Michele Bachmann couldn’t take a little bit of heat from a few restrictionists on the Right and has renounced her Swiss citizenship, apparently pursuant to article 42 of the Swiss nationality law.

It wasn’t clear that Republicans had such a big problem with her keeping it. Check out the comments to Mark Krikorian’s “Swiss Miss” column over at National Review Online, in which he accused Bachmann of “civic bigamy.”  Seems like a high level of dissent among the faithful.  First, there is a sort of libertarian argument that the (U.S.) government shouldn’t be able to dictate a person’s association with other states.  This resonates with an argument I’ve made that the maintenance of dual citizenship is protectable on a free association basis (among others).

Second, there’s the wackier riff that a second citizenship is defensible by way of a hedge against left-wing oppression here at home.  From one NRO commenter, this:

. . . she will be ready to head for the hills (no pun intended) should the US implode into massive civil unrest that will see the masses looking for heads like hers to roll in retribution.
The Swiss will be the economic and sane oasis in the ocean of the oncoming European disaster with mountains that make ingress easy to defend.
Remember too that military conscription remains in Switzerland and the military is modelled as a militia system. These soldiers keep their own personal equipment and guns at home.
I suspect her sons should they have taken Swiss citizenship would have to do their basic training at some time.

Bravo, Switzerland, where the Second Amendment can go into exile!

Bachmann’s about-face isn’t going to dampen the exploding incidence of dual citizenship on the ground, however useful a poster-child she would have been for it.

That’s right, Michele Bachmann has acquired Swiss citizenship and is now a dual national. The news reports say she did it for her kids. (It doesn’t appear that her naturalization was necessary for her children’s, since her husband was already a Swiss citizen. For those interested in the finer points of Swiss nationality law, here is a primer. Note that although Bachmann could sign up through the marital tie notwithstanding the lack of any other substantial ties to Switzerland, many long-term Swiss residents are subjected to tough, even humiliating, hurdles to acquiring citizenship there.)

When an arch-conservative like Bachmann becomes a dual citizen, it takes the steam out of any putative effort to police the status.  Dual citizenship is not like illegal immigration.  It’s not about different looking people streaming across the southern border.  It’s about US and Irish dual citizens, US and Italian dual citizens, US and Israeli dual citizens, and apparently a few US and Swiss dual citizens.  (Of course there are also a lot of US and Mexico dual citizens – among them, pretty much all Mexicans who have naturalized since 1998, but there’s no principled way to single them out.)  An effort to criminalize the status through federal legislation (see this 2005 House bill) was a complete non-starter.

In other words, dual citizenship cuts across the political spectrum.  Nor does it give rise to any concrete problems, not even if you serve in Congress (the other poster child in the Republican camp for this is former governor Arnold Schwarzenegger, who is Austrian and American).  The number of people holding the status is exploding to the point where the status is commonplace among Americans.  It surely counts as among the most dramatic legal incidents of globalization.

. . . your fourth-grader is being taught about the Convention on the Rights of the Child.  Mine had a class last week in which the class was divided into groups, each one given a provision of the treaty, about which they had to develop responses and questions.  His group got article 27, recognizing a child’s right to an adequate standard of living, including with respect to food, clothing, and housing.  Their main question: why is it that the so many children don’t have these things even though the treaty says they should?  Good question!

My son goes to a lefty Quaker school in the Northeast; this kind of lesson plan is no doubt still unusual elsewhere in the US.  (The elementary school teacher that starts teaching the CRC, say, here, would probably be out of a job.)  But it may be a more routine part of primary schooling in Europe, and the UN is otherwise starting to make international law and human rights accessible to the junior set (check out this excellent short, for example).  It’s only one step from trick-or-treating for UNICEF to assimilating a kind of cultural familiarity with international law.  In a jokey sort of way, my son turned around that afternoon and claimed that the CRC gave him a right to an afternoon snack, in the same way that kids will sometimes claim they have a constitutional right to something that’s being (rightfully) denied them.  International law will grow up with this generation.

