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Title: Problems with the Testimony of Robert Brown

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background image PROBLEMS

IN THE TESTIMONY OF

ROBERT BROWN

By Professor Rob Natelson

background image Problems in the Testimony of Robert Brown

By Robert G. Natelson1

 1

About the Author: Professor Natelson is the director of the Article V Information Center at the Independence Institute in 

Denver and has published widely on many parts of the U.S. Constitution for the scholarly and popular markets. He is the most-

published active scholar on the Constitution’s amendment process, and the author of The Law Of arTicLe V//, a legal treatise. //

His research studies have been relied on by the highest courts of 16 states, by federal appeals courts in five cases, and by U.S. 

Supreme Court Justices in seven cases.

Professor Natelson has degrees in history and law, the latter from Cornell University (J.D. 1973), where he was elected to 

both the Cornell Law Review and the University Senate. (He chose the latter.) After practicing law (1974-85), he served as a 

tenure-track and tenured professor of law (1985-2010).

Professor Natelson has split his professional experience between the public and private sectors. He also has extensive political 

experience: In Montana, he led several successful statewide ballot campaigns to restrain taxes and spending, and he placed 

second in a five-candidate field in the open party primaries for governor (2000). A more complete biography is at https:%%//%%i2i.

//org/about/our-people/rob-natelson///.

background image “It is much easier to alarm people than to inform them.” 

—William Davie

Constitutional Convention Delegate

i

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Problems in the testimony of robert brown

I was enjoying success placing research articles in 

academic journals on common legal topics. Then 

I researched and composed an article on the 

more exotic subject of classical Roman law, and I 

submitted it to a peer-reviewed legal history journal.

A “peer reviewed” journal is called that because 

other scholars anonymously examine and report 

on your article before the journal agrees to 

publish it. This ensures the contribution is well-

grounded and adds to human knowledge.

Based on peer review of my submission, the 

journal’s editor rejected it and provided me with 

a copy of the review to explain why.

The reviewer’s assessment was devastating. He 

said it was obvious that I was writing without prior 

education in Roman law—that I knew little about 

scholarship in the field, and, frankly, I was clueless 

as to how much I didn’t know.

I was emotionally crushed, but I also recognized 

that the reviewer was correct. And although the 

reviewer could have remained anonymous, he 

kindly disclosed his identity to me. He helped me 

work through my disappointment. He outlined 

what I needed to do before I could contribute 

to the very specialized realm of Roman law. I 

don’t remember all his recommendations, but I 

do recall that one of them was to acquire some 

formal education on the subject.2 

The experience taught me that I had fallen into 

the common error of undervaluing other people’s 

specialties. (Think of all the disasters wrought by 

overconfident husbands who imagine they can do 

their own plumbing!) The experience also taught 

me that when researching a subject, you should 

gather as much information about it as possible: 

Never limit your universe of sources.

The experience had some implications for the 

reviewer as well. He told me he had a hard time 

writing his assessment, precisely because my 

paper lacked the foundation of basic knowledge 

of the field. If he were responding to a scholar who 

had some foundational knowledge, the review 

could have simply pointed out the mistakes, and 

perhaps suggest ways to correct them. But to 

respond effectively to a beginner, he also had to 

outline and explain many of the fundamentals.

Later I learned how time consuming this is. For 

example, when a lawyer has to thoroughly explain 

a legal conclusion to a non-lawyer, the lawyer 

first must outline basic concepts taught in law 

school before proceeding to the issue at hand. 

The difficulty increases exponentially when the 

non-lawyer thinks he’s already an “expert” in the 

subject, and has reached a different conclusion. 

Such people never want to believe the truth, so 

the lawyer has to pile up sources to support the 

most elementary propositions.

This is one reason lawyers tell each other, “Never 

argue law with a non-lawyer.” Much the same is said 

in other specialties as well, and often less politely.

Early in my 25-year career as a legal academic I had an 

experience both humiliating and invaluable.

After additional research over several years, I was able to publish a related article that did not require as much specialized 

knowledge: Robert G. Natelson, The Government as Fiduciary: Lessons from the Reign of the Emperor Trajan, 35 

Richmond L. Rev. 191 (2001).

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cOnVenTiOn Of STaTeS

This is such a case: Robert Brown is a novice who 

promotes himself as an expert. So to explain why 

his conclusions are incorrect, you often have to 

review the basics understood by all true experts. 

That is why this paper is so long.

Background

Robert Brown is an employee of the John Birch 

Society (JBS). Videos of his performances 

before legislative committees show that he 

holds himself out as a “nationally known 

constitutional scholar.”3 He or JBS apparently 

used like representations of expertise to obtain 

an interview with Joshua Philipp of the Epoch 

Times, an international newspaper.

However, Brown’s biography shows none of the 

background or hard work necessary to make one 

a constitutional scholar, much less a “nationally 

known” one.4 There is no evidence of formal, or 

Brown’s biography shows none of the background or hard work necessary to make one a 
constitutional scholar, much less a “nationally known” one. There is no evidence of formal, or 
even informal, training in law, history, or language. A search of an academic database revealed 

no evidence that he has published any scholarship on the Constitution or on anything else.

3

 https://youtu.be/aeaAfCdQk18. The video shows Mr. Brown representing himself as a “nationally known constitutional scholar” 

at legislative hearings in North Dakota, South Dakota, and South Carolina.

 

4

 Mr. Brown’s official JBS biography is sketchy. It tells us only that “he and some buddies started a bicycle design company for a 

few years,” that he has worked for JBS since 2009 and that he raises chickens and goats on two acres of land.

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Problems in the testimony of robert brown

even informal, training in law, history, or language. 

