Twenty-second Amendment

Section 1.

No person shall be elected to the office of the President more than twice, and no person who has held the office of President, or acted as President, for more than two years of a term to which some other person was elected President shall be elected to the office of the President more than once. But this Article shall not apply to any person holding the office of President when this article was proposed by the Congress, and shall not prevent any person who may be holding the office of President, or acting as President, during the term within which this Article becomes operative from holding the office of President or acting as President during the remainder of such term.

Section 2.

This article shall be inoperative unless it shall have been ratified as an amendment to the Constitution by the legislatures of three-fourths of the several States within seven years from the date of its submission to the States by the Congress.

Few amendments have been passed with as little popular attention as the Twenty-second Amendment. The amendment limits a president to two terms in office. To its backers, it gave the two-term tradition constitutional status. The two-term tradition had dominated the U.S. presidency until the time that President Franklin Delano Roosevelt (FDR) was elected for a third term in 1940 (and to a fourth in 1944). To its critics, the amendment was a politically motivated insult to the memory of FDR. (He had been one of the most popular presidents of the twentieth century.) Debates about the amendment’s necessity continued for years after its passage, and periodic calls for its repeal continue into the twenty-first century..

Ratification Facts

Proposed:

Submitted by Congress to the states on March 21, 1947.

Ratification:

Ratified by the required three-fourths of states (thirty-six of forty-eight) on February 27, 1951, and by five more states on May 4, 1951. Declared to be part of the Constitution on March 1, 1951.

Ratifying States:

Maine, March 31, 1947; Michigan, March 31, 1947; Iowa, April 1, 1947; Kansas, April 1, 1947; New Hampshire, April 1, 1947; Delaware, April 2, 1947; Illinois, April 3, 1947; Oregon, April 3, 1947; Colorado, April 12, 1947; California, April 15, 1947; New Jersey, April 15, 1947; Vermont, April 15, 1947; Ohio, April 16, 1947; Wisconsin, April 16, 1947; Pennsylvania, April 29, 1947; Connecticut, May 21, 1947; Missouri, May 22, 1947; Nebraska, May 23, 1947; Virginia, January 28, 1948; Mississippi, February 12, 1948; New York, March 9, 1948; South Dakota, January 21, 1949; North Dakota, February 25, 1949; Louisiana, May 17, 1950; Montana, January 25, 1951; Indiana, January 29, 1951; Idaho, January 30, 1951; New Mexico, February 12, 1951; Wyoming, February 12, 1951; Arkansas, February 15, 1951; Georgia, February 17, 1951; Tennessee, February 20, 1951; Texas, February 22, 1951; Nevada, February 26, 1951; Utah, February 26, 1951; Minnesota, February 27, 1951.

Limiting the Executive’s Power

The authors of the Constitution faced many major problems. Among them was the need to form an executive officer strong enough to lead, but not so strong that the person would dominate the other branches of government. They surveyed the executive officers of other countries, especially Great Britain. They mostly wanted to avoid allowing the executive to remain in power for too long. They believed presidents or kings who remained in power too long quit caring about the people’s concerns, and only worked to preserve their power. The last thing the Americans wanted was to create another monarchy.

The Americans who wrote the Constitution in 1787 had good reason to fear giving chief executives too much power. They had revolted against England because they believed that King George III ignored the needs of his subjects in the North American colonies. Moreover, they hated the colonial governors, many of whom held office for extended periods and used their office for personal gain.

After the American Revolution (1775–1783), some state constitution writers did away with the office of governor. Others severely limited the number of years and terms that a governor could serve. Such constitutions supported the principle of “rotation in office,” which means public servants hold their offices for a short time then are replaced with newly elected people. The idea behind this arrangement was to make elected officials behave more responsibly, especially since they knew that they had to live as citizens under the laws and policies they created while in office.

The Second Continental Congress created the Articles of Confederation to provide a federal government for the newly independent colonies. But it did not create a separate executive office, or presidency. Instead, it allowed Congress to elect its own president to serve a single one-year term in office. But this was a weakness, and one of the many problems that led Americans to replace the Articles of Confederation with the Constitution. The Constitution created separate executive, legislative, and judicial branches. But now the Constitution’s framers (the people who wrote the Constitution) faced a new problem: how best to establish the office of the president.

