagine the other will grieve privately alongside public admission of our relation and its history. But we are luckier still ⁸ : our noncategorizable living bond ⁹ thrives alongside public acknowledgments to more direct admissions of affection which do not have to wait for tragedy to surface in retrospect.

Alongside this unpredictable course of amity, our initial encounter has other significance too for the framing of this Article. As coworkers exchanging courtesy without commitment, Peter and I had given each other peripheral details about ourselves in our preliminary exchange. This could have easily been just that—passing civility. However, just as we were about to return to our respective offices, Peter said something obnoxious ¹⁰ —he asked me if I knew an Indian person he knew. Before I could dismiss his inquiry and school him on the probabilities of that possibility, I was forced to admit did that I know the person in question—a dear mutual friend who had taken a class with Peter about law and film and who had mentioned to me her wordsmith professor whose emails needed dictionaries to decipher. Perhaps at least as important as the photocopier, then, was this exchange and our mutual sheepishness that forged our public intimacy archive. In this way too, it feels fitting to write about aromantic love and film as fodders for legal theory in a special issue about Goodrich’s law.

Beyond—and because of—nostalgia, two main nodes of Goodrich’s influential bibliography frame the object of this inquiry. The first is Goodrich’s theoretical insistence that important features of law, and particularly justice, are interconnected to logics of desire, affection, and love. ¹¹ The second is his line of research that underscores the ability of media to be an important rhetoric for legal analysis. ¹² In Part I, I motivate my analysis by tracing, respectively, what Goodrich refers to as the minor jurisprudence that connects the relationality between law and love, and the usefulness of using popular media as a metaphor for understanding legal theory and law’s coordinates. My choice of popular media sites that do not directly involve or implicate the law is deliberate. Although there is a line of scholarship that concerns itself with the fashioning of legal consciousness from law’s popular representation, ¹³ this article concerns itself instead with popular media disassociated from legal connections. In doing so, the focus on popular scripts not directly about the law offers both a framework for considering the pulse of contemporary culture and new tools to consider the literature on law and love. ¹⁴ Part II explores the specific sites in question by considering the broad arcs of love and kinship in the popular Korean drama Hometown Cha Cha Cha (2021, “Hometown”), the Hindi-English movie, The Lunchbox (2013, “Lunchbox”), and the British-American television series Ted Lasso (2020–2023, “Lasso”). In each of these sites of mainstream media representations, I suggest that there is a significant movement away from the romantic dyad as a central point of closure and, instead, new subversive ways of considering possible identity flexibilities and partnership utopias. To the extent we can reparatively imagine a law that draws from media’s cultural prompts, I argue that these new exits from heteropatriarchy offer representative alterities for breaking out of what Ratna Kapur terms the “fishbowl” of a liberal queer rights framework. ¹⁵ Part III extends this exploration using the lens of Goodrich’s law, to consider law’s existing commitments to romantic relationality as rooted in relations of property and contract. Instead of these prefigurative notions of commitment that is bound to a “major” legal and capitalist project, this line of argument explores a more expansive conjugation of law’s relationship to love. What, if, instead of our current commitments, our prefiguration allowed for an expansive acknowledgment of asexual community building instead? What, for example, could queer utopia look like if we considered equality beyond marriage? And if the law were to be invested in such construction, what could these scripts teach us?

Together, these inspired strains of critique hope to recalibrate what Goodrich terms a minor jurisprudence to an influential non-minor one that continues to inspire and percolate among those of us who will search without end, with love, for law’s redeeming possibilities.

I. Law-Like Love: Goodrich’s Minor Jurisprudence and Popular Media as Metaphor

Aromantic and nonconjugal relations have attracted the minor-est of jurisprudences. I use the term minor here much as it was initially intended by Minkkinen ¹⁶ to signal a small fraction of the literature ¹⁷ which, as Christopher Tomlins argues, “resisted accommodation within any established canon or genre” ¹⁸ ; as well as Goodrich’s subsequent use of the term to signify a “repressed, forgotten, and failed” version of legal knowledge which “escape[s] the phantom of a sovereign and unitary law.” ¹⁹

The fractionality of interest in this line of inquiry is perhaps evident. Although often public, nonromantic amity, as Goodrich suggests, without paying heed to Cicero’s prompts about Scipio’s dreams, ²⁰ “does not fare well in institutions” and “remains unaccounted in law and marginalized in the practices of scholarship.” Scholars have commiserated about law’s implications for singleness ²¹ and there is some literature on law’s indifference to friendship ²² , but there is less—despite a growing population ²³ —about asexual human intimacy that transcends friendship to be a kind of chosen familial love without a neat category. ²⁴

