On the same day as Rand Paul’s celebrated filibuster against drone strikes last week, the Senate engaged in a less noticed but more typical form of delay and obstruction. A majority of the Senate voted to bring up the nomination of Caitlin Halligan to the Court of Appeals for the D.C. Circuit, but forty-one Republican Senators voted to prevent her from receiving consideration. This is the modern version of the filibuster, far more common than Paul’s thirteen-hour speech. Without sixty votes, it’s now virtually impossible to accomplish anything in the contemporary United States Senate.