The Supreme Court’s recent decisions in New York State Rifle & Pistol Ass’n v. Bruen (2022) and Dobbs v. Jackson Women’s Health Organization (2022) have catalyzed a profound reorientation in American constitutional interpretation. Both cases, though arising from distinct doctrinal contexts—Second Amendment rights and abortion, respectively—signal a decisive turn away from precedent-based balancing and toward a methodology that privileges history and tradition as the primary arbiters of constitutional meaning. Yet, as leading legal scholarship demonstrates, this shift is neither unproblematic nor internally consistent. In this article, I analyze the constitutional reasoning in Bruen and Dobbs, critically engage with the emerging scholarly critiques, and propose a new interpretive frame: a Contextualized Historical-Structural Approach that seeks to reconcile the virtues of historical inquiry with the demands of principled, transparent, and adaptable constitutional adjudication.
I. The Turn to History and Tradition: Methodological Convergence and Divergence
Both Bruen and Dobbs exemplify the Supreme Court’s increasing reliance on history and tradition as the touchstone for constitutional rights. In Bruen, the Court rejected the familiar two-step, means-end scrutiny for Second Amendment cases, instead requiring that modern gun regulations be justified by direct analogy to historical practices. The majority opinion, authored by Justice Thomas, insisted that the government must “affirmatively prove that its firearms regulation is part of the historical tradition that delimits the outer bounds of the right to keep and bear arms” (Blocher and Ruben 2025, 1782). Similarly, in Dobbs, the majority, led by Justice Alito, grounded its rejection of a constitutional right to abortion in the absence of such a right in the nation’s “history and tradition,” concluding that abortion was not “deeply rooted” in the American legal tradition at the time of the Fourteenth Amendment’s ratification (Schneller et al. 2024, 312).
Despite this methodological convergence, the cases diverge in their treatment of precedent and the scope of judicial power. Bruen is evolutionary, building on District of Columbia v. Heller (2008) without overturning longstanding precedent, whereas Dobbs is revolutionary, explicitly discarding nearly fifty years of precedent and signaling a willingness to revisit other substantive due process rights (Columbia Law Review 2025, 1123). This divergence underscores the Court’s selective deployment of history and tradition, raising questions about the coherence and legitimacy of its interpretive methodology.
II. Critiques of the Historical-Analogical Method
Legal scholars have subjected the Court’s new historical-analogical approach to searching critique. Blocher and Ruben (2025) argue that Bruen’s “originalism-by-analogy” does not, in practice, constrain judicial discretion; rather, it enables subjectivity and unpredictability, as courts struggle to identify relevant historical analogues for modern regulations. The lack of clear standards for what constitutes a “sufficiently similar” historical law has led to inconsistent outcomes in lower courts, with empirical studies documenting doctrinal instability and unpredictability (Blocher and Ruben 2025, 1790; “One Year Post-Bruen” 2023).
Similarly, the historical inquiry in Dobbs has been criticized for its selective and sometimes ahistorical use of the past. Schneller et al. (2024) contend that the majority’s account of abortion’s legal status at the time of the Fourteenth Amendment is contestable and that the decision’s narrow reading of substantive due process threatens the security of other unenumerated rights. The Court’s approach, they argue, risks reducing constitutional interpretation to a contest over historical narratives, with little guidance for resolving conflicts in the historical record (Schneller et al. 2024, 320).
Moreover, recent scholarship has identified a “hidden equality analysis” at work in both cases: when faced with conflicting historical traditions, the Court quietly applies reasoning akin to equal protection analysis, sometimes treating outlier laws as constitutionally suspect and sometimes incorporating them into the tradition (Columbia Law Review 2025, 1135). This implicit balancing, masked as neutral historical inquiry, undermines the transparency and predictability of constitutional adjudication.
III. The Limits of Existing Interpretive Frameworks
The ascendancy of history and tradition in Bruen and Dobbs reflects the dominance of originalism in contemporary constitutional theory. Yet, as Barnett and Solum (2023) and others have noted, originalism itself is not monolithic; it encompasses a range of approaches, from “public meaning” originalism to “framework originalism,” each with different implications for judicial discretion and adaptability. Critics of originalism warn that rigid historicism may fail to address contemporary problems, while living constitutionalism is faulted for granting judges excessive discretion (Barnett and Solum 2023, 145; Baude and Sachs 2022, 102).
