The New England Journal of Medicine was released today, with its first assessment of the fallout of the Supreme Court’s decision not to gut Obamacare. Policy analysts writing in the NEJM have been generally supportive of Obamacare, and so of course they’re happy with the result, declaring that it has removed “the largest remaining cloud of judicial uncertainty hanging over the Affordable Care Act” and advocating that now the legislative agenda focus on real improvements to the established law.
The NEJM article also remarks on the importance of assessing the text of the legislation in its full context, not just the strict text of the specific provision. It argues that this is a well-understood principle of Supreme Court jurisprudence, and gives the following example:
An earlier example of this principle comes from the Court’s 2000 decision in FDA v. Brown and Williamson, which King cites or quotes several times. Brown and Williamson held that (before more recent legislation) the Food and Drug Administration (FDA) lacked authority to regulate cigarettes as devices that deliver the drug nicotine. Despite the FDA statute’s broad literal definitions of “drug” and “device,” the Court concluded that “considering the [statute] as a whole, it is clear that Congress intended to exclude tobacco products from the FDA’s jurisdiction.”
This past decision also makes perfect sense to me. While tobacco is clearly a drug, the FDA is not charged with monitoring recreational drugs, and tobacco products should be monitored separately or the FDA’s authority extended to them through an act of Congress.
Interestingly, this is also what the architects and defenders of the King vs. Burwell case thought, back when the FDA v. Brown and Williamson case was decided, and repeatedly since. For example, in a 2007 post the Heritage Foundation cites it as an example of an exception to the trend towards an administrative state. I can’t find any evidence that the legal experts at the Heritage Foundation have decided that this example of the Supreme Court not showing “deference to agencies” must have been wrong due to its willingness to invoke “context,” in which (to quote Scalia) “words have no meaning.” Similarly, the Cato Institute has referred positively to the appeal to context in FDA vs. Brown and Williamson in both its 2006-2007 and 2008-2009 Supreme Court Reviews (see page 201 of the 2006-2007 Review, or a footnote on page 126 of the 2008-2009 Review). The Cato Institute has also issued multiple Amicus Briefs for other court cases where they think that the FDA v. Brown and Williamson case might help to enforce the importance of context. For example, in their Amicus Brief on Texas vs. United States of America (Case 1:14-cv-254) , for example, they argue (citing the case):
The court must “fit, if possible, all parts [of the statute] into an harmonious whole” and use “common sense” to determine the scope of Congress’s delegation to an agency.
Interesting how much their opinion of how the Supreme Court should interpret statutes has changed in just a short time: their amicus brief to that case was submitted in January 2015 but by July 2015 they think that reading the law in its overall context
establishes a precedent that could let any president modify, amend, or suspend any enacted law at his or her whim
What a difference 6 months makes! Apparently now “common sense” is no friend of liberty, and in following the precedent of laws that the Cato Institute relied on heavily (until this year!) the Supreme Court has made it possible for presidents to do anything they want. I guess words really do mean anything these days …
But it’s not just the Cato Institute that appears to have revolutionized its view of the role of context and common sense in the past little while. Four of the majority in King vs. Burwell were dissenters in FDA v Brown and Williamson, the common judge of the two cases being Roberts. Indeed, Scalia agreed fully with Roberts back then that common sense was important, but now appears to think it’s “applesauce” – and the Heritage Institute thinks that “liberals” were shocked then, and applauding now. About, presumably, the same thing.
Where does this leave us? Should there be a common sense test for judges to see if they all agree? Or should we perhaps just roll dice to determine the outcome of Supreme Court decisions where context and common sense are required? Or, perhaps, we could accept that the Supreme Court as it currently works is just an ideological rubber stamp, and the battles in Congress to stack it are way more important than the judges who are on it. It might be of particular value to Republicans to get some bipartisan agreement on this quickly: they’re going to lose the 2016 election after Donald Trump eats a puppy on live TV, and Hilary Clinton is going to get the chance to appoint a couple more judges, which in combination with Obama’s legacy will mean that the nation will be at the mercy of a liberal majority definition of “common sense” for the next 20 years (or 40, if Clinton can find a few young and talented female judges to nominate). Perhaps a move to introduce fixed term limits, and a more objective and less partisan nomination process, might be a good idea. How about 12 year term limits, and nominees for replacement have to be recommended by a consensus of the Supreme Court Bench itself? That would iron out both the kinks in the nomination process and the risk that a single president could dominate the court for years after he or she has gone to the Great Presidential Library in the Sky – a domination, we should note, that will grow over time as life expectancies do.
Of course it’s not going to happen, so Americans will continue to be subject to the tyranny of a system that is clearly broken, invented by a bunch of short-sighted slave-owners a couple of hundred years ago and completely unsuited to the modern world, and now used as a battleground for political retribution rather than solid constitutional decision. Still, at least the USA is on the way to universal health coverage!