A search of an academic database revealed no 

evidence that he has published any scholarship 

on the Constitution or on anything else.5 

I recognize, of course, that everyone has a First 

Amendment right to express his or her opinion, 

expert or not. But no one has the right to mislead 

legislators on important matters of law and policy 

under the cover of false credentials.

To use an analogy: Suppose John Q. Quacker 

regularly influenced government health policy by 

holding himself out as a “nationally known cardiac 

surgeon”—but had never gone to medical school, 

never served a residency, and never performed 

an operation. We would be justifiably concerned. 

We should be equally concerned when a person 

offers constitutional and other legal advice and 

affects legislative policy without any reasonable 

basis for doing so.

Yet Brown has repeatedly purveyed constitutional 

and legal advice, frequently on the very important 

issue of whether state lawmakers should apply for 

a convention for proposing amendments to the 

United States Constitution. Brown’s statements 

are based on citations, sometimes out of 

context, from only a narrow sliver of the sources 

constitutional scholars employ in their work.6

The Interview

To illustrate the problems in Brown’s approach, 

I have chosen his Epoch Times interview with 

Joshua Philipp. The interview is 30 minutes long. 

This paper quotes relevant excerpts, and then 

Suppose John Q. Quacker regularly 
influenced government health policy 
by holding himself out as a “nationally 
known cardiac surgeon”—but had never 
gone to medical school . . . We should 

be equally concerned when a person 

offers constitutional and other 

legal advice and affects 

legislative policy without 

any reasonable basis 

for doing so.

5

 Publishing in scholarly journals subjects one’s work to review and critique from others knowledgeable in the subject.

  
6

 Constitutional scholars work with 18th century law books, cases and statutes; the 18th century educational canon (including 

the Greco-Roman classics); British parliamentary records; political and philosophical works influential with the Founders, such 

as those by Aristotle, Cicero, Locke, Montesquieu and DeLolme; colonial charters and instructions to colonial governors;

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cOnVenTiOn Of STaTeS

It would have been correct to say that there 

are only two ways of proposing amendments. 

However, Brown and other convention critics 

often fudge the difference between proposal and 

ratification to suggest, falsely, that a convention 

alone, without state ratification, could impose 

constitutional change. The Constitution and 

many other sources (see Notes) make it absolutely 

clear this is not so.

Brown also conflates proposal and ratification 

elsewhere in the interview, as explained below.

* * * * 

Brown:  “So, the second method has never been 

used before. We’ve been well over 200 years under 

the current constitution, and it has been brought up 

a number of times throughout our nation’s history.”

Correction: This is a half-truth, because it 

understates the role the Constitution’s application-

and-convention process has played in American 

history. Although the process has not been used 

to  completion, states have adopted hundreds of 

“applications” for a convention, and on several 

occasions America has been quite close to one. 

On several occasions as well, application campaigns 

have forced Congress to propose amendments or 

take other action. Without the convention process, 

it is very likely neither the Bill of Rights nor the 17th 

nor 22nd Amendments would have been adopted.

responds to each. The footnote below provides a 

link to the entire interview.7 

* * * *

Joshua Philipp: “Hey, welcome back everyone. . . . 

Robert Brown. He’s a constitutional expert with the 

John Birch Society. And Robert, it’s a real pleasure 

to have you on Crossroads. . . . Now, I’m curious 

from your standpoint, what is the Convention of 

States? How would you describe it?”

Robert Brown:  “Convention of States is an 

organization pushing to use the second method in 

Article V for obtaining changes or amendments to 

the Constitution. . . . . Yeah, in Article V it talks 

about two different ways of amending or changing 

the Constitution.”

Correction: Mr. Brown’s response is inaccurate in 

two respects. First, he fails to distinguish between 

a “convention of states” as a constitutional 

mechanism and the Convention of States 

Project, which is one of several organizations 

trying to bring about such a convention.

Second, he erroneously states that there are two 

ways of amending the Constitution. In fact, there 

are four: (1) proposal by Congress, ratification 

by state legislatures, (2) proposal by interstate 

convention, ratification by state legislatures, 

(3) proposal by Congress, ratification by state 

conventions, and (4) proposal by interstate 

convention, ratification by state conventions.

 pre-1787 state constitutions; debates in the state legislatures and state ratifying conventions; newspaper articles and speeches; 

and the records of the Continental, Confederation, and First Federal Congresses. These materials sprawl over hundreds of 

volumes. Practicing constitutional lawyers increasingly use the full range of this material as well.

 

Fully competent constitutional scholarship also requires some background in the Latin language. See fOrreST McDOnaLD, 

nOVuS OrDO SecLOruM xi (1985) (Professor McDonald was arguably our greatest 20th century constitutional historian).

 7 https:%%//%%m.theepochtimes.com/video-arguments-against-the-convention-of-states-interview-with-robert-brown_3754686.

//html//

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Problems in the testimony of robert brown

* * * *

Brown:  “James Madison in particular. . . strongly 

pushed against achieving the Bill of Rights through an 

Article V Convention, saying it was a more dangerous 

mode than Congress. He uh- in fact, a letter to 

George Turberville, November 2, 1788, he says he 

would tremble at the results of a convention. . . . .”

Correction: JBS borrows many of its arguments 

from liberal sources opposed to a convention, 

and this is one example. 

The myth that Madison—the principal author of 

Article V—opposed its provision for conventions 

apparently was invented by liberal lawyer Arthur J. 

Goldberg in 1983.8 Madison’s full correspondence 

on this subject includes at least twelve other 

letters, and it tells quite a different story.