The “repressed, forgotten and failed” subversion that the interest in the aromantic unearths is a bit more complicated. Part of this is that despite its absolute incompatibility with such organization, love has necessarily fashioned itself with law-like rigor to be legible to legal institutions and their major jurisprudence. It is not surprising then, that non-strict (and, often, non-straight ²⁵ ) strains of love are beyond law’s heteropatriarchal sight. Historically, the major jurisprudence that governed the rules of love were tied to their function of reproduction with “faith, fidelity, and desire” deemed “alike to be directed to the goal of reproducing the church, the ecclesiastical commonwealth and the male line.” ²⁶ An adjacent strain was that love—at least in the eyes of the courts—could not necessarily only be in the abstract and had to be rooted equally in the sacred and profane ²⁷ for operationalization during existence and extinguishment ²⁸ alike. As a result, the responding critique has, despite new dynamics, ²⁹ remained strong in its relationship to the sacred ³⁰ and subversion to the major jurisprudence of love as conjugal and romantic within known and discernable institutions has taken the same vein of the very thing it has opposed. Specifically, the minor jurisprudence of queer relations—used here to signal alterity beyond sexual choice and experience—has necessarily responded to heterosexual stakes by proving that those from the margins could, too, enjoy the continuingly flawed institutions once reserved for the majority.

This is not to say this subversion is without merit. To the extent the goal of the minor jurisprudence is to expand the pie, no matter its flavor, everyone deserves a piece, including the vegan gluten-intolerant subject asking for a slice on principle. I’m old enough to remember how legal discourse around queer possibility, for example, was not socially and institutionally authorized and how its affirmations and sanctions were not reinforced by what Goodrich refers to as the “socio-linguistic insignia of hierarchy, status, power, and wealth.” ³¹ I can, for example, recall being told as a young undergraduate law student to be “less radical” while writing against archaic queer criminalization laws in India and to recalibrate expectations when “swimming against the tide.” Although this is decades ago, the extent of the change in tide—despite a long invisible history—in a few short decades has been remarkable. The passage of time has other fruits too. I am also now in love enough to know the anguish that follows the realization that my partner and I might not always have the same ease of public sight and accommodations across contexts, and certainly never the invisible ease with which straightness navigates the world without question. Independent of what I feel about wedding clichés, there is a tragedy in knowing that we might never have a ridiculous party in India, that we might always be referred to as “friends” (partners, an elder explained, would just confuse people into thinking we were starting a business together), that if we want to have children, it will be an entire industrial complex of effort, none of which will ever be subsidized by a straight State. Even if I am prone to theorizing against marriage as the most valuable goal for the queer movement, and even if it might not be something I actively want, I can recognize its power as a gateway right to a range of other socio-economic and political equalities I do ground my stakes in. I am also keenly attuned to the paradox that it is in fact my vote against marriage—regardless of political source—that homophobes rely on to kill other ongoing valuable movements for sustainable queer equalities. Most of all, I can acknowledge the importance of this visibility for so many that I love, and hold precariously my own complicated hurt about such institutional sanction and security being out of reach.

It is from this context of complacent ambiguity that I observe the remarkably direct ways in which popular narrative has evolved alongside—and fashioned itself within—legal discourse. It is also from these coordinates that I consider Goodrich’s sight to the minor as major and the potential this offers for considering relations of alterity from sites of alterity. Just as minor jurisdictions offer a plurality of knowledge by usurping the “strangeness of language” ³² to offer possibilities from under-resourced sources (in Goodrich’s case—the use of mixed genre sources to build a subaltern and subversive jurisprudence of the courts of law), popular media offer similar reflective possibilities for law’s futures.

