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Geoffrey R. Stone

Geoffrey R. Stone

Posted: May 30, 2009 08:15 PM

Sonia Sotomayor and the Hypocrisy of "Conservative" Critics


The May 30, 2009, New York Times contains two interesting articles about Sonia Sotomayor. One deals with her views of affirmative action, the other with her views of campaign finance regulation. According to these articles, Judge Sotomayor has been supportive of both policies. What this means in terms of her predicted behavior as a Justice of the Supreme Court is that she will tend to uphold the constitutionality of both policies. The articles report that conservative critics of Judge Sotomayor have begun to attack her for her positions on these issues because, by doing so, she is allegedly making inappropriate policy judgments rather than applying the law in a cautious and respectful manner.

This criticism reveals the inconsistency and, dare I say, hypocrisy of the contemporary conservative stance on constitutional interpretation. Conservatives insist that their heroes - Justices Rehnquist, Roberts, Scalia, Thomas and Alito - are judicial "passivists," rather than judicial "activists," who "strictly construe the Constitution," do not substitute their own views for those of the Framers, and generally defer to the judgments of the democratically-elected branches of the government. Most fundamentally, these conservative Justices do not use the power of judicial review (the power to declare laws unconstitutional) to smuggle their own policy preferences into their interpretations of the Constitution. That vice, they say, is the vice of liberal activists.

Now, let us consider the debate about affirmative action and campaign finance regulation. What does it mean to say that Judge Sotomayor is "supportive" of affirmative action and campaign finance regulation? It does not mean that Judge Sotomayor would use the power of judicial review to require affirmative action or campaign finance regulation. That is not the issue. What it does mean is that she would be inclined to uphold the power of the democratically-elected branches of government to adopt those policies if they choose to do so. This is not judicial activism, but judicial passivism. It is not free-wheeling interpretation to impose her own views on the nation, but strict construction of the Constitution that takes a modest rather than an aggressive view of judicial power. It is precisely the judicial methodology that conservatives say they admire.

What the conservatives commentators really want in a Justice with respect to these issues is not judicial passivism but judicial activism. What they want is not strict construction, but free-wheeling, activist interpretation. What they want is a Justice who will hold unconstitutional programs of affirmative action and campaign finance regulation, which is exactly what they've gotten from Justices Rehnquist, Roberts, Scalia, Thomas and Alito. What they want is conservative activism - the aggressive use of judicial power in order to smuggle conservative political views into the interpretation of the Constitution.

Consider affirmative action. The Equal Protection Clause of the Fourteenth Amendment provides that "No State shall deny to any person the equal protection of the laws." What does this mean? It does not mean that all persons must be treated alike in all circumstances. That would be absurd. For example, citizens can vote, aliens cannot; eighteen-year-olds can drive, fourteen-year-olds cannot; lawyers can practice law, doctors cannot; and so on. What is clear from the history of the adoption of the Equal Protection Clause, which was enacted shortly after the Civil War, is that its Framers intended it primarily to protect African-Americans from continued oppression.

But the Equal Protection Clause doesn't expressly apply only to African-Americans. So the inevitable question is: Who else does it protect? Over the years, the Supreme Court has held that the Equal Protection Clause also protects other groups who have been historically discriminated against, such as women, illegitimate children, and ethnic minorities. The key question in the affirmative action debate is whether laws designed to benefit racial and ethnic minorities and women are unconstitutional because they disadvantage whites and men. Put differently, are whites and men like blacks and women for purposes of the Equal Protection Clause?

The passivist, strict constructionist, originalist answer must be: No. If states want to engage in affirmative action, such programs do not violate the central meaning of the Equal Protection Clause, and they do not violate the intent of its Framers, who never envisioned affirmative action. Nonetheless, Justices Rehnquist, Roberts, Scalia, Thomas and Alito have consistently held affirmative action unconstitutional. Whatever else one might say about those judgments, they do not reflect what are supposed to be "conservative" principles of constitutional interpretation. They represent conservative judicial activism, plain and simple.

Similarly, on the issue of campaign finance regulation, the First Amendment provides that "Congress shall make no law abridging the freedom of speech." Campaign finance legislation limits the amount that wealthy individuals and corporations can spend in order to influence the political process. The goal is to reduce the corrupting influence of money on political candidates and officeholders and to create a greater sense of "one person, one voice" in the political process. Think of a presidential debate in which time was not allocated equally, but was sold in ten-minute segments to the highest bidder.

Does a regulation that limits the amount individuals and corporations can spend in the political process violate the First Amendment? The passivist, originalist, strict constructionist view must be: No. But Justices Rehnquist, Roberts, Scalia, Thomas and Alito consistently say: Yes. Protecting the interests of wealthy individuals and corporations, they invariably hold that such regulations violate the freedom of speech. Whatever else one might say about those judgments, they do not reflect what are supposed to be "conservative" principles of constitutional interpretation. They represent conservative judicial activism, plain and simple.

