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Carsten Hjort Lange & Frederik Juliaan Vervaet

THE ROMAN REPUBLICAN TRIUMPH


THE ROMAN REPUBLICAN TRIUMPH
BEYOND THE SPECTACLE

ANALECTA ROMANA INSTITUTI DANICI. SUPPLEMENTUM XLV


Edizioni Quasar
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The Roman Republican Triumph
Beyond the Spectacle

EDITED BY

CARSTEN HJORT LANGE & FREDERIK JULIAAN VERVAET

EDIZIONI QUASAR
ROMA MMXIV
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Analecta Romana Instituti Danici – Supplementum XLV
Accademia di Danimarca, via Omero, 18, I – 00197, Rome

© 2014 Edizioni Quasar di Severino Tognon srl, Roma


ISBN 978-88-7140-576-6

Published with the support of grants from:

The Carlsberg Foundation

Cover: The Fasti Capitolini, containing the Fasti Consulares and the Fasti Triumphales.
Rome, Musei Capitolini, Palazzo dei Conservatori, Sala della Lupa. Photo: Courtesy of
© Archivio Fotografico dei Musei Capitolini.

Print in Italy by LitografTodi - Todi (PG)


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Claiming Triumphs for Recovered Territories:
Reflections on Valerius Maximus 2.8.4*

by Christopher James Dart & Frederik Juliaan Vervaet

Abstract. In the fourth section of his famous summary of Roman triumphal custom (‘de iure triumphi’, 2.8), Valerius
Maximus asserts that there existed a principle that the public triumph could only be awarded to those whose victories had
increased the Roman dominion rather than merely recovered that which had once been Roman, citing as examples the
failed triumphal petitions of Q. Fulvius Flaccus (cos. 237, 224, 212, 209) and L. Opimius (cos. 121) in 211 and 125 respec-
tively. Although the evidence suggests that this can hardly have been a universally applicable and ongoing requirement, this
case study endeavours to show that, while there are flaws in Valerius’ (manifestly biased) representation and he indiscrim-
inately conflates conventions and rules that emerged and evolved over several centuries, there remains historical value in
this passage. In discussing these and a few other relevant triumphs (esp. those of M. Claudius Marcellus in 211, Q. Fabius
Maximus in 209 and Cn. Pompeius Strabo in 89), this study sheds further light on Valerius Maximus précis of triumphal
law and on how the Senate appraised Roman victories over disloyal allied communities. Rather than being simply incorrect
or unhistorical, the “pro aucto imperio” principle indicates a particular development in Roman triumphal practice, as the
Senate had to justify its decisions in the face of quite specific geopolitical circumstances.

Introduction

In section 2.8.4 of his famous chapter de iure triumphi, Valerius Maximus amongst others cites
the examples of Q. Fulvius Flaccus (cos. 237, 224, 212, 209) and L. Opimius (cos. 121). According
to Valerius, these Roman imperators petitioned the Senate to celebrate triumphs in 211 and 125
respectively and both had their requests rejected, apparently upon the grounds that the celebration
could not be granted for the recovery of territory:

Sapientiores igitur Q. Fuluius, qui Capua capta, et L. Opimius, qui Fregellanis ad deditionem compulsis triumphan-
di potestatem a senatu petierunt, uterque editis operibus magnificus, sed neuter petitae rei compos non quidem
inuidia patrum conscriptorum, cui numquam aditum in curiam esse uoluerunt, sed summa diligentia obseruandi
iuris, quo cautum erat ut pro aucto imperio, non pro reciperatis quae populi Romani fuissent triumphus decernere-
tur: tantum enim interest adicias aliquid an detractum restituas, quantum distat beneficii initium ab iniuriae fine.

Wiser then were Q. Fulvius and L. Opimius, who petitioned from the Senate the power to triumph after taking Cap-
ua and forcing the people of Fregellae to surrender respectively. Both had fine achievements to boast, but neither
gained his point: not from jealousy on the part of the Conscript Fathers, who would never allow such a sentiment
access to their house, but from utmost care to observe the law, which provided that a triumph be decreed for aug-
mentation of the empire, not for recovery of what had belonged to the Roman People. For there is as much differ-
ence between adding something and restoring what has been taken away as between the beginning of a benefaction
and the end of an injury.

The key component of this section is the claim that there existed a customary law that “quo cautum
erat ut pro aucto imperio, non pro reciperatis quae populi Romani fuissent triumphus decerneretur”.

* All dates are BCE unless otherwise indicated. We are incisive feedback and valuable suggestions and assume
particularly indebted to Carsten Hjort Lange for some sole responsibility for any remaining flaws or errors.
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54 CHRISTOPHER JAMES DART & FREDERIK JULIAAN VERVAET

In the face of obvious objections and apparent contradictions in regard to the implications of
this passage, many modern scholars have either devoted scant attention to this alleged principle of
Roman republican triumphal custom or, alternatively, have assumed Valerius’ representation to be
incorrect. This tendency is indeed found in many recent works. Thus, in a brief discussion on the
issue in her recent book on the Roman triumph, Mary Beard (2007), views this passage as simply
mistaken, while Christoph Lundgreen (2011) is equally dismissive.1
In the late eighteenth century Edward Gibbon in his famous treatise on the Roman triumph
had already firmly rejected the existence of a triumphal requirement pro aucto imperio.2 In the
1875 edition of W. Smith’s monumental Dictionary of Greek and Roman Antiquities, W. Ramsey
produced an equally valuable, relatively early, survey of the Roman triumph. He argues that vic-
tories should extend, rather than merely regain, territory, although the “absolute acquisition of
territory does not appear to have been essential”.3 The subsequent revised edition of Smith’s Dic-
tionary, produced in 1890 and extensively drawing from Th. Mommsen’s Römisches Staatsrecht
(the first volume of which appeared in 1878), explains that neither Capua nor Fregellae merited
a triumph as the victory must have been won in “a legitimate contest against public foes”.4 In the
Realencyclopädie W. Ehlers (1939) similarly propounds “daß eine Erweiterung des Reiches erfor-
derlich war (…) ist unzutreffend”.5 William Harris (1979) unequivocally asserts that the concept
was “definitely mistaken”.6
The most detailed analysis of this principle, a discussion offering much sound analysis, is pro-
vided by Claudine Auliard (2001) in her meritorious monograph on Victoires et Triomphes à Rome.7
Although Auliard essentially treats it as a feature of very early triumphal law, she makes the clever
and important observation that “comme pour d’autres règles – et notamment celle qui suit – on a
le sentiment qu’il s’agit de prétextes de circonstance, permettant aux sénateurs de fournir un alibi
d’ordre juridique ou traditionnel à leur décision politique”.8 Miriam Pelikan Pittenger (2008), how-
ever, does not discuss either of the examples cited by Valerius: Opimius’ petition in 125 is outside the
primary scope of the book, whilst Flaccus’ request, which is not mentioned in the preserved books
of Livy, is omitted from the appendix cataloguing triumphal petitions.9
In the somewhat daunting knowledge that many of the principles and requirements that governed
the allocation of the public triumph changed and evolved over time, this contribution endeavours
to revisit this passage in Valerius Maximus from this particular perspective, conducting a close re-
appraisal of both the wider and the specific historical context(s).10 This, then, should contribute to a
better understanding of the cases of Q. Fulvius and L. Opimius, shed further light on the fascinating
vagaries of Roman triumphal awards, and measure the extent to which historians can rely on Vale-
rius’ summation of Roman triumphal law.