The Court’s recent decisions expose the limitations of both approaches. The historical-analogical method, as applied in Bruen and Dobbs, neither fully constrains judicial discretion nor provides a principled basis for resolving novel constitutional questions. At the same time, the rejection of balancing tests and the narrowing of substantive due process threaten to erode the protection of fundamental rights not explicitly enumerated in the Constitution (Schneller et al. 2024, 325).
IV. Toward a Contextualized Historical-Structural Approach
In light of these developments, I propose a new interpretive frame: the Contextualized Historical-Structural Approach. This framework seeks to integrate the insights of historical inquiry with the structural principles and purposes of the Constitution, while maintaining transparency and adaptability in constitutional adjudication.
First, this approach recognizes the value of history and tradition as sources of constitutional meaning, but insists that historical analysis must be contextualized—attentive to the social, political, and technological changes that shape the application of constitutional principles. Rather than searching for direct analogues, courts should identify the underlying purposes and values animating historical practices and assess their relevance to contemporary circumstances (Blocher and Ruben 2025, 1802).
Second, the approach incorporates structural analysis, examining how constitutional provisions interact with one another and with the broader architecture of government. This structural perspective enables courts to consider the implications of their decisions for federalism, separation of powers, and the protection of individual rights, thereby avoiding the pitfalls of narrow textualism or selective historicism (Barnett and Solum 2023, 150).
Third, the Contextualized Historical-Structural Approach demands transparency in judicial reasoning. When historical evidence is ambiguous or contested, courts should candidly acknowledge the limits of historical inquiry and articulate the normative principles guiding their decisions. This transparency fosters legitimacy and predictability, while allowing for principled adaptation to new challenges (Columbia Law Review 2025, 1140).
Finally, this approach encourages a dialogic relationship between courts and the political branches, recognizing that constitutional meaning is shaped not only by judicial interpretation but also by democratic deliberation and social practice. By situating constitutional adjudication within this broader context, the framework balances respect for tradition with the need for constitutional evolution.
V. Conclusion
The Supreme Court’s decisions in Bruen and Dobbs mark a watershed in American constitutional interpretation, entrenching history and tradition as the primary arbiters of constitutional rights. Yet, as leading scholarship reveals, the Court’s historical-analogical method is fraught with indeterminacy and subjectivity, threatening both the coherence and legitimacy of constitutional law. The Contextualized Historical-Structural Approach offers a way forward: by integrating historical inquiry with structural analysis and transparent reasoning, it provides a principled and adaptable framework for constitutional adjudication in a changing society.
Brandon L. Blankenship is an assistant professor, continuing legal education presenter, and business educator. He and his wife Donnalee live on their hobby farm south of Birmingham, Alabama.
Barnett, Randy E., and Lawrence B. Solum. 2023. “Originalism After Dobbs, Bruen, and Kennedy: The Role of History and Tradition.” Northwestern University Law Review 117: 143–188.
Blocher, Joseph, and Eric Ruben. 2025. “Originalism-by-Analogy and Second Amendment Adjudication.” Yale Law Journal 134: 1775–1832.
Columbia Law Review. 2025. “How Bruen and Dobbs Resolved Opposing Historical Traditions Through Hidden Equal Protection Analysis.” Columbia Law Review 125: 1121–1150.
Schneller, Hillary A., Diana Kasdan, Risa E. Kaufman, and Alexander Wilson. 2024. “Dobbs v. Jackson Women’s Health Organization: Reckoning with its Impact and Charting a Path Forward.” University of Pennsylvania Journal of Constitutional Law 26: 311–355.
“One Year Post-Bruen: An Empirical Assessment.” 2023. Duke Law Journal 72: 201–245.
Baude, William, and Stephen E. Sachs. 2022. “Originalism and the Law of the Past.” Law and History Review 40: 101–130.
The concepts of “freedom” and “liberty” occupy a central place in the political discourse of the American founding era, yet their distinction remains a subject of scholarly debate. While these terms are often used interchangeably in both the Federalist and Anti-Federalist Papers, a closer examination of their philosophical, linguistic, and historical contexts reveals nuanced differences that reflect deeper ideological divides regarding the nature of self-government, the structure of political authority, and the protection of individual rights.
