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Judge H. Lee Sarokin

Judge H. Lee Sarokin

Posted: May 22, 2010 07:55 PM

Should There Be Judicial Nullification?

What's Your Reaction:

If Elena Kagan or any other nominee responded during a confirmation hearing that she would follow and enforce the law so long as she agreed with it, the nomination would end in a blink -- as it should. At every confirmation hearing assurances are extracted from nominees that they will follow the law and the Constitution and not substitute their own agenda. No one can quarrel with the concept that a judge has the duty to follow the law if it is constitutional and validly enacted. Both the oath of office and the principle of the separation of powers require it.

Which brings me to Judge Jack B. Weinstein, whom I consider to be a friend and one of the most respected judges in the country. Judge Weinstein "has gone to extraordinary lengths to challenge the strict punishments, issuing a series of rulings that directly attack the mandatory five-year prison sentence faced by defendants charged with receiving child pornography". The defendant in the subject case was a married man with 5 children. (N.Y. Times 5/22/10) In addition to the five year minimum, he faced a sentence of 11 to 14 years. Voicing his clear disapproval of child pornography, Judge Weinstein suggests that those who view the images do not pose the same threat to children as those who produce or sell it. I suppose he could have picked a less emotional crime to take a stand, such as drug users or possessors, but the issue raised is the same. Can a judge nullify or circumvent a law that is otherwise valid and constitutional?

A judge in Nazi Germany ordered the execution of persons who cracked jokes about Hitler, of a doctor who told his patient she was courageous for having a baby in the fifth year of the war (casting aspersions on the chances of a Nazi victory) and of a lawyer who wrote a letter consoling a relative of someone condemned by the court. When charged, the judge claimed that he was following the existing law. (Time, 7/14/67) Now before anyone goes ballistic, I am not suggesting in anyway that the laws about child pornography equate in any way to what was happening in Nazi Germany; so please don't go there. The laws against child pornography and punishment for their violation are appropriate and necessary. I mention Nazi judges only to demonstrate that there are some circumstances in which a judge may have the right or even the duty to refuse to follow the law. Is an unjust, disproportionate sentence in the eyes of the judge such a moment?

Mandatory minimums and three-strike laws have been a frequent thorn to the judiciary. They often result in outrageous sentences against persons who do not deserve them. The Second Circuit recently pointed out that the sentences required by legislation for looking at children being sexually abused sometime eclipse those for actually sexually abusing a child. (N.Y. Times 5/22/10) Judge Weinstein has decided to depart from the usual practice and advise juries in certain cases as to the mandatory minimum sentence that the defendant faces. Whether or not this tactic is upheld on appeal remains to be seen, but I suspect that Judge Weinstein, whose courageous and honorable goal is fairness in sentencing, seeks public awareness of the injustice of certain sentences, and if nothing else, he has accomplished that.

 
 
 
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04:40 AM on 05/25/2010
In summation, it appears that there is no instance where judicial nullification is permissible.

We have a right as citizens to coherent decisions from our judges.
07:32 PM on 05/24/2010
Judge Sarokin, if you went into a steakhouse for dinner and the waiter brought you a steak crawling with maggots, would you complain? A yes or no answer will do.

I would like those readers who would answer no to explain why they would not complain.

I've walked into the Tenth Circuit Cafe and District of Colorado Bistro, and have been served steaks crawling with maggots a dozen times. Don't you think that after a point, the health inspectors ought to be called in to shut the place down?

Through subsequent examination, you learn that the entire chain of legal Denny's routinely serves steaks replete with maggots. At what point do you conclude that none of these franchises are able to serve food fit for human consumption?

Judge Kozinski said it best: what our courts serve on a daily basis is "inedible sausage." This is a species of "judicial nullification" -- of not just a few admittedly unjust and senseless laws, but of the entire Bill of Rights. At what point should the alarm be sounded?
04:58 PM on 05/24/2010
[cont from below] Still, my favorite was the married judge who exposed himself in an airport men’s room Larry Craig-style, apparently while soliciting anonymous gay sex (he ‘got off’ -- because district attorneys try hard not to prosecute judges). He obviously had a wide judicial stance....

