The University of Texas at Austin

Law in Popular Culture collection

Richard K. Sherwin

WHEN LAW
GOES POP

The Vanishing Line between Law and Popular Culture
 
 
 
 
 

THE UNIVERSITY OF CHICAGO PRESS
CHICAGO AND LONDON
2000


 
[T]he advertiser aims to stimulate, to satisfy and even to
transform the tastes of his audience .... The truths the
mathematician persuades us to accept are immutable
and indubitable.
     [R]hetoric starts from the assumption that there are
meaningful truths "about the things which are just and
unjust." . . . [It] is concerned with truths that are variable
and obscure, and permanently subject to dispute, and it
employs the passions as instruments of persuasion ....
     Should we not concede that the rhetorician, mocked
by the champions of both thought and power, has a
respectable craft of his own, one that makes its own
essential contribution to humanity?
ANTHONY T. KRONMAN
"Rhetoric" 



ONE 

Introduction: Law in the Age of Images


It was by accident that I stumbled upon the path that led to this book.
The journey began, simply enough, with a film, The Thin Blue Line
(Miramax, 1988), Errol Morris's documentary account of a botched
capital murder case in Dallas, Texas. As a former prosecutor and cur-
rent professor of criminal procedure, I was struck by the variety of
procedural errors depicted in the film. What a great review for my
students at semester's end, I thought., ``Spot the errors," I would tell
them. It was dramatic, and the students were enthralled.
     But then I began to wonder. Why was this film so convincing? After
all, it wasn't just ordinary film viewers Morris managed to persuade.
His film, which was based on interviews with the actual trial partici-
pants, triggered a formal reopening of the case. As a result of that
review, the defendant was ultimately set free -- after twelve years in
prison, a good part of the time on death row. At last, the real story
had emerged: a corrupt district attorney had persuaded a jury to con-
vict an innocent man of murder and sentence him to death by electro-
cution. It's the story of an unlucky scapegoat, trapped in an unjust
frame-up. What's left to doubt when truth and justice triumph in the
end?
     But not so fast. Something else is going on here, something that
doesn't add up as easily as the clues in the mystery story Morris's film
tells (who framed Randall Dale Adams, and why?). This is no simple
documentary. In fact, the film is loaded with fictional devices, includ-
ing simulations, dramatic reenactments, and humorous overlays of
grade-B film clips -- not to mention that entrancing Philip Glass sound-
track. So what's going on here? How could this Truman Capote-style
narrative -- a real-life crime story told with the tools of fiction
change the outcome in a real criminal case?1
     That is the query around which this book began to take shape. For
it was upon further reflection that I realized that the law is shot
through with fiction. It is not simply the well-known use of legal fic-

[3]

tions I am thinking of here, through which Judges "correct" doctrinal
rules to get the right result in a particular case.2 What I have in mind
is the fictional method of persuasion lawyers use to win cases, in court
and out. It has always been so. Rhetoricians since the generation of
Socrates taught their students as much (much to Socrates' dismay).
Like contemporary postmodernists, these ancient teachers of poli-
ticians and lawyers also realized that reality was subject to de- (and
re-)construction. Meanings could be shaped in ways that might incline
the public or a jury to reach a desired opinion or judgment. And in
the late European Renaissance, Sir Philip Sidney argued much the
same thing in his defense of law's affinity with poetry and the fic-
tional method.3
     No, the intermingling o£ law and fiction, like the interpenetration
of law and popular culture generally, is hardly new. But there is more
to tell. For one thing, the kinds o£ fictions lawyers use, and the ways
in which they are employed, vary from one generation to the next.
Lawyers are storytellers, and the stories they tell reflect changes in the
culture around them. Notorious trials are particularly useful barome-
ters o£ such changes. As chapters 3 and 4 show, these are sites where
deep cultural conflicts and anxieties are symbolically played out; they
are enmeshed in the legal narratives we hear and (with increasing fre-
quency these days) see at trial. We can tell this is so not only from the
stories lawyers recount inside the courtroom, but also from the mass
media's characteristic reconstructions of those stories in the court of
public opinion. Notorious trials are richly overdetermined with latent
meaning; we have but to attend closely. The rituals of meaning-making
they perform are not just for the parties concerned. These symbolic
legal dramas make (as well as distort and repress) meanings that are
of interest to society as a whole.
    But there is more yet to be told. The legal stories we hear and see
today, both in court and out, confront law and the legal process with
new challenges. An unprecedented convergence is now under way
among powerful cultural and economic forces. Constructivist ("post-
modern") theory, communication technology, and the needs of the
marketplace are coming together with tremendous synergistic impact.
As a consequence of this impact we are seeing a marked destabiliza-
tion in our sense of self, and in our social and legal reality. Legal mean-
ings are flattening out as they yield to the compelling visual logic of
film and TV images and the market forces that fuel their production.4
In consequence, the customary balance within the legal system among
disparate forms of knowledge, discourse, and power is under great

