The "Unitary Executive", Part II
Picking up with the Question of Original Intent
One of the toughest parts of having to break up a column into multiple parts (other than just writing so much!) is figuring out how to link the two parts together. For example, when we ended Part I, we were discussing the question of original intent regarding the “unitary executive”. Alexander Hamilton, writing as Publius in The Federalist Papers, wrote that the Constitution explicitly provided that Presidents can only make appointments with the advice and consent of the Senate and then claimed that the same would apply to “displacements” (dismissals).
But he changed his mind (while working in the initial Washington administration, according to Chief Justice Taft in 1926) and, during the first session of Congress, in what has been dubbed the “Decision of 1789”, convinced Congress (after much debate) to not specify a method for dismissal of the heads of the Cabinet departments. In Hamilton’s opinion, Congress should assume that the wording of the Constitution gave all of the unspecified executive power to the President — thus, a “unitary executive”, because the President has all of the executive power and doesn’t share it with Congress, which means that Congress has no say over the Executive Branch of the U.S. government except for a few rigidly-specified duties such as “advice and consent” on executive appointments (where it does share executive power with the President).
Accordingly, Congressional attempts to create executive agencies that operate autonomously and independently of the President are unconstitutional, and we considered one example in Seila Law and took a glimpse of how that doctrine played into the decision in Trump v. U.S. But we also questioned whether Chief Justice Taft’s reliance on the Decision of 1789 actually reflected the “original intent’ of the Constitution.
But before returning to our main theme, which examines the application of the doctrines of originalism and textualism in this case, we should probably come back to the discussion of what exactly constitutes originalism.
Original Intent Original Public Meaning
When Robert Bork articulated the doctrine of originalism as a professor at Yale Law School, he postulated that it should be based on the original intent of a provision, and that, if such intent was determinable, it must prevail. To Professor Bork, this was almost a mechanical determination . . . when it was limited to theory. But when it was put into practice on actual real-world examples, practitioners and judges ran into issues like the Decision of 1789, where it really wasn’t possible to determine original intent. And so the formulation off the theory was changed. Instead of relying on original intent, originalism would rely upon original public meaning, which would include a clear contemporaneous application of the provision.
In many ways, this clears up the questions with regard to the Decision of 1789. The decision was issued only two years after the Constitution was drafted, so it was reasonably contemporaneous, and it even involved the two main participants in the drafting and documenting: Hamilton and Madison. In the Decision of 1789, they both rejected the position taken by Hamilton in the Federalist Papers and, from the legislative history and Hamilton’s notes, it is clear that they did so with full awareness of the likely meanings of each of the different options available to Congress at the time. So . . . if you take the originalist perspective, is the case closed after this revision of what “original” means?
Not quite.
First, the case Myers v. U.S. was decided 6-3 in 1926. If we can say that Chief Justice Taft and the majority took an originalist approach (before the theory was given that name) in deciding in favor of the “unitary executive”, we know that that approach didn’t survive FDR’s New Deal, since, when the unitary executive theory reappeared in the past thirty years, it was treated as a very controversial “innovation”. What happened?
Well, what happened was a 1935 case called Humphrey’s Executor v. United States. Humphrey was appointed to a seven-year term on the Federal Trade Commission (FTC) by President Coolidge and confirmed by the Senate in 1924, and he was reappointed to another seven-year term by President Hoover and again confirmed by the Senate in 1931. But, consistent with Myers, President Roosevelt asked Humphrey to resign from the FTC after he won the White House in November 1932 and was inaugurated in March 1933. Humphrey repeatedly refused, and then President Roosevelt fired him as of October that year. Humphrey insisted that Roosevelt did not have the power to do that and that he was still a member of the commission, and he sued the U.S. for his salary, which had been stopped — but he passed away in 1934, while the suit was ongoing, and the executor of his estate became the plaintiff.
Although three of the justices from Myers had left the Court since then, six justices remained: four from the majority and two from the dissent. However, Humphrey’s Executor was a unanimous decision in favor of Humphrey, written by one of the dissenters. And the court reached that conclusion without overturning Myers. Huh?