It is unsurprising that judicial scandals are so under-investigated, as judges are highly motivated to squelch reports of corruption -- which can hit them where they live. In connection with the Tampa, Florida scandal, which has claimed at least four judges (and may also claim whistle-blowing judge Greg Holder), Christopher Goffard reports:

"The unease extends even to judges untainted by scandal. . . . Some think [Holder’s] crusade has smeared every judge there. They blame him, as much as they blame Alvarez, for the jokes they still hear at cocktail parties, the arched eyebrow when they mention where they work. A judge? In Tampa? How interesting."

Christopher Goffard, “Judge Who Was Accuser Is Accused,†St. Petersburg Times, May 10, 2004.

Most complaints about judicial corruption are relegated to the Internet, as state enforcement mechanisms are essentially non-existent, and ‘self-enforcement schemes,’ even worse. Judicial corruption is almost certainly under-reported, says Florida State University professor Bruce Benson, on account of the institutional need to persuade the general public that the system ‘works’ -- even when it doesn’t. Bernard Cardinal Law can certainly sympathize….
04:55 PM on 05/24/2010
Appleblossom: "We can impeach a judge for failing to uphold the law as I am sure you know. Most of the time it is not an issue because the bad judges resign before that happens.

In most states, there are judicial commissions that can and do remove judges for failing to follow the law.

Willful refusal to accept that shows what little credibility you have."

When you proceed from an ignorance this invincible, you squander any credibility you have, AB. Take a few hours to educate yourself (e.g., http://www.knowyourcourts.com/FedJD/FedJD.htm (extensive collection of articles and actual examples); http://www.knowyourcourts.com/JDC/JDC.htm (specific to Colorado), so that you are not proceeding as a complete and blithering idiot.

While our federal system of self-discipline is completely dysfunctional, and impeachment "is a mere scarecrow" (Jefferson), some states are better than others; Day in and day out, Michigan’s judicial blotter is the most consistently amusing. One alcoholic judge recently insisted that he hadn’t been drinking when he managed to plow his SUV into a convenience store. Another got busted for lighting up a doobie at a Rolling Stones concert. Others include a judge who reportedly referred to himself as God, another caught fixing traffic tickets in exchange for sexual favors, and another suspended for lying to investigators about her love affair with an attorney now serving life in prison for murdering his wife. [cont]
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1murillo
Can't be neutral on a moving train - Zinn
03:32 PM on 05/24/2010
Q(boul): Court of equity or a court of law? Law.
Nothing is fair or equivalent. However, that doesn't mean judges should turn a blind eye to what they perceive is incorrect. There should be various forums, including the courts, where topics are discussed and decided upon.
04:06 PM on 05/24/2010
If we were starting with a clean slate, you could invest judges with that kind of authority. But we aren't, and our Founding Fathers were adamant that we should not do so. And while our public schools do a terrible job of teaching civics, their predecessors were amazing:

A. In some countries a single man makes the laws according to his own pleasure.
Q. What is such a government called?
A. A Despotism, or absolute monarchy: and the person who thus rules is a Despot, or absolute monarch.

Arthur Stansbury, Elementary Catechism On the Constitution of the United States 18-19 (Hilliard, Gray, 1828).

In modern-day America, we call him a federal judge.

Colonial judges understood and respected the limitations of their authority. Presided over by such notables as St. George Tucker, Kamper v. Hawkins, 3 Va. 19 (Va. 1793), was the state-law precursor to Marbury v. Madison. It was Judge Tucker’s view that the judge should never stray beyond the narrowly-circumscribed bounds of his office:

If the principles of our government have established the judiciary as a barrier against the possible usurpation, or abuse of power in the other departments, how easily may that principle be evaded by converting our courts into legislative, instead of constitutional tribunals?

To preserve this principle in its full vigour, it is necessary that the constitutional courts should all be restrained within those limits which the constitution itself seems to have assigned to them respectively."

Id.
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cliffstep
03:30 PM on 05/24/2010
Pardon my ignorance. This instance is about a law concerning the punishment phase. It would be a lot more problematic if the judge nullified on the basis of the underlying (is that the right word?) crime.
I wouldn't mind if a coupla judges nullified , say , drug law...but who , nellie!
I like some mandatory minimums - use of a firearm , say - but on balance like the notion that someone whose job is to judge does more than just preside.
04:37 PM on 05/24/2010
Ignorance is never a crime, as it can always be cured.

