prompt_front: Now, answer the following question based on the text below, only give me the answer and do not output any other words.

Question: How is electricity used in everyday life?

Read the following text and answer briefly.

Context 1: For other uses, see Electricity (disambiguation) 
"Electric" redirects here  For other uses, see Electric (disambiguation) 
Lightning is one of the most dramatic effects of electricity 
Electricity is the set of physical phenomena associated with the presence and motion of matter that has a property of electric charge  In early days, electricity was considered as being not related to magnetism  Later on, many experimental results and the development of Maxwell's equations indicated that both electricity and magnetism are from a single phenomenon: electromagnetism  Various common phenomena are related to electricity, including lightning, static electricity, electric heating, electric discharges and many others 
The presence of an electric charge, which can be either positive or negative, produces an electric field  The movement of electric charges is an electric current and produces a magnetic field 
When a charge is placed in a location with a non-zero electric field, a force will act on it  The magnitude of this force is given by Coulomb's law  Thus, if that charge were to move, the electric field would be doing work on the electric charge  Thus we can speak of electric potential at a certain point in space, which is equal to the work done by an external agent in carrying a unit of positive charge from an arbitrarily chosen reference point to that point without any acceleration and is typically measured in volts 
electronics which deals with electrical circuits that involve active electrical components such as vacuum tubes, transistors, diodes and integrated circuits, and associated passive interconnection technologies 
Electrical phenomena have been studied since antiquity, though progress in theoretical understanding remained slow until the seventeenth and eighteenth centuries  Even then, practical applications for electricity were few, and it would not be until the late nineteenth century that electrical engineers were able to put it to industrial and residential use  The rapid expansion in electrical technology at this time transformed industry and society, becoming a driving force for the Second Industrial Revolution  Electricity's extraordinary versatility means it can be put to an almost limitless set of applications which include transport, heating, lighting, communications, and computation  Electrical power is now the backbone of modern industrial society 
Long before any knowledge of electricity existed, people were aware of shocks from electric fish  Ancient Egyptian texts dating from 2750 BCE referred to these fish as the "Thunderer of the Nile", and described them as the "protectors" of all other fish  Electric fish were again reported millennia later by ancient Greek, Roman and Arabic naturalists and physicians  Several ancient writers, such as Pliny the Elder and Scribonius Largus, attested to the numbing effect of electric shocks delivered by catfish and electric rays, and knew that such shocks could travel along conducting objects  Patients suffering from ailments such as gout or headache were directed to touch electric fish in the hope that the powerful jolt might cure them  Possibly the earliest and nearest approach to the discovery of the identity of lightning, and electricity from any other source, is to be attributed to the Arabs, who before the 15th century had the Arabic word for lightning ra‘ad (رعد) applied to the electric ray 
Ancient cultures around the Mediterranean knew that certain objects, such as rods of amber, could be rubbed with cat's fur to attract light objects like feathers  Thales of Miletus made a series of observations on static electricity around 600 BCE, from which he believed that friction rendered amber magnetic, in contrast to minerals such as magnetite, which needed no rubbing  Thales was incorrect in believing the attraction was due to a magnetic effect, but later science would prove a link between magnetism and electricity  According to a controversial theory, the Parthians may have had knowledge of electroplating, based on the 1936 discovery of the Baghdad Battery, which resembles a galvanic cell, though it is uncertain whether the artifact was electrical in nature 
Benjamin Franklin conducted extensive research on electricity in the 18th century, as documented by Joseph Priestley (1767) History and Present Status of Electricity, with whom Franklin carried on extended correspondence 
Electricity would remain little more than an intellectual curiosity for millennia until 1600, when the English scientist William Gilbert wrote De Magnete, in which he made a careful study of electricity and magnetism, distinguishing the lodestone effect from static electricity produced by rubbing amber  He coined the New Latin word electricus ("of amber" or "like amber", from ἤλεκτρον, elektron, the Greek word for "amber") to refer to the property of attracting small objects after being rubbed  This association gave rise to the English words "electric" and "electricity", which made their first appearance in print in Thomas Browne's Pseudodoxia Epidemica of 1646 
Further work was conducted in the 17th and early 18th centuries by Otto von Guericke, Robert Boyle, Stephen Gray and C  F  du Fay  Later in the 18th century, Benjamin Franklin conducted extensive research in electricity, selling his possessions to fund his work  In June 1752 he is reputed to have attached a metal key to the bottom of a dampened kite string and flown the kite in a storm-threatened sky  A succession of sparks jumping from the key to the back of his hand showed that lightning was indeed electrical in nature  He also explained the apparently paradoxical behavior of the Leyden jar as a device for storing large amounts of electrical charge in terms of electricity consisting of both positive and negative charges 
In 1791, Luigi Galvani published his discovery of bioelectromagnetics, demonstrating that electricity was the medium by which neurons passed signals to the muscles  Alessandro Volta's battery, or voltaic pile, of 1800, made from alternating layers of zinc and copper, provided scientists with a more reliable source of electrical energy than the electrostatic machines previously used  The recognition of electromagnetism, the unity of electric and magnetic phenomena, is due to Hans Christian Ørsted and André-Marie Ampère in 1819–1820  Michael Faraday invented the electric motor in 1821, and Georg Ohm mathematically analysed the electrical circuit in 1827  Electricity and magnetism (and light) were definitively linked by James Clerk Maxwell, in particular in his "On Physical Lines of Force" in 1861 and 1862 
While the early 19th century had seen rapid progress in electrical science, the late 19th century would see the greatest progress in electrical engineering  Through such people as Alexander Graham Bell, Ottó Bláthy, Thomas Edison, Galileo Ferraris, Oliver Heaviside, Ányos Jedlik, William Thomson, 1st Baron Kelvin, Charles Algernon Parsons, Werner von Siemens, Joseph Swan, Reginald Fessenden, Nikola Tesla and George Westinghouse, electricity turned from a scientific curiosity into an essential tool for modern life 
In 1887, Heinrich Hertz:843–44 discovered that electrodes illuminated with ultraviolet light create electric sparks more easily  In 1905, Albert Einstein published a paper that explained experimental data from the photoelectric effect as being the result of light energy being carried in discrete quantized packets, energising electrons  This discovery led to the quantum revolution  Einstein was awarded the Nobel Prize in Physics in 1921 for "his discovery of the law of the photoelectric effect"  The photoelectric effect is also employed in photocells such as can be found in solar panels and this is frequently used to make electricity commercially 
The first solid-state device was the "cat's-whisker detector" first used in the 1900s in radio receivers  A whisker-like wire is placed lightly in contact with a solid crystal (such as a germanium crystal) to detect a radio signal by the contact junction effect  In a solid-state component, the current is confined to solid elements and compounds engineered specifically to switch and amplify it  Current flow can be understood in two forms: as negatively charged electrons, and as positively charged electron deficiencies called holes  These charges and holes are understood in terms of quantum physics  The building material is most often a crystalline semiconductor 
The solid-state device came into its own with the invention of the transistor in 1947  Common solid-state devices include transistors, microprocessor chips, and RAM  A specialized type of RAM called flash RAM is used in USB flash drives and more recently, solid-state drives to replace mechanically rotating magnetic disc hard disk drives  Solid state devices became prevalent in the 1950s and the 1960s, during the transition from vacuum tubes to semiconductor diodes, transistors, integrated circuit (IC) and the light-emitting diode (LED) 
The presence of charge gives rise to an electrostatic force: charges exert a force on each other, an effect that was known, though not understood, in antiquity :457 A lightweight ball suspended from a string can be charged by touching it with a glass rod that has itself been charged by rubbing with a cloth  If a similar ball is charged by the same glass rod, it is found to repel the first: the charge acts to force the two balls apart  Two balls that are charged with a rubbed amber rod also repel each other  However, if one ball is charged by the glass rod, and the other by an amber rod, the two balls are found to attract each other  These phenomena were investigated in the late eighteenth century by Charles-Augustin de Coulomb, who deduced that charge manifests itself in two opposing forms  This discovery led to the well-known axiom: like-charged objects repel and opposite-charged objects attract 
The force acts on the charged particles themselves, hence charge has a tendency to spread itself as evenly as possible over a conducting surface  The magnitude of the electromagnetic force, whether attractive or repulsive, is given by Coulomb's law, which relates the force to the product of the charges and has an inverse-square relation to the distance between them :35 The electromagnetic force is very strong, second only in strength to the strong interaction, but unlike that force it operates over all distances  In comparison with the much weaker gravitational force, the electromagnetic force pushing two electrons apart is 1042 times that of the gravitational attraction pulling them together 
Study has shown that the origin of charge is from certain types of subatomic particles which have the property of electric charge  Electric charge gives rise to and interacts with the electromagnetic force, one of the four fundamental forces of nature  The most familiar carriers of electrical charge are the electron and proton  Experiment has shown charge to be a conserved quantity, that is, the net charge within an electrically isolated system will always remain constant regardless of any changes taking place within that system  Within the system, charge may be transferred between bodies, either by direct contact, or by passing along a conducting material, such as a wire :2–5 The informal term static electricity refers to the net presence (or 'imbalance') of charge on a body, usually caused when dissimilar materials are rubbed together, transferring charge from one to the other 
The charge on electrons and protons is opposite in sign, hence an amount of charge may be expressed as being either negative or positive  By convention, the charge carried by electrons is deemed negative, and that by protons positive, a custom that originated with the work of Benjamin Franklin  The amount of charge is usually given the symbol Q and expressed in coulombs; each electron carries the same charge of approximately −1 6022×10−19 coulomb  The proton has a charge that is equal and opposite, and thus +1 6022×10−19 coulomb  Charge is possessed not just by matter, but also by antimatter, each antiparticle bearing an equal and opposite charge to its corresponding particle 
The movement of electric charge is known as an electric current, the intensity of which is usually measured in amperes  Current can consist of any moving charged particles; most commonly these are electrons, but any charge in motion constitutes a current  Electric current can flow through some things, electrical conductors, but will not flow through an electrical insulator 
By historical convention, a positive current is defined as having the same direction of flow as any positive charge it contains, or to flow from the most positive part of a circuit to the most negative part  Current defined in this manner is called conventional current  The motion of negatively charged electrons around an electric circuit, one of the most familiar forms of current, is thus deemed positive in the opposite direction to that of the electrons  However, depending on the conditions, an electric current can consist of a flow of charged particles in either direction, or even in both directions at once  The positive-to-negative convention is widely used to simplify this situation 