Apparent contradictions

Valerius Maximus’ assessment can easily be read as directly contradicted by a well-known section in
Livy that describes the dictator M. Furius Camillus’ rescue of Rome from the Gauls in ca. 390-385.11
In 5.49.7, Livy recounts that the dictator had “recovered the Fatherland from the enemy” [“dictator

1. Beard 2007, 211 cites as evidence a footnote in Harris 6. Harris 1979, 123.
1979, 123; Lundgreen 2011, 221. Lundgreen suggests 7. Auliard 2001, 90-104.
that if this rule (Regel) was historical, it was only ever 8. Auliard 2001, 104.
applied in the case of Q. Fulvius Flaccus and L. Opimius 9. Pelikan Pittenger 2008.
as a renewed though unsuccessful attempt “militärische 10. On the changing grounds upon which the triumph was
Leistung messbar zu machen.” awarded in the Republic’s turbulent final decades see, most
2. Gibbon 1796, 134-135. recently, Lange 2013 and Rich elsewhere in this volume.
3. Ramsay 1875, 1165. 11. Harris (1979) and Beard (2007) treat it as a direct contra-
4. Neile Rushforth 1890, 895 – cf. infra for a discussion of diction while, alternatively, Auliard 2001, 93-94 viewed
Mommsen’s view on the issue. the Senate as having overlooked a pre-existing principle
5. Ehlers 1939, cc. 498-499. in awarding the triumph to Camillus.
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CLAIMING TRIUMPHS FOR RECOVERED TERRITORIES: REFLECTIONS ON VALERIUS MAXIMUS 2.8.4 55

reciperata ex hostibus patria triumphans in urbem redit”].12 At first sight, one could indeed argue
that Livy here seemingly saw no contradiction in the principle that a triumph should be awarded
“pro reciperatis”. Nonetheless, there are several important caveats which should be noted in respect
to this story. First, as Livy claims in an earlier section of his account of Camillus’ return, the surren-
der and ransom of the City was not yet fully complete when the dictator arrived: “nam forte quadam,
priusquam infanda merces perficeretur”.13 Second, while the dictator had indeed ‘recovered’ the
territory upon which Rome was built in a sense, his great victory was supposedly the defeat of the
Gauls and not exclusively to recover – using Valerius’ words – “quae populi Romani fuissent”. While
the entry for Camillus’ triumph in the Augustan Fasti Triumphales is regrettably not preserved, it
was almost certainly described as de Gallis,14 making no reference to a territorial victory, as is typical
for such early triumphs (cf. infra). Furthermore, the entire thrust of Livy’s account of the siege and
the fortuitous return of the army with Camillus is that a dishonourable and humiliating surrender
was narrowly averted and converted, by virtue of the dictator’s defeat of the Gauls, into a triumph.
Given that the recovery of Rome was an event steeped in myth and ideology it is not surprising that
the other ancient literary sources reflect the extent to which versions of Camillus’ triumph could
differ. Polybius, for example, is ignorant of the entire event, whereas Diodorus Siculus presents a
significantly different account of the Gallic sack and, indeed, asserts that the award of a triumph was
vetoed by the tribunes of the plebs.15
Another significant problem with Valerius’ account concerns his representation of two other tri-
umphal petitions for which we possess better source material. In 2.8.5, Valerius follows his discus-
sion of Fulvius and Opimius’ refused triumphs by citing the examples of P. Cornelius Scipio Afri-
canus (cos. 205, 194) and M. Claudius Marcellus (cos. 222, 215, 210, 208) as having been requested
ob recuperatas Hispanias and ob captas Syracusas respectively. However, the reason Valerius cites
here for the refusal of the triumph is that their official status at the time of their victories was inad-
equate, rather than that these victories were won to reassert Roman control over Spain and Sicily
respectively: they were denied their triumphs because their accomplishments had been achieved by
virtue of consular imperia that did not derive from a magistracy – “quod ad eas res gerendas sine
ullo erant missi magistratu”.16 To the casual observer, the four victories cited in Valerius 2.8.4-5 all
involved the reassertion of Roman control over a territory or community, even though the grounds
upon which the Senate rejected them differed. In the instance of Marcellus in 211, Livy reveals that,
in terms of their official rationale, the Senate failed to accept his claim that he had completed his
task in Sicily (“prouincia confecta”), taking the view that the war there was not yet over and that he
had therefore been ordered to turn over his army to his successor.17 In the end, according to Livy, the

