Balkinization  

Saturday, January 16, 2016

Ted Cruz and the courts

Sandy Levinson

Jack has weighed in with an analysis on how easy it would be for the federal judiciary to declare, once and for all, whether Ted Cruz is a "natural-born citizen" under the Constitution.  At one level he is surely correct:  That is, liberals who generally are skeptical about rigorous theories of standing and/or the "political question" doctrine can easily figure out ways for the case to be properly presented to a court for decision.  And, dare one point out, it is certainly tempting for liberals like Laurence Tribe (and many others) to point to Cruz's sheer hypocrisy in defending a mindless form of originalism at the same time he looks to "practice" to defend his own eligibility.

That being said, it seems to me that any sensible discussion of the issue should recognize that should courts be so unwise as to enter this controversy, there is one and only one appropriate result:  To declare, preferably unanimously, that there is no problem whatsoever with Cruz's eligibility.  And, indeed, I would hope that the unanimous opinion would be far more unequivocal than Jack's posting, which seems altogether too generous in conceding that there is a genuine controversy.

I personally view the attack on Cruz's eligibility as the equivalent of arguing that Hillary Clinton is ineligible to take office because, after all, the Constitution uses language--and there can be no doubt whatsoever that the original public meaning was congruent--suggesting that only males could be President.  Alas, the 19th Amendment is no help because it mentions only a women's right to vote and says nothing at all about their capacity to participate in actual governance.  (Why the Amendment was drafted this way is, I think, an interesting question .  I suspect that its limited focus helps to explain why the 19th Amendment has been so completely non-"jurisgenerative.")

In any sense, it strikes me that it would be an unequivocal disaster, meriting rioting in the streets by Ted Cruz's millions of supporters, if the Supreme Court declared Cruz to be ineligible on the basis of a ridiculously narrow reading of a terminally vague provision of the Constitution.  Indeed, those who take the anti-Cruz argument seriously should read the text carefully and they explain why anyone alive today is eligible for the presidency given that none were alive at the time the Constitution was ratified.  Jack, Jordan Steiker, and I actually devoted an essay to this seemingly important textual question, though one way of reading it is as a satire of just those wooden and mindless approaches to constitutional interpretation that take seriously the potential ineligibility of Texas's Canadian-born junior senator.  As I told the Austin American-Statesman, there are (at least) a 100 reasons to be opposed to our egregious junior senator (educated, I'm always eager to point out, at Princeton and Harvard), but being Canadian-born is not one of them given that there is no argument whatsoever, period, that he was not  a citizen under American law as he emerged from the birth canal.  (Perhaps he was born in a Caeserian operation, which would raise questions about whether he was "natural-born" for Macbeth buffs.  Should Donald Trump be investigating this aspect of his birth?)

Perhaps it would do no harm if the federal judiciary--i.e., the Supreme Court--accepted Jack's analysis, but if and only if it came out with the only tenable result.  To treat Cruz's eligibility as a "purely legal question" that should be decided independently of the consequences is just the kind of "thinking like a lawyer" that justified Mr. Bumble's denunciation of law as "an ass."

[UPDATE:  I happily endorse my colleague Joey Fishkin's observation that the Natural Born Citizenship Clause is morally indefensible inasmuch as it embeds a notion of second-class citizenship in the text, as do, incidentally, the durational residency requirements for candidates for the House and Senate.  Robert Post and Randall Kennedy both identified the Clause as the most objectionable piece of constitutional text.  To prattle on about honoring its original meaning is like Taney's musings on who could be a member of the American political community in Dred Scott.  But at least he was trying, like Story in his equally objectionable opinion in Prigg v. Pennsylvania, was trying to save the Union, whereas the originalist opponents of Ted Cruz are simply living in a legalistic miasma devoid of common sense.

One of the discussants below suggests that anyone who offers any consequentialist cautions (as in "there will be rioting in the streets should judges disqualify Cruz") automatically oppose Brown.  The real question for such purists is whether they believe that the Court in 1955 should have ordered immediate integration (instead of "all deliberate speed") and in 1956 should have declared unconstitutional Virginia's anti-miscegenation law in Naim v. Naim instead of lying through their collective teeth in dismissing it for want of a substantial federal question.  Honorable people can disagree on the answers, but at least the disagreement is on how fast we should move to rectifying the most pervasive American injustice.  With the Cruz, issue, on the other hand, there is no reason whatsoever to believe that any important moral principle is being vindicated if he is ruled ineligible.]

Comments:

Sandy was not in a Rip Van Winkle mode when going back to 2008 Barack Obama, though born in the State of Hawaii - not the Territory - to a mother who was an American citizen, many conservatives challenged his qualifications as a "natural born Citizen." Hawaii's certification was challenged. Some claimed Obama was born in Kenya. Now what if Obama had been born in Kenya to his American citizen mother. What would have been the reaction of those challenging Obama's qualifications? Canada, like Kenya, is not part of America. But Cruz has actually gotten a fairly free ride until he challenged Donald Trump in the Iowa polls. We've had originalists and non-originalists jump into the fray; even originalists have a hard time agreeing among themselves. The "natural born Citizen" presidential qualification is not appropriate in this day and age, as is the case with other provisions in the Constitution. But the current nationalism/xenophobia demonstrated by many GOP 2016 presidential candidates might suggest an Article V amendment doing away with this requirement might not pass. Canada is a friendly county to our north. But there may be concerns with other countries as birthplaces of possible American presidents. (An Article V amendment would not accommodate the 2016 election.) So let this play out a bit as the voters determine whether Trump or Cruz is the crudest presidential candidate. If the Court steps in, some may see this as a Second Act to Bush v. Gore, considering other issues before the Court to be decided before next November's election that might influence that election.

And let's not give Hillary a free ride, whether on originalist (read misogynist) or non-originalist grounds.

With the new open Carry law in Sandy's Texas I understand his fear that a successful challenge to Cruz's eligibility might indeed result in the cooking of machine-gun bacon in Texas and beyond by Cruz's 2nd A gourmands. So Sandy suggests a variation on FDR with his "We have nothing to fear but Cruz himself."

With the GOP Clown Car passenger list getting shorter, we need the entertainment of keeping the "natural born Citizen" rancor alive for a bit more. And part of that entertainment is watching legal scholars of all political stripes making historical discoveries, challenging each other in legal political dysfunction, speaking of the law as "a ass" (contrary to Gene v. and Sandy).

