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The Supreme Court’s Religion Problem

Our courts no longer know how to evaluate religious claims. Historically American law recognized that people do not merely have ideas about God, but rather belong to communities centered on beliefs, rituals, and standards of behavior rooted in a common understanding of the Divine. Unfortunately, courts today generally recognize only the demands of individual conscience rooted in nothing more than a romanticism of self-disclosure.

The Court’s recent decision in Masterpiece Cakeshop v. Colorado Civil Rights Commission provides a telling example. Religious groups soon determined that their supposed “win” at the hands of Justice Anthony Kennedy was so narrow as to be little more than a loss. The decision stands only for the “principle” that a government, motivated by anti-religious bias, may not punish a Christian baker for refusing to celebrate a same-sex union. Even if, in subsequent decisions, the Court more generally upholds individuals’ right not to be forced to express opinions that violate their conscience, the result is hardly encouraging for religious communities. Such a right is no small thing, and the alternative is truly frightening. But it offers no meaningful protection of religious freedom.

In this and two succeeding essays I forego close analysis of specific Supreme Court opinions. For too long legal commentators have wandered fecklessly in the weeds sprouting from an invasive and poisonous species, namely federal “religion clause jurisprudence.” This jurisprudence has been misconceived from the start. Courts and commentators have misconstrued the Constitution’s silence on religious matters for a commanding neutrality rather than its intended acquiescence to state control; they have misread the 14th Amendment as a means of imposing hostility from above in the name of an ideology of individualism foreign to our traditions and constitutional order.

It is time to leave off arguments over details and instead challenge presumptions. Here I argue that today’s courts ignore and/or reject fundamental truths regarding 1) human nature or who we are, 2) the social order or what is necessary for a decent society, and 3) the character and fundamental importance of America’s historically-grounded, common law.

In brief, first, persons are both social and religious by nature; their characters are formed, and they find meaning, in religious communities. Second, religious communities are where people develop the character and habits of association necessary to maintain ordered liberty; our constitutionalism rests on overlapping, self-governing communities—grounded in religion—that maintain order and virtue while limiting the reach of distant political rulers. Third, while it is wrong to assert that America is some sort of “Christian nation,” dedicated to furthering the cause of any specific religious institution or denomination, neither America nor its law is secular. Today’s courts seek to rewrite a Constitution and, especially, a common law deeply imbued with religious assumptions about the nature of justice and right conduct. The more courts succeed in excising religious assumptions from our law, the more our common culture decays, and the less able we are to maintain ordered liberty.

This first essay addresses the problem of human nature as misunderstood by today’s courts, and our elites more generally.

Even the most extreme secularist will claim that he respects the rights of “people of faith.” Such rhetorical gestures seem wise, given that over 90% of Americans believe in God in the sense of a higher power. Faith is an indispensable, inescapable aspect of human nature. All of us who engage in even minimal self-reflection are driven to find some explanation for our lives and deaths, some sense of meaning for our actions, our sins, and our sufferings. But one’s faith may be purely personal—a belief, whether about God, politics, or ice cream, is something one has. Meanwhile, religion (the Latin root means “to bind”) is a set of ordered beliefs and practices in which one engages as part of a group—a religion is a community in which one develops one’s character and personality. Courts today are willing to defend belief, but not religion.

Why? Principally because so many judges misunderstand and/or mistrust religion, even while acting on their own kind of faith. Our elites, and especially our legal elites, largely have set aside traditional religion themselves in favor of a common faith rooted in what Alexis de Tocqueville called “pantheism.” Pantheism is belief in the sacred nature of the universe as a whole, and of oneself as part of that universe. It lends itself to various ersatz religions, especially of the environmentalist variety, but also to the hyper-individualism so characteristic of modern culture. As Tocqueville noted, the problem with this faith is that it encompasses the whole and various individuals, but not the intermediary associations that form people’s character. In the end it is faith in ideology—in the state’s duty and power to create a more “just” society by regulating interpersonal relations as well as income distribution and life chances.

Pantheists—Progressives in common parlance—have little patience with substantive religion and the moral notion of liberty it supports. Such associations compete with the state for power and authority and aim at promoting personal and associational virtue rather than the Progressive brand of social justice—material security, equality, and individual autonomy. Progressives seek the kind of society Tocqueville warned American democracy might become—an undifferentiated mass of isolated and equal individuals, organized by a central government in the name of security and an unbounded, and ultimately illusory freedom, unencumbered by the institutions, beliefs, and practices encompassed in self-governing communities.

