Astrue v. Ratliff and the Death of Strong Purposivism

According to conventional wisdom, the Supreme Court is presently embroiled in an interpretive conflict between textualists, on the one hand, who believe that “the Constitution, properly understood, requires judges to treat the clear import of an enacted text as conclusive, even when the text fits poorly with its apparent background purposes,” 1 and purposivists (or more precisely, “strong purposivists”), on the other, who believe that “the ‘letter’ (text) of a statute must yield to its ‘spirit’ (purpose) when the two conflict[].” This apparent philosophical divide has led one scholar to remark that “textualism has never taken hold as the Court’s single, controlling interpretive method,” and further, that “interpretive consensus” among the Justices “seem[s] impossible.” At first glance, Astrue v. Ratliff, 6