But perhaps Sandy will entertain us with his (at least) 100 reasons to oppose Cruz. This might make the whole brouhaha moot.

Note: A cite/link to Sandy, Jack and Jordan's essay would be appreciated as satire is always appreciated.


 

In most democracies it is absolutely standard for the courts to examine the eligibility of candidates both before and after elections. See Sue v Hill where the High Court of Australia disallowed the election of a senator on dual nationality grounds.

The irony of that case was that the senator-elect under challenge was a member of One Nation, a rather Tea Partyesque movement who argued the case, unsuccessfully, on an originalist interpretation of 'foreign power' in Section 44 of the Constitution. Hill ultimately lost because the High Court held that Britain is a foreign power despite Elizabeth II being Queen in right of both Australia and the United Kingdom.
 

"Indeed, those who take the anti-Cruz argument seriously should read the text carefully and they explain why anyone alive today is eligible for the presidency given that none were alive at the time the Constitution was ratified."

It's not "(No Person except a natural born Citizen, or a Citizen of the United States,) at the time of the Adoption of this Constitution".

It's "No Person except a natural born Citizen, or (a Citizen of the United States, at the time of the Adoption of this Constitution)"

There, that was so difficult.
 

Brett: you are supplying the brackets. The original has commas, so it's ambiguous. Jack's and Sandy's point is that you have to use common sense in interpreting legal texts, not just read the entrails for original intent.

BTW, it is possible to investigate the lay understanding of such phrases as "natural born" by statistical analysis of large corpora of English-language texts from the relevant period that have been hoppered into databases: novels, magazines, letters, works of scholarship. If a phrase does not show up in non-legal contexts, you can infer that it's a term of legal art, and you can go back to the usual trade ways of interpretation.
 

Election Law Blog cited this interesting analysis of "who decides" this question:

http://electionlawblog.org/?p=78791

It turns out there was a minor wannabe candidate that was a naturalized citizen that was not put on the ballot for that reason (click link to Abdul Hassan). (A woman too on account of age; Judge Kozinski, with a reference to Stephen Colbert, upheld that denial.) The Federal Election Commission, in a 2011 advisory opinion, said Mr. Hassan could run for president and solicit campaign contributions even if he couldn’t win. But the agency concluded he wasn’t eligible for matching funds.

I realize you have to apply some assumptions, including not being thrown by 18th Century punctuation to avoid absurdities, but think that sort of thing can be taken too far here. Simple minded textualism or originalism shouldn't be attacked using with respect about the same level of absurdity. This includes, with respect to a past debate with Shag, use of masculine pronouns. Simply put, there are levels of wrong. I agree Prof. Balkin et. al. has taken the "Cruz isn't natural born" side too seriously, but let's not go too far.

The 19A reference is a bit more tricky but it says "The right of citizens of the United States to vote shall not be denied or abridged by the United States or by any State on account of sex." Not being able to vote for Hillary Clinton because she is a woman seems to count. At any rate, if we are going to use the "well the language can mean that approach, it should work. Plus, in 1920, original understanding was women could run. There was already at least one woman candidate for President by then & don't recall (though perhaps there was someone who said it) any talk that she was simply not qualified constitutionally speaking.

Finally, going back to the article cited, the chances of a successful court challenge (a simple case of a state refusing to put his name on the ballot is unlikely as compared to the two much more obvious problem cases, but with troll state officials these days, who knows?) on standing is unlikely at least for a while. And, yeah Bush v. Gore, but there are a lot of reasons to worry about the courts having too much power, but this issue probably isn't one of them.
 

You interpret these things the way you would any old document. Word meanings,grammar, and 'common sense' of the relevant era. And when contemporary sources agree about the meaning, you don't ignore them.

St. George Tucker: "That provision in the constitution which requires that the president shall be a native-born citizen (unless he were a citizen of the United States when the constitution was adopted,) is a happy means of security against foreign influence…"

Sandy's proposed nonsensical meaning would be rejected by anyone with even a minimal acquaintance with the relevant sources. It's not a remotely close call. But some people are desperate for the Constitution to be hopelessly ambiguous.

There are somewhat more difficult questions concerning this clause. But not as difficult as they're being made out to be. Living constitutionists always exaggerate the extent of the Constitution's ambiguity, because a clear Constitution makes it difficult for them to claim the thing means what they wish it meant.
 

I deliberately chose not to comment on Sandy's closing paragraph in my earlier comment, but thought about his intent/meaning overnight (without any nightmares of a President Cruz). This paragraph:

"Perhaps it would do no harm if the federal judiciary--i.e., the Supreme Court--accepted Jack's analysis, but if and only if it came out with the only tenable result. To treat Cruz's eligibility as a "purely legal question" that should be decided independently of the consequences is just the kind of "thinking like a lawyer" that justified Mr. Bumble's denunciation of law as 'an ass.'"

needs to be carefully parsed. What is the "only tenable result"? And doesn't the Court decide purely legal questions? And how should the Court address consequences of deciding a purely legal question? Earlier, Sandy asserts:

"In any sense, it strikes me that it would be an unequivocal disaster, meriting rioting in the streets by Ted Cruz's millions of supporters, if the Supreme Court declared Cruz to be ineligible on the basis of a ridiculously narrow reading of a terminally vague provision of the Constitution.?

Is Sandy suggesting that the Court should avoid such consequences with a decision on the legal question before it? Consider the unanimous decision in Brown v. Bd. of Educ. (1954) where the Justices surely were aware of the consequences of its purely legal decision. There are more recent Court decisions that were not unanimous that seemed to ignore consequences that would be expected to result. (I'll name some such decisions in subsequent comments if others do not.) Were CJ Taney and his slave-owning fellow justices aware of the consequences of their Dred Scott decision?

Let's hear from constitutional consequentialists.

 

Where is the rule that you "interpret these things the way you would any old document" found? Anyway, this isn't any old document. This is a constitution we are expounding (Chief Justice John Marshall, ratifier).

SL put forth a caricature so I think is worthy of some criticism, but not sure how useful caricature ("always") is to answer it. The best argument is not that it is "hopelessly" ambiguous, but that in practice, simplistic analysis alone will not solve things here.