12. Livy 5.49.7. envy. While Plutarch’s mistake in suggesting that this
13. Livy 5.49.1. would have been Marcellus’ third triumph can easily be
14. Degrassi 1947, 539 where the suggested reconstruction explained in that, following his famous triumph over the
of the entry in the Fasti is: “[M. Furius L. f. Sp. n. Camil- Insubrian Gauls in 222, he went on two stage both an
lus III, dictator III, de Gallis]”. Alban Mount triumph and a public ouatio over Syracuse
15. Polyb. 2.18.1-3 and Diod. 14.116-117; 14.117.5. in 211, senatorial envy may very well have been their un-
16. See n. 76 of Vervaet’s (sole-authored) contribution to derlying motivation, rather than having been expressed
this volume for the fact that Valerius is confused as re- publicly and couched in such terms on the occasion of
gards Marcellus in that his extraordinary proconsulship the debate de iure triumphi. That political rivalries sank
should be dated to 215, whereas he captured Syracuse in Marcellus’ petition might also be inferred from [Aur.
212 on the strength of an imperium prorogatum ex con- Vic.] de Vir. Ill. 45.6: “Et cum per calumniam triumphus
sulatu, namely the third consulship he held in 214. For a senatu negaretur, de sua sententia in Albano monte tri-
a full discussion of Marcellus’ extraordinary proconsul- umphauit”. In 207 and 200 successively, two Roman im-
ship of 215, see Vervaet 2012, 86-94. perators would be granted full public triumphs despite
17. Livy 26.21.2-4. In 26.21.14, Livy confirms that the war the fact that their respective armies still remained in the
in Sicily was indeed far from over as he notes that, af- field, the key difference with Marcellus’ situation in 211
ter Marcellus had departed for Italy, a Carthaginian fleet being that the Senate in both of these ensuing instances
landed 8,000 infantry and 3,000 Numidian horse in an felt that their victories had indeed been decisive: C. Clau-
effort to boost Carthaginian fortunes on the island. In dius Nero (cos. 207), discussed infra, and L. Furfurius
Marc. 22.1, Plutarch likewise confirms that Marcellus’ Purpureo (pr. 200), discussed in Vervaet 2014, 107-11. In
enemies in the Senate opposed the granting of a triumph Ann. 2.41, Tacitus also alludes to the requirement that a
to him on the grounds that the campaign in Sicily was commander complete his commission. In reference Ger-
not yet finished, and that a third triumph would arouse manicus’ triumph over the Cherusci, Chatti, Angrivarii
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56 CHRISTOPHER JAMES DART & FREDERIK JULIAAN VERVAET

Senate nonetheless granted Marcellus the privilege of entering the City in ovation, a compromise
he accepted though proudly matched with a private triumph in monte Albano, a ceremony he de-
liberately staged the day before. In his ovation, he further manifested the great pride he took in his
achievement as he conspicuously paraded many of the simulacra and booty typically displayed in a
full triumph.18 As regards Scipio in 206: according to Livy he gave account of his exploits and made
his request of the Senate but did not push the point, likely understanding that it would be deemed
to create an unacceptable precedent.19 Instead, Scipio entered the City on foot with the vast booty
on public display in a sort of private triumph-like procession. This allowed him to acquire the public
acclaim for his victory without the honour of a public triumph.20
Valerius thus identified four examples of famous Roman commanders who had their requests to
triumph rejected, but for two quite distinct reasons. In the instances of Scipio in Spain and Mar-
cellus in Sicily, he believed the justification for refusing the triumph was the official position of
both imperators at the time of the victory, as holders of imperia granted extra ordinem, outside of
the traditional cursus honorum. In the cases of Q. Fulvius and L. Opimius, however, he thought the
justification was the failure to have enlarged the Roman dominion. One can only properly explain
Valerius’ representation of these failed triumphal petitions if one understands his underlying ratio-
nales. For Valerius, these four instances illustrate the strictures of triumphal procedure as they had
once been interpreted by the Senate. He therefore contrasts this supposed ancient reverence for the
authority of the Senate and its infallible and rightful verdicts with the attitude of those, more recent,
Roman imperators who had been possessed by a “lust for glory” that led to the award of triumphs
over desert mountains and pirates galleys – a thinly veiled criticism of Cn. Pompeius Magnus (cos.
70, 55, 52).21 This problem manifests also in Valerius’ account of the dispute which occurred in 241
as to whether the propraetor Q. Valerius Falto (pr. 142), too, should be permitted to celebrate a tri-
umph for the decisive victory off the Aegates Islands on 10 March 241, a stunning feat that he had
achieved as praetor under the auspices of the consul C. Lutatius Catulus, his temporarily incapac-
itated commander-in-chief. Valerius’ unreserved alignment with early imperial triumphal ideology,
which exclusively reserved the right to triumph to the Emperor and few other members of the domus
Augusta, leads him to conclude incorrectly that Falto was denied the right to triumph, though the
surviving fragments of the Fasti Triumphales unequivocally attest to the contrary.22
Valerius’ outline of these aspects of triumphal procedure might easily be dismissed entirely on
such grounds if not for the fact that the principle “pro aucto imperio” is also attested in Ammianus
Marcellinus, who cites it for his own contemporary purposes:

Numquam enim ab Urbis ortu inueniri potest annalibus replicatis (ut arbitror), terrarium pars ulla nostrarum ab
Imperatore uel consule hosti concessa, sed ne ob recepta quidem quae direpta sunt, uerum ob amplificata regna
triumphales glorias fuisse delatas. Unde Publio Scipioni ob recuperatas Hispanias, Fuluio Capua post diuturna cer-
tamine superata, et Opimio post diuersos exitus proeliorum, Fregellanis tunc interneciuis hostibus ad deditionem
compulsis, triumphi sunt negati.

For never (I think) since the founding or our City can it be found by a reader of history that any part of our territory
has been yielded to an enemy by a victorious commander or a consul; but that not even the recovery of anything
that had been lost was ever enough for the honour of a triumph, but only for the increase of our dominions. Hence
it was that triumphs were refused to P. Scipio for the recovery of Hispania; to Fulvius, when Capua was overcome

and other tribes in 17 CE he indicates that it eventually 19. Livy 28.38.4: “ob has res gestas magis temptata est tri-
became expedient for this important principle to be ig- umphi spes quam petita pertinaciter”.
nored: “bellumque, quia conficere prohibitus erat, pro 20. Livy 28.38.1-5. For some further discussion, see Vervaet
confecto accipiebatur” – comp. also Ann. 1.55. On the 2014, 104.
issue of celebrating triumphs without having brought 21. Val. Max. 2.8.5; hardly concealed criticism of Pompeius:
back one’s army, see also Lange elsewhere in this volume. Dart & Vervaet 2011, 276-278, and Vervaet in this volume.
On Claudius Marcellus’ request of a triumph over Syra- 22. Val. Max. 2.8.1-2 and Degrassi 1947, 549. For a full dis-
cuse, see also Pittenger 2008, 150-159. cussion of this historic episode, see Vervaet 2014, 94-99.
18. Livy 26.21.4-10 and see the suggested reconstruction in Contra: Goldbeck & Mittag 2008, 56-69 and 71, who ar-
Degrassi 1947, 551. On the Alban Mount triumph, see gue that Valerius Maximus was critical of the imperial
Lange in this volume. triumphal monopoly.
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CLAIMING TRIUMPHS FOR RECOVERED TERRITORIES: REFLECTIONS ON VALERIUS MAXIMUS 2.8.4 57

after long contests, and to Opimius, when, after shifting fortunes of war, the people of Fregellae, at that time our
deadly enemies, were forced to surrender.23

Unlike Valerius Maximus, Ammianus thus conflates the failed requests for triumphs by Fulvius and
Opimius with that of Scipio as he fails to recognize that the Senate had formulated a very different
official rationale for refusing him his coveted Spanish triumph.