 

Madison’s full correspondence tells us that he did 

not oppose Article V conventions in general; he 

opposed only a specific proposal for a convention 

to re-write the entire Constitution. In that 

correspondence, moreover, Madison also wrote 

he would be fully agreeable to holding a convention 

in a year or two, after some experience under the 

new government. In a letter written later in life, 

Madison endorsed an amendments convention 

over the favorite JBS “solution” of nullification.9

* * * *

Philipp: “Now, on the Convention of States, you 

mentioned that you—you kind of see the same 

problems but you—you don’t think that—that the 

model of using it to amend the Constitution is a good 

model. Why not? What is the argument against it? 

What would you say?” 

Brown: “. . . Given today’s political environment, if we 

were to pull up the anchor of the U.S. Constitution and 

drift to the center of political thought today, do you 

feel that would move us closer to the views of Marx 

or Madison? And obviously, our nation has moved far 

more towards the socialist mentality than we were in 

1787 when the Constitution was originally written . . . .”

Correction: Convention advocates explicitly 

rule out “pull[ing] up the anchor of the 

U.S. Constitution.” They seek only (in the 

Constitution’s words) “a convention for proposing 

amendments” “to this Constitution.”

JBS claims it is a bad time for a convention, and 

it has been making that claim for decades, no 

matter what the political conditions. It is clear 

that JBS does not consider any time to be good.

Practically speaking, right now probably is a good 

time for a convention to propose conservative-

leaning amendments: Thirty-one state 

legislatures are Republican. Congress is deeply 

unpopular, and its narrow Democratic majority 

is widely viewed as overreaching. The present 

justices on the Supreme Court and other federal 

courts are the most favorable in years.

* * * *

//Arthur J. Goldberg, //Commentary: The Proposed Constitutional Convention, 11 hastings const. L.Q. 1 (1983).

I have collected Madison’s correspondence on the subject at the Article V Information Center webpage at https:%%//%%

//articlevinfocenter.com/what-madison-really-said-in-1788-and-1789-about-holding-a-second-convention///. On a Montana 

radio show several years ago, I informed Mr. Brown of this correspondence, what it said, and where to find it.

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cOnVenTiOn Of STaTeS

Madison’s full 

correspondence tells us 

that he did not oppose 

Article V conventions 

in general; he opposed 

only a specific proposal 

for a convention to 

re-write the entire 

Constitution. In that 

correspondence, 

moreover, Madison also 

wrote he would be fully 

agreeable to holding 

a convention in a year 

or two, after some 

experience under the 

new government.

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Problems in the testimony of robert brown

Philipp:  “Now, I know proponents of it, they 

argue that—y’know, they can preven- they can 

propose amendments, but they’re saying that you 

can’t undo current rights within the Constitution. 

Is this accurate? What do you—what do you think 

on this?”

Brown: “It’s really not [accurate] . . . . The problem 

is,  historical precedent does say otherwise. And 

this is probably the number one most important 

argument between the two sides, is what does the 

historical precedent say?”

Correction: There is no “important argument 

between the two sides” about historical precedent, 

because opponents really don’t cite any.

Historical precedents include (1) about forty 

conventions of states and colonies since 1677, (2) 

hundreds of convention applications, and (3) a line 

of reported Article V court decisions dating back 

to 1798. (The case law is discussed in my treatise, 

//The Law of Article V//.) Out of all this material, Mr. 

Brown selects only one incident occurring more 

than 200 years ago—and as we shall see, even his 

understanding of that incident is wrong.

* * * *

Brown:  “The 1787 Convention, where our 

constitution was written, is really the only national 

constitution amending convention we’ve ever had.”

Correction: That’s not true. A national 

amending convention was held in Washington, 

D.C. in 1861. More states participated in that 

convention than at any convention of states 

before or since.10 In addition, the Albany 

Congress of 1754 and the First Continental 

Congress of 1774 were national conventions 

that proposed what were then basic 

constitutional changes.

Even if Brown’s comment were technically 

true, it would be deceptive. This is because 

regional and national conventions of states 

operate under much the same protocols, 

including (1) limited and defined powers and (2) 

equal voting power for each state. The Article 

V Information Center provides a complete list 

of these conventions.11

* * * *

Brown: “And in that case we have the existing 

constitution as the Articles of Confederation.”

Correction: The Articles of Confederation were 

not a constitution as we think of one, and the 

Confederation Congress was not a government. 

The Articles were a multilateral treaty something 

like NATO. The Confederation Congress was a 

limited coordinating body much like NATO’s 

North Atlantic Council.

In thinking of the Articles as a “constitution” in 

the modern sense, Mr. Brown commits a common 

error in historical method called anachronism.

* * * *

Brown: “States sent delegates to the 1787 

Convention and gave them specific delegate 

10 

For a summary, see It’s Been Done Before: A Convention of the States to Propose Constitutional Amendments,  

//https:%%//%%articlevinfocenter.com/its-been-done-before-a-convention-of-the-states-to-propose-constitutional-amendments/.//

11 

List of Conventions of States and Colonies in American Historyhttps:%%//%%articlevinfocenter.com/list-conventions-states-

//colonies-american-history///.

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cOnVenTiOn Of STaTeS

commissions, or authority.”

Correction: As noted above, the 1787 convention 

is the sole precedent opponents cite. Their 

fundamental argument is that the 1787 conclave 

exceeded its authority (“ran away”). From 

that, we are supposed to fear a more limited 

convention held under very different conditions 

over 230 years later.

Even if it were true that the 1787 convention 

had exceeded its authority (and, as explained 

below, it is not true) that is not very good 

evidence of what would happen in a convention 

of states today. 

