"Choate", as used in American law, means "completed or perfected in and of itself", or "perfected, complete, or certain". It is a controversial word due to its etymology as a back-formation from the old and well-established word inchoate that dates from 1534, meaning "in process of formation". Because the prefix "in-", meaning "not", frequently is used to create antonyms, superficially the relationship of the two words seems to make sense, however, the Latin origin of "inchoate", the verb incohare, begins with a different use of the prefix "in-", wherein the prefix denotes "within". Hence, "inchoate" was not derived from "choate", but the reverse has occurred with apparent misunderstanding of the Latin source, leading to its being challenged as an incongruent word.