Establishing the Two-term Tradition

The Federal Convention met in Philadelphia in May 1787, to write the Constitution. “The Framers,” wrote constitutional scholar Richard B. Bernstein, “concluded that repeated eligibility for a short term of office would balance the two goals they sought in designing the Presidency—a President powerful enough to administer the government and secure national objectives, yet limited enough that he would not become a tyrant or a monarch.”

After much argument and compromise, the delegates to the convention settled upon an agreement. The chief executive would serve a four-year term and would seek reelection as often as he wanted. The delegates rested secure, because the first president, George Washington, was a man with a reputation for passing on the reins of power once he had served his term.

Washington was unanimously elected to the presidency in 1788. His immense personal prestige helped him guide the fledgling government to a stable beginning. Washington was a calming figure. He helped moderate the frequent clashes between Federalists and Democratic-Republicans (two early political parties with very different ideas about how the country ought to be run).

Alexander Hamilton and Thomas Jefferson were the leaders of the Federalists and the Democratic-Republicans (not to be confused with the modern-day Democratic and Republican parties; this party split in the 1820s), respectively. Hamilton and Jefferson tried to convince the reluctant Washington to run for another term. But in 1796, Washington announced that he would retire at the end of his second term. His retirement, and the successful transfer of power to a new president, set a precedent that lasted for nearly 150 years.

The two-term tradition in action

Thomas Jefferson was a delegate to the first constitutional convention. He had been a strong supporter of limiting the presidency to a single term in office. He originally preferred a single seven-year term. He changed his mind after he became the nation’s third president in 1800 and decided to seek reelection in 1804. Jefferson explained his thinking as quoted in Kris Palmer’s Constitutional Amendments:

General Washington set the example of voluntary retirement after eight years. I shall follow it, and a few more precedents will oppose the obstacle of habit to any one after a while who shall endeavor to extend his term. Perhaps it may beget a disposition to establish it by an amendment of the Constitution

With these words, Jefferson became the first to announce the two-term tradition. He was neither the first, nor the last, to suggest that the tradition be written into law through a constitutional amendment.

Challenges to the two-term tradition

Throughout the nineteenth century, presidents remained true to the two-term tradition. Presidents James Madison, James Monroe, and Andrew Jackson all resigned willingly at the end of their second term. Other presidents were either defeated for reelection or, as in the case of Abraham Lincoln, were assassinated during their second term. It was not until the Ulysses S. Grant administration that any president even considered running for a third term.

The appeal of a third term.

General Grant had earned the nation’s admiration for his leadership of the Union Army during the Civil War (1861–65). Elected president in 1868, he tried to help the nation heal its wounds from the recently concluded war. His second term was plagued by scandals, but his Republican Party could not find any candidate they liked as well as Grant. Supporters promoted the idea that Grant should run for a third term in 1876. The idea was emphatically rejected by the public and by Congress, which passed a resolution to the effect that breaking the two-term tradition would be “unwise, unpatriotic, and fraught with peril to our free institutions.”

Under slightly different circumstances twenty years later, President Grover Cleveland attempted to secure a third term. Like Grant, he met with resistance. Cleveland had served his first term from 1884 to 1888. He then lost his bid for reelection to Benjamin Harrison. He regained the presidency in 1892. In 1896, he sought to secure the Democratic Party nomination for what would have been his third term.

Again, however, widespread resistance to breaking the two-term tradition kept Cleveland from even securing the nomination. Instead, the Democratic Party nominated William Jennings Bryan. He lost the election to Republican William McKinley. Cleveland’s supporters considered nominating him again in 1904, but Cleveland wisely refused.

The two-term tradition in the twentieth century

During the twentieth century the two-term tradition faced several significant challenges. When Theodore Roosevelt campaigned for the presidency in 1912, he argued that his first administration should not count toward his two terms. He had served as president upon the assassination of President William McKinley in 1900 and did not count this term as his own. He was convinced that he had not had enough time to accomplish the programs and policies he was elected to enact. Roosevelt won the Progressive Party nomination, but lost the election to Democrat Woodrow Wilson (see sidebar).

