Petitioner
John Mistretta
Respondent
United States
Petitioner's Claim
That the Sentencing Reform Act of 1984 violated the constitutional separation-of-powers doctrine by establishing a Sentencing Commission of judges with "excessive legislative powers."
Chief Lawyer for Petitioner
Alan B. Morrison
Chief Lawyer for Respondent
Charles Fried, U.S. Solicitor General
Justices for the Court
Harry A. Blackmun (writing for the Court), William J. Brennan, Jr., Anthony M. Kennedy, Thurgood Marshall, Sandra Day O'Connor, William H. Rehnquist, JohnPaul Stevens, Byron R. White
Justices Dissenting
Antonin Scalia
Place
Washington, D.C.
Date of Decision
18 January 1989
Decision
The Constitution does not prevent Congress from appointing a body of expertswithin the judicial branch to develop guidelines for matters unique to theirarea of knowledge, making the Sentencing Reform Act valid.
Significance
Mistretta v. United States dealt with the separation-of-powers doctrine in the Constitution. In most of its cases involving separation of powers prior to Mistretta, the Court had tended to rule in favor of those who challenged statutes that threatened the principle of separation. This had beenthe case seven years before in 1982 when Northern Pipeline Co. v. Marathon Pipe Line Co. was decided and the trend was reversed. Previously the Court had struck down a 1978 law that had established a group of judges with wide-ranging authority in bankruptcy cases.
The Sentencing Reform Act Comes Under Challenge
"For almost a century," Justice Blackmun wrote for the Supreme Court in Mistretta v. United States, "the Federal Government employed in criminal cases a system of indeterminate sentencing." There were statutes addressing specific crimes, of course, but judges had considerable latitude in establishingsentences. Hand in hand with this system of indeterminate sentencing went another system: that of parole boards, who decided when a prisoner should be released from incarceration and placed under the supervision of a parole officer.
The idea behind this arrangement was an optimistic one--that the prison system could rehabilitate criminals and make them useful members of society. The system required that judges and parole officers work closely together, and each had broad discretionary powers within their realms. Under the Constitution,Congress had the power to establish sentences for federal crimes, but the legislative branch tended to defer to the judicial branch in the area of sentencing, as it assumed that judges knew more about a given case than did Congressmen in Washington.
Soon, however, problems began to arise from this arrangement. Indeterminate sentencing resulted in great disparities--relatively heavy sentences for lesser crimes, or the reverse, all depending upon the judge who reviewed the case.A further problem came from the fact that the prison and parole systems werenot rehabilitating criminals, but were recycling the same people again and again through a chain from crime to trial to prison to parole. As a result, in1958 Congress called for the creation of judicial councils to establish sentencing guidelines. Fifteen years later, in 1973, the United States Parole Board adopted a set of guidelines for the length of time a prisoner should be confined, and in 1976 Congress passed the Parole Commission and ReorganizationAct. Much greater reforms followed in 1984, with the passage of the legislation that would be challenged in Mistretta.
A Senate Report on the 1984 legislation cited two problems with the "outmodedrehabilitation model": disparity in sentencing, and prison terms whose length was made uncertain because parole boards too often intervened and shortenedthem. Therefore Congress passed the Sentencing Reform Act of 1984. The act rejected the rehabilitation model; it consolidated the sentencing functions ofjudges and parole boards by creating the United States Sentencing Commission; it established sentences of fixed length that could be shortened only by aprisoner's good behavior; it made the Sentencing Commission's guidelines binding on the courts, although it did give judges some discretion with regard tomitigating factors in a given offense; and it authorized limited appellate review of sentences. The act established further the Sentencing Commission asan independent entity operating within the judicial branch of government. Thecommission would consist of seven voting members, three of them federal judges chosen from a list of six recommended to the president by the Judicial Conference of the United States. No more than four members of the commission could belong to the same political party, and the attorney general (or his or her designee) would serve as an eighth, non-voting member of the commission. The commission was charged with developing sentencing guidelines, periodicallyreviewing and revising the guidelines it established, and reporting to Congress any amendments it made.
