In this episode of the podcast "Consider the Constitution," host Dr. Katie Crawford-Lackey discusses Article III of the US Constitution, which established the judicial branch. She is joined by Dr. Lauren Bell, a political science professor and former fellow at the United States Supreme Court. They discuss the brevity of Article III compared to other articles, the jurisdiction of the Supreme Court, and the relationship between federal and state courts. They also delve into the significance of the Marbury v. Madison case, in which Chief Justice John Marshall established the power of judicial review. The conversation concludes with a discussion on the current state of the Supreme Court and the challenges it faces in maintaining public trust and legitimacy.
In this episode of the podcast "Consider the Constitution," host Dr. Katie Crawford-Lackey discusses Article III of the US Constitution, which established the judicial branch. She is joined by Dr. Lauren Bell, a political science professor and former fellow at the United States Supreme Court. They discuss the brevity of Article III compared to other articles, the jurisdiction of the Supreme Court, and the relationship between federal and state courts. They also delve into the significance of the Marbury v. Madison case, in which Chief Justice John Marshall established the power of judicial review. The conversation concludes with a discussion on the current state of the Supreme Court and the challenges it faces in maintaining public trust and legitimacy.
announcer:
Welcome to Consider the Constitution, the podcast that cuts through the noise and provides insight into constitutional issues that directly affect every American. Hosted by Dr. Katie Crawford-Lackey, and featuring interviews with constitutional scholars, policy and subject matter experts, heritage professionals and legal practitioners, we examine the rights and responsibilities of citizenship. Consider the Constitution is brought to you by The Robert H. Smith Center for the Constitution at James Madison's Montpelier.
Dr. Katie Crawford-Lackey:
Hello and welcome back to Consider the Constitution. I'm your host, Dr. Katie Crawford-Lackey, director of The Robert H. Smith Center for the Constitution at James Madison's Montpelier. In previous episodes, we discussed the origins of the US Constitution and what our founding documents said when it was signed in September, 1787 at the conclusion of the constitutional convention. We learned from past guest speakers that the Constitution at this point did not address individual rights. It included seven articles that established the structure of federal government with power balanced between three branches that defined the relationship between the federal government and the states, and that outlined the process of amending the Constitution.
Today, we're going to explore Article III of the Constitution, which established the judicial branch. We are joined today by Dr. Lauren Bell. She has a PhD in Political Science and her scholarship runs across all branches of the US federal government and the state governments and even comparative government study of other countries. Dr. Bell is the James L. Miller Professor of Political Science at Randolph Macon College. She's also a former American Political Science Association Congressional fellow, and to today's topic, she is a former fellow at the United States Supreme Court.
We truly don't have enough podcast time to describe her four books and many articles in scholarly journals, but if you'll allow me to pick a couple of highlights, her latest book published in 2022 is entitled The U.S. Congress: A Simulation for Students which perhaps is not surprising given her many awards for teaching excellence. Lauren, welcome to Consider the Constitution.
Dr. Lauren Bell:
Thank you so much for having me, Katie. It's really nice to be here.
Dr. Katie Crawford-Lackey:
To start off our conversation, what are some of the important points about Article III that we should know?
Dr. Lauren Bell:
I'd like to start when I talk about Article III by pointing out how short it is relative to the other articles that establish institutions of our federal government. Unlike Article I, which is really extensive in terms of outlining the powers of Congress and Article II, which articulates in pretty significant detail what the role of the president of the United States is, Article III is incredibly short. It establishes one supreme court and such inferior courts as Congress shall ordain and create.
It establishes that the Supreme Court will have two types of jurisdiction, original jurisdiction, which means that the court can hear a case for the first time and appellate jurisdiction, which means that the court can hear cases that come to it from other courts below it.
Beyond that, there is very little said about who will serve on the court, what their credentials ought to be. We do know that judges or justices in Article III courts serve terms of good behavior or what we traditionally think of as lifetime terms and that they cannot have their compensation reduced while they're serving in office. Both of those are intended to promote an independent federal judiciary.
Dr. Katie Crawford-Lackey:
And is there anything we should know in regard to the federal courts and that relationship with the state courts?
Dr. Lauren Bell:
Yes, absolutely. I should mention that under modern practice, the federal courts are divided into three separate tiers of courts, three levels of courts. So at the lowest level we have US district courts. There are trial courts. They are the courts that typically hear federal cases for the first time. The exception of course, are those cases that have to go to the Supreme Court under its original jurisdiction.