Quite possibly.  Here’s the Third Circuit’s merits opinion in United States v. Bond, involving a conviction under the Chemical Weapons Convention Implementation Act of 1998.  The court upheld the conviction against a Tenth Amendment attack, this after the Supreme Court last year found Ms. Bond to have standing to press the federalism claim.  After rehearsing the academic debates on Missouri v. Holland (many citations here to Curt Bradley, David Golove, and other lawprofs), Judge Jordan’s majority opinion concludes:

Whatever the Treaty Power‟s proper bounds may be, however, we are confident that the Convention we are dealing with here falls comfortably within them.  The Convention, after all, regulates the proliferation and use of chemical weapons.  One need not be a student of modern warfare to have some appreciation for the devastation chemical weapons can cause and the corresponding impetus for international collaboration to take steps against their use.  Given its quintessentially international character, we conclude that the Convention is valid under any reasonable conception of the Treaty Power‟s scope.

So, maybe not the best test case for Missouri?  Think again.  Judge Ambro, concurring, after acknowledging the act’s constitutionality under the precedent:

But if ever there were a statute that did test those limits, it would be [this Act].  With its shockingly broad definitions, [the Act] federalizes purely local, run-of-the-mill criminal conduct.  The statute is a troublesome example of the Federal Government‟s appetite for criminal lawmaking.  Sweeping statutes like [this one] are in deep tension with an important structural feature of our Government:  “The States possess primary authority for defining and enforcing the criminal law.‟

Both Jordan and Ambro expressly urge the Supreme Court to clarify Missouri’s boundaries.  Paul Clement for the petitioner!  Stay tuned!

Ian Hurd has a very interesting essay on law and international relations, “Law and the Practice of Diplomacy,” which I’d strongly recommend to anyone with an IR/IL bent. It’s maybe the only piece of IR theory that I’ve read that really seems to get the dynamic element of international law. It also centers international law to what I suspect is an unprecedented extent, as both a “resource” for and a constraint on state actors. “[S]tates are limited in their agency by the legal resources that they find around them. Their strategic behaviour around diplomacy and international law is therefore tightly structured by the legal environment. This is not a domain of free choice.”

The piece also highlights the change element inherent in the international legal process, and the fact that although state try to put law to work to advance their interests

[t]he social nature of diplomacy ensures that these changes are never fully under the control of any single actor, and that the strategic direction of diplomatic activism is always uncertain. The meaning of precedents depends on how states and others choose to use them. As a social practice, diplomacy has these three formal qualities: sociality, statecentrism, and a productive effect.

With this emphasis on the IL’s dynamic element, Hurd gives the lie to the burgeoning field of IR/IL compliance studies. Insofar as a rule of international law is contested, “answering the question about compliance versus noncompliance amounts to taking sides in the substantive political content of the dispute.” Better, in true constructivist form, to “look at how the actors use the rules, and how the rules shape the actors and their possibilities.”

This is great stuff. Two quick thoughts in response. . .

Uri Feldman and Josh Keating have this excellent piece now up over at Foreign Policy on the history and mechanics of diplomatic asylum, as now possibly playing out in the case of Chen Guangcheng. This in the wake of Wang Lijun, who got the Bo Xilai ball rolling and spent 30 hours holed up in the US consulate in Chengdu.  In a different register — because it involved a US citizen — Sam LaHood sought refuge in the US embassy Cairo for four weeks against criminal charges relating to the NGO activities in Egypt before being allowed to leave the country.

I had always thought “diplomatic asylum” something of a misnomer, as often paired with the common misunderstanding that embassy premises are extraterritorial (as in, that the US embassy in Beijing counts as US territory, which in fact it doesn’t).  Turns out that the term has some historical traction, even though the its operation now appears to turn on the inviolability of diplomatic premises under the Vienna Convention on Diplomatic Relations and not any distinctive legal doctrine.  Much of that history played out in Latin America, where the revolutionary era of a century ago led to multiple accords regularizing the practice.  Feldman and Keating unearthed this definitive, lengthy 1975 report of the UN Secretary General on the subject, which makes for pretty interesting reading.

Are we about to see more of the same?  I doubt it.  The 1975 report documents what was a common practice.  As the FP notes, diplomatic asylum was also a recurrent thorn on the East Bloc’s side during the Cold War.  Today it just doesn’t seem that useful a tool; there is too much at stake in relations with countries like China, and human rights disputes are no doubt better managed without the high-theater that comes with these cases.

As Julian points out below, China is also unlikely to grant safe passage that would be required for these people to leave the country (the diplomatic premises are inviolable, but all bets are off once the person steps out into the street). It would be interesting to see what sort of instructions are being cabled out of the State Department on this, though — obviously it doesn’t look good to turn back dissidents to the lions.