Triumphs and territorial conquest

Any notion that the ‘augmentation of empire’ was an actual expectation or even a customary pre­
requisite for a triumph at any time in the third or second centuries BCE is discredited by a number
of factors. The first of these are those known examples of naval triumphs. These are distinctively not-
ed in the Fasti Triumphales and were awarded specifically for clear-cut naval victories over regular
enemy fleets, where any territorial gain was inherently ephemeral. While in the case of some naval
triumphs the ritual may have, in part, celebrated a general’s other victories on land or have included
the subjugation of enemy ports, territories or peoples, some naval triumphs clearly did not.24 Indeed
the circumstances of the first naval triumph, the victory of the consul C. Duilius (cos. 260) and also
that of the double naval triumph of Catulus (cos. 242) and Falto (pr. urb. 242) in 241 (as proconsul
and propraetor successively) illustrate this clearly. Although Duilius’ sensational victory was cel-
ebrated with extraordinary honours, including the award of lifelong public privileges,25 it neither
ended the war in Sicily nor territorially enlarged Roman imperial holdings in any significant way.
Similarly, in the case of 241, Catulus as holder of the supreme command and the prevailing auspices
duly received the honour of celebrating his triumph first – “de Poenis ex Sicilia naualem” – while the
propraetor Falto’s triumph was exclusive linked to his naval victory off the Aegates Islands – “ex Si-
cilia naualem”.
In a number of examples from the First Punic War the representation in the Fasti is indeed highly
conspicuous. The victorious imperators are regularly featured as having been awarded triumphs
on account of victories over hostile fleets, e.g. de Poenis naualem (i.e., de Poenica classe), omitting
any mention of territorial gains.26 As a matter of fact, up until 260 BCE, the Fasti typically describe
triumphs as over a people, not some territory. The citations are markedly consistent in regard to this
practice throughout the regal period and the early Republic. While the earliest victories of these ear-
ly times as listed in the official records of the Augustan era are clearly intertwined with aetiological
legends, the practice of attributing victories to the defeat of an enemy people, and of recording them
in such terms, continued well into the historically more safely documented era. The first deviation
from this traditional style of citation occurs in the third century BCE, when two triumphs are de-
scribed as celebrated over a people in conjunction with an individual enemy king. Thus in 275 M’.
Curius Dentatus’ victory is cited as “de Samnitibus et rege Pyrrho”, and in 263 M. Valerius Maximus’
victory is described as “de Poeneis et rege Siculorum Hirone”.27 While C. Duilius’ triumph in 260
introduces the term “primus naualem egit”, it, too, is phrased “de Siculeis et classe Poenica”, follow-
ing the precedents set in 275 and 263.28 This novel practice of extending the traditional triumphal
citation by adding an et followed by an explicatory clause perhaps indicates the remarkable nature
of these victories as experienced by contemporaries, involving defeats of particularly challenging
opponents. For the triumph that took place in the year following that of Duilius’ triumph, then, the
Fasti introduce yet another new formula, viz. “de Poeneis et Sardin[ia], Corsica”.29 Here, for the very

23. Amm. Marc. 25.9.9. It is impossible to ascertain whether or 26. Dart & Vervaet 2011, 270-271.
not Ammianus drew on Valerius Maximus in this instance. 27. Degrassi 1947, 75, 546 and 547-548.
24. For a full discussion, see Dart & Vervaet, 2011. 28. Degrassi 1947, 77, 548.
25. ILS, 65; Cic. Sen. 13(44); Livy, Per. 17; Val. Max. 3.6.4; 29. Degrassi 1947, 76-77, 548 (259 BCE): “L. Cornelius
Flor. 1.18; Sil. It. Pun. 6.663-669. See discussion in Kon- L.f.Cn.n. Scipio co(n)s(ul) an. CDXCIV de Poenis et Sar-
dratieff 2004 and Dart &Vervaet 2011. din(ia), Corsica V Id. Mart”.
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58 CHRISTOPHER JAMES DART & FREDERIK JULIAAN VERVAET

first time, the official citation ties the triumph to specific territories, even though in the period after
the First Punic War many triumphs continued to be typically celebrated over conquered peoples,
rather than for territorial acquisitions.30
This likely denotes a subtle change in outlook consistent with the rapidly evolving way in which
Rome was interacting with the world outside of Italy. Whereas the wars in Italy had been essentially
tribal, occasioning triumphs celebrated over rival Italian peoples, the Romans now began to con-
ceive of their victories in much more territorial terms once they ventured beyond the peninsula’s
shores. Interestingly, Livy happens to record what seems to be the emergence of a distinct concept
of Roman victories resulting in the extension of boundaries, recounting that the consuls in 200 re-
ported favourable omens for the war against king Perseus: “that the haruspices had given answer
that the entrails were propitious and portended an extension of territory, victory, and a triumph”
[“haruspices respondere laetaque exta fuisse et prolationem finium uictoriamque et triumphum
portendi”].31 However, that victories might result in the expansion of Roman dominion and, indeed,
that triumphs might be awarded for such achievements does not in any way indicate that such
expansion was a customary requirement. Instead, this merely indicates that where once triumphs
were celebrated over peoples they might after the First Punic War also increasingly be celebrated for
territorial conquest.
An additional consideration is that there are sundry examples in the preserved parts of the Fasti
Triumphales which cite victories for the same territory. This is echoed in some of the literary sources
as well. Confusion as to the extent of the achievements of the consul L. Cornelius Scipio (cos. 259) in
Sardinia and Corsica is clear in the literary sources, with the Periochae giving the most positive as-
sessment: “L. Cornelius consul in Sardinia et Corsica contra Sardos et Corsos et Hannonem Poeno-
rum ducem, feliciter pugnauit”.32 Other ancient literary sources imply that he won modest victories
before leaving with his fleet at the end of the campaigning season. The Fasti Triumphales record
Scipio’s triumph as “de Poeneis et Sardin(ia), Corsica”.33 The reality was that neither island had been
subjugated, nor would they be until decades later.
As with, perhaps, the rituals associated with the triumphal celebration and procession them-
selves, the practices and customary ‘rules’ which the Senate applied when determining whether
or not to award a public triumph to a victorious commander evolved considerably over time.
Fortunately, this important feature of triumphal procedure is now often recognized by modern
scholarship.34 In all cases, lacking any relevant statute laws, the Senate had complete discretion
as to whether or not a triumph would be awarded. Even so, the Roman senators always needed to
frame their decisions in line with the conditions under which past celebrations had occurred and
within contemporary understanding of what constituted customary practice. Tanja Itgenshorst
(2005) has duly emphasized the importance of such debates as an historical source. She observes
that Livy often preserves detailed accounts of senatorial debates over triumphal petitions which
contrast with his repetitive accounts of the actual public rituals associated with the triumph,
suggesting that such debates are a more reliable indication of actual documented proceedings.35
Conversely, the Senate could create novel criteria for either awarding or denying imperators the
right to celebrate a public triumph in accordance with the unique circumstances of any particu-
lar victory. Certainly, as discussed above, this was the case with C. Duilius in 260, whose official
victory celebration represents the first ever example of a naval triumph, duly recorded as such in
the Fasti and complete with extraordinary personal privileges. This, then, created a marked prec-
edent for future commanders to emulate. Similarly, awards of triumphs ex Sicilia, ex Sardinia and
ex Corsica and indeed, examples in the centuries after the First Punic War (ex Achaea, ex Asia, ex