First: There have been about forty conventions 

of states, many after 1787.12  They were governed 

by procedures that have become standardized, 

including rules limiting their authority. Everyone 

concedes that the other conventions remained 

within their authority. Certainly thirty-nine offer 

much more precedential weight than just one.

Second: The 1787 convention was not called 

under the Articles of Confederation. It 

operated outside of any legal restraint other 

than the delegates’ commissions. By contrast, a 

convention for proposing amendments is called 

under the Constitution and is subject to the rules 

of the Constitution. Over a century of decided 

case law affirms that. 

Third: On the modern convention floor, any 

commissioner raising issues outside the prescribed 

agenda can be reined in with a simple point of order.

Fourth: Modern technology enables the state 

legislatures commissioning delegates to use 

video oversight to track them 24/7. If a straying 

delegate somehow were not brought back to 

order, a supervising state legislative committee 

would see the incident in real time and could 

immediately re-instruct or recall.

* * * *

Brown:  “States sent delegates to the 1787 

Convention and gave them specific delegate 

commissions, or authority. You’re authorized to 

make these types of changes; you’re not authorized 

to change these things . . . Mark Meckler, 

Convention of States, organizations like that, will 

repeatedly claim those convention delegates were 

given full authority to make any changes they felt 

were necessary to the Articles of Confederation. 

Now, if that were true, do you think that delegates 

would have known that? And the reason I say that 

is because, as you look through Madison’s notes 

from the federal convention, you see this issue came 

up repeatedly throughout the Convention: do we 

actually have the authority to be creating a new 

constitution, instead of just amending the Articles 

of Confederation? . . . .  

“First side said things like, ‘We really don’t have the 

authority and we should not proceed with changing 

the Constitution this drastically without first going 

back to the States and getting further authority.’ 

That was the argument of William Patterson, uh 

Charles Pinckney, Elbridge Gerry13, John Lansing. 

“The other side of the argument was not what 

Mr. Meckler says, ‘They have full authority.’ The 

12

 See the previous footnote.

13 

In this interview Brown makes an error no genuine constitutional scholar would make: He pronounced Elbridge Gerry’s last 

name with a soft “g” (like “Jerry”) rather than how Gerry actually pronounced it (with a hard “g”). It seems like a small mistake, 

but such mistakes are clues to whether the speaker knows what he or she is talking about.

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Problems in the testimony of robert brown

other side of the argument represented by people 

like Edmund Randolph, Alexander Hamilton, even 

James Madison, was, ‘You’re right, we really don’t 

have the authorization to be doing this, but we 

need to do it anyways. This is an urgent need of our 

nation. . . . We must proceed.’

“Nobody stood up in the 1787 Convention and claimed, 

‘Look at our commissions, we’re fully authorized to 

make any changes we feel are necessary.’”

Correction: These comments depart from the 

traditional JBS line, which is that Congress called 

the 1787 convention and limited it to proposing 

only amendments to the Articles. However, 

modern research has made that position untenable, 

so I am glad to see Mr. Brown abandon it. 

Madison points out in Federalist No. 40 that 

the state-issued commissions (or “credentials”) 

defined the scope of the convention’s authority. 

Founding-era law books confirm this rule. Now, 

among the 12 states participating in the 1787 

convention, all but two (Massachusetts and 

New York) issued commissions conveying full 

power to propose a new form of government. 

The general public overwhelmingly shared the 

expectation that the convention would propose 

a new form of government—some imagined it 

might be a monarchy!

Brown points to statements by commissioners 

questioning the extent of their authority. But 

what determines whether the 1787 convention “ran 

away” is what the commissioners’ credentials said, 

not what anyone said they said! 

There were several reasons why commissioners 

might rhetorically question their authority. 

Some represented one of the two states granting 

narrower powers, such as New York’s John Lansing 

and Massachusetts’ Elbridge Gerry. Virginia’s 

Madison points out 
in Federalist No. 
40 that the state-
issued commissions 
(or “credentials”) 
defined the scope 
of the convention’s 
authority. Founding-
era law books confirm 
this rule. 

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Edmund Randolph clearly did not buy the “no-

authority” argument, but like the good advocate 

he was, he conceded it arguendo (for sake of 

argument) and built his case on practical rather 

than technical legal grounds. William Paterson of 

New Jersey denigrated his authority for strategic 

reasons—to strengthen his case for equal state 

representation in the Senate. Once Paterson 

achieved his goal, he dropped the argument and 

urged creation of a strong government.

Brown’s restriction to a narrow range of sources 

prevented him from learning that during 

the ratification debates the Constitution’s 

advocates addressed the issue. They vigorously 

defended the delegates’ actions as authorized 

by their commissions.14 

* * * *

Brown: “In fact, one of the challenges I repeatedly 

put out to the other side, they never want to answer 

this: show me the delegate. Show me the delegate 

who made that claim, ‘We have full authority.’”

Correction: Mr. Brown has never put the 

challenge to me. I would have responded by 

naming James Wilson, who told the Convention, 

“Relative to the powers of this convention—We 

have powers to conclude nothing; we have power 

to propose anything.” 15

* * * *

Brown: “Instead, what they did was, and this comes 

directly from James Madison, I’m going to read it 

to  you directly. They said that people were in fact, 

the fountain of all power, and by resorting to them, 

all difficulties were got over.”

Correction: This is another example of 

opponents conflating proposal with ratification. 

As Madison (in Federalist No. 40) and other 

Founders made clear, the power to propose 

came from the states via their commissions to 

“We have powers to 

conclude nothing; 

we have power to 

propose anything.”

- James Wilson

14

 See, e.g., Carlisle Gazette, Mar. 12, 1788, in 34 DOcuMenTary hiSTOry Of The raTificaTiOn Of The cOnSTiTuTiOn 1014, 1016.