Transcript of today’s argument before the Supreme Court here.  Not a lot of fireworks.  The key takeaway: the Court (including some on the left) didn’t seem to have much problem with section 2 of the Arizona law, which requires law enforcement to undertake immigrant status determinations in the course of stops or arrests where there is reasonable suspicion that a person is in the United States illegally.  (Here’s the SB 1070 text; here’s an excellent summary of the law and issues from Ben Winograd at the Immigration Policy Center.)

Important to several of the justices on this score: the fact that there would be no necessary consequence to the status determination as made by state law enforcement.  Where Arizona deemed someone to be in the country illegally, it could inform federal immigration authorities, but nothing would require the feds to follow up.

(“Papers, please” is not entirely accurate, insofar as an officer first requires some other reason to stop, detain, or arrest an individual – suspected undocumented status by itself isn’t enough to initiate the process.  But no better label has stuck.)

It’s not nearly as clear where the Court will come out on section 3, which in a roundabout way makes undocumented status a crime under state law (it’s not under federal).  If the Arizona wins on section 2 but loses on section 3, its victory will be largely symbolic.

Not a lot of talk about the foreign relations aspects of the case.  Scalia duly made the “heckler’s veto” argument with respect to dormant foreign affairs preemption: “So we have to — we have to enforce our laws in a manner that will please Mexico. Is that what you’re saying?”  Don Verrelli fumbled the answer, weakly adverting to the Founders (who had no views of any kind on federal control of immigraton, the power over which is not found in the Constitution itself).

Justice Scalia supplied the only erstaz entertainment, with a riff analogizing undocumented aliens to bank robbers.  The feds are going after only the professional bank robbers (read: criminal aliens), that doesn’t mean the state can’t go after the amateurs.  This is about as helpful as “broccoli“.  States have authority to go after bank robbers, professional and amateur; the whole question here is whether states have the authority to go after undocumented aliens.

Finally, Scalia also apparently believes in the enforcement of borders between states:

What does sovereignty mean if it does not include the ability to defend your borders?. . . Arizona is not trying to kick out anybody that the Federal government has not already said do not belong here. And the Constitution provides – even — even with respect to the Commerce Clause — “No State shall without the consent of Congress lay any imposts or duties on imports or exports except,” it says, “what may be absolutely necessary for executing its inspection laws.” The Constitution recognizes that there is such a thing as State borders and the States can police their borders . . .

Look forward to something pretty extreme from him and Thomas; I suspect the rest will split the difference.

I’ve got an op-ed in the NY Times today on the SB 1070 case, the title of which might have been “Let Arizona Law Die a Natural Death.”  In 750 words there wasn’t room to engage the key doctrinal foreign relations elements of the case.  This is central to the Obama Administration’s case against the law: Immigration inherently implicates foreign relations; foreign relations is constitutionally insulated from interference; SB 1070 unconstitutionally interferes with foreign relations.  The mantra: the nation must “speak with one voice” in the context of foreign relations.

The foreign relations argument is expertly made in an amicus brief submitted by a group of former top foreign policy officials led by Madeleine Albright and William Cohen.  (On the Albright brief are Supreme Court veterans Seth Waxman and Paul Wolfson. This is a lopsided case in terms of the quality of briefs, those opposed to SB 1070 completely outclassing those in support.)  In proceedings before the district court, then-Deputy Secretary of State James Steinberg also filed this declaration laying out the case that SB 1070 damages foreign policy.

No doubt immigration inherently involves relations with other countries.  There’s also no question that SB 1070 has several countries — notably Mexico — very unhappy.  But that doesn’t inexorably lead to the conclusion that SB 1070 interferes with national foreign relations.

The Albright brief and Steinberg declaration assert three types of foreign policy damage: 1) other countries will undertake reciprocal retaliation against US nationals in their jurisdictions, 2) SB1070 undermines US efforts to advance human rights in multilateral fora, and 3) the Arizona measure “undermines the willingness of foreign states to engage with the United States to advance US foreign policy goals.”