July 2, 2015 at 9:07 pm
Well said. You might be interested in blog post King Solomon, Wise or Foolish Flies for another perspective on the subject of the Supreme Court.
Regards and goodwill blogging.
July 3, 2015 at 8:57 am
May I should stop calling them philosopher kings and start calling them politician kings?
The bright side is that while the conservatives 180 degree turn is no surprise, the liberals 180 degree turn validates my stance that the state of American politics is fundamentally stuffed.
It also suggests that maybe Roberts is the only one worthy of the title of philosopher king… Not that that’s much of a compliment.
I’d have to say I oppose the idea of allowing the bench to nominate it’s successors. That’s vulnerable to institutional capture. The only real solution would be the detoxification of American politics and/or a vast reduction in the use or scope of the American court systems power.
Mark Steyn is fond of saying “the process is the punishment” and, regardless of a person’s stance on whether Mann should win or lose, I’d hope it’s possible for people to agree that a libel case should probably be worked out within a year or two of the alleged offence. By contrast the Mann case is still debating whether it can be dismissed or something…
July 3, 2015 at 10:50 am
Thanks for commenting scatterwisdom. I’m not sure that the words of Solomon will be heeded particularly carefully around here – Cthulhu is perhaps more our guide …
Paul, perhaps instead of “politician king” you meant “politician”? My impression of Supreme Court candidates is that they’re also plugged into political networks and quite savvy operatives, which might explain their ability to switch sides on “common sense” issues when they need to.
As an example of the in extremis nature of strictly textual interpretations of statutes, I noticed today when reading a “This Day in Labor History” post at Lawyers, Guns and Money that the entire Occupational Health and Safety Act is written in the male pronoun – all the putative workers of the act are male. Surely, if 7 words of a 1000 page Obamacare statute can invalidate an entire leg of the stool, the consistent use of the male pronoun should be interpreted to mean that the Act only applies to men, and women are not subject to any occupational health and safety laws? Some enterprising textile factory owner should get onto that …
A few climate science blogs I read have had comments from people who have pursued litigation in the US courts, successfully, and they say that even when you win it is a difficult experience that can leave you significantly out of pocket. Many correspondents on Mann’s case have said that even if they think his case is water tight he is very brave to be taking it on. I also once met one of the McLibel duo, who was fleeing to the Antipodes after the end of the case just to take a break – she was just exhausted by the process of standing up for her free speech rights, and although she had a lot of public support she had basically lost years of her life to that battle. I think Steyn may find the same thing happens to him, and he seems to be on much more precarious ground than Mann lifestyle wise (in the sense that Mann seems to have the support of his institutions so will be able to keep his job even if he loses). Much as I hate Steyn and want him to lose this case, it doesn’t seem right that one can emerge from a court battle a broken man even if one wins… So yeah, fixing the entire legal system would be a great idea. I wonder if we need something like Universal Health Coverage for the legal system, as well?
July 3, 2015 at 1:37 pm
Faustus
The first Act of the Australian Parliament in 1901 was the Acts Interpretation Act. An early clause of that says that “he” shall be read to include “she” wherever the former appears (I am sure there is a US equivalent).
It’s a basic principle of legal interpretation that an act shall be read in its entirety, and words interpreted in context (and courst routinely check explanatory memoranda, second reading speeches and so on for the intent of the drafters). Burwell vs King was nonsense from the start – only Republican judges could find otherwise.
July 3, 2015 at 2:06 pm
Then perhaps a Pronouns Interpretation Act would have saved the Supreme Court some trouble.
I have read that at some point the architects of King vs. Burwell realized the contextual issue, and that’s when they started playing up Gruber’s comments to try and change the context. But if so that’s just … pure applesauce, really …
July 3, 2015 at 2:22 pm
Paul, perhaps instead of “politician king” you meant “politician”?
The king element reflects the level of power these guys wield without any recourse (I assume) smaller than an amendment to the constitution.
To put in it context, at least King John was constrained by the Magna Carta and the threat of having his balls chopped off. I hope we all agree that the days of summary execution of kings should be in the past. Ideally because the days of kings stupid enough to open their mouths is past.
“As an example of the in extremis nature of strictly textual interpretations of statutes”
I’m not sure if I’ve said that the attempt to stop the law based on a weaselly close reading of the text is stupid, but if I omitted to say so let me say so now. The court case was stupid. Obamacare ain’t great [1], but it ain’t bad.
“I wonder if we need something like Universal Health Coverage for the legal system, as well?”
The problem seems to be the attitude that the wheels of justice need to grind slowly to grind fine. Maybe it would just be better to pay judges and lawyers a capped amount per case with bonuses for especially large or tricky cases? It’d incentivise them to go faster (and the cap would remove the incentive to finish each case in too short a period).
I don’t think I’d seriously support that. But endless court cases suck for all concerned (unless they’re getting funded by someone else, e.g. the lawyers, then they’re awesome).
[1] I’d take the Australian system (and probably even the NHS) over it any day.