Linguistic and Philosophical Foundations
The etymological roots of “liberty” and “freedom” provide an initial point of distinction. “Liberty,” derived from the Latin libertas and Old French liberté, is historically associated with legal and institutional dimensions of self-rule, emphasizing the rights and privileges conferred by membership in a political community. In contrast, “freedom,” with its Old English origin (frēodōm), connotes a more personal or existential state, often linked to individual autonomy and the absence of external restraint (Skinner 1998; Berlin 1969). This linguistic distinction is reflected in the broader philosophical literature, where “liberty” is frequently tied to the structure and limits of political authority, while “freedom” is associated with the individual’s capacity for self-determination (Berlin 1969; Pettit 1997).
Isaiah Berlin’s influential distinction between negative and positive liberty further illuminates these concepts. Negative liberty, or “freedom from” interference, aligns with the classical liberal tradition and is often mapped onto the term “freedom.” Positive liberty, or “freedom to” realize one’s own potential or participate in collective self-governance, resonates with the republican tradition and is more closely associated with “liberty” as a political and civic ideal (Berlin 1969; Pettit 1997). However, as scholars have noted, the mapping of these philosophical distinctions onto the terms “freedom” and “liberty” is not always consistent, particularly in the context of eighteenth-century American political thought (Skinner 1998; Gienapp 2018).
Federalist Conceptions: Liberty as Ordered Self-Government
The Federalist Papers, authored by Hamilton, Madison, and Jay, articulate a vision of liberty that is fundamentally tied to the structure of government and the rule of law. For the Federalists, liberty is not simply the absence of government interference, but the product of a well-constructed constitutional order that prevents the concentration and abuse of power. Madison, for example, famously asserts that “justice is the end of government… until liberty be lost in the pursuit” (Federalist No. 51), emphasizing that liberty is preserved through a system of checks and balances, federalism, and the separation of powers (Madison 1788; Rakove 1996).
In this framework, liberty is a collective good, secured by institutions that channel and restrain both governmental and popular power. The Federalists acknowledge that liberty enables the formation of factions, but argue that the solution is not to suppress liberty, but to control its effects through a large, diverse republic (Federalist No. 10). Thus, liberty is conceived as the condition in which individuals are protected from arbitrary rule, not by minimizing government, but by ensuring its accountability and representativeness (Rakove 1996; Wood 1969).
Anti-Federalist Conceptions: Freedom as Local Autonomy and Non-Domination
The Anti-Federalist Papers, in contrast, foreground the dangers of centralized authority and the erosion of local autonomy. For the Anti-Federalists, freedom is closely tied to the ability of individuals and states to govern themselves without undue interference from a distant federal government (Storing 1981). They argue that true liberty requires not only the absence of oppression, but also the active capacity for self-government at the local level. Brutus, for instance, warns that the proposed Constitution would create a government with “absolute and uncontrollable power,” threatening both state sovereignty and individual freedoms (Brutus No. 1).
The Anti-Federalists’ conception of liberty aligns with the republican ideal of non-domination, where freedom is understood as protection from arbitrary or unchecked authority (Pettit 1997). They insist that only small, local republics can adequately represent the interests of the people and safeguard their liberties. The demand for a bill of rights reflects their concern that explicit protections are necessary to prevent the encroachment of federal power on individual and state rights (Storing 1981; Cornell 1999).
Contemporary Scholarly Interpretations
Recent scholarship underscores that the distinction between freedom and liberty in the founding era is both context-dependent and ideologically charged. Linguistic analyses of founding-era texts reveal that “liberty” was more frequently used to denote political and civil rights within a constitutional order, while “freedom” could refer to both personal autonomy and collective self-determination (Gienapp 2018; COFEA Project). Intellectual historians caution against projecting modern, individualistic notions of liberty onto the Founders, emphasizing instead their communitarian understanding of self-government and the public good (Gienapp 2018; Wood 1969).
Legal scholars have critiqued originalist approaches that equate liberty with deregulation, arguing that the Founders saw a “free state” as one where the people, through representative institutions, could regulate their own rights in the public interest (Gienapp 2018). The ongoing tension between local autonomy (“freedom”) and national unity (“liberty”) reflects deeper, unresolved debates within the American constitutional tradition (Cornell 1999).
