Okay, so in my recent reading, I found a different result which sounds a lot more like the one I was hunting for here. The theorem is called the McKelvey–Schofield chaos theorem, the reference paper appears to be *Intransitivities in multidimensional voting models and some implications for agenda control*.

Anyway, for the statement of the theorem, I'll quote the Handbook of Social Choice and Welfare (Chap. 13, p.27):

Richard McKelvey has stated a famous theorem: Suppose the alternatives lie in an n-dimensional space (n > 1), we choose between alternatives by majority voting (as is standard in legislation), and there is no Condorcet winner. Given any two proposals, a and b, there exists a sequence of proposals, {a'_i}(i = 0, ..., n) such that a'_0 = a, a'_n = b, and a'_i defeats a'_{i+1} for all i = 0, ..., n−1. That is, by a suitably chosen agenda, any proposal can defeat any other if there is no Condorcet winner.