the terms therein has inspired frequent academic debate. Though the Supreme Court has given much attention to the legal issues arising from this provision of the Constitution, many problematic issues remain unresolved. Many critics argue that the standing requirements imposed by the Case or Controversy Clause allow judges to push off difficult issues, ponder the merits of a case before parties had fair opportunity to litigate, and walk away from the responsibility of applying laws that judges may find distasteful. Text Article III, Section 2, Clause 1 of the Constitution states: This clause, in addition to setting out the scope of the jurisdiction of the federal judiciary, prohibits courts from issuing advisory opinions, or from hearing cases that are either unripe, meaning that the controversy has not arisen yet, or moot, meaning that the controversy has already been resolved. History of legal application The earliest expression by the United States Supreme Court of adherence to this requirement came during the presidency of George Washington. Washington sent a letter to the Court asking for their approval should he choose to seek advice from them from time to time on matters that might not come before the Court in a timely manner. Chief Justice John Jay wrote in his response that, although the members of the Court had great confidence in the ability of the president to receive appropriate advice from his executive officers, the Court itself was constitutionally bound not to go beyond its role as an arbiter of judicial questions. The most famous case setting forth the parameters of this requirement is Muskrat v. United States, 219 U.S. 346 (1911), in which the Court held that when Congress paid the legal bills for both the plaintiffs and the defendant (in this case the U.S. Treasury department, by designation), then there was no real controversy between the parties, and a judgment of the Court would be the equivalent of an advisory opinion. The boundaries of the "case and controversy" clause are open to dispute. For instance, the Court has held that where the controversy between parties has ceased because of a change in facts, it has no jurisdiction. However, where the case or controversy ceases—or, in legal terms, is "mooted"—after a case is filed, the Court may render a decision in the interest of justice. In Roe v. Wade, for instance, the Court applied the mootness exception for cases "capable of