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.