The opinion held that the FTC did not exercise any executive power, unlike the postmaster in Myers:
A postmaster is an executive officer restricted to the performance of executive functions. He is charged with no duty at all related to either the legislative or judicial power. The actual decision in the Myers case finds support in the theory that such an officer is merely one of the units in the executive department, and, hence, inherently subject to the exclusive and illimitable power of removal by the Chief Executive, whose subordinate and aid he is. Putting aside dicta, which may be followed if sufficiently persuasive but which are not controlling, the necessary reach of the decision goes far enough to include all purely executive officers. It goes no farther; much less does it include an officer who occupies no place in the executive department, and who exercises no part of the executive power vested by the Constitution in the President.
The Federal Trade Commission is an administrative body created by Congress to carry into effect legislative policies embodied in the statute in accordance with the legislative standard therein prescribed, and to perform other specified duties as a legislative or as a judicial aid. Such a body cannot in any proper sense be characterized as an arm or an eye of the executive. Its duties are performed without executive leave, and, in the contemplation of the statute, must be free from executive control.
Oh my goodness: it’s the acceptance of the administrative state! And so it was.
The “Snivel Service”
To recap: the Constitution established three branches in the U.S. government: Legislative (Article I), Executive (Article II). and Judicial (Article III). So how did SCOTUS in 1935 conclude that “an administrative body created by Congress to carry into effect [in other words, “execute”] legislative policies . . . cannot in any proper sense be characterized as an arm or an eye of the executive”?
Basically, for almost the first 100 years of America after the Constitution was adopted, especially after the election of the populist Andrew Jackson in 1828 and 1832, positions in the executive branch of American government were filled by use of the “spoils system” (“to the victor belong the spoils”): party loyalists who had been important in the party’s election triumph (including by contributing money or time) were hired at once, regardless of their competency. In part, that explained why American government deteriorated so much in the 1840s and 1850s.
And thus, there became a popular movement to have government jobs awarded on the basis of competency, by examination, not by political patronage. Because the Democrats were generally in power during the pre-war period (and thus controlled the patronage and wanted to keep it), the main sponsors of this effort were Republicans.
The advent of the Civil War in 1861 coincided with a Republican takeover of both the Presidency and Congress, which stalled the push for what was dubbed “civil service” legislation, because now the former champions of reform were distributing patronage to their supporters. But the blatant patronage during the Grant administration (1969-77) renewed that push. And President Hayes, who succeeded Grant in 1877 after a truly “corrupt bargain”, was a strong advocate to end the spoils system, but there were still enough Republicans who wanted to keep it (led by the most powerful behind-the-scenes Republican of all, NY senator Roscoe “Boss” Conkling, who controlled patronage at the New York Customs House and led the pro-patronage “Stalwart” faction of the party against the pro-reform “Half-Breeds”) that Hayes simply did not have the votes to do so. [Just by the nicknames used for the two factions, you can see how much more powerful Conkling’s faction was; Conkling famously referred to the proposed “civil service” as “snivel service” (which shows that silly but nasty nicknames did not originate with Donald Trump).]
But then, a battle in 1880 between three factions of the Republican Party over which faction would gain the power of the Presidency (and the patronage that could be handed out by Hayes’ successor) led to a stalemate, with the three candidates: ex-President Grant for the Stalwarts, Maine senator (and former Speaker of the House) James G. Blaine for the Half-Breeds, and Ohio Secretary of the Treasury (and ex-senator) John Sherman for the anti-Grant faction who were not Half-Breeds. After 34 votes, no candidate could gain a majority, but on the 35th vote, several voters defected from all three and voted for Sherman’s campaign manager, Ohio congressman (and incoming senator), former Union Major General, Civil War hero, prominent attorney, former preacher, and former president (called “principal” at the time) of Hiram College James A. Garfield. Although the Half-Breeds had not been willing to support Sherman, Garfield’s varied resumé drew them like moths to the flame, and on the very next ballot (the 36th), almost all of the anti-Grant delegates voted for Garfield, earning him the nomination and then the Presidency. [The Senate seat, to which Garfield had already been elected, was then given to Sherman.]
To placate the Stalwarts, Garfield chose a Stalwart, Chester A. Arthur, for his VP candidate, and he managed to win the election (and, to this day, he is the only sitting member of the House to win the Presidency). But Garfield was adamantly anti-patronage and introduced another civil service bill, which wasn’t going anywhere . . . until he was assassinated by an unstable lawyer (is there any other kind? - ed.), who was both delusional and a Stalwart-supporting patronage seeker, furious that Garfield had not given him the patronage position of a U.S. consulate in France. [To be honest, although the shooter shot Garfield twice and was sure he’d killed him, Garfield died eleven weeks after the shooting from an infection that he contracted because his doctors failed to take Joseph Lister’s relatively new germ theory of disease seriously; the sanitation revolution in medicine followed this, because his doctors did not believe he was going to die from his wounds — and he didn’t. However, although the assassin tried to claim that he was not guilty of murder for that reason, the jury convicted him anyway, and he was executed.]