Woodrow Wilson also flirted with the idea of seeking the presidency for a third term. Wilson was a noted political scientist and historian. He had once criticized the tradition that drove presidents from office just as they had mastered this most complex and challenging of jobs. Wilson was committed to his foreign policy objectives, especially the creation of a League of Nations (a precursor to the United Nations). Towards the end of his second term, Wilson thought seriously of seeking re-nomination in 1920. In the end, however, Wilson’s declining health and the Democratic Party leaders’ fear of breaking with tradition led to the nomination of James M. Cox. He lost to Warren G. Harding.

Coolidge’s curious intentions.

Like Theodore Roosevelt had done when McKinley died, Vice President Calvin Coolidge took over the presidency when President Warren Harding died midway through his term in 1923. Coolidge served the remaining nineteen months of Harding’s term and then won a term of his own. The question was, once again, could he be elected for yet another term in office? Supporters—and Coolidge had many—argued that since he had served less than half of Harding’s term, he should be able to run again. Many political analysts agreed that the two-term tradition was out of date and also thought Coolidge should end the tradition.

Coolidge himself remained neutral on the idea of a third term until August 2, 1927, when he delivered a brief, handwritten message to the press: “I do not choose to run for President in nineteen twenty-eight.” The news flashed around the nation, but it did not altogether stop speculation that Coolidge would in fact try for a third time. Rumors spread that the message was, in fact, a subtle attempt to get his party to draft him for a nomination he felt he could not pursue openly.

The House of Representatives issued a resolution urging him against a third term. Coolidge refrained from running. Historians continue to speculate about whether Coolidge really meant to retire. Their speculations were fueled by the memoirs of a minor White House employee. The employee insisted that Coolidge truly hoped that he would be nominated once more.

Teddy Roosevelt: Challenging the Two-term Tradition

Franklin Delano Roosevelt was the first American president to break the two-term tradition. Years before, however, his fifth cousin, Theodore Roosevelt, severely tested the limits of this political tradition. Teddy Roosevelt was elected vice president to President William McKinley in the election of 1900. McKinley was assassinated in 1901. This placed the forty-three-year-old Roosevelt in the White House with three years left in his term.

In 1904, he was reelected to the presidency, but people wondered if this was his first or second term in office. Since he had succeeded McKinley in office, some argued that Roosevelt’s election victory in 1904 was the start of his first term. Thus, he could be elected again in 1908.

Teddy Roosevelt himself stopped such speculation. After his victory in 1904, he declared that he had already served for three and a half years of McKinley’s term, and his next term would be his last. “The wise custom which limits the President to two terms regards the substance and not the form,” stated Roosevelt, “and under no circumstances will I be a candidate for or accept another nomination.” These emphatic words would come back to haunt him.

Roosevelt was the youngest man ever to hold the presidency. He often regretted his words concerning reelection, but he stuck to them for the 1908 election. Roosevelt backed William Howard Taft of Ohio for the presidency and was pleased when Taft won. But that pleasure soon soured as Roosevelt came to believe that the Taft administration was not living up to the policies Roosevelt had himself begun. In 1912, Roosevelt announced that he would run against Taft for the Republican presidential nomination. Conservatives within the party blocked Roosevelt’s nomination, however, and Roosevelt left the party.

Convinced of his political policies and his popular support, Roosevelt formed a new party, the Progressive Party. He accepted its nomination for the presidency. He became the first presidential candidate to seek what most Americans believed was a third term. Roosevelt reversed the position he had taken in his 1904 statement. He declared that this would only be his second term. Most Americans believed he was right the first time. One popular anti-Roosevelt campaign button read: “WASHINGTON WOULDN’T, GRANT COULDN’T, ROOSEVELT SHOULDN’T.” In the end, the voters agreed and elected Democrat Woodrow Wilson as president. It would take another Roosevelt—Franklin Delano—to finally break the two-term tradition.

FDR Breaks the Two-term Tradition

In 1932, Democrat Franklin Delano Roosevelt (popularly known as FDR) won election as president of the United States. Eight years later, he had led the country through, and nearly out of, the worst economic depression in U.S. history. With no clear successor, and with Europe gripped by a struggle that would soon be known as World War II, Roosevelt broke with tradition. He was determined to seek election for a third time.

Roosevelt spoke on the campaign trail about the war in Europe. As quoted in David E. Kyvig’s Explicit and Authentic Acts: Amending the U.S. Constitution, 1776-1995, Roosevelt said: “There is a great storm raging now, a storm that makes things harder for the world. And that storm, which did not start in this land of ours, is the true reason that I would like to stick by these people of ours until we reach the clear, sure footing ahead.”

