CONSTITUTIONAL LAW
Fall 2006, W.B. Fisch

Assignment #6

Theories of Interpretation

  • Text and Plain Meaning
    • CHISHOLM V. GEORGIA (1793), Wilson's opinion (handout)
    • How persuasive is his argument from the text?
      • NB: he did begin with discussion of the plausibility of his reading, in terms of the nature of the Union and contemporary trends in sovereign immunity
      • Logic:
        • language could be limited to States as plaintiffs
        • but the State-vs-State category shows that States can be defendants
  • Intent of the Framers and Adoption History
    • HANS V. LOUISIANA (1890) (handout)
    • Interpretation of the 11th Amendment, for a case not within its scope
    • Logic:
      • 11th Amendment overruled Chisholm
      • That constituted an endorsement of Iredell's dissent in Chisholm, which was founded on the general law of sovereign immunity!
      • Therefore the 11th Amendment constituted an endorsement of sovereign immunity
    • Why shouldn't it have made a difference that Chisholm was a pure diversity case under state law, whereas Hans was a constitutional case?
  • Precedent and Interpretive Tradition
    • STUART v. LAIRD (1803) (handout): what exactly does it tell you about the proper interpretation of a constitutional provision, that
      • members of the First Congress believed that it was not violated by a specific law that they adopted?
      • those directly affected by the law have followed it from the beginning, without challenging its constitutionality?  How long does that "acquiescence" have to last, to be binding?
    • Harlan, J. (Grandson of the Hans dissenter!), dissenting in POE V. ULLMAN (1961) (handout): How does he know that the due process clause embodies a general concept of liberty?
  • Structure and Effective Functioning of Institutions
    • MISSOURI V. HOLLAND (1920) (handout)
    • "Matters requiring national action"; "power which must belong to and somewhere reside in every civilized government"
  • Extratextual Values: Natural Law
    • Calder v. Bull (1798), excerpted in CB pp. 467-468
    • What is the problem with judges applying "natural law"?
  • Extratextual Values: Contemporary Public Opinion
    • HARPER V. VIRGINIA BOARD OF ELECTIONS (1966)(handout)
    • Can Harlan's opinion here be reconciled with his opinion in Poe?