15

// 1 Farrand’s Records 266 (Jun. 16, 1787) (//as reported by Rufus King).

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Problems in the testimony of robert brown

the delegates. The power to ratify came from 

the people, who elected delegates to their 

state ratifying conventions.

* * * *

Brown:  “They were also given a constitutionally 

defined ratification process, they threw it out, 

retroactively created a much lower bar . . . .”

Correction: Mr. Brown’s claim is that (1) 

the Constitutional Convention provided for 

ratification by nine states rather than the 

thirteen required by the Articles, so therefore 

(2) a modern amendments convention might 

alter the ratification process as well.

Constitutional scholars consider this as one of 

the “runaway” alarmists’ loonier ideas. It is based 

on utter ignorance of governing law, both in 1787 

and now. Specifically:

•  As noted before, the 1787 convention was 

not held under the Articles of Confederation. 

It was held under reserved state powers 

retained by signatories of treaties and 

recognized explicitly by the Articles. The 

convention could, therefore, propose any 

method of ratification it chose. Incidentally, 

the Confederation Congress approved the 

convention’s actions when it forwarded the 

Constitution to the states and urged them to 

hold ratifying conventions.15 

•  A convention for proposing amendments, 

by contrast, receives its power from the 

Constitution and is subject to its rules, 

including ratification rules. One of the 

clearest principles from 223 years of Article 

V court decisions is that no participant in 

the amendment process may change the 

Constitution’s amendment rules. But Mr. 

Brown never mentions case law. From 

listening to him you’d think the courts never 

issued an Article V ruling and all we have to 

go on is what allegedly happened in 1787. Yet 

there are hundreds of cases defining general 

constitutional principles and dozens more 

interpreting Article V. 

•  Nor do alarmists tell us how, if a convention 

purported to change the ratification rules, it 

could enforce its decision. Call out the army?

* * * *

Brown:  “[T]he precedent they set was, these 

types of conventions represent, not the States, 

not the legislatures, but they represent the people 

themselves . . . .”

Correction: It is unclear what Mr. Brown means 

by “these types of conventions.” If he is referring 

to conventions that deal with constitutional 

issues, then his statement is only a half-truth. 

Conventions elected directly by the people within 

a particular state—sometimes called constituent 

conventions—represent the people. Constituent 

conventions were used to ratify the U.S. 

Constitution and the 21st amendment. They also are 

employed to propose and ratify state constitutions. 

Interstate conventions whose commissioners 

are selected as directed by state legislatures 

are called conventions of states or conventions 

of the states. They answer to the states or state 

legislatures directly, so they represent the people 

15

 Did Congress Approve the Constitution? A Member’s Letter Says “Yes”, https:%%//%%articlevinfocenter.com/did-congress-approve-

//the-constitution-a-members-letter-says-yes/.//

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cOnVenTiOn Of STaTeS

only in a remote sense. When called under states’ 

reserved powers, conventions of states meet to 

propose solutions to common problems—such 

as coordinating state laws or negotiating water 

compacts. When called under Article V of the 

Constitution, they may propose amendments 

to the states for ratification. My treatise, The 

Law of Article V, discusses the legal differences 

among conventions.

* * * *

Brown:  “. . . and as such their power cannot be 

limited. Now, we’ve seen that same precedent 

upheld repeatedly in state conventions ever since. I 

mentioned the Montana one, for example.”

Correction: This is legal nonsense. Conventions—

even those that represent the people directly—

usually are limited. Brown cites the 1972 Montana 

constitutional convention as an unlimited body. 

But the Montana Supreme Court specifically held 

that its powers were limited. State of Montana ex rel. 

Kvaalen v. Graybill, 496 P.2d 1127 (Mont. 1972).

Unless a convention is acting in absence of an 

established government (as in some states at the 

opening of the American Revolution), it is always 

limited to some extent. For example, a state 

convention called under an existing constitution 

may not be subject to the legislature, but it is 

limited by the terms of the existing constitution. 

When state conventions were being considered 

to ratify the 21st Amendment, some people 

argued they would be unlimited—but court 

adjudication determined otherwise. As noted 

earlier, the courts have ruled repeatedly that all 

assemblies operating under Article V are bound 

by the rules laid out in the Constitution.

* * * *

Brown: “In fact, if you look to the—the law journal 

that’s called Corpus Juris Secundum, that’s a 

collection of various Supreme Court rulings from 

If a convention purported to change the ratification rules, 
how could it enforce its decision? Call out the army?

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Problems in the testimony of robert brown

the States all across the country, and we’ve seen 

consistently the same thing.”

Correction: Where do we begin with this one? 

There is so much error from which to choose!

First: Contrary to Mr. Brown’s description, 

Corpus Juris Secundum (CJS) is not a “law 

journal.” It is a legal encyclopedia that attempts 

to summarize law on all topics.

Second: CJS is not a “collection of various 

Supreme Court rulings.” It is principally a legal 

text with supporting citations from federal and 

states appellate courts at all levels.

Third: Every first-year law student learns that 

CJS’s text is not fully trustworthy and should 

never be cited as authority. It is used principally 

as a case finder. You have to read the cases it 

cites to find out what the law is, then expand your 

research to find other cases on the same topic.

Fourth: Mr. Brown apparently didn’t read 

the cases referenced in the part of CJS he 

mentions. If he did, he’d know they have 

nothing to do with Article V conventions. 