Republican opponents were furious at FDR’s break with convention. Several state legislatures adopted anti-third-term resolutions. According to Kyvig, the Republican national convention “pledged to seek a constitutional two-term limit ‘to insure against the overthrow of our American system of government,’ and their nominee Wendell Wilkie declared that, if elected, such a measure would be his first request of Congress.” Despite these objections, Roosevelt won. But by a much smaller margin than he had enjoyed in his first two presidential victories.

But Roosevelt’s presidency did not stop at a third term. The country was still heavily involved in World War II during the 1944 presidential election. Roosevelt was once again elected president. Republicans across the country howled with anger. More states passed resolutions demanding term limits, and fifteen members of the U.S. Congress introduced term-limit amendments. Roosevelt’s defenders insisted that the need to maintain consistent policies during wartime justified his extended service, but such arguments did not convince the opposition.

Roosevelt did not live to see the end of the war. He died on April 12, 1945. His death left Vice President Harry Truman to serve out his term and lead the nation to Allied victory in World War II.

A Republican Amendment

In 1946, with the war over and an unpopular Truman in office, Republicans swept to victory in congressional elections. Republican leaders vowed that they would take steps to make sure that no president ever served a third term again.

January 3, 1947, was the first day of the congressional session. House member Earl C. Michener of Michigan introduced an amendment resolution calling for term limits on the presidency. After a brief period of debate on February 6, 1947, every House Republican as well as many southern Democrats voted for the term limit amendment by a count of 285 to 121.

As quoted in Explicit and Authentic Acts, House Republican Karl Mundt expressed the opinions of many when he said that the amendment “grows directly out of the unfortunate experience we had in this country in 1940 and again in 1944 when a President who had entrenched (established) himself in power by use of patronage and the public purse refused to vacate the office at the conclusion of two terms, but used the great powers of the Presidency to perpetuate himself in office.”

Democrats oppose the proposed amendment

Most Democrats opposed term limits on the same principles that had kept term limits from being part of the original Constitution. Democrats insisted that the people should have the power to elect whoever they wanted for as long as they wanted. They borrowed Alexander Hamilton’s argument: Term limits would deprive the people of the most experienced chief executive, and would limit the people’s right to stick with a candidate in a time of crisis, such as the war that had just ended.

But Republican support was too strong. The Senate did change the amendment, however. The change permitted someone elevated to the presidency due to the death or removal of a sitting president to be elected twice to their own presidential candidacies. Also, this proposed amendment would not affect Truman, the sitting president. The amendment passed by a vote of 59 to 23 on March 12, 1947. Democrats complained that the amendment was merely an attempt to dishonor the memory of a Democratic president, but the House sent the amendment to the states for ratification on March 21, 1947.

Ratification.

The Twenty-second Amendment was immensely popular among Republicans. It was quickly ratified by most of the states with Republican-controlled legislatures. Northern Democratic states followed their party’s position and largely rejected the bill. Most Democratic state legislatures in the South, however, rejected the party line and approved the amendment. On February 27, 1951, the Twenty-second Amendment became law.

According to Kyvig, one liberal journal had observed that the amendment “glided through legislatures in a fog of silence—passed by men whose election in no way involved their stand on the question—without hearings, without publicity, without any of that popular participation that might be expected to accompany a change in the organic law of the country.”

An Evaluation of the Amendment

The Twenty-second Amendment passed under strange conditions. The amendment was largely ignored by the public and had taken longer to ratify than any previous amendment in the history of the Constitution to date. Not long after the amendment was ratified, its most ardent backers—the Republican Party—wondered if it had been a mistake. Popular Republican president Dwight D. Eisenhower was nearing the end of his second term. His party dearly wished that he could take a third term. They even considered mounting a campaign for repeal of the amendment.

Repeal

Two more times in the following years, Republican presidents won second terms, which sparked further calls for repeal of the term limit amendment. Richard Nixon’s reelection in 1972 and Ronald Reagan’s reelection in 1984 allowed the Republican Party to dream of a political dynasty should the amendment be repealed. But in both cases other circumstances helped crush the movement for a third term.