At the middle level then are appellate courts, they are the first line of appeals. They don't engage in fact finding the way the district courts do. They're looking at whether procedure is followed and whether outcomes were reasonably related to the facts.
Then you get to the Supreme Court at the highest level, and so if somebody peels a case from the US District Courts, it goes to the appellate court level and then onto the Supreme Court.
Now, on the state court side of things, many states have structured their judicial branches similarly. There will be some low level trial courts. In Virginia, for example, we talk about general district courts, but there are also, even in many states, courts that are lower than that, things we might think of at small claims court or traffic courts set up to decide really specific kinds of questions, but those are still trial courts effectively. Then every state has some kind of appellate court level, and every state has some kind of court of last resort, so we typically also think about state courts as having sort of three levels of courts.
The one thing that I should say about state courts, it's interesting when I talk to students and they say, well, tell us about state courts. What I like to point out to them is it depends on the state. Every single state structures their judicial branch somewhat differently, so even though structurally they might look similar, they have different names. They have courts that do different things. Texas, for example, has two courts of last resort, one for criminal cases and one for civil cases. So states have a lot more ability to do innovative and different things with their court system, but many states have structured their courts to look similar to the federal courts. The last point I'll make is that the state courts of last resort, those decisions can also be appealed to the US Supreme Court.
Dr. Katie Crawford-Lackey:
You describe a pretty complex structure in terms of what the courts look like, federal, state level. Is it fair to say though that in 1787 when the delegates are meeting to draft the constitution, that they're more concerned with defining the powers of the executive branch and the legislative branch versus the judicial branch?
Dr. Lauren Bell:
Yes, that is completely fair to say. The delegates to the convention were trying to correct the deficiencies of the Articles of Confederation. Under the articles, there was a pretty impotent legislative branch. There was no executive branch. There were courts, but they existed at the state level, and of course, we had had colonial courts dating back to the colonial era. At the convention itself, then the framers were really focused on how do we remedy the problems of the legislative branch and how do we create an executive branch at the federal level that isn't going to approximate the king who we just fought a war to break away from. The courts weren't an afterthought, but they weren't top of mind in quite the same way for the delegates to the convention. They didn't spend nearly as much time discussing them, and frankly, there was some debate over whether or not we even needed to have federal courts.
Dr. Katie Crawford-Lackey:
It's interesting to consider the judicial branch in reference to James Madison because as many of our listeners likely know, Madison is a real driving force behind the constitutional convention. And not only is he partaking in drafting the founding document, he's kind of shaping the branches of government intellectually through that process. But then he goes on eventually to be a participant when he is Secretary of State under Thomas Jefferson and eventually as president of the United States from 1809 to 1817. What can you tell us about Madison's thoughts on the judiciary earlier in his career when he's drafting the constitution and if and how this changes over time as he serves as Secretary of State and eventually president?
Dr. Lauren Bell:
That's a really great question. We talk a lot about Madison in terms of being the father of the constitution because of the Virginia plan. Like anyone who's ever had to run a meeting knows or who's attended a meeting, if you can get control of the agenda, you can often influence the outcomes, and Madison is no different. And so when he comes to the convention, he comes with an outline for the new government for what will become the constitution. Now, he's not ignoring the judicial branch, right? When I say that this was to some extent an afterthought or less important to the delegates, to the convention, I don't mean to say that it wasn't important at all, but there was, as I said, a question about do we need a federal judiciary? There's no body of federal law. The state courts are operating to resolve state level disputes.
So it's unclear what a federal judiciary would do, and initially Madison proposes what he calls a council of revision. We'll have an executive, a president and will have a judicial branch, but what we think of as judicial review will be carried out by a council of revision, and that is before laws passed by Congress will take effect the president will look at them and will be joined by members of the judiciary, and they'll decide if these laws can move forward. So judicial review for Madison doesn't happen in the courts, it happens separately before legislation is actually enacted.
Well, if that's the case, then you might say to yourself, well, what's the role of the courts? And Madison had an answer for that. In section nine of the Virginia plan, he comes back and he says, the courts will actually resolve certain kinds of disputes, and these are things like piracy on the high seas and sort of significant national questions involving the government, but it won't necessarily be that the court's job is to resolve disputes about legislation, and he was certainly not anticipating that the court would be resolving individual disputes. He was not anticipating there would be a role for the federal courts in resolving those kinds of very specific individualized cases. It was all about issues that might confront the national government having the court be able to adjudicate those.