As much as we might like at first blush to have our judges do things, we don't have the power to give it to them, and we wouldn't give it to them if we really thought about it hard. The job of a judge, according to the Framers, was to preside -- Thomas Jefferson thought the perfect judge was a "mere machine." As Gibbon noted in his magnum opus on the fall of the Roman Empire (not an exact quote), the grant of discretion to judges was the beginning of tyranny.
12:38 PM on 05/25/2010
Can you list the names of the framers who said "the job of a judge is to preside"? I agree with much of what you say especially on judicial nullification but you are quessing about the intent of the framers. You may be guessing right. But it is a quess.
The grant of discretion to a judge is not the beginning of tyranny anymore than granting discretion to jurors is. Granting discretion to judges and juries is also the beginning of justice.
02:29 PM on 05/24/2010
Judge Sarokin (from down below): "I want to have an open forum and encourage participation, but no matter what the subject, Bouldergeist comments that all judges are "corrupt", "on the take" and are the same as "concentration camp commandants""

And when I have, I have presented a wealth of evidence to that effect. It is the evidence that you find problematic ... not my reasonable interpretation of it.

The Judge: "At every confirmation hearing assurances are extracted from nominees that they will follow the law and the Constitution and not substitute their own agenda. No one can quarrel with the concept that a judge has the duty to follow the law if it is constitutional and validly enacted. Both the oath of office and the principle of the separation of powers require it."

Your Honor, I would accept this as an axiom. But EVERY judge in the Tenth Circuit and District of Colorado (with the exception of John Kane) has flown a defiant middle finger in the face of Congress and the American people, in their repeated and willful refusal to follow law that is constitutional and validly enacted. I can cite an arresting array of pristine examples of same.

Veteran judges in the Third, Eighth, and Ninth Circuit have confirmed that the situation is similar in their Circuits, and dozens upon dozens of your colleagues have told us exactly how the crimes are committed. Everyone knows that it happens, and everyone else is guilty of misprision. [cont]
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02:17 PM on 05/24/2010
I think there are cases in which federal trial and appeals judges should "nullify" laws if their conscience demands it. Appeals courts can always overturn as a safeguard. This is is adjunct to that, but not directly on topic. Shouldn't Kagan's whole record as counsel to the president be considered in her nomination though, and if it should or is, shouldn't her record on rendition and torture opinions be made public just as Bush's legal team was over the torture issue. We are considering a candidate for the Supreme Court right now, which liberals wholly or substantially back that does not look substantially different than Bush's old counsels on this issue and that should be part of the debate in the senate.
04:20 PM on 05/24/2010
If our appellate courts actually did their jobs, I would be less frightened by that -- but to be honest, on average, federal appellate judges spend ten minutes per appeal in unpublished decisions. They freely admit that the work they do is pure carp. But there is a more compelling reason why they should not do so, a proposition supported by Chief Justice Marshall, Justices Chase and Story, St. George Tucker, Madison, and others.

In Kamper, Judge Tyler also apprehended the danger, in observing that "I will not in an extra-judicial manner assume the right to negative a law, for this would be as dangerous as the example before us." 3 Va. at 61 (opinion of Tyler, J., seriatim). And in the wake of Marbury v. Madison, Thomas
Jefferson cautioned that to anoint judges as the ultimate arbiters of constitutional questions was "a very dangerous doctrine indeed, and one which would place us under the despotism of an Oligarchy." Thomas Jefferson, Letter (to William C. Jarvis), Sept. 28, 1820, at 1.

As much as I want the right answer coming out of our courts, I am more interested in the right process; as Justice Douglas famously intoned, the Bill of Rights is about procedure.
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Judge H. Lee Sarokin
Retired after serving 17 years on the federal cour
04:48 PM on 05/24/2010
ghostpigeon - You raise a new and difficult issue. I am uncertain how I feel about the production of advice given to the President or any other client as relevant to judicial qualification. First it invades the privacy of the attorney/client privilege and might chill advice in the future. Secondly, I think it is unfair to equate a lawyer's representation with his or her own beliefs. A lawyer who vigorously defends an accused murderer does not necessarily believe in murder. On the other hand, if any nominee for the Supreme Court advocated or sought to justify torture or rendition as legal, I think it is something which should be disclosed. There may be other such subjects as well. I am ambivalent---probably would make a good topic for another post. Thanks
07:45 PM on 05/24/2010
I don't know why that would be a salient distinction. If the nominee advised to do something of questionable legality (I'm of the mind that no form of waterboarding can pass muster under the CAT), it either should be disclosed (as it has direct bearing upon the candidate's judgment and fitness) or should not (if the attorney-client relationship is deemed paramount). You can't pick and choose.
02:02 PM on 05/24/2010
Judge Sarokin (down below): "What makes this case a little different is that Judge Weinstein has not found the law unconstitutional or invalid. He has concluded that it is too harsh and unfair, but not apparently so much so to declare it unconstitutional. Can or should a judge refuse to enforce a law which he believes to be unjust and unfair?"