II. Various Sarange: Considering Love and Kinship in Hometown, Lunchbox, and Ted Lasso

Visual legacies and the impact they have on cultural politics has been a site of inquiry for scholars of public culture ³³ and my choice of popular visual sites is similarly to excavate the opportunity they offer for considering the state of mainstream acceptability and representation. Should law be reflective of normative order, or at least aspire to hold witness to it in its deliberations, then keeping track of the evolving architectures of sociality seems pertinent. Still, one could argue that reflexivity beyond these scripted stakes ought to have some relationship, or at least interest, in law. For example, popular media has been a useful lens to consider how the law perpetuates inequality but the sites that are used usually portray the law in ways that fashion public imagination ³⁴ or tolerance for its limits. ³⁵ Popular media also has implications for legal socialization for actors who have closer engagement with the institutions of justice. Nielsen and colleagues, for example, argue that mass media ³⁶ that might have shaped the childhood of contemporary practicing lawyers might have had important implications for how they might understand the relationship between morality and justice. ³⁷ Unlike these contemporary cinematic representations that are related to the law, or Kafka’s literary art that lends itself to modern jurisprudence, ³⁸ the sites I chose to focus on in this article do not offer the same tool for understanding the conceptual construction or creation of law from having directly dealt with it. Even so, I argue that these sites of visual observation and the patterns of conformation within them have implications for how the law considers the society it is meant to govern. Instead of taking these sites as linear metaphor, Goodrich’s toolkit offers a more minor socialization segue ³⁹ in suggesting that media might influence audiences—and, in turn, the institutions that govern them—even if it were not to mention the very institutions whose attention they beckon.

Beyond sites of “non-law” (to the extent they exist), commitments to subversion—especially as we consider love’s laws—are strengthened when we consider global visual sites beyond the Western canon. Although the isomorphism of Hollywood travels, representation of social life and interpersonal relation in other contexts offer a broader insight into a range of communal relationships, even if only as foil for understanding the complexity of the (romantic) dyad at the core of their narratives. Whether it be homoerotic friendships, ⁴⁰ the importance of group dynamics in coming-of-age retellings, ⁴¹ or familial buffering of romantic love, ⁴² external frames have been crucial to offering context for the story arc of the romantic dyads. But Lunchbox and Hometown both offer visions of amity and exchange in the nonromantic community that offer a useful framework for considering what others would view as the “main” storyline or plot.

Lunchbox is an internationally produced Hindi drama film that did well on the World Film Festival circuit before also becoming a popular box-office movie success. It is not easy for movies in the subcontinent to receive commercial success and critical acclaim, but the story had everyday resonances that connected with a range of audiences. The plot in Lunchbox revolves around Ila and Saajan, two lonely strangers seeking a connection have not yet articulated for themselves. Ila is a housewife seeking to improve the state of her marriage and follows a friendly neighbor’s advice that the best way to do so is by making better food for her husband. Saajan is a middle-aged widowed accountant about to retire from his seemingly mundane government job. The movie’s plot is put in motion by a miraculous “meet cute” that has no meeting at all, except through, as the movie’s name suggests, a Lunchbox. Ila’s delicious lunch is made for her husband, through a rare slip of the dabbawallas (the local food delivery system in Mumbai, a 125-year-old industry, often lauded to be the most efficient organizational infrastructure, with less than one mistake every six to eight million deliveries), lands on Saajan’s office table and begins for the two protagonists, an opening for new correspondence and community. Through these notes, Ila and Saajan discover gaps and possibilities in their own lives, ultimately leading to them possibly wanting a change in their individual lives. At the end of the movie, inspired by this correspondence, we see Ila preparing to leave her home in search of a new life, and we see Saajan do the same, although it is not clear to the viewer from the script if they will (or can) find each as part of this new beginning.

While there is certainly a romantic reading of Ila and Saajan’s interest in each other, it is not clear when (or if) such a transition happens in the plot. After exchanging notes about a utopic future in Bhutan, the characters try and meet each other, but the attempt is singular and the meeting does not come to pass. It is also not too clear what capacities Ila and Saajan contemplate doing this journey together. We know from a voiceover note in the Lunchbox after the “failed” meeting that Saajan sees Ila at the restaurant where they had decided to meet, but that seeing her—someone too “young and beautiful” for someone like him—made him reconsider his decision to make the virtual connection have a “real life” outcome. As a result, while the (much deserved) epistolary and epicurious centrality of this movie have been diagnosed ⁴³ what is more interesting to me is that the two protagonists never cross paths with each other in the entire 105 minutes of the film. Instead, the frames that offer context for understanding their relation are the (beautifully rendered voiceover) notes that they write each other, and the supportive friendships that the two main characters have in their respective every day. For Ila, it is her friendship with the “invisible aunty” ⁴⁴ whose advice she heeds (about food) and rejects (by not sharing in fullness about her desires for connection) and whose marriage she uses as the subject of contrast in her notes to Saajan. This aunty—again, who we have never seen except through voice-overs—keeps Ila as much company as the missives she gets from her new pen-friend. Similarly, Saajan’s friendship with his new younger colleague Aslam Shaikh is illustrative because Aslam’s navigation of young love offers useful juxtaposition for Saajan’s understanding of his desire and capacity at his age to “start again” with someone in that normative way. Aunty and Aslam are not the protagonists, perhaps, but they are certainly not “side” characters given the nature of their relationship and negotiation with Ila and Saajan. Similarly, Ila and Saajan’s relationship is no less “real” for not having met each other.