Garfield’s murder by a patronage seeker energized the civil service bill that he had introduced, and the Pendleton Civil Service Reform Act was passed over (now ex-Senator) Conkling’s objections (because he resigned in an effort to stop President Garfield from taking away the New York Customs House from his control — and Garfield managed to stop the NY state senate from re-appointing him!) and signed into law by Conkling’s former ally President Arthur (a longtime supporter of the spoils system) in 1883.
Good Enough for Government Work
Originally, the Pendleton Act only applied to about 10% of federal government workers, and it required the selection of workers for some government positions to be done by a bipartisan board called the United States Civil Service Commission based on results on competitive examinations. Once hired, those workers could not be demoted or dismissed for political reasons.
Over time, each administration wanted to put more of its patronage workers under civil service protection, so they could not be demoted or fired by the next administration, to make room for that administration’s own patronage hires. That actually had certain advantages, in terms of creating a permanent body of bureaucrats in the executive branch and of discouraging future disappointed patronage seekers from assassinating any future presidents. This growth became a key plank of the progressive movement, which greatly expanded civil service protections under President Wilson.
But for purposes of this discussion, the main thing that the growth of the civil service in the federal government did was create a view — in the minds of both the workers themselves and the rest of the public — that these non-patronage workers were no longer part of the executive branch but rather belonged to an “administrative branch”. That attitude underlies Humphrey’s Executor, which explains how the Supreme Court in 1935 could rule that the Federal Trade Commission was not part of the executive branch and thus not under the power of the unitary executive.
Although the idea of a professional bureaucracy goes back over 2,000 years in China, and almost that far back in India, it really didn’t make its way into Europe until the European powers started trying to colonize places like China and India in the last 18th century — about the same time that the U.S. was declaring its independence and writing its Constitution. And after the Civil War, many Americans became enthusiastic supporters. One of them was a young American Ph.D working at his first teaching job at Bryn Mawr College (although destined for bigger things), who published an essay entitled “The Study of Administration” in 1886. In this essay, 29-year-old Woodrow Wilson envisioned a state-run system, what might in a few short years be referred to as “communism” (emphasis added):
Where government once might follow the whims of a [royal] court, it must now follow the views of a nation. And those views are steadily widening to new conceptions of state duty; so that, at the same time that the functions of government are every day becoming more complex and difficult, they are also vastly multiplying in number. Administration is everywhere putting its hands to new undertakings. The utility, cheapness, and success of the government’s postal service, for instance, point towards the early establishment of governmental control of the telegraph system. Or, even if our government is not to follow the lead of the governments of Europe in buying or building both telegraph and railroad lines, no one can doubt that in some way it must make itself master of masterful corporations. The creation of national commissioners of railroads, in addition to the older state commissions, involves a very important and delicate extension of administrative functions. Whatever hold of authority state or federal governments are to take upon corporations, there must follow cares and responsibilities which will require not a little wisdom, knowledge, and experience. Such things must be studied in order to be well done. And these, as I have said, are only a few of the doors which are being opened to offices of government. The idea of the state and the consequent ideal of its duty are undergoing noteworthy change; and “the idea of the state is the conscience of administration.” Seeing every day new things which the state ought to do, the next thing is to see clearly how it ought to do them.
