Vicki C. Jackson, Holistic Interpretation: Fitzpatrick v. Bitzer and Our Bifurcated Constitution, Stanford Law Review, Vol. 53, No. 5, Symposium: Shifting the Balance of Power? The Supreme Court, Federalism, and State Sovereign Immunity (May, 2001), pp. 1259-1310
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Vicki C. Jackson (2001) studied this question.