He would also learn that those cases are 

all very old. They were decided long 

before most Article V court rulings 

were issued. Thus:

•  In Cox v. Robison, 105 Tex. 426, 

150 S.W. 1149 (1912), the facts 

were that in 1866, the former 

Confederate state of Texas was 

under federal military occupation. As 

commander-in-chief of the U.S. armed 

forces, President Andrew Johnson called 

for a Texas state constitutional convention. 

The court held that the state constitution did 

not have to be ratified by the people because 

the president had not required it. (Presumably 

he could have limited the convention by 

requiring it.)

•  Frantz v. Autry, 18 Okla. 561, 91 P. 13 (1907) 

dealt with a local constitutional convention 

Congress had authorized in what was then the 

Territory of Oklahoma. The case held that the 

convention had all the power Congress gave 

it, and that Congress had imposed only a few 

limits. The cases said the convention needed 

to respect only the limits Congress imposed.

•  Koehler & Lange v. Hill, 60 Iowa 543, 14 N.W. 

738 (1883) held that when any constitution 

prescribes an amendment procedure, that 

procedure must be followed. It added “The 

powers of a convention are, of course, unlimited. 

The members thereof are the representatives 

of the people, called together for that purpose.” 

But the court was speaking of state constitutional 

conventions, not federal conventions, and this 

case is contradicted by later authority, such 

Every 

first-year law 

student learns that 

Corpus Juris Secundum’s 

text is not fully trustworthy 

and should never be cited 

as authority. It is used 

principally as a case 

finder. 

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cOnVenTiOn Of STaTeS

as State of Montana ex rel. Kvaalen v. Graybill

496 P.2d 1127 (Mont. 1972), mentioned above. 

•  Loomis v. Jackson, 6 W.Va. 613 (1873) says 

that “A [state] constitutional convention, 

lawfully convened, does not derive its powers 

from the legislature; but from the people. 

The powers of such a convention are in the 

nature of sovereign powers.” But in this 

country, we frequently limit sovereignty, and 

a convention’s authority can be limited by an 

existing constitution.16 

•  Sproule v. Fredericks, 69 Miss. 898, 11 So. 

472 (1892) examined the power of a state 

constitutional convention called by the 

legislature. It ruled that the convention’s 

power was very broad, but also acknowledged 

that its power could have been limited.

Again, nothing in these five decisions had 

anything to do with Article V.

So much for Mr. Brown’s cases. I’ve taken some 

time to examine his misuse of CJS because it 

illustrates the conceptual chaos that ensues 

when someone ignorant of law starts interpreting 

legal texts and spouting legal advice.

* * * *

Brown: “Congress is essentially—they often 

refer to it as a sitting constitutional convention 

themselves. Madison differentiated between them. 

Again, as I mentioned as he was putting out his 

opposition to an Article V Convention, he said 

that in his view, the Convention would feel much 

greater latitude in making sweeping changes to 

the Constitution than Congress would, which is 

why he said Congress is the safer mode.”

An amendments convention 

may do only what Congress 

may do at any time: propose 

amendments. But unlike a 

convention, Congress has 

unlimited, unrestricted 

power to do so.

16

 Incidentally, another line in the Loomis case contradicts the common JBS claim that Congress could control an amendments 

convention: “That the legislature can neither limit or restrict [conventions] in the exercise of these powers . . . .”

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Problems in the testimony of robert brown

Correction: As already discussed, Madison was 

not opposed to amendments conventions. The 

reason he opposed New York’s 1788 proposal 

was because its scope was too wide and it came 

too early. But very few convention applications 

have been as broad as that. The applications 

being passed today are all quite focused.

In this passage Mr. Brown does inadvertently 

allude to an inconvenient fact: An amendments 

convention may do only what Congress may 

do at any time — propose amendments. But 

unlike a convention, Congress has unlimited, 

unrestricted power to do so.

MR. BROWN CLAIMS 

HE ORGANIZED 

A GROUP TO 

PRESSURE REP. 

DENNY REHBERG… 

BUT AFTER 

BROWN STARTED 

HARASSING HIM, 

REHBERG’S RATING 

DROPPED TO 80% 

IN 2011 AND 76% IN 

2012—HIS LOWEST 

SCORES EVER.

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cOnVenTiOn Of STaTeS

* * * *

Brown: “Congress already pretty much does whatever 

they want to with regards to what the Constitution says, 

for the most part. And the only reason they get away 

with that, is we the people don’t hold them to it . . . .

“When I first moved to Montana about a decade 

ago, I organized a couple hundred people, and we 

started holding our congressman accountable to 

his voting as it squared with the Constitution. At 

the time, his “constitutional rating,” so to say, was 

somewhere around 40-60%. He was always right 

in the middle. About half the time he’d follow the 

Constitution, half the time he wouldn’t. Within four 

months, he was at 80% and thereafter he was stated 

at 90%, because we started pushing on him on . . . .” 

Correction: This prescription for curing the 

federal government is terminally naïve. The 

majority of members of Congress, particularly 

the leadership, are long-time holders of “safe” 

seats and immune to popular, pro-Constitution 

lobbying. Indeed, they hold their seats largely by 

violating the Constitution.

The Congressman referred to is Rep. Denny 

Rehberg (R.-Mont.), who was in office from 

2001 to early January 2013. Mr. Brown claims 

he organized a group to lobby Rehberg “about 

decade ago” — i.e., sometime between 2009 

and 2011. Now, if anyone was amenable to 

“constitutionalist” lobbying, Congressman 

Rehberg should have been. He served a swing 

district, and I know from personal acquaintance 

that he has conservative values.

But did Brown’s lobbying really have any effect? 

The American Conservative Union ranks 

members of Congress by their commitment to 

smaller, constitutional government. The ranking 

is on a scale of zero to 100. 