[4]

strain, and is at risk of breaking down. For example, the virtues of
the lay jury as a practical reflection of community values, expecta-
tions, and beliefs are well known.5 So too are the virtues of judicial
expertise and prudence, which operate at times as a countermajorit-
arian check on public opinion, particularly when the latter runs afoul
of important legal principles such as due process, among other consti-
tutional safeguards.6 Under the influence of new modes of communi-
cation, however, these disparate forms of lay and expert knowledge,
together with their respective virtues, are growing distorted. This is
what we see when techniques of mass communication fold disparate
meaning-making practices into the homogenous stories and images of
popular culture. It is what happens when the active, offscreen dimen-
sion of lived experience and the varieties of common sense that it
produces give way to the passive, self-gratification-enhancing, and
image-based logic of commercial media. Then, the capacity for critical
judgment -- of external reality, of self and others, of truth and justice
in the individual case, and of the media themselves -- is significantly
undercut.7 We witness a similar institutional breakdown when the ju-
diciary, in an effort to enhance its legitimacy, converges on the same
set of images as the mass media. When that happens the courts'
countermajoritarian function also breaks down. For then the courts
too have internalized the image-based logic of popular culture.
     In this book I will describe more fully these and other institutional
distortions and the ways they affect law and the legal system generally.
My conclusion is that what we are seeing today is no ordinary inter-
mingling of law and popular culture, but a more generalized erosion
of law's legitimacy. This is what happens when law goes pop.
      We begin with the notion of culture as a symbolic order. Culture
provides the signs, images, stories, characters, metaphors, and scenar-
ios, among other familiar materials, with which we make sense of our
lives and the world around us. Being part of a community means that
we perceive or interpret events in overlapping ways using shared cogni-
tive and cultural tools and materials. Law is such a community, with
its own materials and preferred tools of analysis, its own practices and
habits of mind. But it is also the case that law's stories and images and
characters leach back into the culture at large. In this way, law is a co-
producer of popular culture.8
     Notorious trials such as those involving Bernhard Goetz, O. J.
Simpson, or the Los Angeles police officers who beat Rodney King,
like other notorious cases before them, tend to be absorbed into the
vernacular of society. As such they often come to embody larger, sym-

[5] 

bolic meanings. Will society tolerate acts of vigilante justice like Bern-
hard Goetzs shooting of four unarmed youths in a New York subway?
Is the legal process strong enough to resist the cult of celebrity that
attends a defendant like O. J. Simpson? Can it survive unharmed the
publicity and passions such a case arouses on top of the social and
legal questions it raises regarding racial prejudice and spousal abuse?
Can law in our time adapt to the reality-shaping power of mass-
marketed visual images without going the way of public relations and
media spin?
     But this is still only part of the picture. No less significant (though
less well known) than the ways law stories leach back into the culture
at large are the various ways the materials and communicative styles
commonly found in mainstream culture leach into law.9 Savvy trial
lawyers often tap, in order to direct strategically, the familiar meaning-
making tools and materials trial participants carry in their heads into
court. Familiar images, popular story forms, and recurring symbols,
together with a host of unconscious prejudices, impulses, and pas-
sions (including disguised or displaced feelings of rage and desire), are
all grist for the lawyer's storytelling mill. And as the dominant media
or technology of communication change, so too do the means of le-
gal persuasion.
     The proliferation of visual images10 in contemporary society has
been accompanied by a significarit cognitive shift. The linear thinking
style (or interpretive fluency) characteristic of print-based culture is
now in competition with what may be called an "associative" cogni-
tive style, a style that is characteristic of our current image-saturated
culture. As Richard Lanham writes, today we are more inclined to
drift along the surface of electronic screens. We look at the signs and
symbols that flow by, rather than through printed words for whatever
meanings they may offer.11 Or, as some postmodernists are fond of
saying, if meanings are there, they are all on the surface: appearing
and disappearing, being created and recreated by image-makers and
viewers alike as we gain increasing control over the flow of images we
see and the order in which we see them.
     In order to be effective, legal persuasion must keep up with chang-
ing stories as well as changing storytelling styles and technologies.
Lawyers can ill afford to misjudge the thinking and speaking habits
of the audiences they face. If communication fails, how can they ex-
pect to influence the judges and jurors who determine how a particu-
lar case will come out, or the public that will construe and act upon
what it takes that outcome to mean? Thus have the methods of legal