Like progressives in generations to follow, Wilson looked for inspiration to Europe:
But where has this science grown up? Surely not on this side the sea. Not much impartial scientific method is to be discerned in our administrative practices. The poisonous atmosphere of city government, the crooked secrets of state administration, the confusion, sinecurism, and corruption ever and again discovered in the bureaux at Washington forbid us to believe that any clear conceptions of what constitutes good administration are as yet very widely current in the United States. No; American writers have hitherto taken no very important part in the advancement of this science. It has found its doctors in Europe. It is not of our making; it is a foreign science, speaking very little of the language of English or American principle. It employs only foreign tongues; it utters none but what are to our minds alien ideas. Its aims, its examples, its conditions, are almost exclusively grounded in the histories of foreign races, in the precedents of foreign systems, in the lessons of foreign revolutions. It has been developed by French and German professors, and is consequently in all parts adapted to the needs of a compact state, and made to fit highly centralized forms of government; whereas, to answer our purposes, it must be adapted, not to a simple and compact, but to a complex and multiform state, and made to fit highly decentralized forms of government. If we would employ it, we must Americanize it, and that not formally, in language merely, but radically, in thought, principle, and aim as well. It must learn our constitutions by heart; must get the bureaucratic fever out of its veins; must inhale much free American air.
Of course, one of the problems of implementing a system that was developed for “highly centralized forms of government” is that, without careful oversight, implementing it will influence American government to become more centralized. Anyone for the idea of a “deep state”? No? Well, look closer.
If an explanation be sought why a science manifestly so susceptible of being made useful to all governments alike should have received attention first in Europe, where government has long been a monopoly, rather than in England or the United States, where government has long been a common franchise, the reason will doubtless be found to be twofold: first, that in Europe, just because government was independent of popular assent, there was more governing to be done; and, second, that the desire to keep government a monopoly made the monopolists interested in discovering the least irritating means of governing. They were, besides, few enough to adopt means promptly.
Now, if this were a class instead of a column, I might ask the class to consider Wilson’s second reason here and evaluate whether it makes sense. Is there any reason to think that an administrative bureaucracy is “less irritating” than other forms of government?
But which government does Wilson most admire? Why, the most bureaucratic of all, naturally — and one led by a philosopher-king.
Such was the case in Prussia, for instance, where administration has been most studied and most nearly perfected. Frederic the Great, stern and masterful as was his rule, still sincerely professed to regard himself as only the chief servant of the state, to consider his great office a public trust; and it was he who, building upon the foundations laid by his father, began to organize the public service of Prussia as in very earnest a service of the public. His no less absolute successor, Frederic William III, under the inspiration of Stein, again, in his turn, advanced the work still further, planning many of the broader structural features which give firmness and form to Prussian administration to-day. Almost the whole of the admirable system has been developed by kingly initiative.
Wilson gives a half-hearted warning about taking this imitation of Prussia too seriously, but we can decide from the direction that his “innovations” in this regard took the country whether he actually meant it:
Of course all reasonable preference would declare for this English and American course of politics rather than for that of any European country. We should not like to have had Prussia’s history for the sake of having Prussia’s administrative skill; and Prussia’s particular system of administration would quite suffocate us. It is better to be untrained and free than to be servile and systematic. Still there is no denying that it would be better yet to be both free in spirit and proficient in practice. It is this even more reasonable preference which impels us to discover what there may be to hinder or delay us in naturalizing this much-to-be-desired science of administration.
In fact, applying these ideas to the U.S. ended up destroying a critical feedback loop that kept government from getting too far off track. In the patronage-laden American government of the 19th century, bad service by government led people to complain to their elected representatives. If the service was too bad, the elected representatives were replaced, to see if new representatives (and the new patronage employees that they hired) could put systems in place that were more competent or provided better service.
But in the administrative state version of America, government exists to provide more government, not to serve the people. Government workers have powerful unions, which, combined with civil service, eliminate them almost entirely from popular sentiment — which is why we now have a saying in America, “close enough for government work”. That is not a statement that is applied to a job well done. And then came Luévano v. Campbell, a 1981 case in which the federal government signed a consent decree that eliminated the use of examinations for civil service positions due to their possible discriminatory effect in hiring practices, which eliminated the entire justification for the use of civil service (to get the “best people” for the jobs that needed doing) in the first place!
Without any sort of objective criteria for hiring, hiring practices are little different than they were prior to 1883, except that the workers cannot be replaced at will. Is it any wonder that “government work” has fallen to such a low standard?
Isolating executive branch workers from control of the President as part of the “unitary executive” made a great change, and it’s questionable whether it has been a change for the better. But progressives would disagree; they would claim that the president is generally limited to “for-cause” removal, as in the words of this retired Yale Law professor:
The president’s responsibility under Article II is to see that the laws are faithfully executed. The standard forms of for-cause removal provide that an officer may be removed only for “inefficiency, neglect of duty, or malfeasance.” Conduct of this sort, of course, interferes with faithful execution of the law. Removal of an officer on these grounds, thus, is consistent with the president’s constitutional responsibility. Removal on other grounds, for example, that the officer has angered the president because his or her testimony before Congress embarrassed the president or the administration, would seem unconnected to the president’s executive authority under the Constitution.
