The second possibility is a little more promising. It is possible for judges to agree on a criterion (or chain of criteria) that validates a particular method of legal interpretation, yet be unaware that the criterion does so because the application of the criterion is controversial. Thus, for example, a theorist could try to argue that the judges agree on a normative criterion, but they disagree about what that criterion, properly understood, entails. Or a theorist could argue that judges converge on a descriptive criterion, but they have a factual disagreement about what that descriptive criterion entails. Perhaps there is a forgotten custom, validated by the rule of recognition, that specifies (when understood as the rule of recognition requires) that statutes contribute to the law according to their literal meaning, and there are no conflicting norms validated by the rule of recognition. Such possibilities can’t be ruled out a priori, but it is clear that it would be a tall order to show that there is consensus on a criterion that, properly understood, yields a controversial method of interpretation.