The process by which electric current passes through a material is termed electrical conduction, and its nature varies with that of the charged particles and the material through which they are travelling  Examples of electric currents include metallic conduction, where electrons flow through a conductor such as metal, and electrolysis, where ions (charged atoms) flow through liquids, or through plasmas such as electrical sparks  While the particles themselves can move quite slowly, sometimes with an average drift velocity only fractions of a millimetre per second,:17 the electric field that drives them itself propagates at close to the speed of light, enabling electrical signals to pass rapidly along wires 
Current causes several observable effects, which historically were the means of recognising its presence  That water could be decomposed by the current from a voltaic pile was discovered by Nicholson and Carlisle in 1800, a process now known as electrolysis  Their work was greatly expanded upon by Michael Faraday in 1833  Current through a resistance causes localised heating, an effect James Prescott Joule studied mathematically in 1840 :23–24 One of the most important discoveries relating to current was made accidentally by Hans Christian Ørsted in 1820, when, while preparing a lecture, he witnessed the current in a wire disturbing the needle of a magnetic compass  He had discovered electromagnetism, a fundamental interaction between electricity and magnetics  The level of electromagnetic emissions generated by electric arcing is high enough to produce electromagnetic interference, which can be detrimental to the workings of adjacent equipment 
In engineering or household applications, current is often described as being either direct current (DC) or alternating current (AC)  These terms refer to how the current varies in time  Direct current, as produced by example from a battery and required by most electronic devices, is a unidirectional flow from the positive part of a circuit to the negative :11 If, as is most common, this flow is carried by electrons, they will be travelling in the opposite direction  Alternating current is any current that reverses direction repeatedly; almost always this takes the form of a sine wave :206–07 Alternating current thus pulses back and forth within a conductor without the charge moving any net distance over time  The time-averaged value of an alternating current is zero, but it delivers energy in first one direction, and then the reverse  Alternating current is affected by electrical properties that are not observed under steady state direct current, such as inductance and capacitance :223–25 These properties however can become important when circuitry is subjected to transients, such as when first energised 
The concept of the electric field was introduced by Michael Faraday  An electric field is created by a charged body in the space that surrounds it, and results in a force exerted on any other charges placed within the field  The electric field acts between two charges in a similar manner to the way that the gravitational field acts between two masses, and like it, extends towards infinity and shows an inverse square relationship with distance  However, there is an important difference  Gravity always acts in attraction, drawing two masses together, while the electric field can result in either attraction or repulsion  Since large bodies such as planets generally carry no net charge, the electric field at a distance is usually zero  Thus gravity is the dominant force at distance in the universe, despite being much weaker 
A hollow conducting body carries all its charge on its outer surface  The field is therefore zero at all places inside the body :88 This is the operating principal of the Faraday cage, a conducting metal shell which isolates its interior from outside electrical effects 
The principles of electrostatics are important when designing items of high-voltage equipment  There is a finite limit to the electric field strength that may be withstood by any medium  Beyond this point, electrical breakdown occurs and an electric arc causes flashover between the charged parts  Air, for example, tends to arc across small gaps at electric field strengths which exceed 30 kV per centimetre  Over larger gaps, its breakdown strength is weaker, perhaps 1 kV per centimetre  The most visible natural occurrence of this is lightning, caused when charge becomes separated in the clouds by rising columns of air, and raises the electric field in the air to greater than it can withstand  The voltage of a large lightning cloud may be as high as 100 MV and have discharge energies as great as 250 kWh 
A pair of AA cells  The + sign indicates the polarity of the potential difference between the battery terminals 
The concept of electric potential is closely linked to that of the electric field  A small charge placed within an electric field experiences a force, and to have brought that charge to that point against the force requires work  The electric potential at any point is defined as the energy required to bring a unit test charge from an infinite distance slowly to that point  It is usually measured in volts, and one volt is the potential for which one joule of work must be expended to bring a charge of one coulomb from infinity :494–98 This definition of potential, while formal, has little practical application, and a more useful concept is that of electric potential difference, and is the energy required to move a unit charge between two specified points  An electric field has the special property that it is conservative, which means that the path taken by the test charge is irrelevant: all paths between two specified points expend the same energy, and thus a unique value for potential difference may be stated :494–98 The volt is so strongly identified as the unit of choice for measurement and description of electric potential difference that the term voltage sees greater everyday usage 
For practical purposes, it is useful to define a common reference point to which potentials may be expressed and compared  While this could be at infinity, a much more useful reference is the Earth itself, which is assumed to be at the same potential everywhere  This reference point naturally takes the name earth or ground  Earth is assumed to be an infinite source of equal amounts of positive and negative charge, and is therefore electrically uncharged—and unchargeable 
Electric potential is a scalar quantity, that is, it has only magnitude and not direction  It may be viewed as analogous to height: just as a released object will fall through a difference in heights caused by a gravitational field, so a charge will 'fall' across the voltage caused by an electric field  As relief maps show contour lines marking points of equal height, a set of lines marking points of equal potential (known as equipotentials) may be drawn around an electrostatically charged object  The equipotentials cross all lines of force at right angles  They must also lie parallel to a conductor's surface, otherwise this would produce a force that will move the charge carriers to even the potential of the surface 
Ørsted's discovery in 1821 that a magnetic field existed around all sides of a wire carrying an electric current indicated that there was a direct relationship between electricity and magnetism  Moreover, the interaction seemed different from gravitational and electrostatic forces, the two forces of nature then known  The force on the compass needle did not direct it to or away from the current-carrying wire, but acted at right angles to it  Ørsted's slightly obscure words were that "the electric conflict acts in a revolving manner " The force also depended on the direction of the current, for if the flow was reversed, then the force did too 
Ørsted did not fully understand his discovery, but he observed the effect was reciprocal: a current exerts a force on a magnet, and a magnetic field exerts a force on a current  The phenomenon was further investigated by Ampère, who discovered that two parallel current-carrying wires exerted a force upon each other: two wires conducting currents in the same direction are attracted to each other, while wires containing currents in opposite directions are forced apart  The interaction is mediated by the magnetic field each current produces and forms the basis for the international definition of the ampere 
This relationship between magnetic fields and currents is extremely important, for it led to Michael Faraday's invention of the electric motor in 1821  Faraday's homopolar motor consisted of a permanent magnet sitting in a pool of mercury  A current was allowed through a wire suspended from a pivot above the magnet and dipped into the mercury  The magnet exerted a tangential force on the wire, making it circle around the magnet for as long as the current was maintained 
Experimentation by Faraday in 1831 revealed that a wire moving perpendicular to a magnetic field developed a potential difference between its ends  Further analysis of this process, known as electromagnetic induction, enabled him to state the principle, now known as Faraday's law of induction, that the potential difference induced in a closed circuit is proportional to the rate of change of magnetic flux through the loop  Exploitation of this discovery enabled him to invent the first electrical generator in 1831, in which he converted the mechanical energy of a rotating copper disc to electrical energy  Faraday's disc was inefficient and of no use as a practical generator, but it showed the possibility of generating electric power using magnetism, a possibility that would be taken up by those that followed on from his work 
Italian physicist Alessandro Volta showing his "battery" to French emperor Napoleon Bonaparte in the early 19th century 
The ability of chemical reactions to produce electricity, and conversely the ability of electricity to drive chemical reactions has a wide array of uses 
Electrochemistry has always been an important part of electricity  From the initial invention of the Voltaic pile, electrochemical cells have evolved into the many different types of batteries, electroplating and electrolysis cells  Aluminium is produced in vast quantities this way, and many portable devices are electrically powered using rechargeable cells 
A basic electric circuit  The voltage source V on the left drives a current I around the circuit, delivering electrical energy into the resistor R  From the resistor, the current returns to the source, completing the circuit 
An electric circuit is an interconnection of electric components such that electric charge is made to flow along a closed path (a circuit), usually to perform some useful task 
Electric power is the rate at which electric energy is transferred by an electric circuit  The SI unit of power is the watt, one joule per second 
Electricity generation is often done with electric generators, but can also be supplied by chemical sources such as electric batteries or by other means from a wide variety of sources of energy  Electric power is generally supplied to businesses and homes by the electric power industry  Electricity is usually sold by the kilowatt hour (3 6 MJ) which is the product of power in kilowatts multiplied by running time in hours  Electric utilities measure power using electricity meters, which keep a running total of the electric energy delivered to a customer  Unlike fossil fuels, electricity is a low entropy form of energy and can be converted into motion or many other forms of energy with high efficiency 
Electronics deals with electrical circuits that involve active electrical components such as vacuum tubes, transistors, diodes, optoelectronics, sensors and integrated circuits, and associated passive interconnection technologies  The nonlinear behaviour of active components and their ability to control electron flows makes amplification of weak signals possible and electronics is widely used in information processing, telecommunications, and signal processing  The ability of electronic devices to act as switches makes digital information processing possible  Interconnection technologies such as circuit boards, electronics packaging technology, and other varied forms of communication infrastructure complete circuit functionality and transform the mixed components into a regular working system 
Today, most electronic devices use semiconductor components to perform electron control  The study of semiconductor devices and related technology is considered a branch of solid state physics, whereas the design and construction of electronic circuits to solve practical problems come under electronics engineering 
Thus, the work of many researchers enabled the use of electronics to convert signals into high frequency oscillating currents, and via suitably shaped conductors, electricity permits the transmission and reception of these signals via radio waves over very long distances 
Early 20th-century alternator made in Budapest, Hungary, in the power generating hall of a hydroelectric station (photograph by Prokudin-Gorsky, 1905–1915) 
