Dorf on Law

Mostly law-related musings by Cornell Professor Michael Dorf and some of his lawyer/professor friends

Tuesday, June 10, 2008

Con Law in 12,008

Here’s another post inspired by my week in Cleveland. Our panel on constitutional theory consisted of myself, Kim Roosevelt, Steve Griffin, and Mark Tushnet. A not insubstantial portion of the discussion centered around the “new originalism” (to which I also referred in my lunchtime speech). Like the old originalism, the new originalism has, as one of its justifications, a theory of legitimacy. As Griffin said, summarizing Larry Solum (about whose work Griffin has blogged at Balkinization) but not purporting to be stating his own views, given that the Constitution contains an amendment mechanism in Article V, there ought to be at least a pretty strong presumption against changing its meaning by other mechanisms. Here I’ll rehearse a couple of answers to this claim, mostly as an excuse to set out a thought experiment (point 2 below).

(1) If we were just starting our collective project of constitutional interpretation today, this argument would have some force. However, we inherit the Constitution along with a long history of its use—including a tradition of changes in constitutional meaning without changes in the constitutional text. Against this historical background, as a descriptive matter, the best account of Article V is that it provides the exclusive mechanism for changing the text, but that it does not preclude flexible interpretation by political actors and the courts. Indeed, one might even draw this inference in part from Article V itself. In a fascinating paper, Tom Ginsburg presented empirical evidence about the lifetime of constitutions. The average lifespan of a constitution is only 17 years. The U.S. is very much an outlier in its Constitution's longevity and there is good evidence that flexibility strongly correlates with longevity. Where a constitution is very difficult to formally amend, as the U.S. Constitution is, then flexible (i.e., changing) interpretation may be essential to its long-term survival. Thus, one might say that reading Article V and knowing how difficult it makes amendment, if one wants the Constitution to survive over the long term, one MUST engage in non-originalist interpretation.

(2) Originalism is sometimes offered on the ground that it provides substantially greater restraint on judges than non-originalist modes of interpretation. Whatever the truth of this claim with respect to the old originalism, it is not a claim defended by the new originalists, who tend to acknowledge that the new originalism does not resolve many of the most contentious constitutional questions. Nonetheless, they urge originalism on linguistic and political theory grounds---and in fairness, the old originalists made similar points. The basic argument is this: The Constitution is law because it was adopted by democratically legitimate processes, and so the meaning of the Constitution should be the meaning produced by those processes, rather than a meaning substituted for them by unelected judges.

The difficulty with this argument is its premise that the original act of ratification is what makes the Constitution law today. It doesn't. What makes the Constitution law today is the fact that it is accepted as law today. Imagine that, notwithstanding Ginsburg's data, the U.S. Constitution persists for at least another 10,000 years (by which time, according to Sen. McCain, the U.S. could still have troops in Iraq, but I digress). What would make the Constitution the legitimate law of the U.S. in 12,008, binding on our descendants and the intelligent metal bugs who have also been made "persons" by the 28th Amendment? The act of ratification in 1789? The very idea is ridiculous. To be sure, a consensus might exist that our descendants and the metal bug people look to the 1789 original understanding as a way of resolving constitutional disputes, but if so, that 12,008 consensus, not the 1789 ratification itself, will be the legitimating act.

And so, it seems to me, in 2008: One can argue for reading the Constitution to mean what it meant in 1789 on the grounds that this will be better for us than reading it any other way. But one cannot simply say that this reading is commanded by the fact that it was adopted then.

Posted by Mike Dorf

11 Comments:

  • At 1:48 PM, Blogger egarber said…

    The difficulty with this argument is its premise that the original act of ratification is what makes the Constitution law today. It doesn't. What makes the Constitution law today is the fact that it is accepted as law today.

    I understand the point.

    But doesn't this put on equal footing two vastly different burdens? In other words, when an amendment is first ratified, you need 2/3 of Congress and 3/4 of the states -- so there's a very heavy affirmative burden in that first instance. But mere "acceptance" after the fact carries no affirmative obligation at all; so according to your theory, it seems that doing nothing carries the same authority as doing everything.

    Let me try a clumsy analogy:

    Are there three outs in a baseball inning because that's accepted today, or because somebody originally carried the burden of writing the rule in the first place?

     
  • At 2:19 PM, Blogger egarber said…

    I realize my baseball example doesn't quite fit in the bigger (interpretive) sense -- since nobody disputes that specific rules have a static meeting. But hopefully, it's at least illustrative.

     
  • At 2:37 PM, Blogger David C. said…

    I find this post terribly depressing. If we do indeed have a tradition of flexible constitutional interpretation, why, for heavens sake, would we need to have a new Amendment to recognize the personhood of the intelligent metal bugs? The 13th, 14th, 15th, and 19th Amendments all followed periods of shameful intolerance. Why must history repeat itself with the intelligent metal bugs? Will we never learn to love?

     
  • At 5:19 PM, Blogger Carl said…

    The difficulty with this argument is its premise that the original act of ratification is what makes the Constitution law today. It doesn't. What makes the Constitution law today is the fact that it is accepted as law today.

