In criticizing intentionalism, contemporary textualists have emphasized the messiness and opacity of the legislative process, and the importance of compromise in that process (see Manning 2001, 71–78; 2003, 2408–19; Easterbrook 1983, 540–41; 1988, 63–64; 1990, 444–48; 1994, 68; 2010, 916, 922; 2012, xxii; Scalia and Garner 2012, 392–93). Individual legislators who originally propose legislation may have a specific legal intention – to enact a particular legal rule. But, in order to secure passage of the legislation, compromises have to be made. Legislative bargains are often verbal rather than substantive – that is, they often take the form of adding particular words to the legislation without reaching agreement on the net effect of the change in wording. Indeed, compromises are often successful precisely because controversial issues are left opaque and unresolved. In the case of complex and controversial legislation, there may be no reason to think that there is a coherent and discoverable legal intention. (That’s not to say that there isn’t a semantic intention – to use these words – or a minimal intention – to modify the law by passing this bill.) Even setting aside the metaphysical question of what would constitute a collective intention in the relevant circumstances, it is often extremely implausible that a collective legal intention exists and that, if it did, courts could reliably identify it.