In the 6th century BC, the Greek philosopher Thales of Miletus experimented with amber rods and these experiments were the first studies into the production of electrical energy  While this method, now known as the triboelectric effect, can lift light objects and generate sparks, it is extremely inefficient  It was not until the invention of the voltaic pile in the eighteenth century that a viable source of electricity became available  The voltaic pile, and its modern descendant, the electrical battery, store energy chemically and make it available on demand in the form of electrical energy  The battery is a versatile and very common power source which is ideally suited to many applications, but its energy storage is finite, and once discharged it must be disposed of or recharged  For large electrical demands electrical energy must be generated and transmitted continuously over conductive transmission lines 
Electrical power is usually generated by electro-mechanical generators driven by steam produced from fossil fuel combustion, or the heat released from nuclear reactions; or from other sources such as kinetic energy extracted from wind or flowing water  The modern steam turbine invented by Sir Charles Parsons in 1884 today generates about 80 percent of the electric power in the world using a variety of heat sources  Such generators bear no resemblance to Faraday's homopolar disc generator of 1831, but they still rely on his electromagnetic principle that a conductor linking a changing magnetic field induces a potential difference across its ends  The invention in the late nineteenth century of the transformer meant that electrical power could be transmitted more efficiently at a higher voltage but lower current  Efficient electrical transmission meant in turn that electricity could be generated at centralised power stations, where it benefited from economies of scale, and then be despatched relatively long distances to where it was needed 
Since electrical energy cannot easily be stored in quantities large enough to meet demands on a national scale, at all times exactly as much must be produced as is required  This requires electricity utilities to make careful predictions of their electrical loads, and maintain constant co-ordination with their power stations  A certain amount of generation must always be held in reserve to cushion an electrical grid against inevitable disturbances and losses 
Electricity is a very convenient way to transfer energy, and it has been adapted to a huge, and growing, number of uses  The invention of a practical incandescent light bulb in the 1870s led to lighting becoming one of the first publicly available applications of electrical power  Although electrification brought with it its own dangers, replacing the naked flames of gas lighting greatly reduced fire hazards within homes and factories  Public utilities were set up in many cities targeting the burgeoning market for electrical lighting  In the late 20th century and in modern times, the trend has started to flow in the direction of deregulation in the electrical power sector 
The resistive Joule heating effect employed in filament light bulbs also sees more direct use in electric heating  While this is versatile and controllable, it can be seen as wasteful, since most electrical generation has already required the production of heat at a power station  A number of countries, such as Denmark, have issued legislation restricting or banning the use of resistive electric heating in new buildings  Electricity is however still a highly practical energy source for heating and refrigeration, with air conditioning/heat pumps representing a growing sector for electricity demand for heating and cooling, the effects of which electricity utilities are increasingly obliged to accommodate 
Electricity is used within telecommunications, and indeed the electrical telegraph, demonstrated commercially in 1837 by Cooke and Wheatstone, was one of its earliest applications  With the construction of first intercontinental, and then transatlantic, telegraph systems in the 1860s, electricity had enabled communications in minutes across the globe  Optical fibre and satellite communication have taken a share of the market for communications systems, but electricity can be expected to remain an essential part of the process 
The effects of electromagnetism are most visibly employed in the electric motor, which provides a clean and efficient means of motive power  A stationary motor such as a winch is easily provided with a supply of power, but a motor that moves with its application, such as an electric vehicle, is obliged to either carry along a power source such as a battery, or to collect current from a sliding contact such as a pantograph  Electrically powered vehicles are used in public transportation, such as electric buses and trains, and an increasing number of battery-powered electric cars in private ownership 
Electronic devices make use of the transistor, perhaps one of the most important inventions of the twentieth century, and a fundamental building block of all modern circuitry  A modern integrated circuit may contain several billion miniaturised transistors in a region only a few centimetres square 
A voltage applied to a human body causes an electric current through the tissues, and although the relationship is non-linear, the greater the voltage, the greater the current  The threshold for perception varies with the supply frequency and with the path of the current, but is about 0 1 mA to 1 mA for mains-frequency electricity, though a current as low as a microamp can be detected as an electrovibration effect under certain conditions  If the current is sufficiently high, it will cause muscle contraction, fibrillation of the heart, and tissue burns  The lack of any visible sign that a conductor is electrified makes electricity a particular hazard  The pain caused by an electric shock can be intense, leading electricity at times to be employed as a method of torture  Death caused by an electric shock is referred to as electrocution  Electrocution is still the means of judicial execution in some jurisdictions, though its use has become rarer in recent times 
Electricity is not a human invention, and may be observed in several forms in nature, a prominent manifestation of which is lightning  Many interactions familiar at the macroscopic level, such as touch, friction or chemical bonding, are due to interactions between electric fields on the atomic scale  The Earth's magnetic field is thought to arise from a natural dynamo of circulating currents in the planet's core  Certain crystals, such as quartz, or even sugar, generate a potential difference across their faces when subjected to external pressure  This phenomenon is known as piezoelectricity, from the Greek piezein (πιέζειν), meaning to press, and was discovered in 1880 by Pierre and Jacques Curie  The effect is reciprocal, and when a piezoelectric material is subjected to an electric field, a small change in physical dimensions takes place 
§Bioelectrogenesis in microbial life is a prominent phenomenon in soils and sediment ecology resulting from anaerobic respiration  The microbial fuel cell mimics this ubiquitous natural phenomenon 
Some organisms, such as sharks, are able to detect and respond to changes in electric fields, an ability known as electroreception, while others, termed electrogenic, are able to generate voltages themselves to serve as a predatory or defensive weapon  The order Gymnotiformes, of which the best known example is the electric eel, detect or stun their prey via high voltages generated from modified muscle cells called electrocytes  All animals transmit information along their cell membranes with voltage pulses called action potentials, whose functions include communication by the nervous system between neurons and muscles  An electric shock stimulates this system, and causes muscles to contract  Action potentials are also responsible for coordinating activities in certain plants 
In the 19th and early 20th century, electricity was not part of the everyday life of many people, even in the industrialised Western world  The popular culture of the time accordingly often depicted it as a mysterious, quasi-magical force that can slay the living, revive the dead or otherwise bend the laws of nature  This attitude began with the 1771 experiments of Luigi Galvani in which the legs of dead frogs were shown to twitch on application of animal electricity  "Revitalization" or resuscitation of apparently dead or drowned persons was reported in the medical literature shortly after Galvani's work  These results were known to Mary Shelley when she authored Frankenstein (1819), although she does not name the method of revitalization of the monster  The revitalization of monsters with electricity later became a stock theme in horror films 
As the public familiarity with electricity as the lifeblood of the Second Industrial Revolution grew, its wielders were more often cast in a positive light, such as the workers who "finger death at their gloves' end as they piece and repiece the living wires" in Rudyard Kipling's 1907 poem Sons of Martha  Electrically powered vehicles of every sort featured large in adventure stories such as those of Jules Verne and the Tom Swift books  The masters of electricity, whether fictional or real—including scientists such as Thomas Edison, Charles Steinmetz or Nikola Tesla—were popularly conceived of as having wizard-like powers 
With electricity ceasing to be a novelty and becoming a necessity of everyday life in the later half of the 20th century, it required particular attention by popular culture only when it stops flowing, an event that usually signals disaster  The people who keep it flowing, such as the nameless hero of Jimmy Webb’s song "Wichita Lineman" (1968), are still often cast as heroic, wizard-like figures 
Ampère's circuital law, connects the direction of an electric current and its associated magnetic currents 
^ Diogenes Laertius  R D  Hicks (ed )  "Lives of Eminent Philosophers, Book 1 Chapter 1 "  Perseus Digital Library  Tufts University  Retrieved 5 February 2017  Aristotle and Hippias affirm that, arguing from the magnet and from amber, he attributed a soul or life even to inanimate objects 
^ Aristotle  Daniel C  Stevenson (ed )  "De Animus (On the Soul) Book 1 Part 2 (B4 verso)"  The Internet Classics Archive  Translated by J A  Smith  Retrieved 5 February 2017  Thales, too, to judge from what is recorded about him, seems to have held soul to be a motive force, since he said that the magnet has a soul in it because it moves the iron 
^ a b c Guarnieri, M  (2014)  "Electricity in the age of Enlightenment"  IEEE Industrial Electronics Magazine  8 (3): 60–63  doi:10 1109/MIE 2014 2335431 
^ Srodes, James (2002), Franklin: The Essential Founding Father, Regnery Publishing, pp  92–94, ISBN 0-89526-163-4 It is uncertain if Franklin personally carried out this experiment, but it is popularly attributed to him 
^ a b Guarnieri, M  (2014)  "The Big Jump from the Legs of a Frog"  IEEE Industrial Electronics Magazine  8 (4): 59–61, 69  doi:10 1109/MIE 2014 2361237 
^ Hertz, Heinrich (1887)  "Ueber den Einfluss des ultravioletten Lichtes auf die electrische Entladung"  Annalen der Physik  267 (8): S  983–1000  Bibcode:1887AnP   267  983H  doi:10 1002/andp 18872670827 
^ "The Nobel Prize in Physics 1921"  Nobel Foundation  Retrieved 2013-03-16 
^ John Sydney Blakemore, Solid state physics, pp  1–3, Cambridge University Press, 1985 ISBN 0-521-31391-0 
^ Richard C  Jaeger, Travis N  Blalock, Microelectronic circuit design, pp  46–47, McGraw-Hill Professional, 2003 ISBN 0-07-250503-6 
^ "The repulsive force between two small spheres charged with the same type of electricity is inversely proportional to the square of the distance between the centres of the two spheres " Charles-Augustin de Coulomb, Histoire de l'Academie Royal des Sciences, Paris 1785 
^ Sewell, Tyson (1902), The Elements of Electrical Engineering, Lockwood, p  18   The Q originally stood for 'quantity of electricity', the term 'electricity' now more commonly expressed as 'charge' 
^ a b Berkson, William (1974), Fields of Force: The Development of a World View from Faraday to Einstein, Routledge, p  370, ISBN 0-7100-7626-6 Accounts differ as to whether this was before, during, or after a lecture 
^ "Lab Note #105 EMI Reduction – Unsuppressed vs  Suppressed"  Arc Suppression Technologies  April 2011  Retrieved March 7, 2012 
^ Almost all electric fields vary in space  An exception is the electric field surrounding a planar conductor of infinite extent, the field of which is uniform 
^ Paul J  Nahin (9 October 2002)  Oliver Heaviside: The Life, Work, and Times of an Electrical Genius of the Victorian Age  JHU Press  ISBN 978-0-8018-6909-9 
^ "The Bumpy Road to Energy Deregulation"  EnPowered  2016-03-28 
^ a b c d e f g h Van Riper, op cit , p  71 
Look up electricity in Wiktionary, the free dictionary 
Basic Concepts of Electricity chapter from Lessons In Electric Circuits Vol 1 DC book and series 
Context 2: Sir Simon William English  (born 30 December 1961) is a New Zealand former National Party politician who served as the 39th prime minister of New Zealand from 2016 to 2017  He had previously served as the 17th deputy prime minister of New Zealand and minister of finance from 2008 to 2016 under John Key and the Fifth National Government 