The most obvious legal examples of this ideology have been Justice Kennedy’s opinions in Planned Parenthood v. Casey (the infamous “mystery passage”) and again in Obergefell v. Hodges. These decisions raise individual autonomy and choice within a court-created zone of privacy above historically grounded definitions, norms, and practices, especially regarding marriage. Observers have argued that in these decisions the Supreme Court expanded individual rights and dignity. Yet Obergefell in particular rejects the rights of persons as members of groups and traditions to govern themselves in building and maintaining the most essential structures of their lives. The Court has reduced religion to individual faith. It has constructed a model of the person that is atomistic, shallow, and lacking in the essential attributes of full humanity. With this model as its guide it has endeavored  to strip communities of their rights of self-government and even their reason to exist, all in the name of autonomy. As a result, individual persons are left increasingly weak and alone in the face of governmental power, even as this caustic individualism enervates the spiritual energy, the communal habits, norms, and influences, and the historical grounding necessary for ordered liberty and the rule of law.

Progressives are not wrong to see in religion a challenge to their program. Religion is deeper rooted than politics; allowed to flourish, it by nature guides and limits politics. As they say, politics is downstream from culture, and culture is by nature religious. The religious “cult” shares a Latin root with “culture” (and cultivate) because both relate to shared practices that shape people’s characters and their common ways of life. Most secular Americans think of religion as at best a weekly gathering of otherwise disconnected individuals and at worst an irrational mob wreaking havoc at the whim of some charismatic tyrant. Those who belong to strong religious communities know that they nourish true individuality through active participation in religious celebrations, schooling, social outreach, caring for the less fortunate, and the variety of less formal interactions that make up a way of life. These interactions breed associations and more formal institutions. They shape standards of conduct, art, and attitudes about everything from education to commerce to personal honor, forging specific cultures and civilizations.

American culture, as shown by countless colonial examples, recognized the importance of character formation within local associations, especially family, church, and township. This recognition was reflected in and reinforced by laws that upheld public religious celebrations and prayer, supported religious organizations and “public” schools rooted in religious understandings, and embodied, in local common law, overtly Christian conceptions of justice and morality. Numerous colonies had formal or informal religious establishments favoring one religious denomination above all others, though others favored only a generalized belief in God and commitment to Biblical norms. The federal Constitution was written so as not to interfere with these state arrangements, including by instituting any kind of national Church. This certainly made sense given the variety of denominations represented in the new nation and the understanding that communities are by nature relatively small and local. One powerful example of this tendency is John Adams’ Massachusetts Constitution, which both required public support for religion and ceded determination of the particulars to local communities.

Only in the New Deal era did the Supreme Court suddenly discover that centuries-long traditions of government aid to religious institutions and practices and public expressions of religious belief somehow violated the federal Constitution. In effect, as John Courtney Murray pointed out near the beginning of the Court’s usurpation of control over religion in America, the Court has taken the most radical, sectarian view of religion available, that of the young James Madison, and turned it into a false Constitutional holy writ. That sectarian view rests on the flawed assumption, found nowhere in our constitutional text, that it is possible to separate individuals’ “secular” from their religious purposes, effects, and motivations. It is a mechanistic view of human nature and an unreasonably confident view of the law’s capacity to make fine distinctions.

As sociologist Robert Nisbet pointed out, we are by nature communal animals. If we are denied healthy communities, we will have unhealthy ones. So also with religion. We will never escape the hold of religion. But if we neglect thinking about why religion is part of a healthy human life we will blind ourselves to the manifold ways that our need for religious meaning can take dangerous turns. By stifling religious communities, courts undermine the capacity of religious norms to house safely our natural drive for meaning. Torn from these traditional moorings, individuals’ passions attach to wild ideologies such as Marxism or fascism, and/or to dangerous charismatic leaders who will use the state to weaponize ersatz religion and ersatz community for their own ends, be they enervating, brutal or, most likely, both.

Reader Discussion

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on June 28, 2018 at 07:08:21 am

Excellent and well written essay - looking forward to the subsequent installments!

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Paul Binotto
on June 28, 2018 at 10:14:36 am

Bruce:

Brilliant! excellent analysis weaving together the several threads that were torn asunder by the "reasoning(s)" of the Black Robes but which, in fact, united the minds, spirits and culture of the American regime.