The first makes sense in theory, but is highly unlikely in this context.  Neither Albright nor Steinberg can supply examples on the ground.  There aren’t a lot of US citizens who are illegal immigrants in other countries, so direct tit-for-tat (think Mexico adopting its own version of SB1070) doesn’t make a lot of sense.  Nor are other states going to risk US business and tourist dollars as part of this cause by harassing US visitors in some non-specific way.

The second harm is more plausible.  International human rights groups have been all over the state immigration laws, and there have been critical pronouncements out of the UN and OAS.  But the US takes a pretty marginal hit on this, one that it seems willing to take in a number of other contexts.

The last would be most persuasive, if only it were true. The best Jim Steinberg can do on this: “The Mexican Senate stated it would postpone review of a U.S.-Mexico agreement on emergency management cooperation to address natural disasters and accidents signed on October 23, 2008 because of the new Arizona law.”  I don’t think it’s demeaning of emergency management to say that’s not exactly at the center of our bilateral relations with Mexico.  Steinberg also noted the cancellation of a meeting of border state governors in 2010, but that isn’t really about national foreign relations anyway.

The bottom line: SB 1070 hasn’t really hurt US foreign policy, at least not enough to justify departing from our usual rules of federalism.  (Remember: If it were really a problem, Congress could always make SB 1070 go away through express legislative preemption.)  This is ultimately because other countries know that Arizona is going it alone on this.  At a joint press conference in May 2010, Mexican President Felipe Calderon registered his opposition to SB1070 (as Steinberg and Albright note), but then he and Obama presented a united front in that opposition, almost as if Arizona were a third sovereign against which the two heads of state were aligned (and more or less equally powerless to influence).  In these circumstances, it makes no sense for Mexico to take out any offense against the USG or the US as a whole.  That takes the rug out from under foreign affairs preemption.

It’s a far cry from Hines v. Davidowitz, the 1941 decision which figured centrally in the 9th Circuit’s decision below.  Hines struck down a Pennsylvania alien registration regime tracking federal law.  Arizona’s law is also (at least ostensibly) consistent with federal law, as proponents are quick to argue.  So Hines supplies a good response: consistency with federal law doesn’t insulate a state immigration measure from constitutional attack.

I don’t think Hines is going to stick here.  The obvious way to distinguish it: that was 1941, this is 2012.  In 1941, you couldn’t have the states messing with anything, most especially with would-be enemy alien German nationals.  It was way-too hair-trigger a context in which to tolerate the amateur foreign policy backgrounds of state officials.

Today, we may still have foreign-policy amateurs among state officials (AZ governor Jan Brewer likely at the head of the line).  But we’re hardly on the road to WWIII.  I think there a good chance that the Court is going to strike down SB1070′s registration provision, under which aliens who fail to comply with federal registration requirements are subject to penalties under state law, but I doubt it will rely on Hines, which is getting its last hurrah in the run-up (the Court is much more likely to take up NYU’s Nancy Morawetz’s inventive tack on that in her brief for the Leadership Conference on Civil and Human Rights here).

Finally, it’s interesting that Mexico (its offense notwithstanding) is not among those filing amicus briefs in favor of the Administration’s case.  The GOM knows how to put fancy US lawyers to work; it submitted briefs in proceedings before both the district court and the 9th Circuit.  I suspect it stayed out because of the atmospherics.  SB1070 supporters have tried to tar foreign affairs preemption as a “heckler’s veto“, a foreign heckler no less.  To the extent it is, better to have the heckler out of the room.  I don’t think Mexico’s non-participation will make any difference, but it was almost surely a conscious choice.

The Supreme Court hears arguments in the Arizona SB 1070 case on Wednesday.  I’ll have some things to say on the merits over the next couple of days, but first a lament: why did the Court feel like it had to take the case in the first place?

It could have waited. There are a bunch of cases making their way through the lower-court pipeline. Sitting out this round would have allowed for more “percolation”, in Court-speak — the chance to get either a greater diversity of views from the lower courts or the development of a consensus among them. (It also could have waited for a case in which Elena Kagan is not recused — there is a very real chance of a 4-4 deadlock on this one, in which case the Court will have to take a do-over.)

In the interim, the facts might have changed on the ground.  The anti-immigrant campaign at the state and local level looks to be running out of steam.  SB1070 was followed by a small handful of copycat measures, notably in Georgia, South Carolina, and Alabama. But a similar law recently went down in Mississippi, and other states have also managed to deflect anti-immigrant sentiment short of  legislation. That’s not for any love of immigrants. More out of a recognition that these laws implicate substantial economic costs and risk damaging state brands — not a good strategy for moving ahead in the global economy.