On 10 December 1987, John M. Mistretta was indicted, along with another defendant, in the U.S. District Court for the Western District of Missouri on three counts relating to a cocaine deal. Mistretta moved to have the Sentencing Commission's guidelines ruled unconstitutional, his claim being that the Sentencing Commission violated the separation of powers doctrine. Mistretta held that by creating the commission, Congress had established a judicial body withlegislative powers. The district court disagreed, ruling that the commissionwas in effect an executive agency, and that its guidelines were similar in structure to rules established by comparable entities. Nor was the act invalidbecause it required judges, whose powers are granted in Article III of the Constitution, to serve on the commission. Nonetheless, the court stated that its ruling does not imply a lack of "serious doubts about some parts of the Sentencing Guidelines and the legality of their anticipated operation."
Mistretta having plead guilty to the first of his three indictment counts, conspiracy and agreement to distribute cocaine, the federal prosecutor moved todismiss the other two counts. The motion was granted, and in accordance withcommission guidelines, Mistretta was sentenced to 18 months in prison to befollowed by three years of supervised release, along with a $1,000 fine and a$50 special assessment. He filed a notice of appeal in the Eighth Circuit, but both sides--Mistretta and the attorneys representing the United States--petitioned the Supreme Court to review the case before the circuit court gave its judgment. Rule 18 of the Court allowed petitioners to take such an extraordinary step if the issue to be decided was of "imperative public importance."The Court held that this was one of the situations, and agreed to review thecase, along with an ancillary legal action, United States v. Mistretta. The Sentencing Commission filed an amicus curiae brief urging affirmance, as did an attorney representing Joseph E. DiNova. Lawyers representingthe United States Senate and the National Association of Criminal Defense Lawyers also filed briefs.
"An Unusual Hybrid"
By an 8-1 vote, the Court upheld the Sentencing Guidelines. Congress had neither delegated "excessive legislative power" to the commission, nor had it violated the separation-of-powers principle by establishing the commission within the judicial branch, by requiring federal judges to serve on the commissionand share authority with non-judges, or by giving the president power to appoint and remove commission members. Nothing in the Constitution, the Court held, prohibited Congress
Justice Blackmun, writing for the majority, first addressed the delegation-of-powers issue, which Mistretta had raised with his charge that Congress had given the Committee excessive legislative authority. In this context, Blackmunquoted Chief Justice William Howard Taft, who wrote in the Court's opinion on Field v. Clark (1892): "In determining what [Congress] may do in seeking assistance from another branch, the extent and character of that assistance must be fixed according to common sense and the inherent necessities of the government co-ordination." Common sense in the present situation, the Court indicated, would dictate some delegation of power, particularly in "our increasingly complex society, replete with ever changing and more technical problems." Congress itself had established "the specific tool" that the commission was to use, the guidelines system, and while the Court could not "dispute [the] petitioner's contention that the Commission enjoys significant discretion in formulating guidelines," there was no basis in the Court's past rulingsto say that a delegation could not "exercise judgment in matters of policy."In fact, the highly technical and complex nature of the commission's task wasone that especially lent itself to delegation: since members of Congress were not likely to be authorities on sentencing laws, it was wise for them to work with people who were.
Justice Blackmun turned next to the separation of powers issue. President James Madison, often called "the master builder of the Constitution" for his central role in framing the document, had written that
Without these "means and motives," the United States could be in danger of becoming a dictatorship, and the Court had consistently upheld the separation doctrine. In cases specifically related to the judicial branch, the Court hadbeen wary of attempts to assign to judges tasks that other branches could more properly accomplish, and of laws that "threaten[ed] the institutional integrity of the Judicial Branch." In the present case, Mistretta held that Congress had on the one hand given too much authority to the judicial branch, by delegating to the commission legislative authority, and on the other hand had removed power from the judiciary by authorizing a member of the executive branch--the president--to appoint and dismiss commission members. With regard tothese claims, the Court considered the commission from three standpoints: its"location" in the judicial branch, its composition, and the power of the president over it.
The commission was "located in the judicial branch, but it was not a court, nor did it hold judicial power." It was, as Justice Blackmun observed, "a peculiar institution within the framework of our Government." Although Article III of the Constitution limited the work of the judiciary to "Cases" and "Controversies," exceptions were possible, as in a situation involving a commissiondelegated to establish guidelines specifically relevant to the judicial branch. Nor did the existence of the commission within the judicial branch in anyway threaten the power or integrity of the judiciary; given its lack of judicial power, there was no way that it could. As for its composition and Mistretta's challenge to its requirements that three federal judges serve on the commission and share their authority with non-judges, the Court admitted that "We find Congress' requirement of judicial service somewhat troublesome . . ."But "troublesome" did not equal "unconstitutional." Whereas the Constitutionspecifically prohibits legislators from serving in any other office during their term of service, it contained no such provisions for judges. Similarly,with regard to the president's power to appoint and remove members, it did not follow from this mere fact that the president therefore controlled the commission. Under the Constitution, the president has power to appoint many judges- -including those on the Supreme Court--but history has shown that judges by no means necessarily do the bidding of the executive who appointed them.