A farmer and public servant before entering politics, English was elected to the New Zealand Parliament in  as the National Party's candidate in the Wallace electorate  He was elevated to Cabinet in 1996 and in 1999 was made minister of finance, although he served for less than a year due to his party's loss at the 1999 general election  In October 2001, English replaced Jenny Shipley as the leader of the National Party (and consequently as Leader of the Opposition)  He led the party to its worst defeat at the 2002 general election, and as a consequence, in October 2003 he was replaced as leader by Don Brash 

In November 2006, after Brash's resignation, English became deputy leader under John Key  After National's victory at the 2008 general election, he became deputy prime minister and was also made minister of finance for the second time  Under English's direction New Zealand's economy maintained steady growth during National's three terms of government  He became a list-only MP after stepping down as an electorate MP at the 2014 general election 

John Key resigned as leader of the National Party and prime minister in December 2016  English won the resulting leadership election unopposed and was sworn in as prime minister on 12 December 2016  His tenure was only ten months, and included a three-month election campaign  In the 2017 general election, National won the largest number of seats but fell short of a majority  The parties holding the balance of power declined to support the existing government, and English was subsequently replaced as prime minister by Jacinda Ardern, leader of the Labour Party  English initially continued on as Leader of the Opposition, but resigned as leader of the National Party on 27 February 2018 and left parliament two weeks later 

Early life
English was born on 30 December 1961 at Lumsden Maternity Centre in Lumsden  He is the eleventh of twelve children of Mervyn English and Norah (née O'Brien) English  His parents purchased Rosedale, a mixed sheep and cropping farm in Dipton, Southland from Mervyn's uncle, Vincent English, a bachelor, in 1944  English was born in the maternity unit at Lumsden 

English attended St Thomas's School in Winton, then boarded at St  Patrick's College in Upper Hutt, where he became head boy  He played in the first XV of the school's rugby team  English went on to study commerce at the University of Otago, where he was a resident at Selwyn College, and then completed an honours degree in English literature at Victoria University of Wellington 

After finishing his studies, English returned to Dipton and farmed for a few years  From 1987 to 1989, he worked in Wellington as a policy analyst for the New Zealand Treasury, at a time when the free market policies favoured by Labour's finance minister Roger Douglas (known collectively as "Rogernomics") were being implemented 

English joined the National Party in 1980, while at Victoria University  He served for a period as chairman of the Southland branch of the Young Nationals, and became a member of the Wallace electorate committee  After moving to Wellington, he served for periods on the Island Bay and Miramar electorate committees, respectively 

Fourth National Government (1990–1999)

At the 1990 general election, English stood as the National candidate in Wallace, replacing the retiring Derek Angus, and was elected with a large majority  He would hold this seat, renamed Clutha-Southland in 1996, until 2014  He and three other newly elected National MPs (Tony Ryall, Nick Smith, and Roger Sowry) were soon identified as rising stars in New Zealand politics, and at various points were dubbed the "brat pack", the "gang of four", and the "young Turks"  In his first term in parliament, English chaired a select committee into social services  He was made a parliamentary under-secretary in 1993, serving under the Minister of Health 

First period in cabinet (1996–1999)
In early 1996, English was elevated to cabinet by Prime Minister Jim Bolger, becoming the Minister for Crown Health Enterprises and Associate Minister of Education (to Wyatt Creech)  He was 34 at the time, becoming the cabinet's youngest member  After the 1996 general election, the National Party was forced into a coalition with New Zealand First to retain government  In the resulting cabinet reshuffle, English emerged as Minister of Health  However, as a condition of the coalition agreement, NZ First's Neil Kirton (a first-term MP) was made Associate Minister of Health, effectively becoming English's deputy  This arrangement was described in the press as a "shotgun marriage", and there were frequent differences of opinion between the two ministers  After their relationship became unworkable, Kirton was sacked from the role in August 1997, with the agreement of NZ First leader Winston Peters 

As Minister of Health, English was responsible for continuing the reforms to the public health system that National had begun after the 1990 general election  The reforms were unpopular, and health was perceived as one of the government's weaknesses, with the health portfolio consequently being viewed as a challenge  English believed that the unpopularity of the reforms was in part due to a failure in messaging, and encouraged his National colleagues to avoid bureaucratic and money-focused language (such as references to "balance sheets" and "user charges") and instead talk about the improvements to services the government's reforms would bring  He also rejected the idea that public hospitals could be run as commercial enterprises, a view which some of his colleagues had previously promoted 

By early 1997, as dissatisfaction with Bolger's leadership began to grow, English was being touted as a potential successor, along with Jenny Shipley and Doug Graham  His age (35) was viewed as the main impediment to a successful leadership run  National's leadership troubles were resolved in December 1997, when Bolger resigned and Shipley was elected to the leadership unopposed  English had been a supporter of Bolger as leader, but Shipley reappointed him Minister of Health in her new cabinet 

English was promoted to Minister of Finance in a reshuffle in January 1999, a position which was at the time subordinate to the Treasurer, Bill Birch  After a few months, the pair switched positions as part of Birch's transition to retirement, with English assuming the senior portfolio  In early interviews, he emphasised his wish to be seen as a pragmatist rather than an ideologue, and said that the initiatives of some of his predecessors (Roger Douglas's "Rogernomics" and Ruth Richardson's "Ruthanasia") had focused on "fruitless, theoretical debates" when "people just want to see problems solved" 

Opposition (1999–2008)

After the National Party lost the 1999 election to Helen Clark's Labour Party, English continued on in the shadow cabinet as National's spokesperson for finance  He was elected deputy leader of the party in February 2001, following the resignation of Wyatt Creech, with Gerry Brownlee being his unsuccessful opponent 

Leader of the Opposition
In October 2001, after months of speculation, Jenny Shipley resigned as leader of the National Party after being told she no longer had the support of the party caucus  English was elected as her replacement unopposed (with Roger Sowry as his deputy), and consequently became Leader of the Opposition  However, he did not openly organise against Shipley, and according to The Southland Times "there was almost an element of 'aw, shucks, I'll do it then' about Mr English's ascension" 

Aged 39 when he was elected, English became the second-youngest leader in the National Party's history, after Jim McLay (who was 38 when elected in 1984)  He also became only the third Southlander to lead a major New Zealand political party, after Joseph Ward and Adam Hamilton  However, English failed to improve the party's performance  In the 2002 election, National suffered its worst electoral defeat ever, gaining barely more than twenty percent of the vote  English described it as "the worst day of my political life"  Both party insiders and the general public were split as to how much to blame him for the loss, but most of the party believed that English would be able to rebuild National's support 

By late 2003, however, National's performance in opinion polls remained poor  The party had briefly increased its popularity in the year following the election, but by October its support had fallen to levels only slightly better than what it achieved in the last ballot  English also appeared in a boxing match for a charity against entertainer Ted Clarke  This did not boost his polling or that of the National party either, with suggestions that it devalued his image as a serious politician  Don Brash, former governor of the Reserve Bank and a relative newcomer to politics, began to build up support to replace English  On 28 October, Brash gained sufficient backing in Caucus to defeat English in a leadership contest 

Shadow cabinet roles and deputy leader
On 2 November 2003, when Brash changed responsibilities for certain MPs, English became National's spokesman for education, ranked at fifth place in the party's parliamentary hierarchy  He remained in parliament after the 2005 election  In his new shadow education portfolio, English performed strongly, and remained a party favourite despite his election defeat as leader in 2002, eventually being returned to the finance portfolio in August 2004 as deputy spokesman (while still retaining responsibility for education) 

In November 2006, Brash resigned as leader  English was considered as a potential replacement leader (running against John Key) or deputy leader (against incumbent Gerry Brownlee) in the ensuing leadership election  However, a contest was avoided when the MPs agreed a Key/English ticket would run unopposed in a display of party unity  English took over the deputy leadership and the finance portfolio in the Key shadow cabinet 

Fifth National Government (2008–2017)

Deputy Prime Minister and Minister of Finance (2008–2016)

