Once upon a time, there was a constitutional amendment that had avoided all of the disputes characteristic of constitutional law. The Supreme Court had never even mentioned it. Only four district court decisions had in any sense turned on the Amendment’s meaning. Law schools did not hold symposia exploring the subtleties of the Amendment. The definitive law review article on the Amendment had yet to be written. The most attention the Amendment received was as an example of a constitutional provision so straightforward that it generated few of the interpretive controversies that lurked elsewhere in the Constitution.
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