Conclusion
In sum, while “freedom” and “liberty” are often used interchangeably in the Federalist and Anti-Federalist Papers, their distinction lies in the emphasis placed on individual autonomy versus collective self-government, the structure of political authority, and the means by which rights are secured. The Federalists conceive of liberty as the product of a well-ordered constitutional system that balances competing interests and prevents tyranny, while the Anti-Federalists emphasize freedom as local autonomy and protection from centralized power. Contemporary scholarship highlights the importance of situating these terms within their historical and philosophical contexts, recognizing that the American founding tradition is marked by an enduring ambivalence—and creative tension—between the ideals of freedom and liberty.
Brandon L. Blankenship is an assistant professor, continuing legal education presenter, and business educator. He and his wife Donnalee live on their hobby farm south of Birmingham, Alabama.
Berlin, Isaiah. 1969. Two Concepts of Liberty. Oxford: Oxford University Press.
Cornell, Saul. 1999. The Other Founders: Anti-Federalism and the Dissenting Tradition in America, 1788–1828. Chapel Hill: University of North Carolina Press.
Gienapp, Jonathan. 2018. The Second Creation: Fixing the American Constitution in the Founding Era. Cambridge, MA: Harvard University Press.
Madison, James. 1788. “Federalist No. 51.” In The Federalist Papers, edited by Clinton Rossiter. New York: Signet Classics.
Pettit, Philip. 1997. Republicanism: A Theory of Freedom and Government. Oxford: Oxford University Press.
Rakove, Jack N. 1996. Original Meanings: Politics and Ideas in the Making of the Constitution. New York: Vintage.
Skinner, Quentin. 1998. Liberty Before Liberalism. Cambridge: Cambridge University Press.
Storing, Herbert J., ed. 1981. The Complete Anti-Federalist. Chicago: University of Chicago Press.
Wood, Gordon S. 1969. The Creation of the American Republic, 1776–1787. Chapel Hill: University of North Carolina Press.
The case method, which has served as the cornerstone of American legal education since its introduction at Harvard Law School in the late nineteenth century, is predicated on the close analysis of appellate court decisions—many of which are, by their nature, narratives of legal failure or conflict (Stevens 1983; Kimball 2006). This pedagogical approach, while lauded for fostering critical thinking and doctrinal mastery, has been the subject of sustained critique regarding its psychological impact on law students, particularly in relation to the development of cynicism and risk-avoidant thinking.
The Case Method: Pedagogical Foundations and Critiques
The case method was designed to cultivate inductive reasoning, critical analysis, and comfort with legal ambiguity by immersing students in the study of judicial opinions (Kimball 2006). Through the Socratic method, students are challenged to dissect the reasoning behind judicial outcomes, often focusing on the errors, misjudgments, or failures of parties and lower courts (Schwartz 2001). While this approach is intended to mirror the realities of legal practice, it has been critiqued for overemphasizing doctrinal analysis at the expense of practical skills and for insufficiently preparing students for the complexities of real-world lawyering (Sullivan et al. 2007).
Studying Failure: Psychological Impacts
Empirical research in professional education more broadly, and legal education specifically, suggests that repeated exposure to failure cases can have complex psychological effects. On one hand, the analysis of failure is a powerful tool for learning, prompting deeper cognitive engagement, metacognitive reflection, and the development of adaptive expertise (Meyer et al. 2013). However, when failure is presented without adequate scaffolding or within a punitive classroom climate, it can also engender negative affective responses, including anxiety, frustration, and diminished self-efficacy (Steenhuis et al. 2022). In the context of law school, where the error climate is often competitive and high-stakes, these negative emotions may be amplified, contributing to the development of cynicism and risk aversion (Krieger 2002).
Cynicism and Risk Aversion in Law Students
Longitudinal and cross-sectional studies of law student psychology have documented a marked increase in cynicism as students progress through their legal education (Krieger 2002; Sheldon and Krieger 2004). This cynicism is characterized by skepticism toward the motives of others, the legal system, and the possibility of achieving justice. The adversarial and critical nature of the case method, which privileges the identification of flaws and the anticipation of legal pitfalls, is frequently cited as a contributing factor (Sullivan et al. 2007). Moreover, the emphasis on precedent and the avoidance of error in legal reasoning can reinforce a risk-averse mindset, as students learn to prioritize caution and the minimization of liability over innovation or advocacy for systemic change (Hamilton 2013).