Nixon’s dynasty was brought down by the Watergate scandal, which drove him to resign in 1974. Ronald Reagan’s advancing years and declining memory made it wise for him to leave office in 1989 at the age of 78. Democratic president Bill Clinton remained popular at the end of his second term, but his own scandal-ridden presidency had sparked no calls for a third term. But an amendment to repeal presidential term limits was once again offered in 1999.

Efforts to secure repeal recurred over the years. Republican House representative Guy Vander Jagt tried to introduce a repeal amendment in Congress between 1972 and 1991, but the amendment gained little support. But some scholars and politicians continued to support the idea. They adopted all the same arguments that had kept term limits out of the Constitution for so many years. Repeal advocates argued that voters should be able to choose who they want. Other reformers have called for a single six-year term for the presidency. More recently. proposals to repeal the Twenty-second Amendment have been introduced regularly in Congress. Ever since the late 1980s, a measure (or measures) has been introduced in every session of Congress to repeal this amendment. In January 2007, Rep. Jose Serrano introduced H.J. Res. 8, which sought its repeal.

The Permanence of the Twenty-second Amendment

As of the early 2000s, the Twenty-second Amendment had earned much respect and support. In the 1990s, many Americans became distrustful of politicians who spent many years in office. Term limits for other elected officials became increasingly popular (see sidebar).

According to Bernstein, even the amendment’s critics have come to see that it may help to guarantee Americans the best possible presidency. Bernstein noted that the modern presidency exerts such a toll on the president’s health that it would be difficult for any man to withstand physically a third term. Moreover, the second term of most presidents has been far less successful than the first, which makes it unlikely that a president would be strong enough politically to manage a third term.

Perhaps the strongest argument for the Twenty-second Amendment is history. For over 150 years, the two-term tradition successfully guided the peaceful transition of power and ensured that no one president ever gained too much power. As Thomas Jefferson had wished, that two-term tradition is now part of the Constitution.

Term Limits for Congress

The Twenty-second Amendment placed limits on the number of terms a president may serve. Some began calling for term limits for members of Congress as well. During the early years of U.S. history, few legislators served more than a few terms in office, and the citizens truly ran Congress. But by the late twentieth century, many senators and representatives had, in the words of constitutional scholar Richard B. Bernstein, “racked up careers of two, three, or even four decades of service.” Simply, they had become career politicians.

A concern to critics, many career politicians no longer listened to their constituents. They happily enjoyed the perks of their office: the status, office staff, and influence. In 1991, a banking scandal revealed that many House members had been abusing the banking privileges they enjoyed at the House credit union and had been writing checks for more money than they had in their accounts. This banking scandal brought intense public attention to long-serving Congressmen.

Alan Ehrenhalt, author of The United States of Ambition: Politicians, Power, and the Pursuit of Office, writes:

[O]fficeholders comprise a career elite whose lifetime political preoccupation has separated them from most people. … There is something about the image of the entrenched congressional incumbent, immersed in politics as his life’s work and impregnable [unshakable] in an elected office that pays $125,000 a year, that challenges some fundamental American notions of democracy and fairness.

The common fear was that these career politicians were insulated from the people they represent and thus the essential representational nature of the democratic system was undermined by their continual reelection.

In 1994, Republican candidates for Congress rallied behind a set of proposals for reform that they called the “Contract with America.” Among their promises was one to secure a constitutional amendment to limit the terms of members of Congress. Though the House voted on several proposals, none received a two-thirds majority. Proposals before the Senate never came up for a vote. The main problem was the House members could not agree on exactly how to limit service. Some proposed that the limit be six years, while others backed a twelve-year limit.

If nothing else, the defeat of term limits in Congress revealed that there were very good reasons to allow voters the opportunity to reelect their representatives as often as they wished. Despite the dangers associated with career politicians, most voters recognized that experienced politicians were often best suited to protect the interests of the people because they were familiar with handling the difficulties of getting what they wanted. In the end, most believed that the best way to limit a congressional term was at the ballot box.

Republican Senator Criticizes His Party’s Past Behavior

In January 1995, Republican senator Mitch McConnell from Kentucky introduced Senate Joint Resolution 23 to repeal the Twenty-second Amendment. McConnell offered his resolution at the same time as his party offered its “Contract with America,” a provision which called for congressional term limits. McConnell noted that he introduced the measure “with a sense of irony,” but he spoke candidly about his historical assessment of an amendment that he said was passed in error.

