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Between 2009 and 2020, Josh published more than 10,000 blog posts. Here, you can access his blog archives.

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2009

IJ’s Bone Marrow Case: Judicial Minimalism and the Rational Basis Test

November 4th, 2009

Jeff Rowes continues his great series of posts at Volokh. Here is his latest piece, where Jeff discusses unenumerated rights, the rational basis test, Footnote Four of Carolene Products, and judicial minimalism. I have copied a few choice nuggets:

But no one seriously disputes that unenumerated rights exist, although there is considerable debate over their nature and scope.  Who doubts that we have the right to travel or vote or raise children?  The right to earn an honest living in the lawful occupation of your choice was among the first unenumerated rights the Supreme Court recognized and that right has an undeniable basis in the Privileges or Immunities Clause of the Fourteenth Amendment (see Randy Barnett’s outstanding scholarship).

The history of the Constitution supports unenumerated rights.  Madison presciently warned against enumerating rights because he foresaw what has become a cornerstone of the judicial-minimalist worldview: the argument that the only rights we have are enumerated ones.

Inordinate emphasis on protecting only the relatively few enumerated rights cannot be squared with the Constitution as a whole.  The Bill of Rights was part of a constitutional scheme that was both intended and understood to have created a government of limited, enumerated powers.  Had the authors of the Constitution known that what I’ll call “legislative activists” in the elected branches would, with the eventual approval of the courts, repudiate any structural limitations on their power, then we would likely have a much different Bill of Rights, one that presumably would have expressly identified a much larger set of liberties.  Judicial minimalists should understand that the enumeration of certain rights does not reflect a decision by the Constitution’s ratifiers that the federal government is supposed to be, to borrow Randy’s metaphor, a vast sea of government power with tiny islets of liberty.

This slicing and dicing of rights into different categories with different standards of review, and placing an extraordinarily onerous burden on certain rights, is pure judicial invention.  Conservative-leaning judicial minimalists should reflect on the irony that their philosophy is rooted in the big-government agenda of the New Deal Era, and that among the Supreme Court’s most “minimalist” decisions—in the sense of showing extreme deference to the elected branches—are its most activist ones such as the refusal to enforce essentially any structural limits on federal power (Wickard, Raich).

There is no reason why the government’s legitimate functions—like protecting public health and safety—necessitate a standard of review in which courts are required to ignore pro-citizen facts, invent pro-government facts, and actively try to imagine reasons to uphold anything a legislature has done.  Why is the truth antithetical to constitutional adjudication?

 

 

Reason.TV Next Installment on Ayn Rand

November 4th, 2009

Very worthwhile watch.

[youtube=http://www.youtube.com/v/iJf5B7AHo_U&hl=en&fs=1&]

Virginia Election Results, County by County. Arlington and Alexandria went Blue 60%. No Shock.

November 4th, 2009

Check out this interact map from the Washington Post. It breaks down the election results County by County.

Arlington County (my former home) voted for Deeds 66% and Alexandria voted for Deeds 63%. McDonnell won Fairfax 51-49. Very close.

 

 

Judge Allows Constitutional Challenge to Human Gene Patents

November 4th, 2009

From Law.com, H/T @ACSLaw:

Opponents of patenting human gene sequences were handed a rare court victory on Monday, when a federal judge refused to dismiss a suit challenging patents for two genes tied to cancers in women.

The case revolves around seven patents relating to human genes BRCA1 and BRCA2, mutations of which have been tied to breast and ovarian cancer. The patents are owned by the University of Utah and licensed to Salt Lake City-based Myriad Genetics. In the late 1990s, Myriad began contacting researchers at the National Cancer Institute and various universities who were working with BRCA1 and BRCA2, demanding they cease their research on the genes and stop testing women for risk-carrying mutations.

The plaintiffs claimed that the BRCA1 and BRCA2 patents are invalid because they cover “products of nature,” and they alleged that Myriad’s attempts to enforce the patents by limiting genetic research violated First Amendment protections. In their motions to dismiss, Myriad (represented by Jones Day) and the PTO argued that the suit should be dismissed because the plaintiffs lacked personal and subject matter jurisdiction and because they failed to state a claim for a constitutional violation.

Patents for human genes are a hot topic right now. Check out the tragedy of the anticommons for more background.

Is Justice Scalia Wrong? Gruntled Is A Word!

November 4th, 2009

This morning, I discussed an ABA Journal article, wherein Justice Scalia chastised an advocate for making up the word choate. To article reports

As Barnhouse tried to move on, Scalia offered an example. “It’s like ‘gruntled,’ ” he said.

“Exactly. ‘Disgruntled,’ ” Scalia said. Some people mistakenly assume the opposite of “disgruntled” is “gruntled,” he explained.

Well it seems Scalia may be wrong. Josh House, a GW 1L, and an astute commenter, pointed out that gruntled is in fact a word:

Interestingly enough, Scalia is wrong about “gruntled”. Oxford dictionary says it means “pleased, satisfied” – the word was derived from disgruntled in the 1930s.

Oxford English Dictionary Confirms, gruntled seems to be the opposite of disgruntled.

Definition: Pleased, satisfied, contented.

1938 WODEHOUSE Code of Woosters i. 9 He spoke with a certain what-is-it in his voice, and I could see that, if not actually disgruntled, he was far from being gruntled.

1962 C. ROHAN Delinquents 76 Come on, Brownie darling, be gruntled. 1966 New Statesman 11 Nov. 693/2 An action against a barrister for negligence..would open the door to every disgruntled client. Now gruntled clients are rare in the criminal courts. 1967 E. MCGIRR Hearse with Horses i. 17 The Agency has a nice file of gruntled exes who have found their talents in a great variety of jobs.
Is Justice Scalia wrong?
Update: I emailed this question to one of my favorite Law Professors who specializes in etymology and the history of words. His response:
Gruntled is indeed in the dictionary, as the opposite of disgruntled.  But it’s pretty clearly not idiomatic, as a Google search shows.  So it’s not a mistake to assume that there is a word “gruntled” that’s the opposite of “disgruntled.”  But it is a mistake to assume that there is such a word in common usage, and especially in common serious usage (since “gruntled” as the opposite of “disgruntled” has a humorous connotation, I think).
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