Rehberg was rated for the years 2001 through 

2012. His ACU voting record for each year was 

as follows:

2001 - 84%

2002 - 100%

2003 - 84%

2004 - 96%

2005 - 92%

2006 - 83%

2007 - 88%

2008 - 84%

2009 - 92%

2010 - 96%

2011 - 80%

2012 - 76%

If there is any pattern in their figures at all—and I’m 

not sure there is—it suggests Brown’s efforts may 

have been counterproductive. In the years including 

and up to 2010, Rep. Rehberg’s ACU score had 

ranged from 84% to 100%. But after Brown started 

harassing him, Rehberg’s rating dropped to 80% in 

2011 and 76% in 2012—his lowest scores ever.

In theory millions of Americans could pressure 

members of Congress to change. But as a matter 

of historical record, this does not happen: The 

organizational costs for conservative Americans 

are too high. Professional lobbyists concentrated 

in Washington, D.C., are paid big money to 

lobby, and they do it continuously. They offer 

concrete benefits beyond what the conservative 

grassroots can offer, such as connections to many 

large political donors. They enjoy the support of 

the national media, which has strong incentives 

to concentrate power at the federal level.

There are good people in Congress. But as they 

acknowledge, they need firm rules to restrain 

their behavior and enable them to justify voting 

against certain programs. Only constitutional 

amendments can provide those rules.

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Problems in the testimony of robert brown

* * * *

Brown:  “We look at Federalist 16, 26, and 33: 

Alexander Hamilto-Hamilton talking about the 

power that we the people and we the States have 

to push back against federal tyranny. Madison 

picks it up in Federalist 44 and 46, 46 especially. 

And what’s interesting is, in all of those documents 

where they’re talking about what to do to push back 

against federal tyranny, they never mention Article 

V. In fact, when you go onto Federalist 48 and 49, 

Madison directly addresses that.”

Correction: Notice how Mr. Brown’s sources 

for the ratification debates consist solely of 

The Federalist—a minuscule fraction of the 

ratification record. He never mentions the 

other founding-era commentators who spoke 

to the amendments convention process.17 Even 

his use of The Federalist is clumsy. For example, 

at this point he overlooks references to the 

Article V convention process in Federalist No. 

43 and No. 85.

* * * *

Brown: “In 49, [Madison] asks, ‘Is it appropriate 

to use a Convention to address breaches in the 

Constitution when the federal government ignores 

it?’ And his answer is absolutely not . . . .”

 

Correction: This is another example of Brown’s 

inept use of The Federalist. Trying to convert 

one of its essays into an argument against the 

Constitution’s amendment process makes no 

sense at all. The Federalist was written to support 

the Constitution, not trash it.

Here’s the real scoop on Federalist No. 49: When 

Madison was writing, Pennsylvania and Vermont 

had constitutions that provided for a “council of 

censors” to meet every seven years. The censors 

could decide whether their state constitution was 

working well. The censors could call a constitutional 

convention to address any problems.

In 1783, Thomas Jefferson outlined his own ideas 

for a new Virginia constitution. In partial imitation 

of the Pennsylvania-Vermont approach, his draft 

would have permitted some state officials to call 

a convention for “altering this Constitution or 

correcting breaches of it.” Strikingly, this new 

convention was to have all the powers enjoyed by a 

plenary constitutional convention—including power 

to write an entirely new document and impose all 

its changes without a ratification procedure.

Madison had four objections: (1) A rogue state 

legislature could block the process in various ways; 

(2) “frequent appeals” for constitutional revision 

could reduce public respect for government; 

(3) frequent referrals to the citizenry might 

cause constitutional turbulence; and (4) the 

legislature—the branch most likely responsible 

for the problems—might highjack the process.

Notice that none of these objections is 

relevant to calling a convention under Article 

V. The states, not federal officials, initiate 

and staff the convention, thereby preventing 

congressional obstruction or control. Article 

V is very difficult to trigger, eliminating the 

danger of “frequent appeals.” A convention 

for proposing amendments has power only to 

propose specified amendments, not re-write 

17 

For collections of this material, see, for example, my following two articles: Is the Constitution’s Convention for 

Proposing Amendments a ‘Mystery’? Overlooked Evidence in the Narrative of Uncertainty, 104 MarqueTTe L. 

reV. 1 (2020) and Founding-Era Conventions and the Meaning of the Constitution’s “Convention for Proposing 

Amendments,” 65 fLa. L. reV. 615 (2013). See also A Founder Gives Us a Lesson on the Constitution’s Amendment 

Process, https:%%//%%articlevinfocenter.com/founder-gives-us-lesson-constitutions-amendment-process/.

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cOnVenTiOn Of STaTeS

the Constitution. And unlike Jefferson’s idea for 

periodic plenary constitutional conventions, any 

proposal from an Article V convention is subject 

to a difficult ratification process.

In a portion of Federalist No. 49 Brown fails 

to quote, Madison assures us that, although he 

objects to Jefferson’s plan, still “a constitutional 

road to the decision of the people ought to be 

marked out and kept open, for certain great and 

extraordinary occasions.”

Unlike the proposals Madison was criticizing, 

the convention procedure of Article V seems to 

meet his goal very well.

* * * *

Brown: “Now, in Federalist uh, I think it was 43, 

yeah, in Federalist 43, Madison does address the 

Article V Convention. And in that case, he refers to 

it as “the remedy for errors” in the Constitution.”

Correction: Mr. Brown is repeating—perhaps 

is the author of—a common JBS claim that the 

only role for an amendments convention was to 

correct drafting errors in the Constitution.

This is still more nonsense. The fact that Madison 

stated one purpose of the convention procedure 

does not mean he excluded other purposes. 