At the 2008 election, English was re-elected by his electorate, winning by a margin of about 15,500 votes  He became Deputy Prime Minister of New Zealand and Minister of Finance in the fifth National Government, being sworn into office on 19 November 2008 and continued to serve in those roles until becoming Prime Minister on 12 December 2014  He was also made Minister of Infrastructure in National's first term of government and Minister responsible for Housing New Zealand Corporation and minister responsible for the New Zealand flag consideration process in its third
Context 3: South Dakota v  Wayfair, Inc  - Harvard Law Review
Fourth Circuit Invalidates Maryland Statute Regulating Price Gouging in the Sale of Generic Drugs 
South Dakota Supreme Court Holds Unconstitutional State Law Requiring Internet Retailers Without In-State Physical Presence to Remit Sales Tax 
Judicial junk, the Court has long thought, is easier to scrap when the erroneous precedent cannot be fixed by Congress, as in constitutional cases 1× 1  See Burnet v  Coronado Oil & Gas Co , 285 U S  393, 405–10 (1932) (Brandeis, J , dissenting); Lee Epstein, William M  Landes & Adam Liptak, The Decision to Depart (or Not) from Constitutional Precedent: An Empirical Study of the Roberts Court, 90 N Y U  L  Rev  1115, 1116 (2015) (“[Justice Brandeis’s] dissenting opinion       now has the status of black letter law ”)  On the flip side, whenever a bad precedent can be corrected by Congress, stare decisis applies with “special force ”2× 2  See Patterson v  McLean Credit Union, 491 U S  164, 172–73 (1989)  The Court, following Justice Brandeis, usually articulates the rule as distinguishing between “constitutional” and “statutory” precedents  See, e g , id  But the distinction is occasionally said to be between “constitutional” and “nonconstitutional cases ” See, e g , Glidden Co  v  Zdanok, 370 U S  530, 543 (1962) (plurality opinion)  Nomenclature aside, the Court has — until now — adhered to Justice Brandeis’s key insight that the important factor is whether or not the mistake may be legislatively corrected  Last Term, in South Dakota v  Wayfair, Inc ,3× 3  138 S  Ct  2080 (2018)  the Court tinkered with this thinking in overruling an outdated dormant commerce clause precedent  Dormant commerce clause decisions technically produce constitutional holdings, but Congress may override them at will 4× 4  See Prudential Ins  Co  v  Benjamin, 328 U S  408, 421–27 (1946)  Under the usual logic of stare decisis, it should take special force to dislodge such precedents  But Wayfair applied the weakened stare decisis of constitutional cases, asserting that the Court must “address a false constitutional premise         whether or not Congress can or will act ”5× 5  Wayfair, 138 S  Ct  at 2096–97 
Emerging from Wayfair is an odd and ominous development in stare decisis doctrine  Odd, because it turns on a formal classification instead of on Congress’s practical ability to fix the problem  Ominous, because the Court’s logic leads far past the dormant commerce clause  Wayfair grants only feeble stare decisis to precedents that set a “constitutional default rule,”6× 6  Id  at 2096 (“While       Congress has the authority to change the physical presence rule, Congress cannot change the constitutional default rule ”)  meaning constitutional decisions that allow for legislative adjustment or override  This new stare decisis analysis makes other precedents setting constitutional default rules more vulnerable — including, perhaps, mainstays of criminal procedure like Miranda v  Arizona7× 7  384 U S  436 (1966)  and Mapp v  Ohio 8× 8  367 U S  643 (1961) 
Since its 1967 decision in National Bellas Hess, Inc  v  Department of Revenue,9× 9  386 U S  753 (1967)  the Court has held that, under the “dormant” or “negative” implication of the Commerce Clause,10× 10  The dormant or negative commerce clause is a judicial derivation from the Commerce Clause “prohibiting States from discriminating against or imposing excessive burdens on interstate commerce without congressional approval,” which “strikes at one of the chief evils that led to the adoption of the Constitution, namely, state tariffs and other laws that burdened interstate commerce ” Comptroller of the Treasury of Md  v  Wynne, 135 S  Ct  1787, 1794 (2015)  states may not compel remote sellers with no physical presence in the state to collect and remit sales taxes 11× 11  See Bellas Hess, 386 U S  at 759–60  In Quill Corp  v  North Dakota,12× 12  504 U S  298 (1992)  the Court refused to overrule the “bright-line, physical-presence requirement” of Bellas Hess, leaning heavily on stare decisis 13× 13  Id  at 317–18  Three Justices joined a concurrence explaining that their decision rested solely “on the basis of stare decisis ” Id  at 320 (Scalia, J , concurring in part and concurring in the judgment)  So the physical presence test remained the law of the land while the internet conquered the earth  Justice Kennedy had joined the Quill majority and Justice Scalia’s concurring opinion emphasizing stare decisis, but by 2015 he had second thoughts  Writing separately in Direct Marketing Ass’n v  Brohl,14× 14  135 S  Ct  1124 (2015)  Justice Kennedy acknowledged that “[t]he Internet has caused far-reaching systemic and structural changes in the economy” and therefore “Quill now harms States to a degree far greater than could have been anticipated earlier ”15× 15  Id  at 1135 (Kennedy, J , concurring)  He concluded with the wish that “[t]he legal system should find an appropriate case for this Court to reexamine Quill and Bellas Hess ”16× 16  Id 
Seldom has a concurring opinion signed by a lone Justice prompted a state to officially declare an emergency  Yet in 2016, in response to Justice Kennedy’s overture, the South Dakota legislature passed a law, S B  106, “to provide for the collection of sales taxes from certain remote sellers       and to declare an emergency ”17× 17  2016 S D  Sess  Laws ch  70 pmbl  217 (codified at S D  Codified Laws § 10-64 (2017))  It required every remote seller to collect and remit sales tax if the seller’s business in South Dakota comprised either a “gross revenue” greater than $100,000 or at least 200 “separate transactions” within one calendar year 18× 18  Id  § 1  Significantly, the law did not apply retroactively 19× 19  Id  § 5  The “emergency” declaration was necessary to give the law immediate effect, for the purpose of “permitting the most expeditious possible review of the constitutionality of this law” by the U S  Supreme Court 20× 20  Id  § 8(8)  As Justice Alito put it, the “South Dakota law [was] obviously a test case ”21× 21  Transcript of Oral Argument at 27, Wayfair, 138 S  Ct  2080 (No  17-494), https://www supremecourt gov/oral_arguments/argument_transcripts/2017/17-494_7lho pdf [https://perma cc/8HYH-VU8N] 
Expeditiously, a group of remote sellers challenged the law  After being sued by South Dakota for refusing to register for the newly required sales tax license, Wayfair, Inc , Overstock com, Inc , and Newegg, Inc  moved for summary judgment in South Dakota circuit court on the grounds that S B  106 was unconstitutional under Quill and Bellas Hess — a point South Dakota conceded, indicating that it was seeking review by the U S  Supreme Court to overturn Quill 22× 22  State v  Wayfair Inc , 2017 SD 56, ¶¶ 9–11, 901 N W 2d 754, 759–60  Accordingly, the South Dakota circuit court granted the motion for summary judgment and South Dakota appealed to the state’s highest court 23× 23  Id  ¶ 12, 901 N W 2d at 760  The South Dakota Supreme Court unanimously affirmed, recognizing that South Dakota’s “arguments on the merits” may be “persuasive” but “Quill remains the controlling precedent ”24× 24  Id  ¶ 18, 901 N W 2d at 761  See generally Recent Case, State v  Wayfair Inc , 2017 SD 56, 901 N W 2d 754 (S D  2017), 131 Harv  L  Rev  2089 (2018) 
The U S  Supreme Court vacated and remanded 25× 25  Wayfair, 138 S  Ct  at 2100  Writing for the Court one last time, Justice Kennedy26× 26  Justices Thomas, Ginsburg, Alito, and Gorsuch joined Justice Kennedy’s opinion  pilloried Quill’s physical presence rule as “arbitrary, formalistic,” “anachronistic,” and “unfair and unjust” to both states and brick-and-mortar retailers 27× 27  Wayfair, 138 S  Ct  at 2092, 2095  After all, the rationale of Quill was that remote sellers lacked a sufficiently “substantial nexus” with the state to justify imposing a duty of tax collection 28× 28  Quill Corp  v  North Dakota, 504 U S  298, 311 (1992) (quoting Complete Auto Transit, Inc  v  Brady, 430 U S  274, 279 (1977))  This was wrong even in the mail-order catalog days of 1967 and 1992, but “the Internet revolution has made [Quill’s] earlier error all the more egregious and harmful ”29× 29  Wayfair, 138 S  Ct  at 2097; see also id  at 2092  The rule deprived the states of billions of dollars, since they could not force remote sellers to collect the tax and consumers hardly ever paid it on their own 30× 30  Id  at 2088 (“[C]onsumer compliance rates are notoriously low ”)  Quill “serve[d] as a judicially created tax shelter” for remote retailers who do a great deal of business online 31× 31  Id  at 2094 
Satisfied that Bellas Hess and Quill were wrongly decided, the Court then jumped the hurdle of stare decisis  The Quill Court had feared upsetting reliance interests 32× 32  Quill, 504 U S  at 317 (“Bellas Hess       has engendered substantial reliance and has become part of the basic framework of a sizable industry ”)  Wayfair shrugged off this concern, noting that “stare decisis accommodates only ‘legitimate reliance interest[s]’”; by contrast, reliance on the physical presence rule was largely due to consumers evading their use-tax obligations 33× 33  Wayfair, 138 S  Ct  at 2098 (alteration in original) (quoting United States v  Ross, 456 U S  798, 824 (1982))  Quill had also appealed to Congress’s ultimate authority over interstate commerce as a reason to abide by a precedent, even if wrongly decided 34× 34  See Quill, 504 U S  at 318–19; id  at 320 (Scalia, J , concurring in part and concurring in the judgment) (“Congress   



ground_truth: Electricity is used for transport, heating, lighting, communications, and computation.

prompt_front: Now, answer the following question based on the text below, only give me the answer and do not output any other words.

Question: When did the 2017 general election be held?

Read the following text and answer briefly.

Context 2: 

He was comfortably re-elected in Clutha-Southland in the 2011 election but opted to run as a party-list candidate in 2014  

The pairing of John Key as leader of the National Party and English as his deputy has been compared to that of Bob Hawke and Paul Keating (in Australia) and Tony Blair and Gordon Brown (in the UK) 

English acceded to the role of Finance Minister in the continuing wake of the financial crisis  In response to New Zealand's rising debt, English made budget deficit-reduction his main priority  His first budget outlined three focuses in New Zealand's financial recovery: "improving the business environment and removing roadblocks to growth; investment in productive infrastructure; and improving the way government works"  One of his first acts was creating the National Infrastructure Unit, charged with formulating a plan for infrastructure projects and investments  He commissioned a government-wide spending review, with an aim to reducing government expenditure—with the exceptions of a two-year stimulus package and long-term increases on infrastructure spending 

In April 2011, the Opposition criticised English for suggesting that New Zealand businesses could use New Zealand's low wages to help it compete with Australia  The National Government campaigned for re-election in 2011 on its economic record  The Government boasted growth for five consecutive quarters up to mid-2010, totalling 1 6% of real GDP 

Strong growth resulted in a surplus of $473 million for the 2015/16 financial year, projected to rise to $8 5 billion by 2020/21  In his 2016 Economic and Fiscal Update address, English stated that reducing debt and tackling the costs of the 2016 Kaikōura earthquake were higher priorities than reducing rates of tax 