What is now deemed "the separation of church and state' has a quite distinct and significant (malignant?) difference between the *minimal* separation intended by the Founders who envisioned such a *separation* as limited to the State refraining from interfering, controlling or otherwise affecting all the intermediate associations, in particular religious associations. Indeed, read closely (and properly) it may be said that the intention of the Founders was to provide both legal and cultural *cover* for these religious associations without favoring any particular association.
THAT was the limit of the founders *separation* - a far cry from the legal concoction divined by the modern Court.

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gabe
on June 28, 2018 at 10:32:12 am

Bruce, do you think Kennedy was trying to soar past Frankfurter in the first Flag Salute case of Minersville v Gobitis:? "“Certainly the affirmative pursuit of one’s convictions about the ultimate mystery of the universe and man's relation to it is placed beyond the reach of law.” He gave a weak defense of patriotism here, undermining its defense against religious liberty claims as arose in Barnette.
Ken

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Ken Masugi
on June 28, 2018 at 12:35:51 pm

Well, from what I understand from the media lately, it's good when Christians can discriminate against people, but unfair if they are ever asked to leave a restaurant. Did I remember things correctly? And whose religion are we talking about? Are some religions to be favored over others?

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excessivelyperky
on June 28, 2018 at 15:03:44 pm

I think this is a good and well thought-out essay. I do have one minor quibble, and that is with the phrase

[...]imposing hostility from above in the name of an ideology of individualism foreign to our traditions and constitutional order.

I disagree that what is favored is an ideology of individualism. Individualism implies a degree of self-reliance and responsibility that is lacking in the subculture of complaint, grievance and victimhood that gives rise to many of the disputes that the Court seeks to resolve without acknowledging. What Professor Frohnen refers to is not an ideology of individualism but, paradoxically, and ideology of conformity and reverence for cultural fashion.

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z9z99
on June 28, 2018 at 15:19:39 pm

"...from what I understand from the media lately..."

And THEREIN lies "perky"'s problem, n'est ce pas? No doubt it causes her to become an active member of "in the subculture of complaint, grievance and victimhood that gives rise to many of the disputes that the Court seeks to resolve without acknowledging" as she attempts to advance her " ideology of conformity and reverence for cultural fashion."

Keep following the media, child. It has already done you so much good!!!!

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gargamel rules smurfs
on June 28, 2018 at 15:32:33 pm

Following Deneen, I think the distinction is individual autonomy to the absolute limit allowed by the state (Frohnen's "ideology of the individual") as opposed to individualism modulated by community standards. It's tricky area as our vocabulary to describe our understanding of this is still evolving.

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EK
on June 28, 2018 at 18:06:08 pm

I think there is much to admire in this essay and am eager to read the second installment.

I share the author's resentment of the hostility, stupidity and arrogance with which our government and ruling cultural elites treat Christianity which has, for 150 years, endured a wanton, cruel war of attrition in America. Christianity, the eternal faith, and the indomitable Christians who still proclaim it deserve far, far better than they receive today at the hands of Americans whom Christianity has served so well and for whom Christianity has steadfastly carried the heavy social, political and individual burdens that Americans historically have placed on it since America's earliest colonial period. But for Christianity, America as we knew it would not have been founded, would never have prospered and would not be as we know it now, the only country on earth where everyone (except prenatal infants) is born free and equal before the law, is considered a person of inherent dignity and worth and where everyone from everywhere else wants to live and will risk life and limb to get here even illegally.

The plight of Christianity in America and the mistreatment of American Christians today is due to many extra-judicial factors, including the ugly remnants of 19th century anti-Catholic and anti-immigrant prejudices ( incited generally by Know-Nothing xenophobia, particularly the movement to deprive Catholic schools of public funding,) the rise of scientism in higher education, Freudianism in popular culture, Progressivism in politics, the secular impact of mass urbanization and the socially and morally disintegrating impacts of two world wars and the Great Depression.

The Supreme Court cannot be said to have caused hostility to Christianity so much as to have tolerated it almost always and abetted it often, all the while utterly ignoring the clear meaning of the constitution while badly distorting it. Today, the jurisprudence of religious liberty is in shambles, and we have only the Court's unabated ignorance to blame for that. The mess is now such a tangled judicial thicket as to be beyond clearing, and the only hope to restore those provisions of the First and Fourteenth Amendment would be for the Court in one ruling to overturn most if not all the decisions it has rendered against religion since the late FDR Court.

