Time independence conserves the energy . The two cyclic coordinates give
These are respectively angular momentum along the symmetry axis and angular momentum along the fixed upward vertical; is the axial spin rate. For and , eliminate using . The energy becomes
Multiplying and rearranging gives
To justify the double-root condition, use the effective potential
Eliminating the cyclic coordinates by Routh reduction gives the remaining equation . A constant nonvertical angle therefore has and . Since , both and vanish. This argument uses the second-order equation; merely differentiating the energy identity at a stationary angle would not establish the derivative condition.
Thus steady nonvertical precession gives a common root in . The nonvertical qualification is implicit in the denominator used by the source. A top spinning exactly upright or inverted is also possible but corresponds to an endpoint , not an interior root; the unrestricted literal claim would need that exception.

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