Another federal judge: "I'm not going to enforce the law saying that you can sue a judge in tort for committing felonies on the bench (the actual decision was coram non judice, thereby removing any form of judicial immunity; see, Bradley v. Fisher), because I'm a judge and I commit felonies on the bench all the time!" Okay, so it is not a direct quote, but it is a real case, and conveys the sum and substance of the opinion. You can even review the appellate briefs on-line at http://www.knowyourcourts.com/Smith/09-1003.htm.

With that background, I can answer that question emphatically: Not just no, but HELLNO! The judge's office is to interpret the law, not to rewrite it to suit his liking.

Just one of hundreds of cases out there where the judge used the Bill of Rights as a tamp.on.
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Appleblossom
02:11 PM on 05/24/2010
Really, I support people's right to free speech but you are just being rude. Your point has been made so go away.
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03:07 PM on 05/24/2010
Excuse me, but I don't think the post is particularly rude and last I checked rudeness was allowed under free speech though I don't think rudeness helps much. What did you find rude in the post?
03:12 PM on 05/24/2010
Obviously, it hasn't sunk in with you. That you don't perceive a valid comparison between the totalitarian regimes of Mao, Stalin, or Saddam Hussein and the federal judiciary appears to be due to the fact that you haven't really thought about it.

Let's discuss it in detail, shall we?

It is a simple concept, Apple: As Justice Frankfurter observed, the judge’s only legitimate task is “to ascertain the meaning of the words used by the legislature,†for to go beyond it, and rewrite a statute to his or her liking, is to “usurp a power our democracy has lodged in its elected legislature.†When a judge substitutes his personal preference for the law of the land, we cease to enjoy the benefits of the rule of law, and our judges become nothing more than a black-robed band of Ba'athists.

Do the math. If a judge can decide that you don't deserve the protections of the Fourteenth Amendment, do you have them? The Soviet Union had the same protections of speech and assembly -- on paper. But Soviet judges never enforced them -- always finding the "facts" Andrei Vyshinsky needed to hear -- and as such, they do not as a practical matter exist.

The government has an obligation to respect our rights, but judges are free to refuse sua sponte, and the government will not force them to do so. How is our situation any different than that of the unfortunate Soviet citizen?
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Intolerantcentrist
No thanks…I brought my own air.
12:33 PM on 05/24/2010
The creation of all laws, whether regulatory, criminal or constitutional, are legislative; i.e. political. It would be a conflict of the separation of powers for the judiciary to circumvent or modify such statutory or constitutional frameworks. At the same time, such judicial actions that are beyond the bounds of these constraints would be subject to the political forces that developed and maintain such laws. This is one of those places were judicial activism meets legislative activism. Not sure the court will win in this contest.
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dsws
No owning ideas. Limit only commercial use.
11:50 AM on 05/24/2010
Rule of law exists when there there are systematic limits on government power. Its opposite is the arbitrary exercise of power by individuals. Under rule of law, (1) the government can't do anything to you unless it's authorized by law to do so.

It's not enough to say that the government can't do anything to you unless you break a law, though. If you pass a statute forbidding breathing, and authorizing the dictator to enforce it with when and as he or she feels like, that's pure arbitrariness even though criterion (1) is met. You also need to satisfy rule (2): Rule (1) effectively and consistently limits the actions of government.

There's a corollary to (2): you have to be able to tell what the effect of a proposed law will be. Otherwise there may be some limitation but it's not consistent. That's where a judge's duty enters the picture. They have to rule so that their rulings will be as predictable as possible.

Of course, rule of law is not the only principle necessary to a just society, and rebellion is sometimes justified. But if someone uses their power as a judge to advance other principles at the expense of rule of law, they're not really acting as a judge.
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Judge H. Lee Sarokin
Retired after serving 17 years on the federal cour
01:10 PM on 05/24/2010
dsws - Very interesting analysis, but in this case the judge is not using his power "to advance other principles" but rather seeks to make the principle advanced----namely punishment for criminal conduct---fair. Should that make a difference?
01:28 PM on 05/24/2010
Is this a court of equity or a court of law?