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Pukka Luftmensch
on June 29, 2018 at 10:23:37 am

"The mess is now such a tangled judicial thicket as to be beyond clearing, and the only hope to restore those provisions of the First and Fourteenth Amendment would be for the Court in one ruling to overturn most if not all the decisions it has rendered against religion since the late FDR Court."

FAT CHANCE OF THAT! Here is what the Black robes had to say in Casey about precedent and its critical role in *pacifying* the citizenry; and yes, I said pacifying because that is precisely what these presumptuous buggers believe their role to be:

"The joint opinion is perhaps most infamous for declaring, “At the heart of liberty is the right to define one’s own concept of existence, of meaning, of the universe, and of the mystery of human life.” What this gauzy New Age rhetoric obscures is that the justices are claiming the unconstrained power to define for all Americans which particular interests they think should be beyond the bounds of citizens to address through legislation. But it gets far worse. Consider, for example, these passages on stare decisis considerations:

“Where, in the performance of its judicial duties, the Court decides a case in such a way as to resolve the sort of intensely divisive controversy reflected in Roe and those rare, comparable cases, its decision has a dimension that the resolution of the normal case does not carry. It is the dimension present whenever the Court’s interpretation of the Constitution calls the contending sides of a national controversy to end their national division by accepting a common mandate rooted in the Constitution.”

“To all those who will be so tested by following [the Court], the Court implicitly undertakes to remain steadfast, lest in the end a price be paid for nothing. The promise of constancy, once given, binds its maker for as long as the power to stand by the decision survives and the understanding of the issue has not changed so fundamentally as to render the commitment obsolete.”

“Like the character of an individual, the legitimacy of the Court must be earned over time. So, indeed, must be the character of a Nation of people who aspire to live according to the rule of law. Their belief in themselves as such a people is not readily separable from their understanding of the Court invested with the authority to decide their constitutional cases and speak before all others for their constitutional ideals. If the Court’s legitimacy should be undermined, then, so would the country be in its very ability to see itself through its constitutional ideals. The Court’s concern with legitimacy is not for the sake of the Court but for the sake of the Nation to which it is responsible.”"

Scalia was having none of it - see NRO's Bench Memos of 6/29/18.

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gabe
on June 30, 2018 at 20:03:40 pm

“The most obvious legal examples of this ideology have been Justice Kennedy’s opinions in Planned Parenthood v. Casey (the infamous “mystery passage”) and again in Obergefell v. Hodges.”

True, for when a Nation denies Genesis, and thus God’s Truth from The Beginning, it is impossible for that particular Nation to remain, One Nation, Under God, with Liberty and Justice for all.

Salvation History has revealed that Rendering onto Caesar or oneself, what belongs to God, will always end with tyranny. “We are no longer a Christian Nation”, because we have allowed the atheistic materialist to remove God as The Author of Love, of Life, and of Marriage.

Woe to us!

“With Love, comes Responsibility.”
A liberal, like an atheistic materialist, is someone who simply does not want to take responsibility for all the times they have failed to Love, according to The Way, The Truth, and The Life of Love. Liberalism, the erroneous notion that apart from The True God, we can declare what is Good, has been around since Genesis.

We can know through both Faith and reason that “The Mystery Passage”, is not a mystery at all, in fact, “and ye shall be like gods’, declaring what is Good and what is evil”, is that erroneous notion that sent Our Salvation History in motion.

The Mystery passage is itself a judgement on those judges who deny that our unalienable Right to Life, to Liberty, and to The Pusuit of Happiness can only be endowed to us from The True God.

“Before Abraham was, IAm.”
This is a stumbling block for those who do not desire to recognize, by accepting Salvational Love, God’s Gift of Grace And Mercy, that God Is Perfect Love, that Perfect Love Exists In Relationship, That Perfect Love Is Trinitarian: The Lover, The Beloved, and The Spirit Of Perfect Complementary Love Between The Lover And Beloved.

May Justice Kennedy soon recognize The Truth of Love.

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Nancy
on June 30, 2018 at 22:25:02 pm

“The most obvious legal examples of this ideology have been Justice Kennedy’s opinions in Planned Parenthood v. Casey (the infamous “mystery passage”) and again in Obergefell v. Hodges.”