Even using the Brett tests, e.g., there are various ways to interpret the natural born citizen provision. The value of one constitutional commentator of the era (who disagreed with others on various points) is somewhat limited but if "foreign influence" is the issue, e.g., perhaps a Cuban/Canadian father and birth in Canada is problematic. Original understanding might not count the mother here. Plus, Prof. GM's John Bingham (the 14A is of significance here given its own Citizenship Clause) might be against Ted Cruz! "Those born within the Republic, whether black or white, are citizens by birth—natural born citizens."

https://en.wikipedia.org/wiki/Natural-born-citizen_clause

===

Anyway, to toss out another cute claim (no one side has a monopoly of them), one person said the 20A blocked denial of putting an underage candidate on the ballot:

http://caselaw.findlaw.com/us-9th-circuit/1665456.html
 

This comment has been removed by the author.
 

Ted Cruz and Barack Obama if he was born in Kenya are both natural born citizens based on the original meaning of the term, not because the term is terminally vague and courts need to find these men are citizens to avoid mass rioting by their political supporters.

BTW, if deciding cases on the law makes the law an ass, why precisely do we have courts?
 

"Where is the rule that you "interpret these things the way you would any old document " found?"

To quote myself, "This is a language we are using." That's how language works, IF you mean to let it work.

Not everyone does.
 

ETA: Tucker is cited to explain the goal of the clause, which can be advanced by various understandings of the text. Plus, if that is the idea, not sure why McCain was a problem (Brett flagged him as one) given his parents and birth on a United States Navy submarine base more than Cruz.

And, "natural born" was not something everyone at the time agreed upon. Congress didn't even consistently define it in the 1790s. Exaggerations are a problem when the case can be made without them.
 

We are "interpreting" a constitution here. There are various ways you can interpret a constitution, which is not interpreted the same way as "any old document" such as a will or old statutory text. Since, to quote a ratifier of the Constitution and Chief Justice, "this is a constitution we are expounding."

It is simply not common sense to follow what people back in the day thought the document meant today especially given "we the people" continue to have the sovereign power by institutions set forth in it to self-govern ourselves. It is a constitutional interpretation value choice. If you think it is the best one, fine, but you don't want to show the work. Incomplete.
 

The notion that the purpose of the clause was to "avoid foreign influence" comes from one of 2 places: (1) someone's ass; or (2) a letter written by John Jay to Washington on 25 July 1787 suggesting a "Natural born citizen" clause for the commander in chief of the army in order to avoid foreign influence. At that point in the Convention, the CinC power hadn't been allocated to the President, nor had any qualifications whatsoever been set for the President. Not until 4 Sept did the clause acquire its current reading, so there's at best an attenuated connection between Jay's letter and the clause.

There is, to the best of my knowledge, no other commentary on the clause of any sort during the Convention or the ratification debates. Stating the purpose of the clause in some definitive way just proves that some people are more sure about everything than they should be about anything. And that's before we get to the fact, as Joe pointed out, that Ted Cruz could plausibly be deemed "foreign".

It's not "the law" which is an ass here, it's "originalism".
 

If you're into reading the text straightforwardly according to the understanding of the time it seems to me Ted Cruz is ineligible to be President. According to Sam Johnson the most common understanding of 'natural born' was 'native born.' This seems supported by later provisions like the 14th Amendment which distinguishes between citizens born and those naturalized. We can't have courts and Congress changing the meaning of words as they are written, allowing 'state' to mean 'state or federal', or 'legislature' to mean 'popular initiative with legislating powers' or 'native born' to include people born outside the nation. Such would be tyranny, right Bart?
 

Children born of citizens anywhere in the world were themselves citizens under the preceding British and immediately subsequent American law. There is no evidence of any other original meaning for natural born citizen under the Anglo-American law of the time. The 14A has nothing to do with this question, Mr. W.

http://harvardlawreview.org/2015/03/on-the-meaning-of-natural-born-citizen/

Are we seriously giving legal credence to a transparent political attack by The Donald?

Even on its own terms, this political attack is weak tea. Cruz won the last GOP debate in less than two minutes by neatly disposing of the Donald's innuendo.

http://www.realclearpolitics.com/video/2016/01/14/frank_luntz_focus_group_ted_cruz_won_debate.html

 

SPAM I AM! is back in his role at this Blog trolling for Ted Cruz, away from his obvious commercial self promotion. Of course he dismisses out of hand the impact, if any, of the first sentence of Section 1 of the 14th A.

But let the fun and games continue until the issue becomes moot when carpet-bombing Cruz ends up failing to get the nomination.

SPAM I AM! is forced, because of his support for Cruz, to concede that if Obama had been born in Kenya he would still be a "natural born Citizen." But speaking of the Donald's credence, wasn't SPAM I AM! riding the "birther" coattails regarding Obama?

By the Bybee [expletives deleted], Spam has long been part of Hawaiian cuisine.
 

"There is no evidence of any other original meaning for natural born citizen under the Anglo-American law of the time."

That's wrong. The commonly understood meaning of these words, as reflected in Samuel Johson's dictionary of the time, is 'native born.' As you've said, we must give the Constitution the straightforward, simple understanding of the words of the time and not indulge in obfuscating 'terms of art.' More here:

http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2444766

"The 14A has nothing to do with this question, Mr. W."

If you want to know the meaning of a term in a document then looking at other uses in the document makes sense to me.

Ted Cruz is simply ineligible to be President. The proper course is not to rationalize the Constitutional language but to pass an Amendment to change it if that fact stands in the way of you or your party's short term goals.
 

Mr. W:

When determining the meaning of an old legal term of art, you go first to the law of the time.

As your linked article notes, for nearly a century before our Constitutional Convention, English law recognized the foreign born children of Englishmen to be citizens. The rest of the article relies upon medieval common law centuries before the convention or cherry picked commentary, often some years after the fact.

Samuel Johnson's dictionary only reflects part of the law of the time.

The 14A was drafted decades after the Constitution and does not purport to define the qualifications for president.


 

"Samuel Johnson's dictionary only reflects part of the law of the time."

It reflects the straightforward way the term was understood commonly, which is how Constitutional language should be understood rather than obscure, technical 'terms of art' and similar jargon.

"The 14A was drafted decades after the Constitution and does not purport to define the qualifications for president."

It defines what a citizen is, and in doing so restates the widely accepted and texually sound idea that naturalized citizens and citizens born in the US were not the same thing.