Thus, the Court held that, although the commission was "an unusual hybrid," it was constitutional. "Nor does our system of checked and balanced authority," concluded the Court, "prohibit Congress from calling upon the accumulated wisdom and experience of the Judicial Branch in creating policy on a matter uniquely within the ken of judges."
Dissent: "A Sort of Junior-Varsity Congress"
Justice Scalia dissented, writing, "because I can find no place within our constitutional system for an agency created by Congress to exercise no governmental power other than the making of laws." The problem with the commission, he held, was precisely its lack of judicial or executive powers. He was concerned that responsibility for making laws could be delegated to "experts" in agiven field-- people with no official accountability. "How tempting," he wrote,
Scalia particularly took issue with the Court's holding on the commission's location. The fact that Congress chose to locate the commission within the judicial branch, he suggested, was merely a trick of language, but it did not change the facts. In accordance with its ruling in Humphrey's Executor v. United States (1935), the Court should ask which of the three branches controlled the commission, as the answer would solve the question of its location. Citing his dissent in Morrison v. Olson (1988), which upheld a statute providing for an independent counsel to investigate members of the executive branch, Scalia held that the Court's present decision made its earlier ruling seem logical by comparison. The Court had already--wrongly, in his opinion-- authorized the creation of offices within the executive branch that werenot subject to ordinary standards of accountability; now, by extending that principle to the judicial branch, it had made a mistake "we will live to regret . . . Ignoring the Constitution's strict guidelines regarding separation ofpowers, Scalia concluded, the Court had in effect created "a new Branch altogether, a sort of junior-varsity Congress."
Impact
Although few would question the need for a system of sentencing guidelines, some observers were disturbed by the Court's rejection, in its Mistretta ruling, of strict separation-of-powers doctrine. Others, however, viewed the ruling as an example of flexibility on the part of the Court--a common-sense decision, as the Court itself had suggested. With Metropolitan Washington Airports Authority v. Citizens for the Abatement of Aircraft Noise (1991), the Court struck down the creation of a congressional review board with veto power over an interstate airport authority, holding that the statute in question violated the doctrine of separation.
Related Cases
Checks and Balances
The Constitution provides for the separation of powers and a system of checksand balances to prevent the rise of a single branch of government over the other two. Each branch--executive, legislative, and judicial--acts as a checkon and balances the power of the other two. The powers of the branches are mixed in such a way that no one branch is completely separable from the others.The framers of the Constitution designed a lock-and-alarm mechanism to prevent any faction or individual from "stealing" the government. Control of the executive branch, for instance, does not mean control of all executive functions, because the Senate must approve all presidential appointments of Cabinetofficers, judges, and ambassadors. Congress does not hold all legislative power; the president, through the exercise of the veto, can override the vote ofthe legislature in certain cases. Both the executive and the legislative branches can be overridden by a decision of the judiciary, whose members are appointed by the executive branch and approved by the legislative.
Sources
Bacon, Donald C., et al., eds. The Encyclopedia of the United States Congress New York: Simon & Schuster, 1995.
John Mistretta
Respondent
United States
Petitioner's Claim
That the Sentencing Reform Act of 1984 violated the constitutional separation-of-powers doctrine by establishing a Sentencing Commission of judges with "excessive legislative powers."
Chief Lawyer for Petitioner
Alan B. Morrison
Chief Lawyer for Respondent
Charles Fried, U.S. Solicitor General
Justices for the Court
Harry A. Blackmun (writing for the Court), William J. Brennan, Jr., Anthony M. Kennedy, Thurgood Marshall, Sandra Day O'Connor, William H. Rehnquist, JohnPaul Stevens, Byron R. White
Justices Dissenting
Antonin Scalia
Place
Washington, D.C.