The Court’s intervention runs the risk of taking this natural evolution off its tracks.  If the Court upholds SB 1070 (or, more likely, upholds some important components thereof), it will be giving a big green light to Kris Kobach et al and depriving opponents of an important argument (namely, that the laws are unconstitutional). A win for Arizona at the Court would probably spur at least a short term uptick in state and local activity.

If, on the other hand, the Court quashes SB 1070, it will energize restrictionists in Washington, running the risk of unfavorable federal immigration legislation. (More on that in a subsequent post.)

So why did the Court take the case? A veteran Supreme Court litigator who predicted this, unlike me (memo to self: do not include easily falsifiable predictions in blog post headlines!) explained it to me as a matter of economies of scale: once the Court reads into an issue like this — the kind it otherwise leaves alone for decades — it likes to tackle other aspects on a compressed timeline. Sort of a clumping theory of Supreme Court docket management.

This fits the template.  After a 30-year silence, the Court read into immigration federalism last term with Whiting v. Chamber of Commerce, which presented a much narrower question of statutory preemption.  After that practice round, the Court must feel up to speed, equipped to take on the much bigger questions presented in the Arizona case.  We’ll see.

The answers to my questions last week were no further away than the latest copy of the AJIL and an important article by Emilie Hafner-Burton, David Victor, and Yonatan Lupu on Political Science Research and International Law: The State of the Field.  This is a must-read for anyone interested in IR/IL, past and future.

As for the “war on paradigms”, it has apparently been won, decisively.  The major schools of IR theory are not (as was once commonly the case) set out as optics.  In fact, the words “realism,” “liberal”, and “constructivism” are almost entirely absent from the piece.  This can only have been a conscious choice.  I wonder whether the use of “political science” in the title rather than “IR theory” is of some intentional significance. Perhaps the subfield is redefining itself altogether?

That said, not surprisingly, the isms cast a shadow here.  The apparent axis is along four “faces” of power: 1) the ability to coerce, 2) the ability to influence decisionmaking, 3) “the ability to shape what people want and believe, such as through the spread of norms and the creation of interests and identities, and 4) “discursive” power, through the creation of knowledge and social customs.  Sound familiar?  There is something of a refrain in which “scholarship that works with the third and fourth faces of power” points in a different direction than that working with the first two, for which read: constructivism v. realism.

The piece duly notes notes that those third and fourth faces account for the role of nonstate actors in international politics, as constructivism does.  But nods in that direction seem mostly parenthetical. The skepticism surfaces in the course of highlighting areas for interdisciplinary collaboration, including with respect to private actors:

For the last two decades, both fields have devoted substantial attention to NGOs as important private actors, and especially to public interest groups that have mobilized transnationally to press for arms control (for example, the ban on land mines), protection of human rights (for example, the rights of women), and all manner of environmental goals. We are concerned that this focus—which arises in part because many scholars working in these areas are also normatively committed to the ideals of the most active NGOs—has been prone to overstate the importance of NGOs.

Maybe, maybe not.  No doubt most IL/IR scholars are sympathetic to mainstream NGO roles (and some scholarship on NGOs uncritically accepts their universalism), but I’m not sure that translates into an exaggeration of NGO power.  The counterbalance is the interest both IL but perhaps especially IR scholars have in not upsetting received wisdom on the centrality of state power.   Non-state actors don’t fit very well into 2×2′s.  The skepticism seems oddly untethered to anything empirical: if NGOs aren’t powerful, then IR should be able to prove it.

Perhaps the problem is that, “[i]n practice, sifting the effect of international law from other influences on behavior is so complex that essentially all of the political science insights about the causal mechanisms at work are tailored to the particular issue areas where the analysts in question are experts.”  In other words there may not be much that is generalizable, or at least not much that has been generalized, about particular case studies.  Except, that is, where there is a larger n set and an institutional setting that allows for some number crunching.  The piece seems to favor trade law, arms control, international tribunals, and environmental and human rights agreements.  That is where political science and law enjoy a fruitful present and future.