In equity, we give judges latitude sufficient to arrive at the "right" result -- a real-life Judge Judy. In matters criminal, you are either found to have committed the crime to the requisite tolerance, or you are not. Constitutionally speaking, it's not the judge's call.

We're not designing a system of law from scratch. If we were doing so, the Judge's line of argument would carry considerable weight. For good or ill, the responsibility to ensure that the punishment fits the crime lies with the jury -- or would have, had the Imperial Judiciary not usurped this power.
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dsws
No owning ideas. Limit only commercial use.
04:19 PM on 05/24/2010
Fair punishment for (non-official) criminal conduct is another principle from ensuring that government power is systematically limited. It's the prosecution's job to try to ensure that criminal conduct is punished. The judge's primary responsibility -- as a judge -- is to ensure that it's done in accordance with law. Ensuring that the law is fair is the responsibility of all citizens, as participants in the legislative process, not of the judge as judge.

The judge also has a particular responsibility as a law-maker, though: case law is law. The judge's second responsibility, then, is to ensure that any case law made in the case is good. There are several criteria of good law. As I said, there's the corollary to rule (2): the law must be predictable. Precedent must not be overturned unless it conflicts with other precedent. Instead, it must be made obsolete by new legislation. Then there's rule (3): the language of the law must be powerful, i.e. capable of expressing anything the legislature chooses to express. As semanticists of the law, judges play a particularly prominent part in this. Rule (4) is that the language of law must be as easily comprehensible as possible, consistent with the higher-priority rules. Only after all of those are met, and fail to fully determine the outcome of a case, may a judge (as judge) attempt to insert into the semantics of the law a bias toward fair outcomes.
09:19 AM on 05/24/2010
The statements below lay down the foundation for the only constitutionally proper means of nullifying an unjust sentence. The judge, in his proper role as father-confessor and independent source of legal knowledge, informs the jury concerning the nature of the charge and the sentence that ties his hands, and confides that he believes that normal application of this statute would lead to an unjust result. The jury, armed with this information, makes the final call.

For example, take a situation that has happened in Colorado: federal prosecution of a person who is growing marijuana for his personal use, due to medical needs. Colorado has a statute on the books that authorizes this, but federal law is of course pre-eminent.

Judge Bob Sarokin advises the jury of its charge, and that they have a right to nullify the law if it yields an unjust result. They return a verdict of acquittal, even though every fact that matters was admitted by the defendant. The system works as the Framers intended.
10:28 AM on 05/24/2010
I'm all in favor of jury nullification but it ain't always a bowl of cherries. Bribe or intimidate one juror and the verdict changes. What does this historical babble about 'petit' juries mean? Does it refer to something like traffic court, US Grand juries or is it sometimes a reference to the juries of the ancient Athenians that ranged in size from 201 to 1501 jurors with majority verdicts? Could 101 jurors be bribed without it becoming public? How about 751? How about a randomly chosen 1501 member constitutional commission to decide constitutional questions?
10:35 AM on 05/24/2010
Shouldn't have said 'US Grand Juries' they are not in the historical context and they are big juries by petit standards.
10:56 AM on 05/24/2010
The argument is that it is easier to bribe or intimidate a judge than a juror chosen to decide a case. By way of example, Judge Nottingham was evidently taking bribes from litigants to finance his appetite for Elliot Spitzer-class hookers. Anyone who knew this owned his tail in court -- and a lot of well-connected lawyers who traveled in those circles knew.

The difference between a grand jury and a petit jury is that the former indicts, whereas the latter decides the case. The grand jury was supposed to be a check on prosecutorial authority but as one disgraced judge put it, a good prosecutor can indict a ham sandwich.
08:56 AM on 05/24/2010
When justice, rather than law, is paramount; nullification can be a powerful (if crude) tool.

The prospect of jury nullification provides a potential check against prosecutorial excess. Similarly, judge nullification of jury verdicts (if such is possible) provides a check against unjust jury nullification.
09:30 AM on 05/24/2010
In a criminal case, it can only work one way. If a jury acquits, that is the end of the matter.

In a civil case, the runaway jury is controlled by a judge's ability to enter a judgment non obstante veredicto (judgment notwithstanding the verdict). Problem is, this can be a way for the corrupt judge to play favorites (a representative example can be found here: http://www.westword.com/2007-12-13/news/blackburned/ ).