Date of Decision
18 January 1989
Decision
The Constitution does not prevent Congress from appointing a body of expertswithin the judicial branch to develop guidelines for matters unique to theirarea of knowledge, making the Sentencing Reform Act valid.
Significance
Mistretta v. United States dealt with the separation-of-powers doctrine in the Constitution. In most of its cases involving separation of powers prior to Mistretta, the Court had tended to rule in favor of those who challenged statutes that threatened the principle of separation. This had beenthe case seven years before in 1982 when Northern Pipeline Co. v. Marathon Pipe Line Co. was decided and the trend was reversed. Previously the Court had struck down a 1978 law that had established a group of judges with wide-ranging authority in bankruptcy cases.
The Sentencing Reform Act Comes Under Challenge
"For almost a century," Justice Blackmun wrote for the Supreme Court in Mistretta v. United States, "the Federal Government employed in criminal cases a system of indeterminate sentencing." There were statutes addressing specific crimes, of course, but judges had considerable latitude in establishingsentences. Hand in hand with this system of indeterminate sentencing went another system: that of parole boards, who decided when a prisoner should be released from incarceration and placed under the supervision of a parole officer.
The idea behind this arrangement was an optimistic one--that the prison system could rehabilitate criminals and make them useful members of society. The system required that judges and parole officers work closely together, and each had broad discretionary powers within their realms. Under the Constitution,Congress had the power to establish sentences for federal crimes, but the legislative branch tended to defer to the judicial branch in the area of sentencing, as it assumed that judges knew more about a given case than did Congressmen in Washington.
Soon, however, problems began to arise from this arrangement. Indeterminate sentencing resulted in great disparities--relatively heavy sentences for lesser crimes, or the reverse, all depending upon the judge who reviewed the case.A further problem came from the fact that the prison and parole systems werenot rehabilitating criminals, but were recycling the same people again and again through a chain from crime to trial to prison to parole. As a result, in1958 Congress called for the creation of judicial councils to establish sentencing guidelines. Fifteen years later, in 1973, the United States Parole Board adopted a set of guidelines for the length of time a prisoner should be confined, and in 1976 Congress passed the Parole Commission and ReorganizationAct. Much greater reforms followed in 1984, with the passage of the legislation that would be challenged in Mistretta.
A Senate Report on the 1984 legislation cited two problems with the "outmodedrehabilitation model": disparity in sentencing, and prison terms whose length was made uncertain because parole boards too often intervened and shortenedthem. Therefore Congress passed the Sentencing Reform Act of 1984. The act rejected the rehabilitation model; it consolidated the sentencing functions ofjudges and parole boards by creating the United States Sentencing Commission; it established sentences of fixed length that could be shortened only by aprisoner's good behavior; it made the Sentencing Commission's guidelines binding on the courts, although it did give judges some discretion with regard tomitigating factors in a given offense; and it authorized limited appellate review of sentences. The act established further the Sentencing Commission asan independent entity operating within the judicial branch of government. Thecommission would consist of seven voting members, three of them federal judges chosen from a list of six recommended to the president by the Judicial Conference of the United States. No more than four members of the commission could belong to the same political party, and the attorney general (or his or her designee) would serve as an eighth, non-voting member of the commission. The commission was charged with developing sentencing guidelines, periodicallyreviewing and revising the guidelines it established, and reporting to Congress any amendments it made.
On 10 December 1987, John M. Mistretta was indicted, along with another defendant, in the U.S. District Court for the Western District of Missouri on three counts relating to a cocaine deal. Mistretta moved to have the Sentencing Commission's guidelines ruled unconstitutional, his claim being that the Sentencing Commission violated the separation of powers doctrine. Mistretta held that by creating the commission, Congress had established a judicial body withlegislative powers. The district court disagreed, ruling that the commissionwas in effect an executive agency, and that its guidelines were similar in structure to rules established by comparable entities. Nor was the act invalidbecause it required judges, whose powers are granted in Article III of the Constitution, to serve on the commission. Nonetheless, the court stated that its ruling does not imply a lack of "serious doubts about some parts of the Sentencing Guidelines and the legality of their anticipated operation."
