the Tenth Amendment. We must consider what this country has become in deciding what that amendment has reserved. Justice Willis Van Devanter and Justice Mahlon Pitney dissented without issuing an opinion. Reception Many legal analysts have argued that the decision implies that Congress and the President can essentially amend the Constitution by means of treaties with other countries. These concerns came to a head in the 1950s with the Bricker Amendment, a series of proposed amendments that would have placed restrictions on the scope and ratification of treaties and executive agreements entered into by the United States. More recently, a similar provision has been proposed as the fourth article of the Bill of Federalism, a list of ten proposed amendments drafted by law professor Randy Barnett. Legal scholar Judith Resnik contests the implication that Missouri allows for treaties to expand the federal government's power, arguing that in the decades since the decision, courts have ruled that the Commerce Clause of the U.S. Constitution provides Congress with broader regulatory power without the need for a treaty. Jurist and law professor Thomas Healy has suggested that Missouri may not be good law, meaning more recent decisions could overturn the ruling and establish new limits on the Treaty power. See also Louis Marshall, New York lawyer who submitted an amicus curae brief to the U.S. Supreme Court on Missouri v. Holland on behalf of the Association for the Protection of the Adirondacks List of United States Supreme Court cases, volume 252 Living Constitution Bricker Amendment, one of several unsuccessful attempts during the 1950s to restrict the ability of the United States government to expand its power via treaties Reid v. Covert, a 1957 case which stated that no treaty can come in direct violation of the United States Constitution, a partial limitation of the ability of the United States to use treaties Medellin v. Texas (2008), U.S. Supreme Court case that casts some doubt on how broadly Missouri v. Holland can be applied. Texas had ignored obligations of the United States under a convention, despite a relevant presidential order and a finding of the International Court of Justice. The individual defendant (who had been sentenced to death) was held by the courts, including the Supreme Court, not to have any personal rights to challenge his conviction because of this breach of the United States' international obligations Bond v. United States (2014), raised similar