This focus on amity and ambiguity in a story—conceivably—about romantic love feels deliberate. Friendship—visible and visceral—with the aunty and Aslam is precisely what helps both Ila and Saajan, respectively, understand better the contours of the romantic love they desire and disassociate with. Even the more “real” bonds of intimacy between Ila and Saajan stay relevant precisely because they play in the realm of asexual ambiguity without descending into the more formal rules of love and its adjacent morality. If Saajan had walked into the restaurant and met Ila, their intentions would have crystalized and perhaps been differently coded, but in staying ambiguous, it holds our attention and appreciation. This distance from a clear outcome helps orient other parts of the film too. By the last third of the movie, we know that Ila wants to leave her adulterous husband and walk out of the house with her young daughter, but we do not know at the end of the story if she makes it to Bhutan, where she wishes to relocate. We also do not know if Ila’s letter to Saajan telling him that she has decided to leave her marriage reaches him, we only know that by the time she physically seeks out to see him in his office, he has already retired and moved to his hometown, Nasik. In the last scene, we see Saajan travel with the dabbawalas in Mumbai but we do not know, as the credits roll, what he is traveling toward. We also do not know if he succeeds—we do not know if he has changed his mind for some reason about wanting to live with Ila and is journeying toward her with hope, or if he is with them after Ila has left with her child for Bhutan, melancholic but peaceful with his decision. In a way, it is in this abyss of not knowing that we come to trust that what Ila and Saajan share are worthy of our sehnsucht.

In contrast to the love that claims stakes amidst the impossible, the protagonists in the blockbuster show Hometown Cha Cha Cha offer different kinds of utopic readings and possibilities. The show, set in the paradisal seaside village of Gongjin, focuses on the everyday lives of its residents as they welcome a new transplant from Seoul, Yoon Hye-jin. Yoon Hye-jin is an accomplished and successful dentist from the city who comes to the village to find herself after a career setback. Like many films that share this trope of the city protagonist returning to roots, there are culture shocks, misunderstandings in interactions, and a slow-burn romance (in this case, with the local jack-of-all-trades that she has nothing in common with, Hong Du-sik). This could easily have been a boilerplate romantic comedy—a canon I am proudly familiar with—but unlike its peers, the show does not deploy distance between its characters for dramatic effect. Instead, Hya-jin and Du-sik meet early in the series, and although they take a while to warm up to each other, their obvious ease and eventuality are taken for granted in the plot. Unlike usual romance tropes of misunderstandings and dramatic reveals, the tension between the protagonists realistically builds and the focus of the drama, instead, relies on everyday ordinary non-dramatic relationships with community members. Equal screen time is spent between building the romantic plot alongside portraying community relationality—a grandmother whose children live far away relies on Du-sik’s care and her groups of friends to navigate her elder care in various ways, an estranged couple is brought together through the moderation of their mutual friends, an old boyfriend who resurfaces is let down most gently and humanely way that continues to reflect dignity. If I am being imprecise about the details of these connections, it is because the web of relationships in the show leaves the viewer with an affective feeling of community more than an analytical understanding of the plot. This was clearly a widely shared affective response—the show was incredibly successful and achieved notable rankings through its airing schedule—but the timing of the show made its impact even more relevant. A focus on the transformational power of community in the everyday, especially at a time when so many people were contending with the meaning of loneliness (the show released through the pandemic), brought home the reminder that people were meant to live alongside other people. Particularly, this subversion of the romantic comedy plot to expose the “self-reliant man’s bluff” ⁴⁵ (a character trait exhibited by Du-sik in earlier episodes of the show) offered important fodder for television narrative that could hold multiplicity in its possibility.

In both Lunchbox and Hometown, although there remains a focus on the main dyad, other characters are central beyond just offering a contrasting foil for understanding their journey. In fact, as I start to suggest above, it is usually through the lenses of actors who are not “central” that the plot bears most clarity. Indeed, in both these sites, the arc of desire that the main characters traverse is only made possible by the strength, work, and independent storylines of the collectives around them. This capacity to share centrality in narrative offers breadcrumbs of possibility to think about the nodes that kinship plays in arranging dyadic desire and destiny.