30. Compare also the observations in Auliard 2001, 101, 32. Livy, Per. 17.
where it is argued that few, if any, of the triumphs award- 33. See n. 29 supra.
ed between the first two Punic wars involved genuine ter- 34. Thus see, for example, the discussion in Auliard 2001
ritorial expansion, which further discredits the existence and Lange 2013.
of some “pro aucto imperio” principle in this period. 35. Itgenshorst 2005, 159-160.
31. Livy 31.5.7.
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CLAIMING TRIUMPHS FOR RECOVERED TERRITORIES: REFLECTIONS ON VALERIUS MAXIMUS 2.8.4 59

Hispania, etc.) denote an increasingly territorial concept of what constituted a valid victory for a
Roman commander, worthy of full triumphal honours.36

The failed triumphal petitions over Capua and Fregellae

As recorded by Valerius, the earliest known instance of the application of the principle pro aucto
imperio involved the proconsul Q. Fulvius Flaccus’ request for a triumph over Capua, made at some
time in the summer of 211. As a matter of fact, this eventful year would see yet another attempt to
secure the honour of celebrating the first full triumph of the so-called Hannibalic War, as M. Clau-
dius Marcellus (cos. 222, 215, 210, 208) returned to Rome from Sicily in the late summer and re-
quested a public triumph for capturing Syracuse.37 Both victories concerned major successes over
disloyal former allies. Although Livy omits any reference to Flaccus’ failed petition, he does recount
that Marcellus managed to secure an ovation, first staging his own triumph in monte Albano.38 As
indicated in the above, the official rationale for denying Marcellus the regular public triumph was
that he had not fully accomplished his prouincia, namely the war in Sicily. As regards Q. Fulvius’
failed triumphal petition, Valerius and Ammianus Marcellinus (supra) indicate that he was advised
that his success had not resulted in new territorial gains, only in the reconquest of “what had already
belonged to the Romans”. Interestingly, Livy further recounts that M. Valerius Laevinus as consul in
210 convened the Senate to claim he had completed the conquest of Sicily after some sixty years of
warfare by land and by sea, and that no Carthaginian remained on Sicilian soil – “senatum extemplo
habuit, ubi de suis rebus gestis commemorauit: cum annos prope sexaginta in Sicilia terra marique
magnis saepe cladibus bellatum esset, se eam prouinciam confecisse. Neminem Carthaginiensem
in Sicilia esse”. Although Livy fails to identify this occasion as a petition for a triumph ex Sicilia, his
representation nonetheless strongly suggests that this was what Laevinus was after, well aware of
how the Senate had dealt with Marcellus the year before.39
The first triumphs of the Second Punic War came in 209 and 207 successively. In 209, none other
than Marcellus’ main political rival, Q. Fabius Maximus (cos. 233, 228, 215, 214, 209), celebrated
a triumph over the Tarentines, whilst the triumph of 207 was granted on account of the consuls
M. Livius Salinator and C. Claudius Nero’s crushing defeat of Hasdrubal and his army at the Metau-
rus.40 Fabius’ remarkable success in achieving the distinction of celebrating the first full public
triumph of the war powerfully demonstrates how political clout could always trump precedent, as
his brutal capture of Tarentum, another disloyal former ally, did not signify the end of hostilities in
southern Italy. Down to 203, successive consuls would be entrusted with the war against Hannibal
in Apulia, Lucania and especially Bruttium.41