Dr. Katie Crawford-Lackey:
One of the most significant Supreme Court decisions is made while Madison is Secretary of State and he actually has a role in this case. I'm referring to the Marbury v. Madison case. Can you tell us about the details of the case and why it was so significant?
Dr. Lauren Bell:
Marbury versus Madison, in my view, is one of the most brilliant decisions ever issued by the US Supreme Court. Madison does play a role. The background, what gets us to that case is the election of 1800, and so from 1789 until 1800, actually 1801, the Federalists had effectively been in charge of the national government, but they lose the presidential election in 1800. We know Thomas Jefferson is poised to take over in 1801. And John Adams and the Federalist Congress are very concerned that what they view as the progress they've made over those first 11 years of governing is going to be dismantled by politicians who represented more of the anti-Federalists approach to governing, who were afraid of a strong central government.
So what the Federalists do in the lame duck session of Congress following the election of 1800 is they enact the Judiciary Act of 1801. We call it the Midnight Judges Act, because it's literally at the 11th hour as Congress is getting ready to adjourn that they create 16 New Circuit Court Judgeships and 42 new Justice of the Peace positions. And of course, these new positions have no one to fill them. So the Federalists are going to, as their outgoing parting shots, get to fill these positions with federalist oriented judges. This is how they intend to get around the arrival of the Democratic Jefferson administration and the Democratic Congress.
It's important to recognize that the Secretary of State at the time that the Adams administration is doing this is John Marshall. We know John Marshall as the great Chief Justice. He's the fourth Chief Justice of the United States, and in fact, it's his fault that we end up with Marbury versus Madison. Once the Senate had approved the Adams nominations for these new Circuit Court judgeships and justice of the peace positions, it was Marshall's job to make sure that those commissions were signed, sealed, and delivered to the people who were supposed to receive them.
Well, he takes care of the first two. He has President Adams signed them. He affixes the presidential seal, and then I like to say he leaves them in the equivalent of his outbox. His thinking is, well, my successor will just take care of it. All we got to do is deliver these to folks. They're done. He leaves them. The Jefferson administration takes over. James Madison is Jefferson's Secretary of State. Madison finds these commissions signed and sealed, but sitting on his desk and he says to his friend, Thomas Jefferson, "What should I do with these?" Well, Jefferson gives the answer that we all would give in the same kind of political situation. Jefferson says, "Don't deliver them." So Madison says, okay, and they don't deliver the commissions.
One of the individuals who was slated to receive a commission as Justice of the Peace was William Marbury. Marbury sues Madison and sues under a provision of the Judiciary Act of 1789 that allowed the Supreme Court to issue what are called writs of mandamus. Mandamus, mandate, they're orders from the court directing somebody to do something. So Marbury asked the court to issue a writ of mandamus to James Madison to compel him to deliver his commission and the commissions of the others who didn't receive them.
When the case gets to the Supreme Court, now, John Marshall is Chief Justice. Again, John Marshall, the same John Marshall who was responsible for the fact that we are hearing this case, and Marshall has a problem because there are three questions that the court points out that are at issue. The first is whether Marbury is entitled to his commission. The second is whether if he was entitled to it since he didn't get it, is he entitled to a remedy? And the third question is is the remedy, a writ of mandamus issued by the court? The court's pretty clear. Marbury is entitled to his commission. The President nominated him. The Senate confirmed him. The commission was signed, it was sealed. He had been commissioned.
Okay, well, he didn't get it. So is he entitled to a remedy? The court says, absolutely. He's entitled to a remedy. If the laws are to mean anything, then government cannot simply refuse to honor them. Marbury's absolutely entitled to a remedy. So great, those of us cheering for William Marbury think he's going to get his commission. But Marshall comes back to the third question and says, the thing is we can't issue the commission. We cannot issue a writ of mandamus because section 13 of the Judiciary Act of 1789, which gave us that power, said that it was a power we had under our original jurisdiction, but Congress is prohibited under Article III from tampering with original jurisdiction. Congress can regulate appellate jurisdiction, but Congress cannot regulate original jurisdiction. Therefore, section 13 is unconstitutional and we have no choice but to strike it down. So sorry, William Marbury, you were commissioned. You didn't get it, so you're entitled to a remedy, but we can't compel Secretary Madison to deliver you your commission.