By contrast, there isn’t much discussion on the potential for collaboration in such areas as international criminal law; international financial regulation; international migration; international health regulation; everything cyber; anything in which “pressure groups” are genuinely transnational, as opposed to “domestic” and thus easily cabined in two-level games.  I’m sure IR has a lot to say about these (some of which has already been said).  But I’m not sure what the takeaway is for IL scholars, other than to understand the importance of non-doctrinal analysis.  This piece by Ken Abbott and Duncan Snidal on codes of conduct and “new governance” regimes supplies an example: not IR in any distinctive way (as far as I can tell), but a very useful systematization.  One might even feel nostalgic for the isms, especially as an outsider to IR (and thus less invested in the tournament) – they set out interesting templates for thinking critically through IL puzzles.

And what about normativity?  Political science refrains from normative assessment where law has long been comfortable with it.  Is there some sort of middle ground?

The European Court of Human Rights is getting a lot of play today with its decision to okay the extradition of Abu Hamza to the US.  To much less (read: no) fanfare, it also denied a petition to compel external voting rights in Greek parliamentary elections for Greek citizens living outside of Greece in the case of Sitaropoulos and Giakoumopoulos v. Greece (press release here).  The opinion includes an excellent overview of where we are on external voting, at least among European states.  The short answer: it’s come along way, but we’re not quite at the point at which it is required as an individual right.

The applicants were making the case for a right to vote in their place of external residence (here, Strasbourg, where they both work as EU civil servants).  They premised their case on the fact that:

they followed political developments in their country of origin with particular interest and wished to maintain close ties with Greece. In particular, they pointed out that they were registered on the electoral roll in Greece, held valid Greek passports, owned immovable property in Greece on which they paid income tax and were still authorised to practise as lawyers in Greece. They maintained that being unable to vote in the Greek parliamentary elections from their State of residence constituted interference with their voting rights, in breach of both the Greek Constitution and the Convention. That interference arose out of the fact that they would have to travel to Greece in order to exercise their right to vote. The applicants acknowledged that they could fly to Samos and Thessaloniki, their respective home towns, for parliamentary elections. However, that possibility did not alter the substance of their claim, namely that they would thereby incur significant expense and that their professional and family life would be disrupted since they would be obliged to be away from their work and families for a few days.

Sounds like a self-governance claim to me.  The Greek government countered with the standards argument against external voting, that non-resident citizens “could not legitimately argue that they were affected by the decisions of the country’s political institutions to a greater extent than Greek citizens living in Greece.”

As described by the ECHR, most European countries now enable external voting (in fact only eight bar it altogether, none of them major and some of them micro, like Andorra and San Marino).  The Venice Commission and the Council of Europe have been pushing for facilitating the franchise by external populations.  But the Court couldn’t find enough there to require under the Convention that voting rights be accommodated in place of foreign residence.  The ECHR implied, however, that external residents cannot be denied the franchise altogether, even if it means getting on an airplane to exercise it.  ”As to the disruption to the applicants’ financial, family and professional lives that would have been caused had they had to travel to Greece in order to exercise their right to vote in the 2007 parliamentary elections, the Court is not convinced that this would have been disproportionate to the point of impairing the very essence of the voting rights in question.”

Daniel Nexon has a gem of a short review of books by Samuel Barkin and Charles Glaser in the December 2011 edition of Perspectives on Politics.  I am enough of an outsider to International Relations theory to have missed the “war on paradigmism”.  I’m glad to hear that it has apparently been won.  The next challenge, according to Nexon:

What should we do with the remnants of the last war—articles and books whose contributions to collective knowledge will be difficult to parse once “liberal institutionalism” becomes about as meaningful to the average reader as “phlogiston”? How should we (and should we) understand the “isms” if we no longer accept their status as paradigms? What the heck is “puzzle-driven research” if we have no baseline theoretical expectations, let alone “analytical eclecticism,” without heterogeneous schools of thought?

Good questions.  What’s remains of IR if the models are taken off the table, beyond some very general rationalist premises?  Maybe it looks something more like legal scholarship, which might itself dba as “puzzle-driven research”.

I wonder if there might also be a cautionary lesson here for legal academics. International law may have become a little bewitched by the prospect of our own isms and the academic respectability that comes with them.  The downside is a scholaticism that doesn’t always move knowledge along (see this interesting piece by Larry Meade, also in Perspectives).  We’re along way from that at the moment, but it’s not hard to imagine our going down this path, too.