Kinship has increasingly been alluded to as important in Western visual culture as well, but the stakes in the popular narrative have more centrally relied on individualistic or dyadic outcomes like self-realization, romantic actualization, or any number of other genres. Fraiser, a show that did focus primarily on the relationship between siblings, never described itself to be a show about siblings, and the main siblings characters’ reliance on each other was routinely referenced in the show as an undesirable codependency. Similarly, even in the broader genre of family shows (e.g., Everybody Loves Raymond, Parenthood, Brothers and Sisters, The Middle), where the focus was on family dynamics, the specific focus was always the central marital partnerships and how other relationships buffered or cause tensions for these main dynamics. To the extent asexual kinship has been at the root of the main narrative in non-family-focused shows, its importance has been valorized in recall and audience perspective, rarely in framing itself. Contemporary popular sitcoms like Cheers, Seinfeld, FRIENDS, and How I Met Your Mother all focus on friendship and site (a particular bar or coffee shop that the main group collects together in) as a central framework to the narrative, but the actualization of the arc across seasons is always about romantic endings and eventualities that produce heteronormative ideals, with the lone bachelor vilified or caricatured as acceptable toxic masculinity. ⁴⁶ Part of the focus in shows like these has been to examine how (white, cis, straight) people in their twenties go from being precarious in their singleness and reliance on friendships to a more evolved version of their selves that marries, raises children, and moves out to the suburb to live a more normative life. Even in the recent show Single Parents that refreshingly focused on—as the title suggests—single parenthood, the stakes for four of the five parents to partner with each other over the course of the show offered a similar signaling to the texture of what “good outcomes” for story arcs look like in mainstream visual culture. This is not unlike a genre of romantic comedies that have followed in the wake of the Nora Ephron classic Harry Met Sally to remind viewers that men and women cannot ever be just friends and that even if friendship were the starting point, it would eventually only serve to be the petri dish for more meaningful connection that was romantic. ⁴⁷ Culminating exits across these visual fields, then, beyond what “shipping” viewers would find valuable, have always reinforced the stakes of what the “real” valuable outcomes in life were—partnership, children, property—and how friendship and nonromantic connection can only be “there for you” until other ties take its place.

In some contrast, Western shows that focused on non-white kinships—like Girlfriends, Fresh Off The Boat, or One Day at a Time—have been more invested in asexual kin and possibilities but these shows have always been seen as targeted shows, often on specialized platforms, ⁴⁸ meant more for representation and niche audiences than a signaling of mainstream culture. More recently, shows with minority protagonists have evolved beyond their primary audience base to be seen as more mainstream, ⁴⁹ offering new representations to popular television about kinship and asexual centrality. ⁵⁰ For example, even though framed as a coming-of-age story, the diasporic Tamil American show Never Have I Ever focuses on intergenerational community, the usefulness of reliance (e.g., in a subversion of the evil-in-law trope, Nalini, one of the show’s main characters, relies more on her Indian mother-in-law for support after her husband’s death rather than her parents) and in the final season, the “trainwreck” ⁵¹ main character, Maitreyi, who graduates from high school, acknowledges that her two best friends (whose journeys we have followed throughout the show) are her most stable relationships. Similarly, although framed as a show predicated around a central (romantic) love story, the core focus of a show like Insecure which follows the lives of Black Angelinos, reinforced in its last season’s arc, that at the core of its narrative was centrally the relationship between its two main female characters and their asexual kinship. These depictions offer further evidence of the changing pulse of the cues visual narrative may offer law’s construction of love and dependency. Still, as shows about minority protagonists and cultures, they are easy to be seen as non-normative representations: part of the mainstream, but still othered.

