Scholars who study American political institutions have tended to specialize in a single body such as the U.S. Congress or the federal courts. However, a growing movement among judicial scholars argues that the courts cannot be understood in isolation, but instead must be understood as a part of the larger system of government. As Neustadt (1980, 26) has reminded us, in reality the U.S. system of government features “separated institutions sharing powers.” Alexander Bickel (1962) was one of the first voices in what one could label the Governance as Dialogue movement. Bickel said that the courts must engage in a “continuing colloquy” with the more political branches of government and with other political actors, refuting the judicial supremacy approach that was popular at that time. In Constitutional Dialogues (1988) and in his other writings, Louis Fisher has argued that the courts, and especially the U.S. Supreme Court, do not have the sole responsibility of interpreting the U.S. Constitution, but that constitutional interpretation involves a very complicated dialogue among various political actors. Others, such as William N. Eskridge (1991a; 1991b), have argued that the interactions between the courts, the executive, and Congress are a highly complex multiple-player game. Recent literature on the interactions between courts and Congress has been growing steadily, and includes, among others, works by Geyh (2006); Devins and Whittington (2005); Barnes (2004); Pickerill (2004); Miller and Barnes (2004); and Lovell (2003).