Philip Bobbitt, the best-known pluralist theorist of constitutional interpretation, distinguished six modalities of constitutional argumentation. These include, for example, structural, ethical, and prudential argumentative modalities. (Bobbitt 1982; 1991). Bobbitt’s work is neither merely descriptive of existing practice, nor based on a larger underlying theory, e.g., of what determines the content of the law. Instead, Bobbitt takes constitutional practices generally to legitimate the use of the different modalities, though in some instances he offers criticisms of existing practices (Bobbitt 1982; 1991).