Dr. Katie Crawford-Lackey:
So in addition to learning that we should all check our draft folders.
Dr. Lauren Bell:
Yes.
Dr. Katie Crawford-Lackey:
What is the big takeaway? Because this is a really complex decision. Why does this matter then but also now?
Dr. Lauren Bell:
Yeah, so this is an incredibly significant decision. And to explain why, I have to get a little bit of the genius of John Marshall here. The reason that Marshall didn't simply say to Madison, look, Marbury's commissioned, so he's entitled to receive it, since he didn't, he's entitled to a remedy. And look, Congress said, we can compel you to do this under section 13, so give him his commission, is because Marshall knew that if he said to Jefferson and Madison deliver the commissions, they just wouldn't do it. And if they didn't do it, what could John Marshall do about it? The court has no ability to enforce its own decisions. It has to rely on Congress and the President. And so Marshall recognized that if he said deliver the commission, nothing would happen and the power of the Supreme Court would be diminished even further than it already was.
It's worth noting that the court makes its first significant decision in a case called Chisholm v. Georgia in 1793, that Congress immediately overturns with the 11th amendment. So the court was not considered to be anything approaching co-equal, and Marshall knew that if he said deliver the commissions, the Jefferson administration would simply not act, and then the court would appear even more impotent than it already was perceived to be. So Marshall has to find a way to say, yes, Marbury was commissioned, but no, Jefferson and Madison, you don't have to deliver it to him. So he does it by striking down Section 13. It's the first formal use of the power of judicial review that we have documented happening by the US Supreme Court.
Now, a listener who is learning about this case for the first time might say, well, why didn't the Jefferson administration say to the court, you can't just claim the power of judicial review for yourself. You can't just declare that you can strike down acts of Congress. And the answer to that is if Jefferson objected, the only logical response would be, okay, then deliver the commission. But Madison and Jefferson absolutely don't want to deliver the commissions. They don't want to further entrench the Federalist viewpoint in the federal judiciary or elsewhere in the federal government. And so Marshall makes it impossible for the Jefferson administration to complain and effectively increases the power of the court.
So to your question about how does that affect us today, anytime the US Supreme Court hears a case and strikes down an act of Congress, an act of the state legislature, an act of an executive somewhere, the court is using the power of judicial review, which it claimed for itself in 1803 in Marbury versus Madison.
Dr. Katie Crawford-Lackey:
This is a really fascinating, not just legal case, a study of the different branches of government and kind of how they're negotiating power, but of personalities as well. And it sounds like the judicial branch really was struggling in terms of asserting its own independence as a branch in the early years of America.
Dr. Lauren Bell:
That's absolutely true. What a lot of Americans don't realize is that beautiful Supreme Court building that we see in Washington DC that's called the Marble Temple. That building did not exist until 1935. Up until then, the Supreme Court essentially had to rely on the Congress to provide it with space. So if you tore the US Capitol, you can see the old Supreme Court Chamber. You can also see the old Senate Chamber. The old Senate Chamber became the Supreme Court chambers when the Senate moved to its current location in the Capitol.
So you have a Supreme Court that is supposed to be an independent, that the judiciary is supposed to be independent, but the Supreme Court is a tenant in the US Capitol building. It's not simply that up until Marbury, the court was struggling to be treated with respect, it took another 130 years for the court to come into its own institutionally, to have a space that was its own. And I think that's a really important thing to think about. The Supreme Court we think of today with the amount of power that we think of it wielding and its ability to have influence over the laws, that's not necessarily the Supreme Court of the 19th and early 20th century.
Dr. Katie Crawford-Lackey:
I'm glad you mentioned that because the Supreme Court today, I mean, we think of it as really a decider for what laws, policies we have, which shape culture, which shape our experience as American citizens, and it sounds like in this moment, in 1803 with this court case, this is a very significant step and it's done with John Marshall. He messed up. He didn't deliver those commissions, but when confronted with this problem, he sees the solution as recognizing that the biggest win here is okay, the commissions won't be delivered. He won't have people of his preferred party in these positions that were created, but the power of the Supreme Court is amplified because he's just defined the Supreme Court's power to overturn and define law.