Research in educational psychology further supports the notion that exclusive focus on failure cases, without balancing narratives of success or resilience, can foster risk-avoidant thinking and undermine professional confidence (Steenhuis et al. 2022). While the ability to anticipate and mitigate risk is a valuable legal skill, excessive risk aversion may limit students’ willingness to pursue entrepreneurial or public interest careers, and may stifle the development of creative problem-solving abilities (Hamilton 2013).
Professional Identity Formation and the Limits of the Case Method
The process of professional identity formation in law school is deeply influenced by the curriculum, faculty role models, and peer interactions (Sullivan et al. 2007). The case method, by centering legal education on the analysis of failure and conflict, may inadvertently shape students’ sense of what it means to be a lawyer—privileging skepticism, adversarialism, and risk minimization over collaboration, ethical reflection, and social justice advocacy (Hamilton 2013). While some degree of cynicism and risk awareness is arguably necessary for effective legal practice, the challenge for legal educators is to balance these traits with the cultivation of resilience, ethical commitment, and a sense of professional purpose.
Conclusion
In sum, while the case method remains a powerful tool for developing legal reasoning, its focus on the failures of others can contribute to the development of cynicism and risk-avoidant thinking among law students. These psychological tendencies are not inevitable, but are shaped by the broader educational climate, the presence or absence of supportive pedagogical practices, and the integration of alternative approaches that highlight success, resilience, and ethical engagement. A more balanced and reflective pedagogy—one that integrates both failure and success cases, fosters a positive error climate, and supports professional identity formation—may better prepare law students for the complexities and demands of legal practice.
Brandon L. Blankenship is an assistant professor, continuing legal education presenter, and business educator. He and his wife Donnalee live on their hobby farm south of Birmingham, Alabama.
Hamilton, Neil W. 2013. “Professional Formation and the Case Method.” In Educating Lawyers: Preparation for the Profession of Law, edited by William M. Sullivan et al., 190–220. San Francisco: Jossey-Bass.
Kimball, Bruce A. 2006. The Inception of Modern Professional Education: C.C. Langdell, Harvard Law School, and the American Model of Legal Education. Chapel Hill: University of North Carolina Press.
Krieger, Lawrence S. 2002. “Institutional Denial about the Dark Side of Law School, and Fresh Empirical Guidance for Constructively Breaking the Silence.” Journal of Legal Education 52 (1): 112–29.
Meyer, Bernd, et al. 2013. “Learning from Errors: Theory and Educational Implications.” Frontiers in Psychology 4: 1–10.
Schwartz, Michael H. 2001. “Teaching Law by Design: How Learning Theory and Instructional Design Can Inform and Reform Law Teaching.” San Diego Law Review 38: 347–420.
Sheldon, Kennon M., and Lawrence S. Krieger. 2004. “Does Legal Education Have Undermining Effects on Law Students? Evaluating Changes in Motivation, Values, and Well-Being.” Behavioral Sciences & the Law 22 (2): 261–86.
Steenhuis, Ineke H., et al. 2022. “Learning from Failure: The Role of Error Climate and Feedback in Professional Education.” Studies in Higher Education 47 (2): 345–62.
Stevens, Robert Bocking. 1983. Law School: Legal Education in America from the 1850s to the 1980s. Chapel Hill: University of North Carolina Press.
Sullivan, William M., Anne Colby, Judith Welch Wegner, Lloyd Bond, and Lee S. Shulman. 2007. Educating Lawyers: Preparation for the Profession of Law. San Francisco: Jossey-Bass.
There is no single, authoritative national statistic on how many U.S. attorneys primarily practice criminal law. Federal data sources classify lawyers by employer or industry rather than by subject-matter specialization, and bar organizations’ tabulations are not standardized across jurisdictions. Consequently, the best evidence comes from large, peer-reviewed studies of the legal profession that measure practice fields within representative samples and from scholarly syntheses of that literature. Taken together, these sources converge on a consistent picture: criminal practice constitutes a small minority of the U.S. bar—on the order of the mid–single digits, rising when prosecutors and public defenders are included.