True, for when a Nation denies Genesis, and thus God’s Truth from The Beginning, it is impossible for that particular Nation to remain, One Nation, Under God, with Liberty and Justice for all.

Salvation History has revealed that Rendering onto Caesar or oneself, what belongs to God, will always end with tyranny. “We are no longer a Christian Nation”, because we have allowed the atheistic materialist to remove God as The Author of Love, of Life, and of Marriage.

Woe to us!

“With Love, comes Responsibility.”
A liberal, like an atheistic materialist, is someone who simply does not want to take responsibility for all the times they have failed to Love, according to The Way, The Truth, and The Life of Love. Liberalism, the erroneous notion that apart from The True God, we can declare what is Good, has been around since Genesis.

We can know through both Faith and reason that “The Mystery Passage”, is not a mystery at all, in fact, “and ye shall be like gods’, declaring what is Good and what is evil”, is that erroneous notion that sent Our Salvation History in motion.

The Mystery passage is itself a judgement on those judges who deny that our unalienable Right to Life, to Liberty, and to The Pusuit of Happiness can only be endowed to us from The True God.

“Before Abraham was, IAm.”
This is a stumbling block for those who do not desire to recognize, by accepting Salvational Love, God’s Gift of Grace And Mercy, that God Is Perfect Love, that Perfect Love Exists In Relationship, That Perfect Love Is Trinitarian: The Lover, The Beloved, and The Spirit Of Perfect Complementary Love Between The Lover And Beloved.

May Justice Kennedy soon recognize The Truth of Love.

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Nancy
on June 30, 2018 at 22:30:48 pm

“The most obvious legal examples of this ideology have been Justice Kennedy’s opinions in Planned Parenthood v. Casey (the infamous “mystery passage”) and again in Obergefell v. Hodges.”

True, for when a Nation denies Genesis, and thus God’s Truth from The Beginning, it is impossible for that particular Nation to remain, One Nation, Under God, with Liberty and Justice for all.

Salvation History has revealed that Rendering onto Caesar or oneself, what belongs to God, will always end with tyranny. “We are no longer a Christian Nation”, because we have allowed the atheistic materialist to remove God as The Author of Love, of Life, and of Marriage.

Woe to us!

“With Love comes responsibility.”

We can know through both Faith and reason that “The Mystery Passage”, is not a mystery at all, in fact, “and ye shall be like gods’, declaring what is Good and what is evil”, is that erroneous notion that sent Our Salvation History in motion.

The Mystery passage is itself a judgement on those judges who deny that our unalienable Right to Life, to Liberty, and to The Pusuit of Happiness can only be endowed to us from The True God.

“Before Abraham was, IAm.”
This is a stumbling block for those who do not desire to recognize, by accepting Salvational Love, God’s Gift of Grace And Mercy, that God Is Perfect Love, that Perfect Love Exists In Relationship, That Perfect Love Is Trinitarian: The Lover, The Beloved, and The Spirit Of Perfect Complementary Love Between The Lover And Beloved.

May Justice Kennedy soon recognize The Truth of Love.

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Nancy
on July 02, 2018 at 13:25:20 pm

I’ll echo the enthusiasm for the project, and for the future installments. I also share a nagging anxiety about an unsustainable kind of individualism.

But the best way I know of to address this concern is in specifics, not generalities. I suspect we’ve all read “oh, woe is us, the sky is falling” essays from time immemorial. These accounts are always exercises in confirmation bias, where people discover whatever they’re inclined to discover.

So if we’re going to make factual claims, it would be nice to have, you know, facts. Consider Steven Pinker’s Enlightenment Now: If the present is so terrible and the past was so great, why don’t we find evidence of this in the data?

So let’s look at some data: Since long before the First Amendment existed, God-fearing Christians have been only too happy to kill their fellow God-fearing Christians in the name of their faiths. Consider the Knights' Revolt, the German Peasants' War, the Wars of Kappel, the Münster rebellion, the Anabaptist riot, Bigod's rebellion, the Schmalkaldic War, the Prayer Book Rebellion, the Second Schmalkaldic War, the French Wars of Religion, the Eighty Years' War, the Cologne War, the Strasbourg Bishops' War, the War against Sigismund, the War of the Jülich Succession, the Thirty Years' Warthe Huguenot rebellions, the Wars of the Three Kingdoms, the Savoyard-Waldensian Wars, the First War of Villmergen, the Second Anglo-Dutch War, the Nine Years' War, the War of the Spanish Succession, the War in the Cevennes, and the Second War of Villmergen, the reign of the Ku Klux Klan—right up through The Troubles of Northern Ireland. And all of this leaves aside religious wars waged against non-Christians.