36. See Degrassi 1947, 79-85, 552-553. credit the triumph of 207 as the first full public triumph
37. That Q. Fulvius made his failed bid for the triumph a of the war. Alternatively, Livy may have felt that the (cir-
short time before that of Marcellus can be safely inferred cumstances of the) capture of Tarentum did not merit
from Livy 26.20.7; 21.1-2. On the issue of triumphs in the a full public triumph. Livy 27.26 highlights the coward-
Second Punic War, compare also section 9 of John Rich’s ice of Tarentine defenders, an unsuccessful attempt by
substantial and insightful contribution to this volume. Carthalo to surrender and the indiscriminate slaughter
38. Livy 26.21. intended to conceal that treachery had been involved in
39. Livy 27.5.1-7. Regrettably, the loss of the relevant entries taking the city. In this respect, it is also well worth noting
in the Fasti Triumphales greatly complicates the answer repeated comparisons of the conduct of Marcellus and
as to whether or not Laevinus was successful. Degrassi Fabius: Livy 27.16.8; 27.20.9-10; Plut. Fab. 22; cf. Marc.
1947, 551 seems to have believed that Laevinus was not 21. On the triumph of 207, see Livy 28.9.7; Degrassi
able to secure a triumph. 1947, 551; Vervaet 2014, 100-103.
40. On Fabius’ triumph over Italiote former amici et socii, 41. See Broughton 1951, 289-90 (208 BCE), 294 (207 BCE),
see Plut. Fab. 23.1-2; Comp. Per. et Fab. 2; CIL 11, 1828 298 (206 BCE), 301 (205 BCE), 305 (204 BCE), 310-1 (203
(Elogium Fabii); Degrassi 1947, 551. Quite remarkably, BCE). Interestingly, Plut. Fab. 23.1 recounts that the fall of
Livy does not make any mention whatsoever of Fabius’ Tarentum made Hannibal for the first time fully appreciate
triumph de Tarentinis, perhaps because he felt that Mar- that he could impossibly master Italy with his present for­
cellus had been wrongly denied his over Syracuse, a very ces. This may well echo Fabius’ own rhetoric as he asked
similar achievement that in every respect easily matched the Senate for a triumph over Tarentum, emphasizing that
Fabius’ capture of Tarentum, and therefore decided to his victory represented a genuine turning point in the war.
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Whilst Marcellus and Fabius thus experienced markedly different outcomes on the strength of
similar successes against former Italiote or Hellenic allies42, there remains the question of whether
Valerius Maximus’ explanation of Fulvius’ failure is entirely false or nonsensical. In all probability,
the answer consists of two mutually compounding considerations. First, one has to observe the spe-
cial status of both Capua and its adjacent territory, setting it aside from such communities like Syr-
acuse and Tarentum. In the wake of the Latin and Campanian defeat in c. 340, Capua was deprived
of valuable land, and the fertile Ager Falernus in Campania was annexed by Rome.43 Thereafter,
the city possessed ciuitas sine suffragio.44 Following the disaster at Cannae in 216, a faction within
Capua had induced Campania’s ranking city to side with the Carthaginians.45 The consuls Q. Fulvius
Flaccus and Ap. Claudius Pulcher laid siege to Capua in 212, and the town finally surrendered to
Fulvius in 211. Taking the city was also an important objective in terms of regaining control of the
agricultural produce of the region. Although Capua’s lands were now seized altogether, the Senate
decided to maintain a community on the site, precisely in consideration of the region’s important
agricultural production.46 Second, there is Flaccus’ high-handed behaviour. Following the capture of
Capua, the Senate in Rome sent correspondence advising that the local elites of the city should be,
for the time, spared. Livy records two versions of the proconsul’s notorious response to the letter. In
one, having the document brought to him, he refused to open and read it until after his lictors had
scourged and beheaded the captive nobles. In the other, exploiting the traditional phraseology of
senatorial correspondence to a ranking Roman commander (“si tibi uideretur”), he read the letter
and then executed the leading men anyway.47 Faced with the proconsul’s request for a triumph, the
Senate obviously felt his self-willed brutality had not earned him the eternal honour of what would
be the first such celebration of the war. By objecting that Flaccus’ victory, however significant, had
really achieved nothing but to recapture Roman possessions, they thus killed two birds with one
stone: a reassertion of the auctoritas senatus vis-à-vis an imperator in the field who had deliberately
ignored his peers, and a politically expedient avoidance of further public humiliation of an utterly
defeated Italic ally.48 It is, indeed, not hard to imagine how many senators would have felt it inappro-
priate for Rome to stage what would have been its first triumphus publicus of this gigantic struggle
over a community of traitorous ciues sine suffragio, rather than over some suitably foreign enemy.49
The circumstances of Opimius’ victory over Fregellae were similarly contentious. Fregellae was a
prosperous Latin colony founded by Rome in 328 as a bulwark against the Volscians. However, in
125, in the consulship of M. Plautius Hypsaeus and M. Fulvius Flaccus, the people of the colony re-
nounced their allegiance to Rome after a failed bid to seek greater legal rights.50 Occurring in the peri-
od of the Gracchan land commission, the motivations of the Fregellans can reasonably be understood
in the context of growing disaffection among some Latin and allied communities with their treatment
by, and relations with, Rome.51 The Senate swiftly dispatched the praetor L. Opimius (cos. 121) to
Fregellae. After a local man betrayed the community, Opimius put down the revolt with great sav-
agery, destroying the city in the process.52 As with Capua, the city was located in far too opportune
a position for its territory to be simply abandoned, and a new settlement was quickly established on

42. By virtue of his Tarentine triumph, Fabius, who had cel- prior senatorial authorization: Vervaet 2007.The sheer
ebrated his first public triumph as consul in 233 over depth of grievance amongst surviving Capuan nobles is
the Ligurians (Degrassi 1947, 76-77, 549), could rival clear from Livy 26.27, where it is recorded that a group
the achievement of Marcellus, who had earned one reg- of them set fire to the city of Rome at the outset of (the
ular triumph (including a dedication of Spolia Opima consular year) 210.
to Juppiter Feretrius) and one public ovation, coupling 49. That might well explain why Livy chose to suppress any
the latter with his own triumphal procession in monte mention of Q. Fulvius’ petition.
Albano. 50. Livy, Per. 60; Vell. Pat. 2.6.4; Cic. Pis. 95; Phil. 3.17. See
43. Livy 8.11.12-6. App. B Civ. 1.21 and 1.23 on proposals to extend citizen-
44. Livy 8.11-14. ship to Latins in the period. See also Cic. Brut. 170.
45. Livy 23.2-10. 51. See Dart 2014.
46. Erdkamp 2011, 72-73. 52. On the betrayal of Fregellae by Q. Numitorius Pullus:
47. Livy 26.15; compare also Cic. Leg. agr. 1.6. Cic. Phil. 3.17; Fin. 5.22(62); Inv. Rhet. 2.34(105). On its
48. Some six years before, Q. Fabius Maximus himself as destruction: Livy, Per. 60; Val. Max. 2.8.4; Iul. Obseq. 30:
dictator had incurred the immediate wrath of the Senate “Fregellae, quae aduersus Romanos coniurauerunt, diru-
as he had agreed to exchange prisoners-of-war without tae”.
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a nearby site under the new name of Fabrateria Nova, settling the hapless survivors of Fregellae.53
Upon his return to Rome, Opimius dauntlessly petitioned the Senate for a triumph. As his career in
the years that followed would demonstrate, he was a particularly divisive figure. Prevented from win-
ning the consulship of 122 by C. Fannius (cos. 122), on the instigation of the tribune C. Sempronius
Gracchus, Opimius aggressively responded with a successful bid for the consulship of 121. As Cicero’s
appraisals attest, Opimius certainly had supporters in the Senate, both during and beyond his own
lifetime. In January 63, in his second speech against the agrarian bill of P. Servilius Rullus, Cicero
even blithely associates the war against Fregellae with the Social War: “bella cum sociis, Fregellanum
Marsicumque”.54 He was, moreover, highly critical of the eventual conviction and exile of Opimius as
a result of his actions against C. Gracchus in 121.55 Writing after his own suppression of the so-called
Catilinarian conspiracy, Cicero’s support for Opimius’ brutal repression of Fregellae should not sur-
prise. Velleius Paterculus’ representation, however, indicates that there continued to exist a different
judgment on Opimius as a man of excessive and uncompromising brutality:

Hunc L. Opimius consul, qui praetor Fregellas exciderat, persecutus armis unaque Fuluium Flaccum, consularem
ac triumphalem uirum, aeque praua cupientem (…)56

The consul, L. Opimius, who, as praetor, had destroyed Fregellae, hunted down Gracchus with armed men and put
him to death, slaying him with Fulvius Flaccus, a man who, though now entertaining the same distorted ambitions,
had held the consulship and had won a triumph (etc.)

It is, therefore, not implausible to suggest that the consul M. Fulvius Flaccus himself may have
played an important role in obstructing Opimius’ triumphal petition in 125, calling to mind the Sen-
ate’s official rationale for denying his famous ancestor’s request to triumph over Capua.
In both the cases of Capua and Fregellae, rebellious Italic communities which already enjoyed a
privileged legal status (ciuitas sine suffragio and ius Latii respectively), setting them apart from such
independent amici et socii as the Syracusans and the Tarentines, were repressed and destroyed with
especial brutality. In both instances the communities were rebuilt shortly after, and in both instances
the Senate decided to avoid adding insult to injury by granting triumphs to the imperators involved,
the more so as many ranking senators had taken offence at their high-handed ruthlessness. Dictated
by the circumstances of the moment and political expediency, the official rationale appears to have
been elevated to principle: “ut pro aucto imperio, non pro reciperatis quae populi Romani fuissent
triumphus decerneretur”. It is, perhaps, also not surprising that, to the best of our knowledge, the
Senate only ever invoked this principle in regard to legally privileged communities in Italy, given that
such communities were increasingly thought of, and treated as though they were, Roman posses-
sions. In light of these considerations, Mommsen is thus not too far off the mark when he argues “die
rechte Siegesfeier setzt einen rechten Krieg voraus; die Ueberwindung aufständischer Bürger oder
aufrührerischer Sclaven berechtigt also weder zum Triumph noch zur Ovation”, and that “aus die-
sem Grunde (nicht, wie Valerius Maximus 2, 8, 4 irrig sagt, weil nur pro aucto imperio, nicht pro re-
ciperatis quae populi Romani fuissent triumphirt ward) ist auch nicht triumphirt worden wegen der
Einnahme der Halbbürgergemeinde Capua 543 und der latinischen Colonie Fregellae 629; letzteres
is geschichtlich wichtig insofern sich daraus ergiebt, dass die Latiner damals in dieser Beziehung
den Bürgern gleich geachtet wurden.”57 Nonetheless, it is important to emphasize that, in terms of
public law, the conquests of such traitorous or seditious cities as Capua and Fregellae did not at
all constitute civil war victories.58 Rather than entirely misrepresenting matters, Valerius Maximus

53. Vell. Pat. 1.15.4. See Crawford, Keppie, Patterson & Verc- 55. Cic. Planc. 70-71. Written in 54.
nocke 1986 and Launaro 2011, 130-132. The destruction 56. Vell. Pat. 2.6.4.
of the old site was significant, with subsequent activity 57. Mommsen 18873, 133 (with n. 3).
on the area of the old city concentrated close to the new 58. For the odium attached to civil war victory (triumphs),
settlement. see Val. Max. 2.8.7; Flor. 2.22.9, comp. also Lange 2013.
54. Cic. Leg. agr. 2.33(90).
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62 CHRISTOPHER JAMES DART & FREDERIK JULIAAN VERVAET

merely records a principle formally defined by the Senate in the face of complicated circumstances,
involving the capture of cities enjoying a privileged status by imperators applying strong-arm tactics
at their own discretion. Besides, if the ancients had perceived Q. Fulvius Flaccus’ victory over Capua
in 211 as a genuine forerunner to the civil wars of the final century of the Republic, one could rea-
sonable expect them to have highlighted such an early precedent.

Epilogue: the one triumph of the Social War

The Social War presented what was quite probably the most serious military threat in Italy Rome
had faced since the Second Punic War.59 Nevertheless, regardless of a series of impressive victories
won by ranking nobles, received enthusiastically by the people in Rome, this conflict only produced
a single triumph which took place at a very late stage of hostilities. Thus for instance in 90, Orosius
claims that the consul L. Iulius Caesar was hailed Imperator by his troops on account of a major vic-
tory over the Samnites and Lucanians.60 Although the Senate was so delighted and relieved at news
of this success that they ordered laying off military cloaks (the saga) in the City,61 there is no record
whatsoever of a triumph in either the literary sources or the fully preserved Fasti Triumphales, re-
cording the entries of the years 98 through 81.62 Instead, Caesar returned to Rome, presided over the
elections for 89 and was subsequently elected to the censorship for 89. December of that year, how-
ever, would see the one and only triumph of the entire war, celebrated by the consul Cn. Pompeius
Strabo for his suppression of the Social War in Picenum and the capture of Asculum, the region’s
principle bulwark: “Cn. Pompeius Sex. f. Cn. n. Strabo co(n)s(ul) de Asculaneis Picentibus VI k.
Ian. a. DCLXIV”.63 As had happened at Capua, the consul had executed the leading men, stripped
the surviving citizens of the city and permitted them to leave.64 There certainly was a precedent for
a triumph over Italiote amici and socii, namely that of Q. Fabius Maximus over the Tarentines in
209. Nonetheless, Strabo’s triumph has a particularly odious streak in that the Picentes had been
long-term Italic allies of Rome and harboured his family’s principle estates and main client base.65
As events in future years would prove, the Pompeii would even continue to be a major influence in
a region they considered to be a personal stronghold. In another ironic twist of fate, the very people
over whom the triumph was celebrated were soon to be enfranchised as Roman citizens.66
Whereas the Senate had denied Fulvius and Opimius their not entirely dissimilar requests, offi-
cially objecting that their victories had merely restored Roman supremacy, and men like L. Iulius
Caesar seem to have wisely desisted from triumphal requests over once close and long-lasting Italic
allies, if only because the war was far from over and for reasons of diplomacy,67 Cn. Pompeius Stra-
bo’s successful petition should probably be explained in terms of its wider political message. After
all, it was the killing of a Roman (pro?)magistrate and his legatus at Asculum in 91 that had triggered
the outbreak of the Social War.68 While Wolfgang Havener (in this volume) suggests that (certain as-
pects of) Sulla’s triumph of 81, though officially celebrated de rege Mithridate, represent(s) a first, if