Bart, you seem quite 'progressive' in your twisting of the plain language in pursuit of short term political goals!
 

The Wikipedia page cites Federalist No. 68 as a means to determine the rationale of the provision, but not clear why. The concern for foreign intrigue is cited, yes, but in a section on the "appointment of the President" and the wording (though some op-ed essay isn't conclusive) might reasonably deem the whole thing a "political question."

It also references a later (fwiw) speech given to the Senate by Charles Pinckney in 1800:

They well knew, that to give to the members of Congress a right to give votes in this election, or to decide upon them when given, was to destroy the independence of the Executive, and make him the creature of the Legislature. This therefore they have guarded against, and to insure experience and attachment to the country, they have determined that no man who is not a natural born citizen, or citizen at the adoption of the Constitution, of fourteen years residence, and thirty-five years of age, shall be eligible.

https://en.wikisource.org/wiki/The_Records_of_the_Federal_Convention_of_1787/Volume_3/Appendix_A/CCLXXXVIII

And, "insure experience and attachment" is not quite "foreign influence," as seen in part by including the residence/age requirement in the mix. So, that's an inexact source for that purpose & anyways comes over a decade later.

The other thing cited was Prof. Amar discussing general concerns:

http://www.legalaffairs.org/issues/March-April-2004/argument_amar_marpar04.msp

I'm inclined to think that foreign intrigue was a major concern here but it wasn't the only thing & applying it (see later post on this very blog re mothers) is tricky.
 

"The Fourteenth Amendment of the Constitution . . . contemplates two sources of citizenship, and two only: birth and naturalization. . . . Every person born in the United States, and subject to the jurisdiction thereof, becomes at once a citizen of the United States, and needs no naturalization. A person born out of the jurisdiction of the United States can only become a citizen by being naturalized "

United States v. Wong Kim Ark (1898)
 

BD: "Samuel Johnson's dictionary only reflects part of the law of the time."

Mr. W: It reflects the straightforward way the term was understood commonly, which is how Constitutional language should be understood rather than obscure, technical 'terms of art' and similar jargon.


How could a dictionary definition which inaccurately described the written law of the day reflect the way the law was understood at the time? The rule of foreign born citizenship had been the law for nearly a century before the Founder drafted the Constitution. There was nothing obscure and technical about that long standing rule.

BD: "The 14A was drafted decades after the Constitution and does not purport to define the qualifications for president."

It defines what a citizen is, and in doing so restates the widely accepted and texually sound idea that naturalized citizens and citizens born in the US were not the same thing.


The 14A in no way outlawed the long standing rule that the children of citizens born outside the country are themselves citizens. This rule has been the law since the early 18th Century and remains so today.

Wong Kim Ark was the child of Chinese parents born in the territorial United States and his case has nothing to do with the rule we are discussing.


 

The author's "concern" about second-class citizenship is ridiculous; it's obvious naturalized citizens are in that category. The only question is how big the category should be.
 

Perhaps SPAM I AM! can point to a pre-14th A provision in the Constitution defining a "citizen"? The first sentence of Section 1 of the 14th A provides help in defining a "citizen." Using the 5-4 logic of Heller, a case could be made that birth in America is natural whereas other forms are via naturalization.

So let's bask in the SCHADENFREUDE as Trump and Cruz battle over which of them is the crudest of all.

Joseph Fishkin's post is a good read. Hopefully others may pick up on it.

But I'm still awaiting responses to Sandy's fears of Cruz's minions' reaction to a Court decision to the effect that Cruz does not qualify as a "natural born Citizen."

And I haven't heard any views on how America might react to an effort via an Article V amendment to cover Cruz.
 

"How could a dictionary definition which inaccurately described the written law of the day reflect the way the law was understood at the time? "

The commonly understood meaning of the text is the better guide, as those called to ratify the Constitution were not all lawyers. Note that the Constitution did not adopt the language of the English statute verbatim (which is good for you in a way, in that that language was limited to the children of English fathers) , something the Founders knew how to do when wanted (see the 7th Amendment). Also, the colonies often adopted English common law while resisting many enactments of Parliament (a rejection of English immigration and naturalization law was implied in the Declaration itself).

"Wong Kim Ark was the child of Chinese parents born in the territorial United States and his case has nothing to do with the rule we are discussing."

Wrong. The case was about Ark's citizenship, and in deciding the matter the Court discussed the nature of citizenship in the United States. And as the language I quoted clearly states, "A person born out of the jurisdiction of the United States can only become a citizen by being naturalized " Cruz was born out of the jurisdiction of the United States, he is at best a naturalized citizen, not a natural born one. He is ineligible to be President. We cannot waive the plain straight forward reading of our Constitutional texts for political short term gains, so I'm surprised at your advocating such a lawless position. It seems you would sacrifice our Constitutional Republic in order to save it...
 

The update argues the natural born provision is "indefensible" and it is simply antiquated at best though "durational residency requirements" to me are quite "defensible" (even if some rather them out) and should not be put in the same class.

As to Story/Taney, historians have noted the sine qua non theory regarding the Fugitive Slave Clause Story et. al. put out seemed honestly believed even if it was confused and in various cases biased (what isn't?) presentist thinking. Taney particularly put forth a confused version of originalism. Even the most reasonable reading of the natural born citizenship provision would "indefensibly" block people who should be under a fair system be qualified. But, as with Wyoming having two senators, the rule of law would require upholding it. Taney can take us only so far.

As to the consequences, it's a lot easier here - the right imho interpretation would give Cruz a victory. We should worry about extreme cases of dealing with potential civil unrest when it actually is a compelling problem. But, if it turned out he was simply not natural born (turns out his mother was not really an American citizen), the "moral principle" here would be upholding the law and not bending it to give in to those who would riot. This would hold even if we grant the provision itself is unjust, which simply is a somewhat dangerous ground to rest on, even if I knew exactly how to determine it.
 

BD: "How could a dictionary definition which inaccurately described the written law of the day reflect the way the law was understood at the time? "

Mr. W: The commonly understood meaning of the text is the better guide, as those called to ratify the Constitution were not all lawyers.


Those who drafted the Constitution were lawyers and historical scholars and none of them claimed to be changing the prevailing rules of citizenship.

"A person born out of the jurisdiction of the United States can only become a citizen by being naturalized."

When you are talking about the children of foreign parents as was Ark, that statement is most certainly true.

