No doubt when a textual pretext was available for his reactionary opinions, 
Scalia would use it. He was also happy to use non-textual pretexts on other 
occasions, which is why he is a fraud.
-raghu.

This is circular reasoning without any substantiation.  This should not be 
complicated.  William Brennan, for example, was result oriented.  Brennan knew 
how he wanted to come out, and he did his best to come up with a reason for his 
opinion.  He had no predisposition judicial methodology that restrained his 
decision-making. Scalia is different – he has an explicit judicial methodology 
by which he can be judged.  There are four conceptual criticisms of Scalia: (1) 
textualism is impossible, because the text is always indeterminate, (2) 
textualism is possible, but the text should be trumped by higher criteria, such 
as democracy or evolving standards, (3) textualism is the correct methodology, 
but Scalia was not very good at it, and (4) textualism is the correct 
methodology, but Scalia would vary from it whenever textualism produced a 
result he did not like.

In serious legal circles, as opposed to the Pen-L list, the 4th criticism is 
the weakest, which is why Scalia received accolades from across the political 
spectrum.  It is exceedingly difficult to find a case where there is a 
consensus that Scalia reached a result that knowingly (or even unknowingly) 
varied from the obviously correct textualist answer.  You may not want to 
accept it, but Heller and Citizens United were textualist opinions consistent 
with his judicial methodology, so keep looking for an example that supports 
your opinion.

David Shemano
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