Judicial nullification would be less problematic if judges could be sued for misconduct on the bench, as it would disincentivize the corruption which happens on a regular basis in the District of Colorado.
lastpost
see biography
08:17 AM on 05/24/2010
“enforce the law so long as she agreed with itâ€
As opposed to, I knew it was wrong, I was simply following orders?

“No one can quarrel with the concept that a judge has the duty to follow the law if it is constitutional and validly enacted.â€
I do, your Honour. Since laws are devised by humanity. And are as such, subject to error. True justice constitutes the next level up. A height to which we may ever only aspire.

“The laws against child pornography and punishment for their violation are appropriate and necessary.â€
But are they addressing the problem? If not, then for how much longer must we unquestionably continue to thrash the same equine cadaver?

“sentences against persons who do not deserve themâ€
If we had a means of determining guilt without the role-play-games so beloved of lawyers, wouldn’t we use it? Well we have, and we haven’t seen fit to use it yet.
If other countries could present proven methods of decreasing incidents of recidivism, wouldn’t we investigate and adopt them. Well they have, but no one seems interested in importing them.
Isn’t it the case that the ultimate intention of law has been lost? To be replaced with a prime requirement to maintain the status quo.
09:22 AM on 05/24/2010
Judge Sarokin: "No one can quarrel with the concept that a judge has the duty to follow the law if it is constitutional and validly enacted.â€

I agree. Funny that the Judge can't bring himself to admit that it is wrong for a judge to sit in judgment of his own case. But that dig aside, nullification of unjust laws is the constitutional prerogative of the jury, and this has always been so since the English common law was devised.
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Rooster Coburn
Less Gov't + More Responsibility = A Better World
08:10 AM on 05/24/2010
Well, I support "Jury Nullification". http://fija.org/
08:56 AM on 05/24/2010
To me, all that matters is the Constitution, and its definition of the Article III power. Judge Weinstein wants the absolute power of the despot -- to be a black-robed JosephStalin. The framers had other ideas.

In the Federalist Papers, Alexander Hamilton referred to the federal judiciary as the weakest branch, The Federalist No. 78 (A. Hamilton), and with good cause: the colonial judge could scarcely blow his nose without a note from the jury foreman signed in triplicate. At common law, the ultimate power to decide both fact AND law resided with the jury; trial judges were mainly administrators, and sources of objective counsel:

[In] 1793 John Jay, sitting as chief justice of the United States, informed a civil jury that while the court usually determined the law and the jury found the facts, the jury nevertheless had "a right to take upon yourselves to judge of both, and to determine the law as well as the fact in controversy." "[B]oth objects," Jay concluded, "are lawfully, within your power of decision."

"The Jury and Consensus Government in Mid-Eighteenth-Century America," William Nelson, in The Bill of Rights: Original Meaning and Current Understanding (ed. Eugene W. Hickok, Jr., Univ. Press of Va. 1991), reprinted at http://www.constitution.org/jury/pj/nelson.htm (unpaginated).

Colonial judges knew their place, because colonial juries understood theirs. See e.g., Kamper v. Hawkins, 3 Va. 19 (Va. 1793) (state-law precursor to Marbury v. Madison).
09:00 AM on 05/24/2010
If the rationale for judges arrogating the power to decide the constitutionality of a statute is to ensure uniformity of decisions, and judicial review does not produce uniformity of decisions, then just maybe, we would be better off allowing juries to decide what is and what is not constitutional, as the Framers intended. As Thomas Jefferson explains, what they lack in raw legal skill, they more than make up for in integrity and impartiality:

"We all know that permanent judges acquire an esprit de corps; that, being known, they are liable to be tempted by bribery; that they are misled by favor, by relationship, by a spirit of party, by a devotion to the executive or legislative; that it is better to leave a cause to the decision of cross and pile than to that of a judge biased to one side; and that the opinion of twelve honest jurymen gives still a better hope of right than cross and pile does. It is left therefore, to the juries, if they think the permanent judges are under any bias whatever in any cause, to take on themselves to judge the law as well as the fact. They never exercise this power but when they suspect partiality in the judges; and by the exercise of this power they have been the firmest bulwarks of English liberty. "

Thomas Jefferson, Letter (to L’Abbe Arnoux), Jul. 19, 1789 at 2.