This statement was never true concerning the children of American citizens at any time in our history.

While I enjoy our conversations, you do not have anything close to a viable argument here.
 

In his Update Sandy states that CJ Taney in Dred Scott "was trying to save the Union." How effective was that? Should we be critical of Lincoln for being victorious in 1860 and for his subsequent steps as President in challenging the secessions of the slave states that Taney had intended to benefit in his Dred Scott decision? (But for the Civil War, Taney was waiting to address New York's Lemmon Case to make slavery universal in America.

How should the Court address what Sandy considers to be dumb provisions in the Constitution? For "natural born Citizen," he seems to seek a consequentialist role, with this:

"In any sense, it strikes me that it would be an unequivocal disaster, meriting rioting in the streets by Ted Cruz's millions of supporters, if the Supreme Court declared Cruz to be ineligible on the basis of a ridiculously narrow reading of a terminally vague provision of the Constitution."

Since a Constitutional Convention may be difficult to convene, perhaps a convention of legal constitutional scholars might be easier to convened to address the dumb "natural born Citizen" presidential qualification in the Constitution. We've heard from a few, perhaps too many so far. But let's get them all together like angels on the tip of a pin. Let these scholars consider whether such anticipated (by Sandy) "meriting rioting in the streets" should determine how the Court should rule. And then the scholars might address consequentialist approaches to Bundy and his ilk. What are the chances of such scholars being in agreement unanimously with Sandy?
 

Some grammar here, Mr. DePalma. Not "Barack Obama if he was born in Kenya" as you have it, as if it were an open question, which it's not, but "Barack Obama if he were born in Kenya" i.e., contrary to the fact that he was born in Hawai'i.
 

FWIW, I think even punctilious “original public meaning” originalists have left *at least* one pro-eligibility argument unexplored:

In 1789, “natural born citizen” was not a precise term-of-art--not like, say “letters of marque and reprisal” or “writ of habeas corpus.” It had a rich history in the common law, and Acts of Parliament, sure—but it didn’t develop an exotic meaning in niche applications. And that’s what terms of art are: words/phrases with exotic meanings in niche applications.

A “letter of marque” is not simply a written communication with a stamp on it—or my tax acknowledgement from the City would qualify. A “writ of habeas corpus” is not simply a written order to raise a body—or an exhumation order from an inquest would qualify. Rather, these things are specific and anomalous instantiations of broader items, from which they take their name.

“Natural born citizen” is not like this. “Natural born citizen” has no far-removed, boutique meaning poles apart from the broader, inferable meaning available to a non-privy user of English. That broader, inferable meaning is “being a citizen by natural incident of birth.” How “natural born citizen” was used in the Acts of Parliament, Constitution, etc. was basically no different.
The takeaway? “Natural born citizen” may have been legislatively refined for legal clarity in Year Y via Act of Parliament X. Sure. And maybe it was re-refined in Year A via Act of Parliament B. But who fucking cares? What you’re changing isn’t the *meaning* of that phrase. What you’re changing is how that phrase *operates* in a *stipulated legal context.* You are describing how that phrase fuses with the law; you are not redefining it.

The Indiana General Assembly once adopted 3.2 for pi. That did not make pi 3.2.
 

" I happily endorse my colleague Joey Fishkin's observation that the Natural Born Citizenship Clause is morally indefensible"

So what? Seriously, so what? Fine, if he's a judge, and he's in a place where he has to apply it, he should resign. Maybe he should advocate passing an amendment to repeal it. But his, or your, opinion that it's morally indefensible, is of no legal significance at all.

Are we really going to get into a fighting match over which parts of the Constitution are morally indefensible, and assume they should be ignored? People do disagree in their moral perceptions, after all.
 

Joe, much earlier: " ... but with troll state officials these days ..."
Which are the troll states? Don't answer. But "(troll state) officials" is as natural a parsing in English syntax as "troll {state officials)".

It's a pity that legal draftsmen do not avail themselves of the standard typographical devices for setting out the logical hierarchy of terms, the nested brackets I have used here or the nested indents of programmers. At best you have the clumsy and limited alphabetical scheme of "I.1.a.i".
 

Some 3+ hours prior to Sandy's "Update," I included this in a comment:

"Joseph Fishkin's post is a good read. Hopefully others may pick up on it."

I read Fishkin's post as a critique of the legal community, including originalists and non-originalists, perhaps even of Sandy's post. I hoped others would build upon it. While I did not mention it, I had some problems with Fishkin's exploration of this brouhaha as perhaps connected to Cruz being a person of color.

As for Brett, I assume his position is that Cruz does not qualify as a "natural born Citizen" not because of his color but because he was not born in America. SPAM I AM! is openly shilling/trolling for Cruz. But I'mm not aware of Brett's candidate, if he has one currently. But considering the lily white Iowa evangelical support for Cruz, who is Fishkin suggesting objects to Cruz because of his color? Is it Democrats? It is no secret that many in the Republican Party are concerned with the changing demographics. So perhaps Fishkin and others might pick up on that aspect of Fishkin's post.

Also regarding Brett, I wonder how he and his fellow anarcho-libertarians/2nd A absolutists might react if the Court would decline to rule or rule in favor of Cruz on the "natural born Citizen" brouhaha, perhaps in Sandy's words " ... meriting rioting in the streets ...."
 

"Those who drafted the Constitution were lawyers and historical scholars"

That's not really true (take New Hampshire's delegates, the first I looked up, a mercantile businessperson and retailer turned soldier as an example). But it's neither here nor there, what's important is how the ratifying public would understand the words.

"none of them claimed to be changing the prevailing rules of citizenship."

You mean like that stated by William and Mary law professor St. Tucker in 1803, who said "natural born citizens, or those born within the state"?

"When you are talking about the children of foreign parents as was Ark, that statement is most certainly true."

You're a torturer of grammar at times Bart, but I doubt even you'd like to argue that the quote from Ark wasn't speaking generally beyond Ark's specific case (note the language used throughout, " two sources of citizenship, and two only: birth and naturalization. . . . Every person born in the United States"

Face it Bart, you're arguing to usurp the Constitution for short term political goals.

 

BD: "Those who drafted the Constitution were lawyers and historical scholars"

Mr. W: That's not really true (take New Hampshire's delegates...


Those who drafted the Constitution, not necessarily all of the delegates who voted on it at the convention or those that ratified it in the legislatures.