Mistretta having plead guilty to the first of his three indictment counts, conspiracy and agreement to distribute cocaine, the federal prosecutor moved todismiss the other two counts. The motion was granted, and in accordance withcommission guidelines, Mistretta was sentenced to 18 months in prison to befollowed by three years of supervised release, along with a $1,000 fine and a$50 special assessment. He filed a notice of appeal in the Eighth Circuit, but both sides--Mistretta and the attorneys representing the United States--petitioned the Supreme Court to review the case before the circuit court gave its judgment. Rule 18 of the Court allowed petitioners to take such an extraordinary step if the issue to be decided was of "imperative public importance."The Court held that this was one of the situations, and agreed to review thecase, along with an ancillary legal action, United States v. Mistretta. The Sentencing Commission filed an amicus curiae brief urging affirmance, as did an attorney representing Joseph E. DiNova. Lawyers representingthe United States Senate and the National Association of Criminal Defense Lawyers also filed briefs.
"An Unusual Hybrid"
By an 8-1 vote, the Court upheld the Sentencing Guidelines. Congress had neither delegated "excessive legislative power" to the commission, nor had it violated the separation-of-powers principle by establishing the commission within the judicial branch, by requiring federal judges to serve on the commissionand share authority with non-judges, or by giving the president power to appoint and remove commission members. Nothing in the Constitution, the Court held, prohibited Congress
from delegating to an expert body withinthe Judicial Branch the intricate task of formulating sentencing guidelines consistent with such significant statutory discretion as is present here, norfrom calling upon the accumulated wisdom and experience of the Judicial Branch in creating policy on a matter uniquely within the ken of judges.A judge, the Court's ruling suggested, would best know the business of judges, and Congress was simply calling on the knowledge and experience of thecommission members.
Justice Blackmun, writing for the majority, first addressed the delegation-of-powers issue, which Mistretta had raised with his charge that Congress had given the Committee excessive legislative authority. In this context, Blackmunquoted Chief Justice William Howard Taft, who wrote in the Court's opinion on Field v. Clark (1892): "In determining what [Congress] may do in seeking assistance from another branch, the extent and character of that assistance must be fixed according to common sense and the inherent necessities of the government co-ordination." Common sense in the present situation, the Court indicated, would dictate some delegation of power, particularly in "our increasingly complex society, replete with ever changing and more technical problems." Congress itself had established "the specific tool" that the commission was to use, the guidelines system, and while the Court could not "dispute [the] petitioner's contention that the Commission enjoys significant discretion in formulating guidelines," there was no basis in the Court's past rulingsto say that a delegation could not "exercise judgment in matters of policy."In fact, the highly technical and complex nature of the commission's task wasone that especially lent itself to delegation: since members of Congress were not likely to be authorities on sentencing laws, it was wise for them to work with people who were.
Justice Blackmun turned next to the separation of powers issue. President James Madison, often called "the master builder of the Constitution" for his central role in framing the document, had written that
the greatestsecurity against a gradual concentration of the several powers in the same department, consists in giving to those who administer each department, the necessary constitutional means, and personal motives, to resist encroachments ofothers.
Without these "means and motives," the United States could be in danger of becoming a dictatorship, and the Court had consistently upheld the separation doctrine. In cases specifically related to the judicial branch, the Court hadbeen wary of attempts to assign to judges tasks that other branches could more properly accomplish, and of laws that "threaten[ed] the institutional integrity of the Judicial Branch." In the present case, Mistretta held that Congress had on the one hand given too much authority to the judicial branch, by delegating to the commission legislative authority, and on the other hand had removed power from the judiciary by authorizing a member of the executive branch--the president--to appoint and dismiss commission members. With regard tothese claims, the Court considered the commission from three standpoints: its"location" in the judicial branch, its composition, and the power of the president over it.
The commission was "located in the judicial branch, but it was not a court, nor did it hold judicial power." It was, as Justice Blackmun observed, "a peculiar institution within the framework of our Government." Although Article III of the Constitution limited the work of the judiciary to "Cases" and "Controversies," exceptions were possible, as in a situation involving a commissiondelegated to establish guidelines specifically relevant to the judicial branch. Nor did the existence of the commission within the judicial branch in anyway threaten the power or integrity of the judiciary; given its lack of judicial power, there was no way that it could. As for its composition and Mistretta's challenge to its requirements that three federal judges serve on the commission and share their authority with non-judges, the Court admitted that "We find Congress' requirement of judicial service somewhat troublesome . . ."But "troublesome" did not equal "unconstitutional." Whereas the Constitutionspecifically prohibits legislators from serving in any other office during their term of service, it contained no such provisions for judges. Similarly,with regard to the president's power to appoint and remove members, it did not follow from this mere fact that the president therefore controlled the commission. Under the Constitution, the president has power to appoint many judges- -including those on the Supreme Court--but history has shown that judges by no means necessarily do the bidding of the executive who appointed them.