But how do you reconcile this limitation with Article II, Section 1 of the Constitution, which, as a reminder, reads:
The executive Power shall be vested in a President of the United States of America.
Of course, you don’t. In the view of progressives, if the Constitution conflicts with some imperative that will advance progressive goals, then the Constitution must be wrong — and instead of amending it, we’ll just find a way to ignore the provision, as in Humphrey’s Executor.
Interestingly, in Seila Law, the current Supreme Court did not overturn Humphrey’s Executor, but it did limit it to its facts. Practically, what this means is that the existing cases that cite Humphrey’s Executor are still valid, but outside of those cases, it is no longer good law.
A Structural Argument Against the Unitary Executive?
In addition to the arguments presented above against the unitary executive, there is one other structural argument, made by (among others) progressives, purposivists, and pragmatists. Instead of differentiating the “administrative branch” from the executive branch, as Humphrey’s Executor did, this argument contends that there can be executive power located outside the President within the executive branch: for example, in federal department heads or in special prosecutors such as Leon Jaworski. See, for example, this excerpt from the “Opinions Clause” in Article II, Section 2:
[The President] may require the Opinion, in writing, of the principal Officer in each of the executive Departments, upon any Subject relating to the Duties of their respective Offices[.]
Does this imply that there are separate duties that are the responsibilities of the “principal officers” (i.e., Cabinet) that are separate from the President — or is it just a statement that these “principal officers” are, in fact, NOT separate and must answer to the President? I wish that I could make a good argument for the former view, but it seems to me that the latter view is so obviously correct that the argument has little to commend it in my hands. However, a progressive might view it differently . . . and if anyone would like to take on the task of writing a progressive argument for this viewpoint, please by my guest.
But . . . The Political Argument
Because the “unitary executive” is such a broad subject that touches on so many areas, we’ve really gone all around the block in these columns. We’ll come back to the “administrative branch” discussions in the future, but it’s instructive that we’ve had to look at it twice in two discussions about SCOTUS cases decided in the October 2023 term. I really hadn’t wanted to get into it here, but you can’t talk about the unitary executive without discussing why it existed at the time of Myers but didn’t exist at the time of Seila Law, and that means Humphrey’s Executor, for better or worse (OK, worse).
But there is one other argument that has to be made with regard to the unitary executive: a political one. The political argument is much more straightforward that Humphrey’s Executor: it is simply a fact that centralization of executive power under the executive is a pathway that can produce more authoritarian results and may even be a defining characteristic of autocracy, as argued by a progressive law professor in this 2021 law review article:
In all of these [authoritarian] countries, authoritarian leaders secured legislation or constitutional amendments establishing effective head-of-state control over key bureaucracies that usually enjoy substantial independence in a well-functioning democracy, such as the prosecution service, the electoral commission, and the media authority. Autocrats use this power to shield their supporters from prosecution while persecuting political opponents, to tilt the electoral playing field in favor of the ruling party, and to shrink the public space for debate; thus, severely impairing democracy and the rule of law.
On the one hand, the U.S. survived over 110 years of a unitary executive without becoming a dictatorship or becoming dysfunctional due to corruption. But there was corruption, and in some cases there was quite a bit of it. And the progressives pushed for a bureaucracy because, in their view, it was a key element in getting to a less corrupt system.
However, applying the textualist-originalist view: in a democratic society, the creation of a new federal structure, amending or replacing the one created by the Constitution, should be done through constitutional amendment, not judicial fiat. “Living constoitutuionalism”, which was the dominant method of Constitutional interpretation being taught when I took my first law class (as a senior in high school, taught by a licensed attorney who was working full-time as a high-school teacher), evolved into purposivism: the idea that the Constitution in a living document that gets transformed to take into account the changes in the world and the structure of American life and does not have a meaning that is fixed in time since the drafting (or amending) of the Constitution. This (now renamed judicial pragmatism) is no longer the dominant legal theory; even Justice Jackson said, during her confirmation hearing in 2021, that “we’re all originalists now”. Yet to some extent, all legal and judicial interpretation of text needs to take into account the changes that have been made since the time of drafting, because things that were illegal in 1789 are not legal just because they can be done through newer technology.