    I thought originalists were making a claim about the meaning of the Constitution, not its bindingness. But if that's true, they can accept your view that the Constitution is law today because it is accepted as law while simultaneously denying your arguably distinct claim that hard cases ought to be decided on how a subset of legal academics would like to think "we" read the Constitution when "we" endorse it. As far as I can tell, your polemical point does nothing to resolve this issue in you favor.

     
  • At 6:17 PM, Blogger egarber said…

    I should say six outs in an inning, unless the batter reaches first after a strikeout / wild pitch combo, then it could be much more. But I digress.

     
  • At 6:50 PM, Blogger Róbert said…

    Couldn´t the originalists object to your point by saying that their argument from democracy is not based only on the premise that the original act of ratification is what makes the Constitution law today. Their argument is also based on the premise that society today only accepts the Constitution being law because it is a legal text adopted by the people through the ratification process. The "acceptance" of modern-day Americans that the Constitution is law is in other words based on their sense of its democratic origins. Therefore the meaning of the Constitution "today" must, as a starting-point, reflect the democratic act that created it in the first place.

    Sincerely yours, Robert R. Spano, Professor, University of Iceland.

     
  • At 9:01 PM, Blogger Michael C. Dorf said…

    Good questions all. To be clearer (or perhaps to be more esoteric), I was making a point in the spirit of H.L.A. Hart, i.e., a descriptive point that the way we know the Constitution is law is that it is accepted by the People today. There is a further question of what the Constitution is that the People accept. I fully acknowledge that if what contemporary acceptance validated was the Constitution equated with the original understanding (or the variant that Prof Spano sets forth), then the Constitution would be its original meaning. However, my claim is that, as a matter of sociological fact, what the People accept is the Constitution as it has come to be understood through evolutionary interpretation.

    Eric raises the question of whether it is normatively desirable to have a constitution that can be changed formally only by supermajority but informally by something less, perhaps even less than a majority where elite opinion on the Supreme Court differs from public opinion more generally. I happen to think that an argument for this approach is justifiable but that wasn't my claim in this post.

     
  • At 11:32 PM, Blogger Tom Hanna said…

    One can argue for reading the Constitution to mean what it meant in 1789 on the grounds that this will be better for us than reading it any other way.

    The legitimate end of government is not to be "good for us;" it is to secure our rights. In 1776, 1787, 2008 and 12008, the measure of a government is whether it is protective or destructive of the rights of the citizen.

     
  • At 7:38 AM, Blogger egarber said…

    Eric raises the question of whether it is normatively desirable to have a constitution that can be changed formally only by supermajority but informally by something less, perhaps even less than a majority where elite opinion on the Supreme Court differs from public opinion more generally.

    As far as constitutional interpretation goes, I don't have a problem with judges making bold rulings; however, I do think those rulings should emanate from original *principles* (it's not: "what would James Madison do today?" -- it's more "what philosophical seeds did he plant?")

    For example, I think the Ninth Amendment was intended as a signal to future generations to read individual liberties broadly. So given this principle, it is absolutely correct (imo) for the Supreme Court to defend privacy as an inalienable right. With this type of "originalism", the application of (unchanging) broad concepts must evolve with the times, or the framework becomes stale and irrelevant.

    The more I think about it, the more it seems to me that the constitution is a sort of common-law charter -- where courts must abide by its principles, but those very courts by design also have independent discretion as a separate and unique branch to determine contemporary applications.

     
  • At 2:47 PM, Blogger Andrew Scott said…

    My gratitude for your reference to Mr. Ginsburg's indeed fascinating discovery that most constitutions only last 17 years. I found this fact particularly interesting, as Thomas Jefferson himself is known to have advocated that no constitution (or law, for that matter) ever last beyond 19 years. (1787 Letter to Madison)

    I find your proposed rule of recognition (that what we all agree is law is law) ultimately right but vague. I think it would benefit from a legally realistic analysis.

    Let us accept Holmes' premise that what a judge says is law is law. This has been historically so despite public disagreement (some supporting examples might be the lightning rod Brown or Roe decisions). Judges are also the source of law because many (if not most) statutes suffer from what Professor Grundfest would call "Multiple Personality Disorder" (54 Stanford Law Review 627-736 (2002). This requires judges to decide their meaning and efficacy. Such deciding power is virtually unlimited: realistically speaking, judge made law runs the gamut of constitutional, statutory and common law.

    Of course, Congress may balances this power by overruling the decision by statute. However, I find this to be rare. Impeachment is an even lesser threat (the Chase impeachment being a great example of why).

    Coming back to your claim: that "we" (by which I'm assuming the general public) make the Constitution the law. I'd agree that we do this, but only by tacit consent. By not pressuring congress to limit the judiciary, the people tacitly consent to judge-made law. Thus, in a roundabout way, what we all tacitly agree is law, is law, until it bothers us enough to do something about it at the voting booth (which is rare).

     
  • At 7:21 PM, Blogger Chris said…

    "[W]hat the People accept is the Constitution as it has come to be understood through evolutionary interpretation."

    I don't think that's right. What officials accept in their oaths is "this Constitution" described in Article VI. A search through the Congressional Record, for instance, shows that office-holders today frequently invoke Article VI and think that they follow it. What we really need to do, then, is figure out what "this Constitution" refers to in Article VI. I think that we can unpack that phrase as the historically-situated text, though it requires some work to do so.

     

Post a Comment

<< Home