Thus, the Court held that, although the commission was "an unusual hybrid," it was constitutional. "Nor does our system of checked and balanced authority," concluded the Court, "prohibit Congress from calling upon the accumulated wisdom and experience of the Judicial Branch in creating policy on a matter uniquely within the ken of judges."
Dissent: "A Sort of Junior-Varsity Congress"
Justice Scalia dissented, writing, "because I can find no place within our constitutional system for an agency created by Congress to exercise no governmental power other than the making of laws." The problem with the commission, he held, was precisely its lack of judicial or executive powers. He was concerned that responsibility for making laws could be delegated to "experts" in agiven field-- people with no official accountability. "How tempting," he wrote,
to create an expert Medical Commission (mostly M.D.'s, with perhaps a few Ph.D.'s in moral philosophy) to dispose of such thorny, `no-win'political issues as the withholding of life-support systems in federally funded hospitals, or the use of fetal tissue for research.The commission, in Scalia's view, was an unelected body with the powers of an electivelegislature.
Scalia particularly took issue with the Court's holding on the commission's location. The fact that Congress chose to locate the commission within the judicial branch, he suggested, was merely a trick of language, but it did not change the facts. In accordance with its ruling in Humphrey's Executor v. United States (1935), the Court should ask which of the three branches controlled the commission, as the answer would solve the question of its location. Citing his dissent in Morrison v. Olson (1988), which upheld a statute providing for an independent counsel to investigate members of the executive branch, Scalia held that the Court's present decision made its earlier ruling seem logical by comparison. The Court had already--wrongly, in his opinion-- authorized the creation of offices within the executive branch that werenot subject to ordinary standards of accountability; now, by extending that principle to the judicial branch, it had made a mistake "we will live to regret . . . Ignoring the Constitution's strict guidelines regarding separation ofpowers, Scalia concluded, the Court had in effect created "a new Branch altogether, a sort of junior-varsity Congress."
Impact
Although few would question the need for a system of sentencing guidelines, some observers were disturbed by the Court's rejection, in its Mistretta ruling, of strict separation-of-powers doctrine. Others, however, viewed the ruling as an example of flexibility on the part of the Court--a common-sense decision, as the Court itself had suggested. With Metropolitan Washington Airports Authority v. Citizens for the Abatement of Aircraft Noise (1991), the Court struck down the creation of a congressional review board with veto power over an interstate airport authority, holding that the statute in question violated the doctrine of separation.
Related Cases
- Humphrey's Executor v. United States, 295 U.S. 602 (1935).
- Nixon v. Administrator of General Services, 433 U.S. 425 (1977).
- Northern Pipeline Co. v. Marathon Pipe Line Co., 458 U.S. 50 (1982).
- Morrison v. Olson, 487 U.S. 654 (1988).
- Metropolitan Washington Airports Authority v. Citizens for the Abatement of Aircraft Noise, 501 U.S. 252 (1991).
- Nixon v. United States, 506 U.S. 224 (1993).
- Clinton v. Jones, 520 U.S. 681 (1997).
Checks and Balances
The Constitution provides for the separation of powers and a system of checksand balances to prevent the rise of a single branch of government over the other two. Each branch--executive, legislative, and judicial--acts as a checkon and balances the power of the other two. The powers of the branches are mixed in such a way that no one branch is completely separable from the others.The framers of the Constitution designed a lock-and-alarm mechanism to prevent any faction or individual from "stealing" the government. Control of the executive branch, for instance, does not mean control of all executive functions, because the Senate must approve all presidential appointments of Cabinetofficers, judges, and ambassadors. Congress does not hold all legislative power; the president, through the exercise of the veto, can override the vote ofthe legislature in certain cases. Both the executive and the legislative branches can be overridden by a decision of the judiciary, whose members are appointed by the executive branch and approved by the legislative.
Sources
Bacon, Donald C., et al., eds. The Encyclopedia of the United States Congress New York: Simon & Schuster, 1995.
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