I don't mean here to say that affirmative action and campaign finance regulation should be constitutional or unconstitutional. (My own view is that the former generally is constitutional while the latter generally is not.) My point, rather, is that the conservative commentators and critics have to be held accountable for their inconsistency and cynicism. If they truly believe in conservative judicial principles, then they should be delighted with Judge Sotomayor's apparent views on affirmative action and campaign finance regulation, for those views reflect precisely the interpretative principles the conservatives say they admire. And, at the same time, they should be furious with Justices Rehnquist, Roberts, Scalia, Thomas and Alito for departing from those principles in order to impose conservative political values on the nation in the guise of constitutional interpretation.

 
 
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04:46 PM on 06/02/2009
When Sotomayor held other political positions she was under the influenced politics of the positions she held, there could be a myriad of influences to any given situation such as the firefighter discrimination example. She may have made the choices she did as the lesser of multiple evils and choices such as the mentioned cost of litigation to take another position. By sitting on the very highest court in the land she theoretically has no politically influenced agendas, her job is to rule in an unbiased manner as to constitutionality alone. I don't understand how anyone can drift so far away from equal protections granted to everyone regardles of race, religion, or sex as happens with affirmative actions. The very nature of recognizing any group by sex or race so as to offer any preferential status is going to negate and render harm to the group not recognized and favored. Eliminating affirmative actions of any type is the only way to assure truly equal treatment between everyone.
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smiz
01:11 PM on 06/02/2009
I think it is about time we had a Slavic-American woman on the Supreme Court.
12:03 PM on 06/02/2009
It is time to be very clear and unapologetically honest. If a white Republican male said the things she has said, he would be run right out on a rail. Period. To deny this is to be completely unrealistic and dishonest. So that leaves us with one question: does anyone who has made such comments deserve to be a Supreme Court Justice? This is all that matters and the answer is an obvious no. NEVER.
11:02 AM on 06/07/2009
It is time to be very clear and unapologetically honest. If a sock_puppet says anything, we laugh. When will you sit on the Supreme Court, my Friend?
NEVER
01:40 PM on 06/07/2009
But, but, but . . . a sitting Supreme said just such similar things, with nary a response from the Censors . . . it was not even noticed, much less commented on.

He talked about how he couldn't help but think of his immigrant ancestors when dealing with certain matters before him. I think it was Alito, though I wouldn't bet my life on it.

Double Standards at Work. . . hmmmmm?
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bighat
Truth as I see it
12:23 AM on 06/02/2009
It does not mean that Judge Sotomayor would use the power of judicial review to require affirmative action or campaign finance regulation. That is not the issue. What it does mean is that she would be inclined to uphold the power of the democratically-elected branches of government to adopt those policies if they choose to do so.

I disagree with your statement. The supreme court is supposed to decide if the laws passed by democratically-elected branches of our govt are constitutional. The big case is the firefighters of New haven Conn. On a firefighter promotion test, no blacks passed the test, the city, in hindsight, decided the test must be biased. No consideration given as to if the city invalidated the test because of possible lawsuits by NAACP and the ACLU. Did they have the money to fight. Would the US given the city a grant to fight the lawsuit. If the city decided to fight a lawsuit would the city be seen as fighting for justice and the best firefighter or biased against blacks. Opportunity should be equal. Not changed because someone fails the test. Now if some points out questions on this test for promotion had answers that only white males would know than that would be different. Judge Sotomayor decided the test was biased.
07:51 PM on 06/01/2009
"The key question in the affirmative action debate is whether laws designed to benefit racial and ethnic minorities and women are unconstitutional because they disadvantage whites and men. Put differently, are whites and men like blacks and women for purposes of the Equal Protection Clause?"
There is so much wrong with this article that I barely knew where to start but anyway the above will do for now. The arrogant assumption here is that those who wrote the constitution shared the ubiquitous victim mentality (with all it's inverse racism and bigotry!) and assumptions of today's radically feminised democrats. Has it not occurred to you that an INDIVIDUAL is not a 'class' nor is an individual responsible for the projected 'crimes' alleged against his or her class. Furthermore the 'pursuit of happiness' is an INDIVIDUAL pursuit - there are practically endless clues that the constitution was not written to put group identity before human rights butn that each human no matter their colour or creed etc is worthy of equal protection.
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1dogs2
10:17 PM on 06/01/2009
Have you ever read the 14th Amendment? Do you know when it was ratified? Do you know what its purpose was? Don't know much, do you?
04:26 PM on 06/01/2009
Author asks: "Put differently, are whites and men like blacks and women for purposes of the Equal Protection Clause? The passivist, strict constructionist, originalist answer must be: No."