Allowances issue
In 2009, the media, including TVNZ and TV3 revealed that English was receiving about NZ$900 a week as part of a living allowance for ministers, to live in his own NZ$1 2 million Wellington home  At the time, English also received $276,200 in his annual salary as Deputy Prime Minister  It was also revealed other ministers with homes in the capital city were also claiming accommodation allowances  On 3 August 2009, Prime Minister John Key started a review of the housing allowances claimed by cabinet ministers  English subsequently paid back $12,000 and only claimed about $24,000 a year in living allowances  The Auditor-General's office said in September 2009 that they were making "preliminary enquiries" into parliamentary housing expenses in response to a letter of complaint from Progressive party leader Jim Anderton  Two days later English stated that he would no longer take up any housing allowance and had paid back all the allowance he had received since the November 2008 election 

Prime Minister (2016–2017)

John Key resigned on 12 December, and endorsed English as his successor in the resulting leadership election  Following the drop-out of both Judith Collins and Jonathan Coleman from the leadership election, English was sworn in as the 39th Prime Minister of New Zealand on 12 December 2016 

English appointed his first cabinet on 18 December  In a reshuffle, he appointed Steven Joyce to succeed him as Finance Minister, while most ministerial portfolios remained the same 

In February 2017, English did not attend Waitangi Day commemorations at the historic treaty grounds, reportedly in response to the Ngāpuhi iwi's decision to stop the Prime Minister from speaking at the marae  Ngāpuhi have protested the Government's negotiation of the Trans Pacific Partnership Agreement (TPPA), which the iwi believe infringes upon Māori sovereignty, and thus does not adhere to the Treaty of Waitangi  English had been invited to attend in an official capacity; his non-attendance was criticised by a Ngāpuhi elder and Opposition leader Andrew Little 

In his first overseas trip as Prime Minister, English travelled to Europe to discuss trade ties, including a prospective New Zealand–European Union free trade agreement  He first travelled to London on 13 January 2017 to meet British Prime Minister Theresa May  Discussing trade relations, English said the two nations were "natural partners" and would "continue to forge ties" after the UK's withdrawal from the EU  He also arranged to meet with London Mayor Sadiq Khan, Belgian Prime Minister Charles Michel and German Chancellor Angela Merkel   In a meeting with Merkel, English received crucial backing from Germany for a trade deal with the EU  On 16 January, English stated that his government would continue to promote TPPA, despite the United States' decision to withdraw from the agreement  He explained that Southeast Asian countries would now be treated as a priority in negotiations—he also asserted that the United States was ceding influence to China by its rejection of the trade pact 

At a press conference at the Beehive on 1 February 2017, English announced that the 2017 general election would be held on 23 September  The Prime Minister later confirmed that his party would approach ACT, United Future and the Māori Party if confidence and supply agreements were required to form a government following the election  In his second cabinet reshuffle on 24 April, English appointed Gerry Brownlee as his new Foreign Affairs Minister; he also promoted Nikki Kaye to the portfolio of Education Minister, and moved Mark Mitchell into the cabinet to become Defence Minister  The reshuffle was perceived as an election preparation 

On 13 February 2017, English welcomed Australian Prime Minister Malcolm Turnbull to Wellington  The two leaders reaffirmed their shared trade agenda, and discussed changes to the Australian citizenship pathway which will affect permanent residents originating from New Zealand 

On 19 June, it was reported that Todd Barclay, who succeeded English as MP for Clutha-Southland, had clandestinely recorded one of his employee's conversations the previous year, and that John Key's leaders' budget was used to pay a confidential settlement after the employee resigned  English admitted that he had been aware of the illegal recording and the settlement, and thus implicated in the scandal 

During the 2017 National campaign launch, English introduced a $379 million social investment package including digital learning academies for high school students, more resources for mathematics, and boosting support for teaching second languages in schools, and maintaining National Standards in the school curriculum  Prime Minister English also sought to defend National's financial management and economic track record and claimed that the opposition Labour Party would raise taxes  Early opinion polling had forecast a poor showing in the election for the Labour Party, but in early August 37-year-old Jacinda Ardern took over as Labour leader and seemingly energised younger voters 

At the 2017 general election, National won the largest share of the party vote (44 4%) and the largest number of seats (56) in the House Representatives  However, National lacked enough seats to govern alone due to two of the party's support partners, the Māori Party and United Future, losing their parliamentary seats  In response, English stated that the party would be entering into talks to form a coalition with New Zealand First  Following talks with the two largest parties, New Zealand First entered a coalition arrangement with the Labour Party  English was succeeded as prime minister by Jacinda Ardern on 26 October 

Opposition (2017–2018)

Leader of the Opposition
English was re-elected as National Party leader on 24 October 2017  At the time of his re-election, English announced his intention to stay on as leader until the next general election  On 13 February 2018, however, he stood down as National Party leader due to personal reasons, and instructed the party to put into motion the processes to elect a new leader  He also retired from Parliament  English's resignation followed weeks of speculation that he would step aside for a new leader  On 27 February, he was succeeded as party leader by Simon Bridges as the result of the leadership election held that day 

Post-premiership 
In 2018, English joined the board of Australian conglomerate, Wesfarmers  English serves in Chairmanships of Mount Cook Alpine Salmon, Impact Lab Ltd and Manawanui Support Ltd  He is also a director of The Instillery, Centre for Independent Studies and The Todd Corporation Limited, and is a member of the Impact Advisory Group of Macquarie Infrastructure and Real Assets 

Political and social views

English is regarded as more socially conservative than his predecessor, John Key  He has stated his opposition to voluntary euthanasia and physician-assisted suicide, same-sex civil unions, and the decriminalisation of prostitution  As Prime Minister he opposed any "liberalisation" of abortion law 

In 2004, English voted against a bill to establish civil unions for both same-sex and opposite-sex couples  In 2005, he voted for the Marriage (Gender Clarification) Amendment Bill, which would have amended the Marriage Act to define marriage as only between a man and a woman  English voted against the Marriage (Definition of Marriage) Amendment Bill, a bill that legalised same-sex marriage in New Zealand  However, in December 2016 he stated, "I'd probably vote differently now on the gay marriage issue  I don't think that gay marriage is a threat to anyone else's marriage" 

In 2009, English voted against the Misuse of Drugs (Medicinal Cannabis) Amendment Bill, a bill aimed at amending the Misuse of Drugs Act so that cannabis could be used for medical purposes 

Personal life 
English met his future wife, Mary Scanlon, at university  She was studying medicine at the time, and became a general practitioner  Both her parents were immigrants, her father being Samoan and her mother Italian, born on the island of Stromboli  They have six children: a daughter and five sons 

English is a practising Roman Catholic, but has stated that he considers his religious beliefs personal and thus separate from politics 

In June 2002, English took part in TV3's Fight For Life, a celebrity boxing fundraiser to raise money for the Yellow Ribbon anti-youth-suicide campaign, influenced by the death of a teenage nephew in 1997  He lost a split decision to former university colleague Ted Clarke 

