During the past quarter century there has been a constant acceleration in legal periodical comment concerning statutory construction. Judges, practicing attorneys and law professors all have echoed basic dissatisfaction with the operation and application of the rules of statutory interpretation. Some would return to the "safe old ground" of literal interpretation; others would find relief in an expanded use of extrinsic aids; all find the process in a state of confusion and disintegration.
Frank E. Horack Jr.,
Cooperative Action for Improved Statutory Interpretation,
3 Vanderbilt Law Review
Available at: https://scholarship.law.vanderbilt.edu/vlr/vol3/iss3/22