It is with this context that a show like Ted Lasso—the last site for considering amity—and its cult following within the mainstream Anglo-American context offers contrast. Lasso, which just finished its (possibly final) fourth season, follows what has been described, beyond comfort pandemic viewing, as the “quest to build the perfect man.” ⁵² But beyond that individual journey—which loses its course after the second season—the through line of the show is the friendships across contexts as the main protagonist—Ted Lasso—leaves his life in America as a college football coach to move to England and coach a premiere league team despite having no experience coaching soccer (football for us others). As in Lunchbox and Hometown, Lasso is full of examples that amplify the importance of bonds beyond the normative as Ted, a divorced dad, moves to the United Kingdom and makes this journey. But the show is not just about Ted. Friendship and relationality are at the root of all connections in the show. Just as the invisible aunty in the Lunchbox, a group posse of male friends within the club, “the diamond dogs” ⁵³ bear witness to each other’s struggles and give meandering—yet meaningful ⁵⁴ —advice to each other. Unlike flat portrayals of ancillary friendships, the amity arcs in the show move well beyond just forgiveness and redemption (as in the case of the show’s straw man of an unlikable character, Nate Shelly ⁵⁵ or Ted’s right-hand man, Coach Beard ⁵⁶ ) to offer central understanding to the characters and their limitations. These friendships sometimes teeter on the seemingly inappropriate (as with Ted’s eagerness to be friends with his therapist), but they are also radical in their intergenerationality (as in the case of the two main female characters, the club’s manager Keeley Jones and the new owner of the club, Rebecca Welton, ⁵⁷ as well as the older sports reporter Trent Crimm and player Colin Hughes). Even when dyadic bonds and cliques exist, they are romance-agnostic (as in the case of Ted and Rebecca, who delightfully never had a will they/won’t they arc in the show, despite several chances to be able to do that, ⁵⁸ or the beautiful arc between two men who vie at different points in the show for the affection of a character that they both end up in the final montage being friends with). In addition, the show is committed to keeping distance from the regular tropes that reinforce individual stereotypes (like jealousy or competition) which could have so easily taken over the narrative in a show about men and sports. Instead, the show offers scripts for aromantic relationality that places human connectedness beyond institutional scripts at the center. When there is a reveal about a queer soccer player—instead of throwing the character in romantic relation to the other out character, the show subverts that possibility by offering intergenerational asexual community as the mode of exchange between them instead. In the last few scenes of the fourth season, where Ted navigates a difficult decision about staying back and playing for the club or returning to his family and young child back in the United States (here again, the draw is a child who needs him, not a romantic interest in his ex-wife), Rebeccca says “If you go, I’ll go”: a line that could have so easily been a punchline for a romantic connection but here instead allowed for a utopic intimacy by framing friendship to be more than a mere starter block to some preconceived notion of “truer” romantic connection. To see a show this mainstream and successful in the global north—its first season was nominated for a historic 20 Emmy Awards—prioritize community and friendship as the central node of relationality offers deep promise that perhaps we do not need to always look at “specific sites” to consider the subversions we seek.

And yet, perhaps because I am seeking them, there seems to be more mainstream primacy offered to the asexual community in a new wave of shows post Ted Lasso. For example, in the Bear (2022-), a story about two brilliant chefs, it is their tight-knit Chicago community and reliance on close asexual others who form their family of choice that keeps their beloved restaurant—and the show—bustling. The plot necessarily leaves romantic possibilities on the sidelines. Instead, it is alongside sibling dynamics, childhood friends, and a Cuz who is not a cousin, that the two intimate business partners who share a “beautiful platonic friendship” ⁵⁹ build their vision together. And here too, there is active, deliberate subversion. In the most recent series finale of the show, the characters expressly ask for and receive reinforcement about their commitments to each other. The idea that a friendship could acknowledge the nature of its dependency and demands priority ⁶⁰ in this way, alludes to a grander queer possibility of reconfiguring relation. Similarly, in the even more recent hit Apple TV show Platonic (2023-), the narrative experiments with the friends without benefits trope by showing two straight leads never explore romantic possibility despite being deeply connected and codependent. The asexuality inherent between the leads is both directly depicted and indicated by the lack of jealousy or threat from their respective partners. These representations of friendship as central offer new queer possibilities to our understandings of relation. Not only are these visual sites markedly different from their predecessors in their focus on kinship beyond the dyad, but they offer reflection through these friendships of one’s interiority and capacity (similar to the characters in Lunchbox) alongside offering actual community (similar to the characters in Hometown). And it is the kernel of their promise that a more loving law might find its main muse in considering community as central rather than additive context.