Honours
In the 2018 Queen's Birthday Honours, English was appointed a Knight Companion of the New Zealand Order of Merit, for services of over 27 years to the State 
Context 3:    can change the rule of Bellas Hess by simply saying so ”)  But Wayfair denied that Congress’s ability to change the law was a proper consideration:
While it can be conceded that Congress has the authority to change the physical presence rule, Congress cannot change the constitutional default rule  It is inconsistent with the Court’s proper role to ask Congress to address a false constitutional premise of this Court’s own creation  Courts have acted as the front line of review in this limited sphere; and hence it is important that their principles be accurate and logical, whether or not Congress can or will act in response 35× 35  Wayfair, 138 S  Ct  at 2096–97 
Having dispensed with the physical presence rule, the Court remanded the case to the South Dakota courts to determine in the first instance “whether some other principle in the Court’s Commerce Clause doctrine might invalidate the Act ”36× 36  Id  at 2099  But the Court listed “several features [of South Dakota law] that appear[ed] designed to prevent discrimination against or undue burdens upon interstate commerce ” Id 
Justices Thomas and Gorsuch each filed concurring opinions  Justice Thomas wistfully likened himself to Justice White — who voted for Bellas Hess but against Quill a quarter-century later — and confessed that he “should have joined [Justice White’s dissenting] opinion ”37× 37  Id  at 2100 (Thomas, J , concurring)  Justice Thomas added that the “Court’s entire negative Commerce Clause jurisprudence” is wrong and should be abandoned 38× 38  Id  Justice Gorsuch also wrote separately to express skepticism of the Court’s dormant commerce clause jurisprudence, raising “questions for another day” of whether the doctrine “can be squared with the text of the Commerce Clause, justified by stare decisis, or defended as misbranded products of federalism or antidiscrimination imperatives flowing from Article IV’s Privileges and Immunities Clause ”39× 39  Id  at 2100–01 (Gorsuch, J , concurring) 
Chief Justice Roberts dissented 40× 40  Justices Breyer, Sotomayor, and Kagan joined the Chief Justice’s dissent  Surprisingly, the dissenting Justices “agree[d] that Bellas Hess was wrongly decided, for many of the reasons given by the Court ”41× 41  Wayfair, 138 S  Ct  at 2101 (Roberts, C J , dissenting)  The dispute between the majority and the dissent turned entirely on the principles and application of stare decisis  Chief Justice Roberts argued that whether or how to reverse Quill should be left to Congress, which “has the flexibility to address these questions in a wide variety of ways” and “can focus directly on current policy concerns rather than past legal mistakes ”42× 42  Id  at 2104  He also pointed to the “baffling” burdens of compliance with the idiosyncratic tax codes of “[o]ver 10,000 jurisdictions,” particularly for small businesses, and doubted that new “software” — the majority’s proposed solution to this mess43× 43  Id  at 2098 (majority opinion) (“Eventually, software that is available at a reasonable cost may make it easier for small businesses to cope with these problems ”)  — would soon solve the problem 44× 44  Id  at 2103–04 (Roberts, C J , dissenting)  In Bellas Hess, the Court reasoned that the dormant commerce clause protects interstate business from being “entangle[d]       in a virtual welter of complicated obligations to local jurisdictions ” Nat’l Bellas Hess, Inc  v  Dep’t of Revenue, 386 U S  753, 759–60 (1967)  The dissent replied that the Court “vastly underestimate[d] the skill of contemporary man and his machines ” Id  at 766 (Fortas, J , dissenting)  The dispute in Wayfair over whether software is up to the task effectively reprised the old debate from Bellas Hess, only this time couched as part of the stare decisis inquiry’s concern for reliance interests rather than as a matter of dormant commerce clause doctrine  While Wayfair acknowledged that “[c]omplex state tax systems could have the effect of discriminating against interstate commerce,” 138 S  Ct  at 2099, the Court remarked that “[t]he physical presence rule is a poor proxy” for an inquiry into any actual burdens imposed on interstate commerce, id  at 2093 
Chief Justice Roberts emphasized that a “heightened form of stare decisis”45× 45  Wayfair, 138 S  Ct  at 2102 (Roberts, C J , dissenting)  applies when “Congress       can, if it wishes, override this Court’s decisions with contrary legislation ”46× 46  Id  at 2101 (first citing Michigan v  Bay Mills Indian Cmty , 134 S  Ct  2024, 2036 (2014) (tribal sovereign immunity); then citing Kimble v  Marvel Entm’t, LLC, 135 S  Ct  2401, 2409 (2015) (statutory interpretation); and then citing Halliburton Co  v  Erica P  John Fund, Inc , 134 S  Ct  2398, 2411 (2014) (judicially created doctrine implementing a judicially created cause of action))  In Quill, the Chief Justice noted, the Court had taken to heart that “Congress may be better qualified” and “has the ultimate power to resolve” the question47× 47  Id  at 2102 (quoting Quill Corp  v  North Dakota, 504 U S  279, 318 (1992))  while Justice Scalia had “recogniz[ed] that stare decisis has ‘special force’ in the dormant Commerce Clause context due to Congress’s ‘final say over regulation of interstate commerce ’”48× 48  Id  (quoting Quill, 504 U S  at 320 (Scalia, J , concurring in part and concurring in the judgment))  Moreover, “[i]f stare decisis applied with special force in Quill, it should be an even greater impediment” afterward since Quill effectively “tossed [the ball] into Congress’s court ”49× 49  Id  (alteration in original) (quoting Kimble, 135 S  Ct  at 2409); cf  Bay Mills, 134 S  Ct  at 2039 n 12 (“When we inform Congress that it has primary responsibility over a sphere of law, and invite Congress to consider a specific issue within that sphere, we cannot deem irrelevant how Congress responds ”)  Because the Court invited Congress to act and then “suddenly chang[ed] the ground rules, the Court may have waylaid Congress’s consideration of the issue ”50× 50  Wayfair, 138 S  Ct  at 2102–03 (Roberts, C J , dissenting) 
In Wayfair, the Court applied the flimsier form of stare decisis to a precedent that could have been overruled by Congress  It did so in the context of a dormant commerce clause case, but Wayfair’s logic extends to all constitutional default rules — that is, constitutional decisions that Congress remains free to change  Not only does Wayfair deviate from the Court’s decades-old stare decisis analysis, it also imperils other precedents that set constitutional default rules 
The Court’s reasoning in Wayfair departs from its prior stare decisis analysis  In 1932, Justice Brandeis posited that stare decisis must bend “in cases involving the Federal Constitution, where correction through legislative action is practically impossible ”51× 51  Burnet v  Coronado Oil & Gas Co , 285 U S  393, 406–07 (1932) (Brandeis, J , dissenting)  The Court has long since adopted his argument,52× 52  See, e g , Smith v  Allwright, 321 U S  649, 665 (1944)  as well as its corollary — that stare decisis commands “special force in the area of statutory interpretation” where “Congress remains free to alter what [the Court has] done ”53× 53  Patterson v  McLean Credit Union, 491 U S  164, 172–73 (1989)  For normative evaluations of heightened stare decisis for statutory precedents, see generally Einer Elhauge, Statutory Default Rules: How to Interpret Unclear Legislation 211–23 (2008); and William N  Eskridge, Jr , Overruling Statutory Precedents, 76 Geo  L J  1361, 1364–1409 (1988)  Justice Brandeis’s logic demands that dormant commerce clause cases, where Congress is free to act, be granted the weightier stare decisis 54× 54  Scholars have noted the curious fact that Justice Brandeis included many dormant commerce clause cases as examples of overruled constitutional precedents  See, e g , Earl M  Maltz, Commentary, Some Thoughts on the Death of Stare Decisis in Constitutional Law, 1980 Wis  L  Rev  467, 468–469, 469 n 11  One explanation for this is that Justice Brandeis sought the authority of Chief Justice Taney’s dictum that the Court’s “opinion upon the construction of the Constitution is always open to discussion” — which referred to the dormant commerce clause  See Burnet, 285 U S  at 408 n 3 (Brandeis, J , dissenting) (quoting The Passenger Cases, 48 U S  (7 How ) 283, 470 (1849) (Taney, C J , dissenting))  In Chief Justice Taney’s time, it was thought that Congress could not override the Court’s dormant commerce clause decisions, see Cooley v  Bd  of Wardens, 53 U S  (12 How ) 299, 321 (1852), so the context of Chief Justice Taney’s dictum does not conflict with Justice Brandeis’s theory of stare decisis  The Court applied this reasoning in Quill, as Chief Justice Roberts underscored 55× 55  Wayfair, 138 S  Ct  at 2102 (Roberts, C J , dissenting) 
Yet the Wayfair majority refused to consider Congress’s authority to legislate as a relevant factor for stare decisis 56× 56  Even Justice Kennedy’s earlier opinion in Direct Marketing contemplated judicially overruling Quill, conspicuously neglecting a possible legislative solution  See supra p  278  The Court even insisted that to do so “is inconsistent with the Court’s proper role,” since Quill embodied “a false constitutional premise of th[e] Court’s own creation ”57× 57  Wayfair, 138 S  Ct  at 2096 (emphasis added)  This refusal breaks from the practical Brandeisian wisdom that has guided the Court’s treatment of precedent for the better part of a century  The point is not that stare decisis should have ultimately propped up Bellas Hess yet again, as Wayfair’s dissenting Justices maintained  After all, a realistic approach that is alert to each branch’s institutional capacities might have led to the conclusion that Congress was actually ill-equipped to overrule Quill  In this vein, the Court could have sensibly pointed out that Congress is unlikely to stick its neck out with a tax hike (or a look-alike) from which only the states would benefit 58× 58  For two practical arguments to this effect, see Brian Galle, Essay, Kill Quill, Keep the Dormant Commerce Clause: History’s Lessons on Congressional Control of State Taxation, 70 Stan  L  Rev  Online 158, 160–62 (2018), https://review law stanford edu/wp-content/uploads/sites/3/2018/03/70-Stan -L -Rev -Online-158-Galle pdf [https://perma cc/22YP-P4V5]; Edward A  Zelinsky, The Political Process Argument for Overruling Quill, 82 Brook  L  Rev  1177, 1191–92 (2017)  Indeed, South Dakota advanced such practical arguments in its brief 59× 59  See Petitioner’s Brief at 54, Wayfair, 138 S  Ct  2080 (No  17-494) (“Congress has little incentive to act here because it would be (or appear to be) authorizing new or greater tax collections from its constituents, while receiving none of the revenue in return ”)  More generally, the Court might have discussed the limits of the states’ influence in the federal system as a reason not to wait for congressional intervention, a topic it has debated on other occasions 60× 60  See Richard H  Pildes, Institutional Formalism and Realism in Constitutional and Public Law, 2013 Sup  Ct  Rev  1, 30–32; see also Galle, supra note 58, at 159 (“Congress is not a trustworthy guardian of state fiscal power, making continuing judicial involvement a more appealing prospect ”)  Or it could have argued that new facts on the ground — namely, the blast of e-commerce that hit like a comet after Quill — overpowered stare decisis of any force, special or plain 61× 61  Two recent studies of stare decisis highlighted the physical presence rule as exemplifying a precedent that may reasonably be overruled due to changed facts  See Bryan A  Garner et al , The Law of Judicial Precedent 364–65 (2016); Randy J  Kozel, Settled Versus Right: A Theory of Precedent 112–13 (2017)  It should be noted that the authors of The Law of Judicial Precedent classify the physical presence rule as a constitutional precedent for stare decisis purposes, thus anticipating the Court’s misstep in Wayfair  Garner et al , supra, at 354–65  Because even statutory precedents may sometimes be overruled,62× 62  See Patterson v  McLean Credit Union, 491 U S  164, 173–74 (1989) (discussing justifications for overruling statutory precedents)  Contra Lawrence C  Marshall, “Let Congress Do It”: The Case for an Absolute Rule of Statutory Stare Decisis, 88 Mich  L  Rev  177 (1989)  the Court could have killed Quill without first planting its constitutional kiss of death 63× 63  Cf  Thomas R  Lee, Stare Decisis in Historical Perspective: From the Founding Era to the Rehnquist Court, 52 Vand  L  Rev  647, 704 (1999) (“Justice Brandeis’       memorable prose has since become a mandatory part of the burial rite for any constitutional precedent ”) 
The Court resisted such arguments  Instead, Wayfair reasoned that Congress’s total ability to correct an erroneous decision counts for nothing when the Court gets the Constitution wrong  That such a theory sprouts from a case like Wayfair, which repudiated a “formalistic distinction,”64× 64  Wayfair, 138 S



ground_truth: 23 September.

prompt_front: Now, answer the following question based on the text below, only give me the answer and do not output any other words.

Question: What did Justice Kennedy argue about Quill in Direct Marketing Ass'n v. Brohl?

Read the following text and answer briefly.

