The continental 'full proof' standard of being 'clearer than the midday sun' is attested independently of the 1911 Catholic Encyclopedia, via Whitman citing Alessi Palazzolo

legal-historylaw-of-evidencecanon-lawlegal-epistemologymedieval-lawcriminal-procedure

International criminal-defense lawyer Michael G. Karnavas, citing James Q. Whitman's The Origins of Reasonable Doubt (Yale University Press, 2008), writes that continental inquisitorial procedure "employed highly rationalized procedures and required 'full proof' that had to be '"clearer that [sic] the light of the midday sun."'" Whitman's own citation for the phrase, per Karnavas's footnote, traces it to Italian legal historian Giorgia Alessi Palazzolo's 1979 Naples monograph, at pp. 3–5. Karnavas's footnote reads in full: "Whitman, p. 115, citing Giorgia Alessi Palazzolo, Provo Legale e Pena. La Crisi del Sistema Tra Evo Medio et Modern, Naples, (1979), p. 3-5." — the Italian is garbled in his rendering; the work is Prova legale e pena: la crisi del sistema tra evo medio e moderno. The same page confirms, again citing Whitman (p. 115), that torture could not be ordered "unless there was 'semiplena probatio' or 'half-full proof'" — the mechanism documented at claim-medieval-judicial-torture-required-a-half-proof-and-produced-the-completing-confession.

A third chain, independent of both, runs through a source already held in this vault at Tier 1. John H. Langbein's Torture and Plea Bargaining (1978) describes the Italian Glossators entrenching the two-eyewitness rule and calls the resulting standard, in his own words, "evidence that was, in the famous phrase, 'clear as the noonday sun'" (p. 4) — the same solar formula, in the noonday wording, from a legal historian writing from his own monograph Torture and the Law of Proof rather than from Whitman or from any encyclopedia. Langbein is the source behind claim-confessio-est-regina-probationum-named-confession-queen-of-proof.

This matters because claim-two-half-proofs-combined-to-full-proof-except-in-grave-criminal-cases carries the phrase "clearer than the noonday sun" sourced only to the 1911 Catholic Encyclopedia (Tier 3/4). This note reaches the same standard — "clearer than the [midday/noonday] sun" — through two separate citation chains (Whitman → Alessi Palazzolo; Langbein → his own archival work) that never touch the encyclopedia. It establishes the phrase is a genuine finding in the legal-history literature rather than an encyclopedia flourish, without on its own confirming the encyclopedia's specific claim that half-proof combination was generally allowed but barred in criminal cases: it speaks to the standard for full proof in inquisitorial criminal matters generally, not to the combination rule's scope. The unresolved scope question stays routed at question-verify-half-proof-combination-rule-criminal-exception-primary.