Other Founders itemized additional purposes. 

One was the need to correct federal abuses 

and overreach. That was the reason George 

Mason gave at the Constitutional Convention. 

During the ratification debates, prominent 

advocates cited the convention procedure again 

and again as a key safeguard against abuse.18 

* * * *

Trying to convert one 
of The Federalist essays 
into an argument against 
the Constitution’s 
amendment process 
makes no sense at 
all. The Federalist was 
written to support the 
Constitution, not trash it.

18

 See, e.g., The Founders Pointed to Article V as a Cure for Federal Abuse//, https:%%//%%articlevinfocenter.com/the-founders-//

//pointed-to-article-v-as-a-cure-for-federal-abuse/ (//collecting examples).

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Problems in the testimony of robert brown

Brown: “Article V has never been used 

technically, as far as the convention mode. It has 

no track record of any success other than, well, 

it did pressure Congress into passing the 17th 

Amendment, which I wouldn’t really consider a 

good thing but, on the other hand, nullification is 

just one of many tools in our quiver.”

Correction: Mr. Brown incorrectly uses the term 

“nullification” to refer to all methods of what 

Madison called “interposition.” In constitutional 

scholarship, “nullification” usually refers to 

formally adopting a state law or state convention 

resolution declaring that a federal law is void 

within state boundaries. The Constitution has 

no provision for nullification and, contrary 

to JBS claims, Madison firmly opposed it—

recommending an Article V convention instead.19

* * * *

Brown: “Well, y’know, in that light, it really gives a 

feeling of there’s a sense of urgency here: We’ve gotta 

get something done, we’ve gotta do it soon. And if 

we look at the timetable, Convention of States is the 

example again, they’ve been around for seven years, 

they’ve gotten less than halfway to the thirty-four 

states mark. If they don’t lose momentum . . . we’re 

looking at another ten years before they get to 34 

states. 

“They also admit that there will be numerous legal 

challenges stalling the process along the way. When 

we eventually get to a convention, Congress calls 

the convention, they finally conclude their—their 

whatever amendment proposals they come up with, 

and then it goes out to the States for ratification. 

. . . You’re looking at a minimum of 20 years for 

anything to actually go into effect from a convention. 

I don’t think we have 20 years to turn this around.”

Correction: It ill behooves someone who had 

been slowing down a process to gripe about 

it being slow. On several occasions in recent 

American history, we have been at the cusp 

It also ill behooves an organization to complain about length of time 

when it has had over 50 years for its own “solutions” to work.

19

 James Madison to Edward Everett, Aug. 28, 1830, https:%%//%%articlevinfocenter.com/wp-content/uploads/2021/02/1830-0828-

//JM-to-E-Everett.pdf//.

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cOnVenTiOn Of STaTeS

of a convention only to see JBS and other 

alarmists frighten people away.

It also ill behooves an organization to complain 

about length of time when it has had over 50 

years for its own “solutions” to work. Of course, 

they haven’t worked, and by any measure, the 

political system is more dysfunctional than ever.

History shows that once a popular amendment 

is proposed, it can be ratified in fairly short 

order—depending on the proposal, 15 months is a 

reasonable estimate. The 26th Amendment was 

ratified in slightly more than three months. 

As for litigation: Mr. Brown probably is wrong on 

this one as well. The Convention of States Project 

application is designed in a way to minimize the 

chances of lengthy litigation. (That is not true of 

the non-uniform applications promoted by some 

other Article V organizations.)

* * * *

Brown: “. . . the moment. . . the balanced budget 

becomes a higher priority than all these other 

programs, then Congress will make it their highest 

priority as well and will pass a balanced budget. 

“So, the problem really isn’t Congress, it really isn’t 

the federal government, it really comes down to 

what we the people tolerate.”

Correction: This reflects Mr. Brown’s ignorance of 

how the federal government works. As the Public 

Choice school of economics has documented, 

politicians respond to incentives. Over the long 

term, these incentives are more important than 

the character of the politicians themselves. When 

the incentives are bad, the results usually are 

bad. When the incentives are good, the results 

usually are good. However, concentrated special 

interests, with media support, almost always can 

offer stronger incentives than the diffused public.

There are various ways to change incentives, but one 

of the most direct is to alter the system in which 

political actors work—by constitutional amendment.

When given the opportunity for constitutional 

change, people act differently than they do 

from day to day. Take the balanced budget 

amendment as an example: Right now, Congress 

has strong incentives to deficit-spend and very 

weak incentives to balance the budget. Special 

interests fight for as much federal booty as 

they can, knowing that if they don’t do so, the 

spending will happen anyway—but it will go to 

someone else. Fiscal conservatives have never 

been able to match that clout, even though they 

probably comprise most of the U.S. population.

But when people are given a chance to adopt a rule 

that they know (1) is for the good of all and (2) will 

bind others as much as themselves, they act very 

differently. A carefully-worded balanced budget 

amendment will never be proposed by Congress—

the incentives to deficit spending are too strong. 

But if a convention of the states proposed it, it 

probably would be ratified fairly quickly.

Conclusion

Mr. Brown has little knowledge of constitutional 

history, constitutional law, law in general, or 

government operations. But his claims to 

expertise have certainly helped to disable a 

key constitutional check-and-balance. Brown 

proposes other remedies, but he and his 

predecessors have argued for those remedies for 

decades, while federal dysfunction grows ever 

worse.

Our ability to extricate ourselves from our current 

political problems depends heavily on whether 

we use the most powerful tool the Founders gave 

us for correcting federal dysfunction and abuse. 

The time for using it is here—in fact, it has been 

here for a very long time.

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