Okay, try this: "Put differently, are blacks and women like whites and men for purposes of the Equal Protection Clause?" Hmmm. I guess his answer to that would be Yes.

Equal is equal. And the Equal Protection Clause today tells us that people who were slaves one day ago should today have equal protection under the law. That's the strict and correct construction of that portion of the amendment. And the expansion of application to other groups is a recent (last 50 years) manifestation.

Also, thanks to the Fourteenth Amendment, people can no longer be insulted by their slave owners insisting that they be counted as one full person for purposes of determining representation for their states.
05:01 PM on 06/01/2009
Another way to put paragraph 3 is that the Equal Protection Clause was treated (correctly) as dead wood for almost 90 years.
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04:17 PM on 06/01/2009
if you want to know what Scalia means by original intent consider his opining that the 8th amendment only restricts the use of torture as punishment. apparently the authors of the bill of rights felt we could do anything we wanted to individuals who are still presumed innocent and the 5th amendment was also only intended to protect the already convicted.
04:06 PM on 06/01/2009
"Activist judges" is just another way of saying "judges who don't vote the way I want them to."
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marecek
What has always made the state a hell on earth has
03:07 AM on 06/02/2009
Sometimes the most profound truths can be encapsulated in a single phrase. Roberto2201 has done so in this case. Bravo, sir!
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cvwilson
03:45 PM on 06/01/2009
Mr. Stone did not even mention the recent Supreme Court decision that overturned 200+ years of settled opinion on the Second Amendment. Declaring gun ownership to be an individual right instead of the collective right of a state militia. Conservative judicial activism at its finest.
03:03 PM on 06/01/2009
Obviously, the GOP, is not interested in the finer points of law as regards Sotomayor. They simply want to block anything that Obama does. Period. If Obama picked her that is reason enough for them to hate her and to fabricate reasons to tear her down.
Knowing this, when Obama picked her, she had to be clean as new fallen snow. But a lack of dirt in a person's background has never stopped the corrupt pols in DC or over at FOX News; they just make up something juicy. That is something they are really good at!
02:35 PM on 06/01/2009
Ms. Soto may have friends in Lapoza, but hat doesn't excuse that she is a racist, queen of reverse discrimination, is reverse discrimination legal in the US? Just think if Ms. Soto was white and the blacks scored highest but not promoted and she ruled the same way, hahahahahahahahahahaaha

Does affirmative action still apply to everything? Sould the lower performers be in charge?
If thats the case, we'll soon be trillions in debt and owned by China
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cvwilson
03:41 PM on 06/01/2009
Being trillions of dollars in debt and owned by China is something for which you need to thank Reagan and the Bushs and their borrow and spend economic policies. Thanks also needs to be given to a destructive (if not nihilistic) conservative governing philosophy that has dominated political thinking for the last 30 years. Read Thomas Frank's "The Wrecking Crew", very enlightening.
05:03 PM on 06/01/2009
Based on debt versus GDP, Reagan and Bush inflicted small paper cuts. Obama cut it off at the wrists.
06:56 PM on 06/01/2009
One of these days, people like you may want to get your facts straight. The city of New Haven threw out the test results. The non-promoted firefighters sued the city and lost, the lower court ruled against the firefighters and the circuit court affirmed. Judge Sotomayor along with 2 other judges wrote a brief missive that said they affirmed the lower court.
I realize that you are just parroting what talk radio has told you to think, but you are wrong in your depiction of the case.
Facts, kid, they matter.
01:51 PM on 06/01/2009
Mr. Stone,
Affirmative action is giving a special advantage to one group over another so by definition it violates the equal protection clause. Therefore, knocking down affirmative action laws as unconstitutional IS strict construction.
On your 2nd point, remember that, as you quoted in your article the constitution says, "Congress shall make no law abridging the freedom of speech." So how is the court not allowing congress to make such a law anything but strict construction?
02:36 PM on 06/01/2009
sorry, justadmitit, Affirmative action is far more complex than a sound bite. you ought to look into it before carroling an opinion like that. what the good judge was upholding was that the existing affirmative action plan was constitutional, as evidenced by the prior supreme court rulings. her decision, and that of the other judges, was that the claimant's arguement that their constitutional rights had been violated had no foundation in law. Fine. but if we are going to change the existing 6 court-approved guidlines for affirmative action programs the lower courts have to allow these cases to move forward to the Supreme Court. Judging for the plaintiff would not have changed the law and would not stand up on appeal.
this case was not actually about afirmative action per se, it was about wether or not the firemen's rights had been violated. they had not because the government agency that adopted the affirmative action plan was bound by it. the city/state/org is free to adopt another plan or dismiss the plan all together, but they would also have to be ready for the legal challenges and there just isn't enough money to take on too many battles at once.
like I said, there's more to this than a sound bite and it is not a good case for determining sotomayor's position on affirmative action.
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1dogs2
02:50 PM on 06/01/2009
Reading comprehension and a capacity to follow, much less counter, an argument are not your long suits, are they?
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1dogs2
01:14 PM on 06/01/2009
Bravo once again, Prof. Stone. I would go a step farther: not only is the conservative justices' claim to be "strict constructionists" intellectually dishonest, but it is also a smoke-screen intended to conceal their concerted effort to undermine long-established legal principles for the purpose of changing the political landscape of this country. I was still in law school when I discovered the penchant of Justices Rhenquist and Scalia for burying delayed-trigger time bombs in their opinions -- i.e., little pieces of dicta, unremarkable in their original context, which they would then assert in later opinions were binding precedent. You can't get much more dishonest than that. Unless, of course, you look at the per curiam opinion in Bush v. Gore, joined by Justices Rhenquist, Scalia and Thomas, and compare the "rationale" in that case to their previous opinions on the Equal Protection Clause.
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middleoftheroad
01:12 PM on 06/01/2009
Is it out of line to wonder why she has been over turned so many times. She will probably be over turned by the SC just as she takes a seat on it. In response to HER statements, is it out of line to ask how she feels about open borders, Drivers licenses for illegals, Amnesty, etc? And some of you guys forget how the Dems act when a Republican President has a nomination. Democratic senators say some ludicrous things and play character assassination constantly.
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1dogs2
04:26 PM on 06/01/2009
Yes, it would be "out of line to wonder why she has been over turned so many times," since she has been overruled exactly three times out of the hundreds of cases she has ruled on. Justice Alito was overruled or his dissent explicitly disapproved by the SC in the same number of cases, though he had been a judge for a far shorter time and had ruled on far fewer cases, yet those who are now running this silly argument against Judge Sotomayor's confirmation had no problem with Alito's reversal rate. Nor did any Democratic Senator.