The most detailed field-distribution evidence comes from the American Bar Foundation’s landmark “Chicago Lawyers” research program, which repeatedly mapped the practice ecology of a large metropolitan bar. In the 1990s wave reported in Urban Lawyers, criminal work accounted for only a small slice of the bar overall, with criminal defense occupying a modest share of private practitioners and a substantial fraction of government lawyers working as prosecutors or public defenders; combined, the criminal sphere in that metropolitan sample fell in the mid–single digits of the total bar (Heinz et al. 2005). An earlier analysis of the same bar in the 1990s similarly found that criminal practice remained a numerically small specialty relative to civil litigation and business-related fields, underscoring the stability of this pattern over time (Heinz, Nelson, and Laumann 1998). These studies also show that criminal practice is disproportionately located in solo and small-firm settings and in the public sector—features that keep its overall share limited even as it is central within those segments of the profession (Heinz et al. 2005).
National syntheses reach parallel conclusions. Reviewing multiple empirical studies, Sandefur characterizes criminal practice as a minority field within the stratified “two hemispheres” of the bar, concentrated in “people law” practices and in government roles rather than in the corporate hemisphere that numerically dominates large-firm employment; in aggregate, this places criminal practice below one-tenth of the profession and typically in the mid–single-digit range (Sandefur 2007). Classic structural accounts of the U.S. profession likewise emphasize that only a small fraction of lawyers specialize primarily in criminal matters, with most legal labor allocated to civil and commercial work; historical estimates in these accounts have consistently located criminal practice as a minor share of the bar (Abel 1989).
Triangulating across these research traditions yields a cautious but defensible estimate for the contemporary United States: approximately 5–8 percent of practicing attorneys primarily practice criminal law. The lower end of that range reflects the small proportion of private practitioners who identify criminal defense as a principal specialty; the upper end reflects inclusion of the sizeable corps of prosecutors and public defenders within government lawyering. Because many civil practitioners occasionally handle criminal matters, the proportion of lawyers who ever do any criminal work is higher than the proportion whose primary practice is criminal. But as a share of the bar defined by primary specialization, the best academic evidence places criminal practice firmly in the single digits (Heinz et al. 2005; Heinz, Nelson, and Laumann 1998; Sandefur 2007; Abel 1989).
Brandon L. Blankenship is an assistant professor, continuing legal education presenter, and business educator. He and his wife Donnalee live on their hobby farm south of Birmingham, Alabama.
Abel, Richard L. 1989. American Lawyers. New York: Oxford University Press.
Heinz, John P., Robert L. Nelson, Rebecca L. Sandefur, and Edward O. Laumann. 1998. “The Changing Character of Lawyers’ Work: Chicago in 1975 and 1995.” Law & Society Review 32 (4): 751–775.
Heinz, John P., Robert L. Nelson, Rebecca L. Sandefur, and Edward O. Laumann. 2005. Urban Lawyers: The New Social Structure of the Bar. Chicago: University of Chicago Press.
Sandefur, Rebecca L. 2007. “Staying Power? The Persistence of Social Inequality in the U.S. Legal Profession.” Annual Review of Law and Social Science 3: 377–401.
A mechanism generally refers to a process, system, or structure by which something is accomplished or a result is achieved. In law and political science, mechanisms are procedural or structural means that enable or enforce certain outcomes.
Jury Trial as a Mechanism
A jury trial is a legal proceeding in which a group of ordinary citizens (the jury) is tasked with making findings of fact and rendering a verdict, while the judge oversees the process and rules on questions of law. This process is distinct from a bench trial, where a judge decides both the facts and the law.
The purpose of a jury trial is to provide a structured, impartial method for resolving disputes—whether criminal or civil—by relying on the collective judgment of peers rather than a single official. The stages of a jury trial (jury selection, presentation of evidence, deliberation, and verdict) form a procedural system designed to ensure fairness and transparency.
Jury Trial as a Legal Mechanism
In the context of legal and governmental systems, a jury trial functions as a mechanism for:
Fact-finding in legal disputes
Ensuring public participation in the justice system
Providing a check on government power and judicial authority
Safeguarding constitutional rights (as enshrined in the Sixth and Seventh Amendments in the U.S.)
Conclusion
A jury trial is indeed considered a mechanism—specifically, a procedural mechanism within the legal system for resolving disputes and protecting individual rights. It operates as a structured process that enables impartial decision-making by a group of citizens, serving both practical and constitutional functions in democratic societies.
Brandon L. Blankenship is an assistant professor, continuing legal education presenter, and business educator. He and his wife Donnalee live on their hobby farm south of Birmingham, Alabama.