III. Law’s Biases and Relational Utopias: Considering the Major Jurisprudence of a Loving Law

Sharing Goodrich’s trust in the power of image and popular culture to help renegotiate existing contracts of possibility, the article tries to make three interventions that connect the role of visual culture in shaping expectations for individuals, communities, and their shared spaces. The first is to think, alongside Goodrich’s metaverse, about law’s didactic scripts of love and how its expansions usually follow limiting path dependencies. ⁶¹ One of the advantages of being a field without explicit canon ⁶² is that law and humanities scholarship has an ever-expanding set of muses to draw inspiration from. Visual narrative has long been used to consider the law—so much so that it has become a sort of canon within non-cannon, or, as Goodrich argues, a “common law” ⁶³ unto itself with specific typologies and possibilities for how rhetoric and extension might follow from representation. ⁶⁴ Although it is not novel to use film as fodder to think about the law, using sites with no connection to the law—although, when seen through a lens, what is not colored in the ways in which we wish to see it—offers new ways to consider law’s utopic possibilities. ⁶⁵ Visual representation also offers a pulse of places the audiences are prepared for, especially if such visible representation occupies popular space and receives mainstream attention and reinforcement. The visual sites I use in the article offer a chance to refocus our considerations of “good” and “bad” outcomes in relationships and kinds of intimacy. In Lasso, the lack of any romantic outcomes for the main characters could be seen as bittersweet and the show ends with the main character returning to where he was at the start of the series. Hometown, similarly, feels like it has an obvious “good” ending, but the actual success of the show is more subtle. Despite notionally being a show about lovers finding each other, at its core, Hometown’s resonance comes from it being a story about community. Its successful ending, then, is the realization that it is the harmony of community that allows individual members to feel more complete in their solitude. Similarly, ambiguity in the Lunchbox ending makes the film’s enchantment accessible and open to interpretation. Those who seek normative endings could see the last scene as Saajan going toward Ila; for others, the journey is a nourishing ending in itself. Similarly, the “failures” offer important direction too—Saajan’s incapacity to walk through the door for their planned in-person meeting might seem to some as a failure on his part to make the relationship “more real” but seen another way, it might be an active disassociation with normativity, an interest, perhaps in other kinds of possibilities for their relationship. This kind of analysis offers legal tools. The ability to look at precedent as “good” or “bad” follows a liberal functionalist model that does not always serve the actors embedded in the outcomes. As I have argued in other places, processes, rather than outcomes are more generative containers for sustainable change. ⁶⁶ In 2023, only five years after decriminalizing homosexuality, the Supreme Court of India considered—and rejected—the possibility of recognizing queer marriage. One could read this as a failure outcome, and it is in many ways, for the reason I set up at the start of this article. But alongside the failure is an opening too, for a possible utopia that can be contained in non-marriage, especially as a foil to consider different queer progressions and meanings of court-sanctioned love. Non-endings, in this way, offer more expansive potential for legal imagination than rigid, cardinal, and fully realized precedents. Just as how favorable outcomes lend themselves to complacency, unfavorable ones can offer chances for constructive repair. It is in these processes that law’s most abundant capacities flourish.

This connection between law and love as ongoing and recursive aids in a second objective, which is to consider the emerging trend within normative Western frameworks the power of relationships beyond the romantic and conjugal as necessary of sight as central rather than ancillary categories. Western modernity has long been enshrined in law to make vital the individual rational agent as the only subject of importance. It follows then that law has a disincentive to imagine a vast perimeter of rights and duties for this rational actor. The dyad as the archetype of the family unit and of modern consciousness is a function of this predisposition. ⁶⁷ In her book on the liberal rights industrial complex and its straightforward trappings, Kapur uses a range of unexplored literary materials of alterity (e.g., spiritual poetry and Vedic philosophy) to counsel that if meaningful freedom is what we are after, we need to look past the language of human rights toward the transformative potential of other, non-liberal registers. ⁶⁸ I have argued elsewhere ⁶⁹ that extending this metaphor requires that we not just change the water or the container that the fish reside in themselves, but that we need to seek alternatives that lie beyond the trapped fishbowl altogether. Marriage and dyadic possibility as equality was always going to be a right embedded in an insufficient container ⁷⁰ and true freedom is always going to have to exist beyond it.

The argument that I strive to persuade the reader here, using Ted Lasso as a temporal foil, is that beyond queer articulation and experience, there is an evolving interest in Western mainstream media about how communities—rather than individualistic dyadic outcomes of romance—matter, and that, in turn, these points of multiplicity are primary nodes through which to understand a person’s coordinates. Law has long been dependent on a model of conjugality that has systematically excluded private organizations of intimacy that fall outside its reductive purview. ⁷¹ Friendship and other social contracts of amity have necessarily been illegible to the law and, in turn, its recourse and protection. Nonconjugal intimacies have always threatened law with what Goodrich refers to as the “anxiety that amity engenders” ⁷² because they have forced legal institutions to contend with the deep-seated frameworks of property and contract that underline the spectacle of law’s love. This is why law creates fictions of proper love (i.e., heteropatriarchal monogamy, no matter the sex and orientation of the subjects involved) that is deserving of attention rather than acknowledge its range of disincentives for caring about love. As Goodrich reminds us, promises between friends and lovers in intimate contexts are necessarily treated differently because of this fiction, rendering them to be governed by ambiguity, or, as he calls it “an Alsatia of domesticity, in a kind of Alaska subject only to the precarious, tacit, and often arbitrary bonds of amity that are sovereign there.” ⁷³