The drafters often used legal terms of art and small "r" republican theory of the day.

Finally, the Supreme Court could not be speaking beyond Ark's particular set of facts because, for one final time, US law has ALWAYS recognized that the foreign born children of citizens are themselves citizens. Ark was not discussing that situation and most definitely did not change that law.
 

A suggestion has been made that "natural born" in the "natural born Citizen" clause had the same meaning as "native born." Alas, it might have been a tad uncomfortable for the Framers to use "native born" because of the possible confusion with the 1787 Constitution's treatment of Native Americans. The first sentence of Section 1 of the 14th A in defining "citizen" excluded Native Americans. It wasn't until the Indian Citizenship Act of 1924 that Native Americans became citizens. What was the source of Congress' enumerated authority for this Act? Would the birth of a Native American on an Indian Reservation satisfy the "natural born Citizen" clause? Might America some day have a Native American President?
 

"As for Brett, I assume his position is that Cruz does not qualify as a "natural born Citizen" not because of his color but because he was not born in America."

My position, already expressed, is that you are a "natural born citizen" if you are a citizen at the moment of your birth, rather than being made a citizen afterwards by some legal act. Once born not a citizen, no subsequent legal act can make you a "natural born citizen".

Those born in America, with some exceptions, (Children of diplomats, for instance.) are citizens at birth as a constitutional rule.

However, it is possible to be a citizen at birth as a statutory matter. To determine this, you have to look at the relevant law, as it stood at the moment of birth.

Cruz was a citizen at the moment of his birth, as a statutory matter. McCain was not. In the case of McCain, the relevant statutory law was changed a few months later, and purported to have retroactive application.

But this is not the sort of subject where a law can be retroactive. Laws can't change the past, and the constitutional clause would be a nulity if we accepted retroactive application of naturalization in this way.
 

I'm pleased Brett clarified his view on Cruz. While Congress under Article I has an enumerated power regarding naturalization, it is not clear that this gives Congress the power to define "natural born Citizen" in Article II. A "statutory citizen" pursuant to Congress' Article I enumerated naturalization power can be distinguished from a "natural born Citizen" under Article II.
 

@ James Wimberley ... well, my comment wasn't an act of legal draftmanship though as you say that often is clunky -- one problem with some legal interpretative techniques is that they are too artificial for the real world.

Yes, the Constitution isn't framed in code. The additional flexibility etc. that results is as much feature as bug.

@Brett ... It isn't clear just what SL would take as a matter for judges regarding his belief that the clause is morally indefensible. It is quite possible that it is relevant along the edges such as applying the slavery privileges would be as compared to settling an issue regarding tariffs.

When constitutional provisions clash, e.g., it can change how to apply the details such as when public trials clash with due process. It might be, e.g., more important to have a clear statement rule before applying a possible limit on citizenship. And, "indefensible" here can mean in that sense -- it clashes with some constitutional principle.

"Cruz was a citizen at the moment of his birth"

Assuming that -- e.g., to avoid "foreign influence" -- birth in Canada to a non-citizen father (see new post as to mothers) by constitutional rule doesn't disqualify.

"McCain was not"

That's rather debatable even w/o bipartisan arguments such as by Tribe-Olson. See, e.g. https://cases.justia.com/federal/district-courts/california/candce/3:2008cv03836/206145/39/0.pdf

"the sort of subject where a law can be retroactive"

Must be one of those obvious rules that aren't obvious to all of us including where "nullity" means that use of legislation to tinker along the edges (e.g., to clarify two citizen parents who have a child in a U.S. military base had a natural born citizen) is impossible. Anyway, it doesn't matter - McCain's natural born citizenship, even factoring in the statute in place at his birth, has been repeatedly been defended (provided examples in a past thread).
 

The Originalism Blog has a couple of recent posts on this topic. One says not clear from history, etc, but if Cruz were elected the tie goes to the runner according to Corpus Juris Secundium. (Tillman) Several others take the position that Cruz is a "natural born Citizen" by routes differing somewhat from the route Mike (I'm not Rappaport) Ramsey took in his article.

Imagine a constitutional GPS with different routings getting to the same destination. Could be the destination - Cruz qualified - was first assumed and then the route determined. Might that suggest that at times constitutional scholars act back-asswards? (See Heller, 5-4)
 

ICYMI -- http://www.acslaw.org/acsblog/%E2%80%98heller%E2%80%99-guns-and-the-living-constitution
 

Joe, your link assumes without argument that the Canal Zone qualified for natural born citizenship, even though Congress thought it necessary to change the law. And admits the law purported to be retroactive.

What was it retroactively changing, if there was nothing to change?

I don't see a lot of argument or debate there, just dismissal.
 

I take it from Brett's argument that no former slave, or indeed any black person alive in 1868, whose citizenship depended on the 14th A, was eligible to be President.

I doubt that Brett's argument really qualifies as "originalism". Under any "originalist" theory, the accepted meaning of the phrase "natural born" would have been fixed in 1788. No later act of Congress could add (or subtract) from those who, at that time, would have been considered "citizens at birth". And that's assuming that his reading of the phrase is the correct one. It's a possible reading, of course, but hardly the only one.
 

This comment has been removed by the author.
 

Brett, the judge references the citizen provision of the Act of May 24, 1934 (McCain was born in 1936), noted how the Supreme Court interpreted it, and applied it to McCain. Not sure how this is 'without argument,' but if you want more analysis, again, I cited various sources in another thread that provided just that.

THEN, in the alternative, the judges cites the later law which was passed to remove "any doubt" (such is the argument) to reaffirm this as applied to the Canal Zone (the law before covered more ground, but the judge notes this special concern). The judge notes it retroactively rendered him a citizen, "if he was not one already." Under your rule, this law shouldn't count, since it was passed after his birth. Thus, we would have to use the earlier one, which the judge deemed enough on its own.

Finally, apparently, retroactively granting citizenship here is not as controversial as you seem to think. Yes, the nature of the order made the argument briefer than a full opinion would tend to be.
 

"Originalist theory" confuses me.

What if the original public meaning of a term, let's say "citizen," was "what state law at the time of a person's birth granted." This would make the term variable over time, though the definition does in a certain sense stay fixed.