For example, the Fourth Amendment, which blocks “unreasonable search and seizure”, was written at a time when agents of the state would have to invade your home to do that. But now, the government can conduct surveillance using means as varied as wiretaps, drone overflights, and even Trojan spyware. Yet the Fourth Amendment should still apply to those methods, just as it did to methods in use in 1789. Similarly, at the time of the Second Amendment, rifles were huge and bulky, and every one was handmade; mass production of firearms didn’t begin until Eli Whitney developed a system of interchangeable parts (and learned how to deal with manufacturing variance) during the Jefferson administration.
Originalism versus Pragmatism
For example, in Kyllo v. United States (2001), the U.S. Department of the Interior received a tip that a man was growing marijuana inside of his home in Oregon. In response, two agents from the department stationed a forward-looking infrared (FLIR) device in a parked car across the street from his home, which detected an unusual amount of heat radiation coming from the house. They also scanned other homes in the neighborhood, which did not show the same pattern. Based on this evidence, the Interior agents were able to get a search warrant for the house, and they did indeed find a marijuana growing operation using halide heat lamps. In a 5-4 SCOTUS decision, the FLIR data was held to be gathered in violation of the Fourth Amendment, because the FLIR data was gathered without a warrant. At the time, there were only two originalists on SCOTUS, Scalia and Thomas, and both voted with the majority, with Scalia writing the majority opinion, beginning with the basic definition of the case:
This case presents the question whether the use of a thermal-imaging device aimed at a private home from a public street to detect relative amounts of heat within the home constitutes a "search" within the meaning of the Fourth Amendment.
And the opinion noted the development of Fourth Amendment law, which had been linked to common-law trespass by SCOTUS until 1961. In this case, though, SCOTUS differentiated between visual surveillance of a private home from the street, which has traditionally been lawful, and electronic surveillance, which the court concluded was step too far, because it violates the expectation of privacy, especially privacy within your own home, that was the reason for the Fourth Amendment.
The question we confront today is what limits there are upon this power of technology to shrink the realm of guaranteed privacy.
Is this ruling consistent with the original public meaning of the Fourth Amendment? Well, obviously FLIR technology wasn’t invented at the time . . . or for about 200 years later. But the idea that the Fourth Amendment was intended to protect privacy in your own home is certainly consistent with the original public meaning.
However, this ruling is also consistent with pragmatism. Can originalism and pragmatism lead to the same result? Despite commentators who might argue that “no band-fide originalist” would believe that was possible, here is such an example, as the originalists Scalia and Thomas were joined by the pragmatists Breyer, Ginsburg, and Souter in the majority.
But that agreement on an interpretive question would never take place on a structural question. There are a number of subtle and not-so-subtle differences between different originalists and textualists, but I think it is completely safe to say that no originalist or textualist, no matter what variant of originalism or textualism that person followed, would agree that the federal courts could recognize a FOURTH branch of the federal government — an administrative branch, separate from the executive branch — without a constitutional amendment having been ratified first.
And that’s the crux of the matter: after SCOTUS had been so willing to take on the persona of the wise progressive philosopher-kings willing to make new law for the good of the nation in the Brennan years, progressives find it unsatisfying to go through the hard slog of ratifying constitutional amendments . . . and we’ve seen another example of this with the Biden-Harris court “reform” proposal, where the administration waives its hands and the constitutional language that federal judges “shall hold their Offices during good Behavior” (Article III, Section 1) goes away, and justices can be retired from the Supreme Court after 18 years without a constitutional amendment.
But, if either Biden or Harris had been at all competent as lawyers, they would know better. President Garfield and his law partner were co-counsel on an 1861 case that they actually won at the Supreme Court; judging from this proposal, President Biden and VP Harris would be hard-pressed to try anything harder than DUIs or vagrancies.
But that’s all for another day. Unfortunately, in trying to wrap this up, I’ve gone on for about 5,500 words. My apologies for the length and digressions, but at least I hope these pieces helped you to understand the complex legal issues that always are oversimplified by the mainstream media, who can’t afford to go on for 10,000 words over two articles about them!
But I can. Whether that’s a good thing or a bad thing is up to you. And the only thing I’m sure about is that next week’s columns will be shorter.
Be seeing you.