Glenn is certainly correct that I don't believe in a hard-and-fast rule of stare 
decisis (nor do I know anyone who does).  I'm not sure how much the Second Amendment 
analogy works; I trotted it out because of Glenn/  My principal question remains how 
and why we decide to honor certain precedents and reopen others.

I've had time only to skim Larry Solum's blog essay.  It's terrific, with lots to 
think about.  Insofar as he relies, to some extent, on the fact that Washington 
himself made recess appointments that were unopposed by constitutional adepts, then 
I'm reminded, once again, of Marbury and the Section 13-Article III problem.  I.e., 
why isn't the First Congress dispositive on the fact that the two are in harmony 
rathter than, as Marshall held, in fatal tension?  But this might take us too far 
afield.

sandy

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