Firey concludes her remarks on Hamilton 132 by positing some connection between this manuscript and the great reform council that convened at Paris in 829. She writes that “…perhaps the most interesting question about the testimony of Hamilton 132 with respect to its historical context is that it may reveal something about the purposes for production of canon law codices in the early ninth century in the Paris basin.”
The somewhat unusual…texts in Hamilton 132…are attested in the Council of Paris. … The Pseudo-Leo text on chorepiscopi (JK †551; fol. 95v) is reproduced in the Council of Paris as cap. 37. The insertion of this text, transcribed in a Caroline hand, occasioned more disruption in Hamilton 132. The leaves in this portion of the manuscript are prepared differently from others, and could have been added even later than the other Caroline leaves, although the continuation of the text [onto pre-existing a-b folios] shows the same method of integration as other Caroline-inscribed leaves. The Pseudo-Leo decretal is replicated in Paris, Bibliothèque nationale, lat. 3838, where it is also attributed to Leo, on a flyleaf… It appears to be written by the same scribe as that who wrote it in Hamilton 132. In Paris 3838, the first three lines of the decretal are annotated with later interlinear neumes and, above the second column of the text, is an annotation Fiat, fiat, both suggesting that the Paris copy was perhaps later used for public acclamation, as at a council. …
First, a very minor point: The Fiat fiat thing in Paris lat. 3838 (it is actually fiat fiant) is a pen trial; it is followed by Tironian notes for qua or quia and in the middle of the page between columns the same doodler has written DEUS in adiut t t t. You can go to the photos of Paris lat. 3838 at Gallica yourself and see. I don’t see any reason to read these marks in light of Pseudo-Leo.
Otherwise, to further our understanding of Hamilton 132, the relative chronology of its materials, and its importance for the history of Carolingian church councils, I must point out that Firey is mistaken on several levels:
1) Paris 829 legislates on chorbishops at c. 27, not c. 37. Whatever relationship c. 27 might have to Pseudo-Leo, JK †551/J3 †1118 is as yet undetermined. Both Paris 829 and Pseudo-Leo make what you might call related arguments with reference to the same (genuine) patristic-era canons, but no decretal forgeries occur in the acta of Paris 829. If they did, our entire estimation of both the Pseudo-Isidorian problem and Paris 829 would be much different.
2) Right below Pseudo-Leo in Hamilton 132, we find our Caroline scribe adding not Paris 829, c. 27, on chorbishops, but instead the related c. 9 from the Relatio episcoporum of 829. The distinction is a minor one, of course, as this is the summary of c. 27 that got sent to Louis the Pious. And the upshot is the same either way, namely that this particular scribe must have copied after the promulgation of the Paris acta in 829. This scribe also goes on to add (from the Dionysio-Hadriana) the first part of Antioch, c. 10; then Ancyra, c. 12; Laodicea, c. 57; and then the final part of Antioch, c. 10. What we are looking at here is a miniature dossier to the disadvantage of chorbishops. The exact same dossier also occurs as an addition to Paris, BnF Ms. lat. 1453, so we now have a total of three manuscripts with this same sequence of texts: Hamilton 132, Paris lat. 3838 and Paris lat. 1453. In all three cases we are dealing with a manuscript of the Dionysio-Hadriana; in Hamilton 132 and Paris lat. 1453, the dossier is clearly a later addition, and in Paris lat. 3838 it occurs on a flyleaf.
I am not sure what all of this does for Firey’s arguments about the relationship between Hamilton 132 and Paris 829, but it might imply that she has gotten the chronology wrong when she wonders (as at points she seems to) whether the activity we witness in Hamilton 132 was in some way preparatory for the Paris council. I would think that the anti-chorbishop dossier in all three manuscripts postdates Paris 829, perhaps substantially; and also Hamilton 132 is merely one of three witnesses to these texts, so any relationship between this chorbishop dossier and this or that council is not specific to Hamilton 132.
3) If the Caroline scribe adding Pseudo-Leo is writing after Paris 829, what are we to make of Firey’s thesis of collaboration, given that paleographers date the a-b folios of Hamilton 132 to the years around 800 (Ganz, 50; Bischoff, 74; the CLA at VIII, no. 1047)? This consideration would seem to be why Firey allows that the Pseudo-Leo decretal might have been added to Hamilton 132 even later than the rest of the Caroline material. But how much later can it have been added, if this Caroline folio “shows the same method of integration as other Caroline-inscribed leaves”? Three decades later? Five?
4) Five decades would seem around the minimum necessary for Firey’s scenario to work, since Paris 3838 was copied in the third quarter of the ninth century according to Hubert Mordek, and if the scribe copying Pseudo-Leo in Hamilton 132 and Paris 3838 is indeed the same (more on that later, perhaps), we seem to be exactly where Bischoff said we were vis-a-vis the dates for the Caroline material in Hamilton 132: In the middle of the ninth century, as opposed to the beginning of it, when the a-b folios were copied.
 For Pseudo-Leo on chorbishops (J3 †1118), a forgery with Pseudo-Isidorian tendencies that is based on a canon from the Hispana Gallica (Seville II, c. 7) and shows a close relationship to the interpolated Hispana, see Fuhrmann, “Pseudo-Isidorian Forgeries,” in Papal Letters in the Early Middle Ages, ed. Hartmann and Pennington, p. 167.
 Hubert Mordek, Bibliotheca capitularium regum Francorum manuscripta, MGH Hilfsmittel 15 (1995) p. 435.
In conclusion, a few observations:
Firey calls into question arguments that Klaus Zechiel-Eckes and Paul Hinschius made in two lengthy, sophisticated, and difficult articles. She discards the finer points of argument in both. In the face of Zechiel-Eckes’s analysis, she raises pedestrian concerns about the uncertainties of manuscript provenance that do not apply in the case of the St. Petersburg codex, that ignore a wealth of other evidence, and that have aged poorly as still more evidence comes to light.
Firey’s analysis of Hamilton 132, meanwhile, appears almost totally oblivious to Hinschius’s analysis and overlooks basic features of the manuscript. I am as nervous about palaeographical dates as anybody, but I also think it unwise to argue against the grain of too much established opinion on this front without good reason. If we accept Firey’s arguments for collaboration in Hamilton 132, we are forced either to reject the entirety of scholarship that dates the a-b hands in these folios to the years around 800 (moving a-b towards the middle of the ninth century), or to backdate the interpolated Hispana to the reign of Charlemagne (so that Caroline scribes can have collaborated with the a-b scriptorium in copying interpolated Hispana texts). There is no reason to do either.