Dr. Lauren Bell:
Imagine if he had delivered the commissions and we don't ever get Marbury. I think it's likely that we would've had some other case that would've come along where the court would have taken the opportunity to kind of codify the principle of judicial review. We know from reading Federalist number 78 that Alexander Hamilton and the founders sort of assumed judicial review, so it's not written into the document, but there's a degree to which it's kind of like, well, yeah, but what else would courts do, right? If courts can't adjudicate disputes between laws or acts of government actors and the constitution, why would we have courts? So if Marbury hadn't happened, I'm confident that at some point something would've happened that would have been the catalyst for a similar ruling, at least where the court is striking down an act of Congress, not with all of the nuance and intrigue that accompanies Marbury. But if Marshall had delivered those commissions, we wouldn't have had Marbury versus Madison. And it's an interesting thought experiment to think about how the judicial branch might look different.
Dr. Katie Crawford-Lackey:
In discussing the power of the federal court during this conversation, I began thinking about cases decided within my own lifetime, just over the past several decades, and I'm struck by the number of recent landmark decisions that have been made. This includes right to intimate relations, right to abortion, right of enemy combatants to challenge detention, free exercise of religion, school, prayer, affirmative action. I could go on. The rulings have not only defined the law, but they influence our culture, societal norms, the ramifications also have not just national impact, but also global impact. Based on your work, your scholarship, can you talk a little bit about where the Supreme Court is at today and where you see it headed?
Dr. Lauren Bell:
Yeah. The court today, I think is in a bit of a tenuous place. You're absolutely correct that there are so many political, social and economic issues that end up in front of the court whose response not only affects our own government and our own experiences, but has a ripple effect out into the global community. In that sense, the court has come a tremendously long way from its pre Marbury era and from its pre 1930s working in the capitol building phase. At the same time, we know from looking at recent public opinion polling that the public's evaluation of the court right now is as low as it has maybe ever been.
If we go back to the early to mid 1990s, the court was enjoying approval ratings in the high 80 percents. Now the court is actually underwater in most polls, it's under 50% approval. And the other thing that's striking when you look at the polling data is the extent to which approval now depends on partisan identification, and that had not been the case up until about the last decade. That's problematic because if the court is not seen as being above party politics, the extent to which people are willing to abide by its rulings will be diminished.
Again, we go back to Federalist Number 78. The court has neither their purse nor the sword. It can't fund itself. It's dependent on Congress for appropriations to keep the lights on, and it also can't enforce its own decisions. On the one hand, yes, it's dependent on the executive branch or ultimately maybe Congress to pass laws that enforce Supreme Court decisions, but it's also dependent on the public's willingness to see the court as an authority and to say, okay, when the court speaks, that's the law. That's the ruling, we abide by it because the court has legitimacy. And I think the polling data is suggestive of a court that is now perceived in political terms, which I think suggests a loss of legitimacy.
In part, it's because the media focus on the big cases, so they are the abortion rights cases, the marriage equality cases, cases involving Americans with disabilities, things that have real impact on people, but because those are the only cases we see, what we don't see are all of the really technical legal cases. In fact, if you look at the current court, if you look at last year, last year was probably the most contentious term on the Supreme Court in recent memory. The most liberal justice on the court agreed with the most conservative justice on the court 60% of the time. I'm talking about Elena Kagan, who is perceived or considered to be most liberal, agreeing with Samuel Alito, who is perceived to be most conservative. They were in agreement on 60% of all decisions, and the numbers go up from there. There's nothing below 60%.
The vast majority of cases decided by the court are decided by large majorities. They're not controversial. There's not huge ideological distance between the justices, but I think where the court is now is the court is being perceived as being political. The media are, in part, to blame for that because why would you cover a technical bankruptcy case? Nobody cares about that. But I think that presents real challenges for the court. Certainly we know that the court has been intention internally over allegations of ethical lapses by the justices recently. There was a leak of the draft decision in the Dobbs v. Jackson Women's Health case last year. I think the court, as I said, is in a tenuous spot right now, and that's going to require some internal work by the Chief Justice and a commitment by the justices themselves to try to rebuild the public trust in the institution. I think until that happens, the court's facing something of a legitimacy problem right now.