Context 3:  Ct  at 2092  is ironic  Wayfair’s stare decisis analysis resorts to the formalism of making constitutional a “magic” word65× 65  See Transcript of Oral Argument, supra note 21, at 12  rather than asking whether Congress can step in 
Moreover, the Court’s new thinking on stare decisis threatens other constitutional default rules  Wayfair now stands for the proposition that a “constitutional default rule” — a term the Court apparently lifted from South Dakota’s reply brief on the merits66× 66  Reply Brief at 22, Wayfair, 138 S  Ct  2080 (No  17-494) (“Congress is polarized, which makes it critical       to get the constitutional default rule right ”)  — gets only weakened stare decisis  To appreciate why this holding matters, it is worth exploring the concept and scope of constitutional default rules  Contract theory describes default rules as legal rules that the parties may “contract around ”67× 67  See, e g , Ian Ayres & Robert Gertner, Filling Gaps in Incomplete Contracts: An Economic Theory of Default Rules, 99 Yale L J  87, 87 (1989)  Although “constitutional default rule” could be read broadly to include a variety of actors and contracting mechanisms,68× 68  See John Ferejohn & Barry Friedman, Toward a Political Theory of Constitutional Default Rules, 33 Fla  St  U  L  Rev  825, 826 (2006) (“When we speak of default rules in constitutional law, we typically are talking about specifications of ways the government can act (or modify its behavior) to get around a constitutional prohibition ”)  the Court’s use of the term for purposes of stare decisis may be narrowly defined as judicial precedents of constitutional law that “are ultimately subject to congressional control ”69× 69  Gillian E  Metzger, Congress, Article IV, and Interstate Relations, 120 Harv  L  Rev  1468, 1525 (2007) (describing judicially enforceable “constitutional default rules imposing obligations on the states in the name of union [that] are ultimately subject to congressional control”)  The dormant commerce clause is a paradigmatic constitutional default rule because what the Court does today Congress may undo tomorrow  Justice Scalia declared this fact “[t]he clearest sign that the negative Commerce Clause is a judicial fraud,” for “[h]ow could congressional consent lift a constitutional prohibition?”70× 70  Comptroller of the Treasury of Md  v  Wynne, 135 S  Ct  1787, 1808 (2015) (Scalia, J , dissenting)  But that’s what a constitutional default rule is  The Court has allowed Congress to overturn its dormant commerce clause cases since 1891 71× 71  See In re Rahrer, 140 U S  545, 560–62 (1891) 
Dormant commerce clause cases are not the only constitutional default rules  Professor Laurence Tribe’s treatise identifies two others 72× 72  1 Laurence H  Tribe, American Constitutional Law § 6-35 (3d ed  2000)  And in a groundbreaking article, Professor Henry Monaghan revealed “a substructure of substantive, procedural, and remedial rules” forming “a constitutional common law subject to amendment, modification, or even reversal by Congress ”73× 73  Henry P  Monaghan, The Supreme Court, 1974 Term — Foreword: Constitutional Common Law, 89 Harv  L  Rev  1, 2–3 (1975); see also Susan R  Klein, Identifying and (Re)Formulating Prophylactic Rules, Safe Harbors, and Incidental Rights in Constitutional Criminal Procedure, 99 Mich  L  Rev  1030 (2001) (further developing Monaghan’s theory in criminal procedure context)  What follows is a list of six lines of cases beyond the dormant commerce clause that may be fairly described as constitutional default rules  The first two are drawn from Tribe’s treatise while the next four are found in Monaghan’s article:
(1) State Taxation of Federal Instrumentalities: States may not tax instrumentalities of the federal government74× 74  McCulloch v  Maryland, 17 U S  (4 Wheat ) 316, 436 (1819)  — unless Congress consents 75× 75  See, e g , Helvering v  Gerhardt, 304 U S  405, 411 n 1 (1938) (“Congress may curtail an immunity which might otherwise be implied or enlarge it beyond the point where, Congress being silent, the Court would set its limits ” (citations omitted))  One court has described such judicial decisions as setting a “constitutional default rule ” United States v  Delaware, 958 F 2d 555, 560 n 9 (3d Cir  1992) (“[W]e must decide the constitutional default rule for this type of tax, fully aware that Congress could decide at any time to reverse our decision statutorily ”)  (2) Article I, Section 10 Cases: Article I, Section 10 provides that certain prohibitions on the states may be waived by Congress 76× 76  See U S  Const  art  I, § 10, cls  2–3  The Court has taken note of this when considering whether to overrule, for instance, an Import-Export Clause precedent 77× 77  See Hooven & Allison Co  v  Evatt, 324 U S  652, 668 (1945) (“In view of the fact that the Constitution gives Congress authority to consent to state taxation of imports and hence to lay down its own test for determining when the immunity ends, we see no convincing practical reason for abandoning the test which has been applied for more than a century        ”), overruled on other grounds by Limbach v  Hooven & Allison Co , 466 U S  353 (1984)  In Michelin Tire Corp  v  Wages, 423 U S  276 (1976), the Court left open the question whether “Congress may authorize, under the Import-Export Clause, an exaction that it could not directly impose under the Tax Clause ” Id  at 301 n 13  Metzger, however, argues that the Import-Export Clause is free of other clauses’ limits on congressional power  See Metzger, supra note 69, at 1500 & n 120  (3) Bivens Cases: In Bivens v  Six Unknown Named Agents of Federal Bureau of Narcotics,78× 78  403 U S  388 (1971)  the Court held that a violation of the Fourth Amendment gives rise to a right to sue for damages 79× 79  Id  at 397  But the Court has also held that “[s]uch a cause of action may be defeated       when       Congress has provided an alternative remedy which it explicitly declared to be a substitute for recovery directly under the Constitution and viewed as equally effective ”80× 80  Carlson v  Green, 446 U S  14, 18–19 (1980)  (4) Miranda Cases: The Miranda Court famously “encourage[d]” Congress and the states to explore alternative “procedures which are at least as effective in apprising accused persons of their right of silence and in assuring a continuous opportunity to exercise it ”81× 81  Miranda v  Arizona, 384 U S  436, 467 (1966)  In Dickerson v  United States, 530 U S  428 (2000), the Court struck down a congressional attempt to effectively abolish Miranda, holding that “Miranda announced a constitutional rule that Congress may not supersede legislatively ” Id  at 444  But Dickerson also stood by Miranda’s “invitation for legislative action” to replace Miranda with an adequate substitute  Id  at 440; see also Michael C  Dorf & Barry Friedman, Shared Constitutional Interpretation, 2000 Sup  Ct  Rev  61 (discussing legislative alternatives to Miranda)  (5) The Police Lineup Case: In United States v  Wade,82× 82  388 U S  218 (1967)  the Court created an exclusionary rule for evidence obtained from a police lineup in violation of the Sixth Amendment right to counsel but acknowledged that it could be replaced by “[l]egislative or other regulations       which eliminate the risks of abuse ”83× 83  Id  at 239  (6) The Exclusionary Rule Cases: Mapp v  Ohio made the Fourth Amendment “exclusionary rule” binding on the states,84× 84  367 U S  643, 655 (1961)  yet Congress is thought to have the power to replace it 85× 85  See Bivens v  Six Unknown Named Agents of Fed  Bureau of Narcotics, 403 U S  388, 422–24 (1971) (Burger, C J , dissenting) (inviting Congress to replace the Fourth Amendment exclusionary rule); Harold J  Krent, How to Move Beyond the Exclusionary Rule: Structuring Judicial Response to Legislative Reform Efforts, 26 Pepp  L  Rev  855, 864–71 (1999) 
All of the above are arguably constitutional default rules set by the Court that remain, to one degree or another, open to congressional revision  The list could be longer or shorter, depending on which default rules the Court will view as constitutional86× 86  A shorter list could be produced by whittling away at the constitutional status of the cases identified by Monaghan  While the Court has held that Miranda is a constitutional decision, Dickerson, 530 U S  at 444, some of the other cases may be viewed as nonconstitutional  See, e g , Collins v  Virginia, 138 S  Ct  1663, 1675–80 (2018) (Thomas, J , concurring) (arguing that Mapp is “nonconstitutional,” id  at 1678 n 5); Richard H  Fallon, Jr  et al , Hart and Wechsler’s The Federal Courts and the Federal System 775–77 (7th ed  2015) (discussing whether Bivens is constitutionally required)  Conversely, a longer list might include any constitutional right that can be waived by a party  See, e g , Daniel A  Farber, Another View of the Quagmire: Unconstitutional Conditions and Contract Theory, 33 Fla  St  U  L  Rev  913, 918 (2006) (describing the Eleventh Amendment as “just a contractual default rule that the states are free to barter away”)  Such a list might also include various constitutionally inspired judicial presumptions  See, e g , Jack Goldsmith & John F  Manning, The President’s Completion Power, 115 Yale L J  2280, 2299 (2006) (describing the Chevron presumption of delegated interpretive power to administrative agencies as “a constitutionally inspired default rule”); Nicholas Quinn Rosenkranz, Federal Rules of Statutory Interpretation, 115 Harv  L  Rev  2085, 2097–98 (2002) (describing clear statement rules as “constitutional default rules” reversible by Congress)  Many other decisions could likely be characterized as constitutional default rules; the list above is only an initial stab  and on how it will answer open questions about congressional authority over certain constitutional provisions 87× 87  See, e g , Thomas v  Wash  Gas Light Co , 448 U S  261, 272 n 18 (1980) (plurality opinion) (leaving unresolved whether Congress may limit constitutional full faith and credit obligations); White v  Mass  Council of Constr  Emp’rs, Inc , 460 U S  204, 215 n 1 (1983) (Blackmun, J , concurring in part and dissenting in part) (leaving unresolved “whether Congress may authorize       what otherwise would be a violation” of the Privileges and Immunities Clause); 1 Tribe, supra note 72, § 6-35, at 1243–44 (arguing that Congress cannot override judicial constructions of the Privileges and Immunities Clause); Metzger, supra note 69, at 1486–89 (arguing the opposite)  But the takeaway is clear: weaker stare decisis for constitutional default rules  Pre-Wayfair, one would have thought that stare decisis applies with special force to such precedents, given congressional power to set them straight  Not anymore  Why? Because it is improper to “ask Congress to address a false constitutional premise of th[e] Court’s own creation ”88× 88  Wayfair, 138 S  Ct  at 2096  The Latin for Wayfair’s doctrine is not stare decisis, which should reflect a realistic, working relationship between the legislative and judicial branches  It is mea culpa 
In its zeal to update the Constitution for “the Cyber Age,”89× 89  Id  at 2097  the Court deleted Congress from stare decisis doctrine in constitutional cases  The Court had better options  It could have left Quill on Congress’s doorstep, as the dissent argued  Or it could have justified overruling Quill notwithstanding the special force of stare decisis  Instead, the Court reasoned that it doesn’t matter whether Congress is willing and able to do the job: a constitutional mess calls for a judicial clean-up crew  For constitutional default rules — a category of decisions embracing the dormant commerce clause and sweeping far beyond — Wayfair’s new theory of stare decisis makes the Court’s precedents less sticky and Congress less relevant 



ground_truth: Quill harmed states more than anticipated due to the Internet.