This flows to the whole "levels of abstraction" problem. What level of abstraction should we rely on here for words like "equal protection"? Or, what level of discretion -- perhaps, original understanding was that such and such a term was a "political question" and even if we now find that troubling (e.g., it would result in uncontrollable federal power), so sorry. Amend the Constitution.

Brett finds Jack Balkin's originalism essays absurd here, but not sure why, especially his "Commerce" article.
 

Joe: What if the original public meaning of a term, let's say "citizen," was "what state law at the time of a person's birth granted." This would make the term variable over time, though the definition does in a certain sense stay fixed.

Original meaning interpretation would freeze the meaning of a word or term as it was understood when the constitution, law, contract or will was put into effect.

I know of no word or term which is defined as "what state law will grant in the future." Such terms would be indeterminate and unenforceable.
 

"Those who drafted the Constitution, not necessarily all of the delegates who voted on it at the convention or those that ratified it in the legislatures."

What gives the Constitution legitimacy is not the drafters understanding but the ratifying public. Your logic leads to the absurd conclusion that what matters in federal law would be the thoughts of the staffers that draft most measures rather than the elected representatives that pass the law. Absurd.

"the Supreme Court could not be speaking beyond Ark's particular set of facts because"

It could and it did. You're welcome to try to parse those words to get something specific out of them (the qualifier 'every' or the phrase 'two sources of citizenship, and two only' should make for some fun there I imagine). They were plainly general statements about the law of citizenship in the US.

"Original meaning interpretation would freeze the meaning of a word or term as it was understood when the constitution, law, contract or will was put into effect.

I know of no word or term which is defined as "what state law will grant in the future." "

Of course you're flatly wrong about this, the Constitution contains examples of this sort of thing where provisions are left up to the determination of the states. For example, Art. I, Sec. 4, Clause 1 ('The Times, Places and Manner of holding Elections for Senators and Representatives, shall be prescribed in each State by the Legislature thereof') or Art. I, Sec. 2, Clause 1 ('the Electors in each State shall have the Qualifications requisite for Electors of the most numerous Branch of the State Legislature.').
 

"While Congress under Article I has an enumerated power regarding naturalization, it is not clear that this gives Congress the power to define "natural born Citizen" in Article II."

Indeed. Saying Congress could under its Art. I power regarding naturalization change the definition of 'natural born Citizen' in Art. II would be like saying Congress could under its Art. I power regarding commerce or militia define what 'arms' in the 2nd Amendment means.
 

"I take it from Brett's argument that no former slave, or indeed any black person alive in 1868, whose citizenship depended on the 14th A, was eligible to be President."

No, because I think Taney was totally off base in denying the citizenship, indeed personhood, of blacks. He really had no good legal basis for doing so, just his horror at the consequences of blacks having rights. Freed blacks had a prior history in several states of exercising all the rights of whites. (Including, alas, owning slaves...)
 

Brett

Were black slaves citizens? If they were, how's that squared, in your view, with, for example, the privileges and immunities clause of the Constitution (Art. IV)?
 

It's pretty hard to see how slaves could have been citizens, which would mean no former slave granted citizenship under the 14A could have been eligible for President under Brett's theory. The response that Dred Scott was wrongly decided works for free blacks, maybe, but not for slaves.
 

"It's pretty hard to see how slaves could have been citizens"

Oh, really? You'll notice that the 13th amendment still permits slavery as a punishment for crime. If somebody commits a felony, and is sentenced to become a slave, do they lose their citizenship?

DID they lose their citizenship? Because it was a punishment for crime, it did get used.

I don't see it even a little hard to see how slaves could have been citizens. Taney's objection to the idea ran the other way: That it was difficult to see how it would be feasible to keep citizens slaves, when they'd have all manner of rights that would inconvenience their owners.

[sarcasm]I weep for their owners' inconvenience.[/sarcasm]
 

If somebody commits a felony, and is sentenced to become a slave, do they lose their citizenship?

They did and do (often) lose the right to vote. That's certainly a key component of citizenship.

That aside, traditionally slaves were not considered citizens, for exactly the reasons Taney gave: they would have rights which society had to recognize, while slaves had none. Slavery and citizenship are incompatible.
 

Losing the right to vote is a common consequence of being convicted of a felony, regardless of the penalty. It doesn't imply you're not a citizen, or else we have an awful lot of non-citizens in the US.

I agree that slavery and citizenship are, as a practical, if not theoretical matter, incompatable. I just draw from this the opposite conclusion you do. Taney ruled slaves could not be citizens, because he wanted to preserve slavery, wanted to preserve it as a practical institution.

I don't care to, so I don't need to assert they couldn't be citizens.
 

Of course CJ Taney was well aware of the 3/5th clause of the 1787 Constitution and that it did not confer upon slaves even a 3/5th vote. The 1787 Constitution was stacked before Dred Scott for protecting slavery and depriving slaves of rights. And the 1850 Fugitive Slave Act was used against free Blacks. Imagine, no jury trial permitted under that Act.
 

When opponents of the Constitution drag out that hoary old tale about how the 3/5th clause was to support slavery, it's time to throw up your hands and go away, reason has left the room.
 

"I don't see it even a little hard to see how slaves could have been citizens."

It would be a "little hard," e.g., because than they would have the privileges and immunities of citizenship which slaves as a class simply did not have. In fact, many free blacks were not considered U.S. citizens by state law & it is reasonable argue even the median view of the time was only a small subset of them could be.

I still am not sure the Constitution allows "slavery" as in the whole gambit of loss of rights including because the word "and" could mean this concerns prison involuntary servitude plus other protections in the document. Regardless, yes, in antebellum times being a felon was deemed a sort of civil death so perhaps they did lose citizenship rights.

Its possible to conceive of a "citizen" slave though the term to many, including probably in Roman times when being a slave meant more freedom, absurd. As to the 3/5 Clause, at the very least, "other persons" were treated in an inferior way, in part because they were deemed particularly different. This includes for most people the idea they weren't citizens. The fact the clause was a compromise that helped and hurt slave states doesn't change that.

Finally, slaves did have some rights, however underprotected, including often some due process rights when they were charged with a crime. the Constitution even called them "persons" and "persons" have rights there. Lincoln noted this at Cooper Union though didn't (for obvious reasons) highlight the second part.

The biggest right was the right in some cases to be freed, something actual chattel like a cow would not have. Slaves weren't citizens because citizens "would have rights which society had to recognize" that slaves did not have.