In short, I suspect most of us could agree that leaving religions to sort everything out on their own is hardly a desirable outcome either. The challenge is not in finding fault with government or finding fault with religion. The challenge is in finding the appropriate principles for guiding social policy.

Our courts no longer know how to evaluate religious claims. Historically American law recognized that people do not merely have ideas about God, but rather belong to communities centered on beliefs, rituals, and standards of behavior rooted in a common understanding of the Divine. Unfortunately, courts today generally recognize only the demands of individual conscience rooted in nothing more than a romanticism of self-disclosure.

Frohnen identifies a real distinction—religion as individual belief vs. religion as some kind of group attribute. Consider: Under the federal Religious Freedom Restoration Act, a religious sect might be able to import and use otherwise banned drugs as part of their religious practices. (See Gonzales v. O Centro Espirita Beneficiente Uniao Do Vegetal). But what if the person carrying the drugs had posted on his Facebook page that he regards the religion as nonsense, and he only participates to get high. Should the Court interpret his “religion” as manifesting his personal views, or the practices of his group regardless of his personal views?

Obergefell in particular rejects the rights of persons as members of groups and traditions to govern themselves in building and maintaining the most essential structures of their lives.

Examples?

The Court … has endeavored to strip communities of their rights of self-government and even their reason to exist, all in the name of autonomy.

Examples?

As a result, individual persons are left increasingly weak and alone….

Examples?

[C]ourts undermine the capacity of religious norms to house safely our natural drive for meaning. Torn from these traditional moorings, individuals’ passions attach to wild ideologies such as Marxism or fascism, and/or to dangerous charismatic leaders who will use the state to weaponize ersatz religion and ersatz community for their own ends, be they enervating, brutal or, most likely, both.

Again, I harbor some anxiety about this possibility. Indeed, some people argue that our current era of political polarization arising in part from the decline of traditional religion, as people strive to find meaning and “tribe” in political affiliations.

But again, concrete examples would permit us to explore the claim.

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nobody.really
on July 03, 2018 at 09:00:32 am

This is an embarrassingly low-brow essay, filled with heavily-propagandized assertions and a crabbed, uninformed view of the Constitution and the Court. Where to begin?
-- Kennedy was no accidental nomination; the fact that he was nominated after the weirdo Bork and the doper Ginsburg means nothing. Kennedy was a known entity whom Reagan (an orangey-looking fellow with died hair -- sound familiar?) had nominated after declaring that he sought justices opposed to Roe v Wade and "judicial activism." DOJ lawyers had warned the Reagan administration about Kennedy's jurisprudence, such as it was, and Reagan clearly knew what he was getting when he nominated Kennedy.
-- That Kennedy acted out of his belief in "living Constitutionalism" (where do these academics come up with grammar and syntax?) presumes 1) that Kennedy had any appreciable views of the Constitution; and 2) that he was anything other than results-oriented.
-- The idea that Casey and its related case enunciated a "new" standard when evaluating restrictions on abortions assumes that there was some existing, "old" standard. There was not.
-- Using phrases like "ideals hostile to" "a principle found nowhere" "stood for the proposition" or "paradigm motivating" is the sign of an intellect mired in low-level academic trope. And how many times can one be said to have "leveraged" this or that?
So, this is neither a brilliant, good, or even acceptable collection of cliches and unoriginal thoughts cobbled together.
Not even a nice try, "professor."

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Albert
on July 03, 2018 at 15:44:25 pm

One need defend neither the merit nor the style, neither its constitutional arguments nor the literary quality of Frohnen's commentary, in order to conclude that the caustic comment on it by "Albert" lacks both substance and style .

Albert asks, "Where to begin?'
I would say, "Don't; your writing appears to possess all of the negative qualities which you bemoan in Frohnen."

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Pukka Luftmensch

Law & Liberty welcomes civil and lively discussion of its articles. Abusive comments will not be tolerated. We reserve the right to delete comments - or ban users - without notification or explanation.