McConnell announced on the Senate floor:

Mr. President, not a single Republican in the House or Senate voted against that term limit announcement in 1947. It was a brash, ill-conceived, hastily executed and strictly partisan response to the unprecedented tenure of President Roosevelt. As constitutional scholars have observed, this was the first constitutional modification that constricted voter suffrage. And Republicans should take heed, for it is we who have been hoisted by their petard. It is poetic justice, that Presidents Eisenhower and Reagan are the only ones, thus far, who have been constrained by the 22d amendment. … The 22d amendment was a mistake, Mr. President, and that is why I am introducing today a Senate Joint Resolution to repeal it. It would be fitting, and in the national interest, for a Republican majority of 1995 to rectify a mistake made by the Republican majority of 1947.

As with most of the other measures, McConnell’s resolution was referred to the Judiciary Committee and never came up for a full vote. It may logically be argued that the people who enjoy long terms in office would not be likely to vote for a resolution that promised the end of their careers in government.

Conclusion

As of 2007, the Twenty-second Amendment appears to have the support of the majority of the public. Anytime a proposal to repeal the Twenty-second Amendment is introduced, political advocates warn that the opposing political party is seeking to gain a stranglehold on executive power. Others criticize the Twenty-second Amendment because it takes away a choice from the voters by precluding people from voting for the potential candidate that they would like to see stay in office. Despite these criticisms, it retains support.

However, questions remain about the Twenty-second Amendment. For example, there was academic discussion of the constitutionality of two-term president Bill Clinton running as vice president with his vice-president Al Gore who was the Democratic nominee for president in the 2000 election. Would the Twenty-second Amendment prohibit Clinton from serving as vice president (with potential to succeed to the presidency) if the had already served two elected terms as president? Commentator and Findlaw columnist Michael Dorf answered in the negative in his column: “if Clinton were to be elected Vice President, and ascend[ed] to the Presidency based on, for example, Mr. Gore’s resignation, then nothing unconstitutional would have occurred. Clinton would have been elected to the Presidency only twice—though he would serve as President thrice. Under the Twenty-Second Amendment, that is perfectly permissible.” Bruce Peabody and Scott E. Grant wrote a detailed law review article, arguing that there were several situations where a two-term president could assume the presidency again as a vice-president.

However, these discussions have never garnered broad attention from the general public, and repeal measures have not taken a serious foothold. It appears in 2007 that at least for the immediate future the Twenty-second Amendment remains an important staple of the U.S. Constitution.

FOR MORE INFORMATION

Books

Bernstein, Richard B., with Jerome Agel. Amending America: If We Love the Constitution So Much, Why Do We Keep Trying to Change It? New York: Times Books, 1993.

Ehrenhalt, Alan. The United States of Ambition: Politicians, Power, and the Pursuit of Office. New York: Times Books, 1992.

Flynn, Vince. Term Limits. New York: Simon & Schuster, 1999.

Kousser, Thad. Term Limits and the Dismantling of State Legislative Professionalism. Cambridge, U.K.: Press Syndicate of the University of Cambridge, 2004.

Kyvig, David E. Explicit and Authentic Acts: Amending the U.S. Constitution, 1776–1995. Lawrence: University of Press of Kansas, 1996.

Morin, Isobel V. Our Changing Constitution: How and Why We Have Amended It. Brookfield, CT: Millbrook Press, 1998.

Palmer, Kris E., ed. Constitutional Amendments, 1789 to the Present. Farmington Hills, MI: Thomson Gale, 2000.

Racheter, Donald P., Richard E. Wagner, and Holbert L. Harris, eds. Limiting Leviathan. Northampton, MA: Edward Elgar Publishing, 1999.

Sarbaugh-Thomson, Marjorie. The Political and Institutional Effects of Term Limits. New York: Palgrave Macmillan, 2004.

Periodicals

Peabody, Bruce G., and Scott E. Gant. “The Twice and Future President: Constitutional Interstices and the Twenty-Second Amendment.” Minnesota Law Review 83 (1999).

Web sites

Dorf, Michael C. “The Case for a Gore-Clinton Ticket.” Findlaw, July 31, 2000. (accessed September 13, 2007).

Green, Eric. “Term Limits Help Prevent Dictatorships: Attempts to Repeal U.S. two-term law not succeeding.” Washington File, August 27, 2007 accessible online at (accessed September 13, 2007).