 

As for felons being "citizens", remember that at common law all felonies were punishable by death. This made citizenship and its associated rights a bit moot.
 

"I still am not sure the Constitution allows "slavery""

"Neither slavery nor involuntary servitude, except as a punishment for crime whereof the party shall have been duly convicted, shall exist within the United States, or any place subject to their jurisdiction."

That's pretty darned explicit.
 

Brett, the standard (and to me obvious) reading is that the exception clause modifies "involuntary servitude" only.
 

Brett, I think you're misunderstanding Shaq's point.

If the correct view is that slaves could be citizens, how does that square with provisions in the original Constitution like the 3/5th clause (3/5ths of a citizen???) or the Fugitive Slave Clause (which seems to conflict with the P&I Clause). It's incompatible with the text.
 

"The fact the clause was a compromise that helped and hurt slave states "

I'm not sure how it 'hurt' them, other than that they 'only' got 3/5th of the absurd goal they put forward.
 

I think Mark Field's point as to the 13A reasonable without -- I covered this in a past thread covering the topic -- perhaps relying on the 14A (e.g., slavery would be a cruel and unusual punishment under the Due Process Clause) etc.

---

Mr. W, not sure why it's called the 3/5 compromise if only one side got something out of the deal. The term to me implies something for each side, each side giving up something.

It hurt them by counting "other persons" only by 3/5 though women and children had limited rights and in effect also were virtually represented but received full representation. It is a bit assuming the point to note it patently obvious that their goal was 'absurd.'
 

the 3/5th clause (3/5ths of a citizen???) or the Fugitive Slave Clause (which seems to conflict with the P&I Clause). It's incompatible with the text.

No, "other persons" are counted for purposes of representation and direct taxes 3/5 of the regular rule. I think it sensible to infer the reason they did this was an understanding that the persons were in some fashion inferior. Using Brett's usual techniques on normal understanding at the time of language, this would help the no citizen side. But, it is not, full stop, "incompatible."

As to the Fugitive Slave Clause, it speaks of the right to retrieve those whose labor is owed to someone else. I don't think it alone -- any more than states having an obligation to send back prison escapees -- conflicts with P&I. We do have a right to travel between states, but if a member of the navy is unable to do so given their duty of service, I don't think it violated.




 

"I think it sensible to infer the reason they did this was an understanding that the persons were in some fashion inferior."

I think it reasonable to infer they did it to reduce the political power of slave states, compared to the default 1/1 rule. It was, after all, the free states that pulled for 0/1, and the slave states 1/1, with 3/5 arrived at as a compromise; Do you think the free states were more inclined to think slaves inferior than slave states were?

It requires a certain historical blindness to think the 3/5ths compromise was a pro-slavery clause. But there is a push on to delegitimize the Constitution, so that it can be tossed aside, and this is part of it.
 

Brett might learn something else today:

http://www.nytimes.com/roomfordebate/2013/02/26/the

The Union Wasn’t Worth the Three-Fifths Compromise on Slavery
Paul Finkelman

This take has been around for a long. Apparently Brett has been reading southern historians' historic revisions that floated around on the Centennial off the Civil War.

 

Joe-I can't wrap my head around the idea of someone who is a citizen but 3/5ths a person in nation. That does seem incompatible to me.

Brett-"It requires a certain historical blindness to think the 3/5ths compromise was a pro-slavery clause."

It was pro-slavery because the Southern position was patently ridiculous on its face-that, for the purposes for apportioning political representation the people they owned as chattel should be counted-and they got 3/5ths of that absurd position ratified.

Think about a negotiation where one side makes a totally pie in the sky opening offer, and then after dickering ultimately gets 3/5ths of that pie. We'd say they won the negotiation for sure.
 

It was patently ridiculous that slaves, who could not vote, would count for representation in exactly the same manner as anybody else who couldn't vote? Children got counted 1 for 1. Women got counted 1 for 1. Convicted criminals counted 1 for 1. But it was pie in the sky that slaves would?

I think you're basically taking the position that anything short of immediate eradication of slavery was a pro-slavery position. Which is a fine position to take at this distant remove, but demands that the US should have been still born, a victim of the best slaying the good. Imagine the consequences of the 0/5ths non-compromise: Two nations from the beginning, one free, one slave.

That would not have offended me, but people of the time reasonably thought that the step after that was America being reconquered by the British, or some other European power. ("or we shall surely hang separately...") And thought a compromise to avoid that worth it.

 

Joe-I can't wrap my head around the idea of someone who is a citizen but 3/5ths a person in nation. That does seem incompatible to me.

They weren't 3/5 of a person. They were counted as such for representation and direct taxes purposes. The compromise in part grew out of the idea slaves would produce less so would be less worthy of full representation. In theory, you could also apply the principle to children or women. In a political convention, various fractional representation are possible too, so perhaps a governor could have 1.5 votes while a simple civilian only one. But, they still can be both 'citizens.'

Slaves considered as a whole were not treated as citizens and the 3/5 Clause does advance the argument. But, merely citing the text won't get you there.
 

Brett, Yes, it's patently ridiculous. It's totally contrary to democratic principles. Children were thought to be represented by their parents, women were represented under coverture by their husband (they were legally one), and felons were under civil death. Slaves, however, were people that were thought of as either property or under the forcible dominion of the slaveholder, the idea that under either the former would be represented by the latter is patently ridiculous. The Northern delegates who opposed the measure saw it this way, btw.
 

Joe-representation and tax obligations are intertwined with citizenship in a democracy, and being 3/5 of a citizen is just incoherent.

"you could also apply the principle to children or women"

But, iirc, women and children were counted as whole persons, unless they were slaves, and they were citizens.
 

This comment has been removed by the author.
 

There is no "3/5 citizen" here -- "other persons" are counted for two purposes differently. This didn't by itself suddenly deny them citizenship.

Voting is basic in a democracy, but white women except for a short term narrow exception, couldn't vote in antebellum times. Still citizens. If blind people have to pay 3/5 taxes of others given their reduced abilities to earn a living, would that mean they weren't citizens? A fraction of a million people in North Dakota gets equal representation in the Senate than millions in other states. All are citizens. This in effect is a sort of fractional representation which is why it was deemed unconstitutional as applied to state legislation.

Women and children were counted as whole persons, but in theory, a labor view of representation could be applied to them. It wouldn't by that reason alone mean they weren't citizens.
 

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