In a sense, the law’s ultimate Love has necessarily been institutions that support and reinforce its power—so the interest in the heteropatriarchal dyad is not surprising; and in making marriage the base right that all other rights are stacked upon, the law has successfully produced an equality ecosystem that reinforces its power over intimacy. It is exactly this supersedence that demands that we inquire more critically about the coordinates of alterity beyond this architecture. What this “beyond” might look like of course changes with context and desire, but at its center, it demands a more critical reading of how we understand and valorize legal outcomes and stakes. What, for example, might it look like to give every person a single relation with rights regardless of the nature of the relation? What if we were to be attentive to signifiers beyond the obvious? I use the case of friendship here, but several other forms of popular anormativity continue to exist in legal shadows. At the same time, if bonds beyond the obvious do in fact intend to create significant relations, and there are new social contracts that relay the importance of these dependencies, then perhaps it calls on readers to see, as Goodrich suggests, that “agreements prevail over law and love over judgment.” ⁷⁴ If anormative bonds are crucial dependencies—and they are, for so many individuals that live outside the limiting lens of nuclear heteropatriarchy—then the reliance on dyadic primacy as the main framework within which to think about legal obligation and entitlement becomes insufficient. Further still, moving away from this “major” quality of law and reconfiguring the essence of its primal relationality become imperative. As Hua Hsu (whose memoir on childhood intimacy demands this question) reflects, “in the face of abundant, tenuous connections, the instinct to sort people according to more rigid logic than that of mere friendship seems greater than ever.” ⁷⁵ If we were to take personal choice in the construction of intimacy seriously, how could the law ignore—or, worse, remain puritan about—alterities in romantic connection and partnership? Relatedly, how could we expect the law to hold the capacity for such alterity if we continue to demand from it scripts that do not serve us? ⁷⁶ Among others, communities of color, immigrant families, and queers have historically had to organize outside of the model of dyadic romantic or conjugal partnership. ⁷⁷ What would law look like—how loving could we demand it to be—if these alternate models of organization were given the same kinds of benefits and structural possibility, we automate for the suburban white picket fence? And better still, what if we recognized the non-alterity of such connection by recognizing that communities have existed in models of close kinship for longer than this modern conception of the romantic dyad and that the nuclear family is a direct function of a much more recent—and middle class white-centric—turn toward property relationships? Inherent in responding to these prompts is the recognition that law, by existing in its current form, subsidizes certain kinds of living and partnership arrangements but not others and that a model of better—and truly more equal—distribution might require a recalibration of our assumptions of where love resides. ⁷⁸ At the same time, a move beyond Goodrich’s observation that promises made by friends or lovers are bound “not in law but only in conscience, morality or honor” ⁷⁹ feels paradoxical. How do we abolish these imagined residences of intimacies while also resisting, as Goodrich warns, the “further juridification of intimacy or imagination’? ⁸⁰ One could agree with Bulter that at least some part of this balance plagues all alterity that seeks recognition within normalcy. ⁸¹ This is not a laboriously lucid response—but perhaps we can garner comfort in knowing that with such reconditeness embedded in argument, we are certainly theorizing about love.

The third intervention in this line of suggestion is to consider the globality inherent in Lunchbox and Hometown despite their hyperlocal execution. Despite societal kinship models inherent in many parts of the world, projections of relationality often continue to struggle with the global isomorphism of Hollywood (and its dyadic) primary scripts. Although global mainstream media scripts about love as primarily romantic have followed Western constructs, these two examples of well-received visual sites in India and Korea, respectively, subvert our gaze quietly by focusing instead on the possibility of community and everyday reliance on asexual nodes as a point of reflection. Lunchbox and Hometown remind us of the ways in which subversion of these tropes in mainstream media can offer new frameworks for imagining model kinships and their dependencies. Others have theorized on the place love has in the legal discourse of more formal, normative institutional structures like marriage ⁸² but the attempt in this article instead is to use invisible scripts of subversion in plain sight—through relational interdependencies and platonic connection—to consider more critically the utopic possibilities the law could fashion its scripts around. This kind of trust in community as central—to borrow from Derrida’s theorizing on friendship ⁸³ —allows one to not merely hold the carcass of institutional limitations, but, instead, move toward an ever-evolving construction of love that is sustained by recognition. Although relatively novel to individualist Western contexts, the centrality of community over dyadic relation has always been an imminent organizing social structure in other contexts. When these ideas of law, like love, flow recursively rather than from one dominant site of creation and performance, what possibilities might they offer to the otherwise linear directionalities that global legal orders are stifled with? These new waves of a popular narrative moving beyond the dyad ever so slightly precisely offer such queer possibility for meaningful alterity. They also afford us a chance to reconsider what we ascribe to be “major” and “minor” in law’s stakes and theories.