In the literature on legal interpretation, theorists offer various arguments in favor of their preferred theories of legal interpretation. As noted, normative arguments, appealing to moral values such as democracy, fairness, and the rule of law, are the most common. For example, both textualists and intentionalists offer arguments based on democracy (see Eskridge 1994, 13; Eskridge and Frickey 1990, 326; Barak 2005, 248; Alexander 2013, 540; Easterbrook 1994, 63). According to Justice Scalia, “it is simply incompatible with democratic government, or indeed, even with fair government, to have the meaning of a law determined by what the lawgiver meant, rather than by what the lawgiver promulgated.” (Scalia 1997, 17.)