Dr. Katie Crawford-Lackey:
This makes me think of an episode we recorded with Adam Belmar, who is communications expert and has experience with the executive branch. We spoke about the media and the messaging that we're getting, and you bring up a great point about we're kind of being directed, our attention is being directed at some of these really big cases, but we're not seeing a lot of the consensus that's going on behind the scenes. And you talk about some of the solutions that can be addressed in the justice system, it seems to me that it's also an opportunity for us as citizens to learn more about the judicial branch, how it operates, why it has the power it has, and what we as citizens can do, not just to know about what's going on, but to know how to navigate it and why it's significant as we move forward.
Dr. Lauren Bell:
I agree with you wholeheartedly. One of the things that I encourage people to do, and this can be challenging depending on the case, I encourage people to actually look at the decisions themselves rather than simply relying on the media reports. The vast majority of people are not lawyers. Supreme Court opinions are often written for attorneys, so I recognize that that can be challenging. But every case starts with what's called a syllabus. That's where the court offers a quick summary. Now, sometimes quick is like three pages, but those are in the cases that have hundreds of pages of opinion. But it's usually three to five paragraphs summarizing the issue, summarizing the way the court answered the question, and giving just enough information that a layperson can get the gist of the case without necessarily having to read the whole thing, or if they choose to want to read the whole thing, it gives them a roadmap for what they're going to read.
I'll just give you a quick anecdote for why I do this, why I encourage this for people. In 2012, the Supreme Court decided NFIB v. Sebelius, that's the Affordable Care Act case, and the world was waiting for that opinion to come down, and it's late June, and it's one of the last decisions that the court issues, and we all know it's coming because there's only one day left. So every major media network is staked outside the Supreme Court waiting for the Opinion. SCOTUSblog, one of my favorite sources of information about the courts is live blogging the opinion. And the way it works is that the court always announces its decisions from the bench, and so when the Chief Justice says, we're going to turn to NFIB v. Sebelius, simultaneously the Public Information Office releases the text of the decision.
Now, I'm not a communications expert, but what I know with a fair amount of certainty is that every reporter is clamoring to be the first to get that hard copy decision in their hands, and the first to call back to the newsroom and say, here's what the decision says. So I'm watching the live blog on my laptop. I'm also watching CNN on my TV screen, I'm sitting in my living room. And SCOTUSblog starts spelling it out, the individual mandate is not upheld under the Commerce clause, the individual mandate is upheld under the taxation clause. Meanwhile, CNN puts a massive headline up on the screen, individual mandate struck down. Because the reporter read the first part of the syllabus. The individual mandate is not upheld under the Commerce clause calls the newsroom and says they struck it down. But if you just kept reading a little further down, it says, the mandate is upheld as a tax.
And I use that to illustrate that even in the syllabus, even in that quick summary, you can get a really good sense of what the court has actually done. I am not kidding that that headline stayed up for 40 minutes. I was able to go to my laptop, open up CNN, screenshot it, and I use this all the time am I teaching now to make that point. It's not that the media are deliberately trying to mislead. I know there's a lot of concern about what we might call "fake news" or misinformation. It's that the imperatives of being a reporter in the 24 hour news cycle where you've got Twitter or sorry X, it's to be first. It's to get the information out there as quickly as possible. But Supreme Court decisions are complicated. They often address really difficult issues, and the court writes a lot to try to explain its decisions.
And so I would always say one of the things the public can do is not simply rely on the media reports. Increasingly, the reporters covering the court are not lawyers, so they're trying to do the best they can to make sense of the decision, but sometimes that leads to coverage that simply misrepresents what the court has done, and meanwhile, we're all over here being furious that the court has done something that they haven't even done. So I think you're absolutely right. We have a responsibility as citizens to inform ourselves. I think the more we learn about the courts and how they function and really what their role is, I think the more we can understand why they reach the decisions they reach. We don't always have to like them, but at least we can understand where they're coming from.
Dr. Katie Crawford-Lackey:
Thank you for sharing that example. It's important to note that yes, while some information on media platforms can be intentionally misleading, oftentimes there's not mal intention in it. And we make mistakes, as you said, these are very complex cases. A lot of reporters are not lawyers, neither are most of us, so trying to understand what is happening with these cases. Dr. Lauren Bell, it was an honor to have you join us on Consider the Constitution.
Dr. Lauren Bell:
This has been great.
Dr. Katie Crawford-Lackey:
And I want to thank everyone who's listening to this podcast, I hope you'll subscribe. Please share this show with your friends and family, and join us again in two weeks to hear our next episode of Consider the Constitution.