The Poenitentiale or Liber Poenitentialis of Robert of Flamborough, canon penitentiary of the Abbey of St. Victor at Paris, is a practical manual which made available to the ordinary confessor of the early thirteenth century the fruit of the speculation of canonists and theologians as well as the jurisprudence of popes — all of which had been accumulating during the latter half of the twelfth century. It applied the canon law of the time to such matters as marriage, ordination, simony, usury and feudal contracts. Such a work is of obvious interest to the scholar, and two recent articles, one by Stephan Kuttner in Traditio in 1944 and the other by Pierre Michaud-Quantin in Recherches de Théologie ancienne et médiévale in 1959, have dealt with it at some length. Some features have come to my attention which apparently had escaped the notice of others.