If the SC reverses the ruling in the New Haven firemen's case, it will simply illustrate Prof. Stone's point about conservative "activist" justices on the SC, since the appellate court decision was entirely consistent with the governing case law.

And, yes, it is out of line to ask "how she feels" about issues that have not yet reached the SC but are likely to do so during her tenure since cases must be decided on their facts, not hypotheticals, as Alito and Roberts repeatedly said during their confirmation hearings.

In the absence of a single example to illustrate your last sentence, it is impossible to reply.
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marecek
What has always made the state a hell on earth has
02:55 AM on 06/02/2009
No, it is not out of line to ask questions about the nominee's record: what else should we look at, if not that? What I do object to, however, is the use of "statistics" to distort a nominee's record when the person disseminating said "statistics" is generally uninformed about how the federal judiciary works, so that they have no basis upon which to draw any valid conclusions from the statistics. This is not baseball or basketball, where we can assess quality by hits per at-bats or scores per shot. Those shouting to the mountaintops that Sotomayor was overturned 3 out of 6 times, completely ignor the fact that Alito was overturned 4 out of 4 times. Am I trying to say that we should approve her because Alito is worse? By no means. I just mean that we should beware of people who selective cite statistics. As for how the federal judiciary works. First, the US Supreme Court gets about 8000 requests per year for review and reviews only about 80 (as in 1 percent). So nobody is citing statistics about the Sotomayor cases which the SCOTUS did not review (did the Justices thus approve?). Also, SCOTUS generally reviews federal appellate only when they wish to CHANGE the line of decisions developing there - so SCOTUS review is inherently stacked towards overturning decisions. This brief comment should be enough to indicate that the "statistic" you are citing, standing alone, tells us NOTHING about whether Sotomayor should be confirmed.
12:11 PM on 06/01/2009
Saying the other side wants activist judges is hypocrisy in and of itself. Of course each party wants judges favorable to their side - always have and always will. By the way the example of the limitation on contributions being a limitation on free speech wasn't a particularly good example to pick of right wing activism since it can cut both ways. Obama's campaign contrbutions from Wall Street was 2 to 1 over McCain's from the same constituency. Wealthy people vote for Democrats too, not just Republicans. More hypocrisy.
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marecek
What has always made the state a hell on earth has
02:42 AM on 06/02/2009
I can't agree with you. Mr. Obama, like everyone else, must accept the rules as they are at present. Apparently you would insist that, if Obama or the Democrats, believe the rules on campaign finance are bad, then they should forego any benefits of those rules, thus leaving the Republicans a HUGE advantage, and letting them win all the elections. That is ridiculous. If I think the Democrats should work to abolish the Electoral College, does that mean they should never take part in another presidential election until it is abolished? No, it does not. It is not wrong to follow the rules that are presently in force (unless you are convinced they are not just bad rules, but immoral). We all have to live under the same laws. In any case, electoral rules have a special status, because they are the keys to attaining electoral office. Think again.