59. For a full treatment of the Social War, see Dart 2014. Pompeius’ life, as well as his father’s property, were saved
60. Oros. 5.18, possibly supported by Livy, Per. 73. by Cn. Papirius Carbo (cos. 85, 84), quite ironically in
61. Livy, Per. 73; Vell. Pat. 2.16.4; Oros. 5.18. light of subsequent events: see Cic. Brut. 230; Val. Max.
62. Degrassi 1947, 84-85. 6.2.8. On the trial see: Broughton 1952, 54 and Hillman
63. Degrassi 1947, 84-85, 563. 1998, 179.
64. Livy Per, 76; Oros. 5.18.26. 67. Apart from the fact that the ongoing war in Italy made
65. For instance, Vell. Pat. 2.29.1 describes Pompeius as “qui for a good reason not to award any triumphs, such cele-
totus paternis eius clientus refertus erat”, comp. also brations could have further radicalised anti-Roman sen-
Livy, Per. 85; App. B Civ. 1.80. On the family’s Picentine timent across Italy. L. Caesar’s own consular legislation
connections see discussion in Seager 2002, 20-21. in 90 extended Roman citizenship to communities in Ita-
66. In a peculiar turn of circumstances, a group of Ascu- ly which had remained loyal. The continuing seriousness
lani even brought legal proceedings against Strabo’s son of the Social War was confirmed early the following year
Cn. Pompeius early in 86 for his continued possession when the consul Cato was killed in battle with the Marsi:
of their personal items, looted from the city in 89: Plut. see Dart 2014.
Pomp. 4.1-4. It may be that it was on this occasion that 68. See discussion in Dart 2014, Chapter 5.
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CLAIMING TRIUMPHS FOR RECOVERED TERRITORIES: REFLECTIONS ON VALERIUS MAXIMUS 2.8.4 63

partial and covert, step on the notorious road to civil war triumphs, Pompeius Strabo’s “triumphus
de Asculaneis Picentibus” does stand out as an historic and ominous exemplum in its own right,
representing the first public triumph over a rebellious Italic ally.69 Less than ten years later, in March
81, his no less vainglorious son, Cn. Pompeius Magnus, would not flinch from raising the stakes by
arrogating, and staging, a triumph that would shake Roman triumphal custom to the core.70

Conclusions

Rather than being incorrect, or even entirely fictitious, the pro aucto imperio passage in Valerius
Maximus possibly indicates a development in triumphal practice and in the way in which the Senate
justified its decisions in consideration of specific geopolitical circumstances.71 On the one hand,
Q. Fulvius’ request of a triumph in the face of his disregard of the Senate’s intentions called for a
justification of why he should not be permitted public honours. On the other hand, the Capuans
were not just like any other community that had defected to Hannibal. Accordingly, the Senate
turned down his petition with the justification that he had failed to enlarge Roman territory, merely
recovering what had already been lawfully held by Rome. This was, after all, true. In 125, the Senate
invoked the same rationale to thwart the triumphal ambitions of the praetor L. Opimius, who had
conquered a Latin colony, planted upon land which was already legitimately Roman and which had
been distributed by Rome to its colonists of Latin status.
In the absence of binding statute law, the Senate was always at liberty to construct rationales for
whether or not to grant a triumph in response to the specific circumstances under which a com-
mander had gained significant military success. Once a new principle had been asserted, it naturally
provided a precedent for any individual within the Senate who wished to exploit it when judging a
future case. Once a principle had been formulated to deny Q. Fulvius his requested triumph over
Capua, it could be reinvoked in any later instance where a majority of senators saw fit. This was pre-
cisely what happened in the consulship of another Fulvius Flaccus, roughly some ninety years later.
The example of the First Punic War, however, shows that the Senate had not originally conceived
of new territorial conquests as a necessary prerequisite for a public triumph, and later examples
of multiple triumphs over the same territories72 suggest that the principle “pro aucto imperio” was
only ever applied with regard those regions of the Italian peninsula that already enjoyed a legally
privileged and particularly close relationship with Rome.
The main problem with Valerius’ famous section de iure triumphi is that his précis of Roman trium-
phal custom indiscriminately lumps together a series of triumphal conventions, rules and regulations
that emerged gradually and haphazardly, and likewise often fell into partial or complete abeyance,
over several centuries, casting them into iron as one timeless and immutable set of ‘triumphal laws’.
His representation of Roman republican triumphal practice is then further distorted by the fact that
he evidently adhered to the relatively new ideology of the exclusive imperial monopoly of the public
triumph as it had been established by Augustus and next consolidated by Tiberius, combined with an
equally dogmatic assertion of the Senate’s traditional discretion over triumphal custom. These caveats
in mind, the above analysis nonetheless suggests that Roman historians should attach some credibility
to each and every ‘law’ attested, and undertake to study it within its specific historical context(s), rather
than merely discrediting, all or part of, Valerius’ summary as fanciful or unhistorical fabrication.

69. More on these issues in Lange’s forthcoming monograph Fregellae in 125.


on the Roman triumph in the troubled era of internecine 70. See Vervaet elsewhere in this volume.
strife and civil wars that followed the troubled plebeian 71. Weileder’s suggestion in 1998, 289 that Valerius here con-
tribunates of Ti. and C. Gracchus. On Sulla’s triumph de sciously linked “Expansion und Triumph” to pay lip ser-
rege Mithridate, compare also Lange 2013, 73-74. In this vice to contemporary Tiberian ideology rather amounts
respect, it is well worth reminding that Asculum and the to another attempt at explaining (away) the seemingly
(majority of) Picentes did not enjoy some form of ciuitas absurd or untenable.
Romana or ius Latii, as opposed to Capua in 211 and 72. See, e.g., Auliard 2001, 102.
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