[6]

proof always adapted to reflect the introduction of new communica-
tive technologies, from photographic evidence to tape recordings, sur-
veillance videos, and digital simulations.
     For purposes of clarity, let me say again that I do not mean to sug-
gest here that the interpenetration of law and popular culture is a new
phenomenon. It is not, as the historic trials discussed in chapter 4
should make clear. What is new, however, is the extent to which law
today is converging with the popular, and the deleterious effects of
this convergence on law's stability and continuing legitimacy in the
eyes of the public. The communication practices of law, both inside
the courtroom and in the court of public opinion, are increasingly
going the way of contemporary political discourse -- law too is suc-
cumbing to the influence of public relations, mass advertising, and
fabricated media events. An increasing reliance upon public relations
campaigns in the court of public opinion as an adjunct to litigation is
part and parcel of this trend. The shift in communication practices
toward visual representations, including videos, computer-based ani-
mations, and reenactments, also reflects the growing influence of the
visual mass media on the way trial lawyers represent their clients' in-
terests.
     In these and other ways law is showing signs of postmoderniza-
tion. Along the way, it is inheriting many of the problems we associate
with postmodern culture generally. Of particular concern in this re-
spect are: the increasing conflation of truth and fiction; the image-
based manipulation of irrational desire, prejudice, and popular pas-
sions; and the concerted effort to deliberately construct preferred
versions of (and judgments about) self and social reality. These and
other meaning-making practices are displacing what, in earlier times,
one might more readily (albeit naively) have referred to as the search
for "objective" truth and "universal" justice through law. The belief
that truth and justice are "out there," just waiting to be "discovered,"
is of course only one among the numerous ideas handed down to us
from the European Enlightenment that postmodern thought has ren-
dered problematic. Notions about the unified self, universalistic rea-
son, and the linear logic of causation are others.12
     In this book I maintain that the advent of postmodernism is not
without value with regard to law. Certain unrealistic aspirations and
repressive tendencies in the immoderately rationalist culture of mo-
dernity are now undergoing an important and necessary corrective.
At the same time, however, there is the danger of a new excess. Irratio-
nal forces, long repressed by mainstream culture, are breaking into

[7] 

the popular imagination. They bring with them a new sense of anxiety,
fear, and powerlessness. For surely the rational mind is helpless in the
face of blind chance, implacable fate, surging fury, and intractable
desire.
     The cultural juncture we have reached has been a long time in the
making. We are no doubt now reaping the harvest of modernity's de-
cline and the surge of nihilism Nietzsche foresaw over a century ago.13
In a more immediate sense, however, the current situation is also be-
ing affected by a strange and powerful convergence. Constructivist
("postmodern") theory, the promulgation of visual communication
technology, and the insistent gratification demands of the marketplace
are working in unison. Our increased theoretical and technical facility
with reality construction, our ability to manipulate images and sounds
for the sake of verisimilitude, reflect and feed into the market's need
for and capacity to produce and absorb (and just as quickly discard)
new images and new information. In conjunction with the increasing
technological and market capacity to commoditize reality and derea-
lize experience we continue to learn more about the contingency of
meaning, the multiplicity of self and social reality, and the manifold
ways of reality making. A basic and far-reaching insight is at work
here: while a great deal of order may exist in the reality we experience,
much of the order we perceive is there only because we put it there.
Today this constructivist perspective informs such diverse fields as psy-
chology, linguistics, sociology, anthropology, history, philosophy, law,
and, of course, the study of popular culture.
     Because law is both a producer and a byproduct of mainstream
culture it cannot escape the forces and conflicts that play out in the
culture at large. It is my contention that in law as elsewhere in the cul-
ture we are becoming increasingly enmeshed in a futile and dangerous
oscillation between two extremes. I refer to them as radical disen-
chantment (or "skeptical postmodernism") on the one hand and a
reactionary nostalgia for Enlightenment rationality and control on the
other. 14 For the skeptical postmodern, the surge of the irrational is
overpowering. In defense against being overwhelmed, many skeptics
have retreated to a passive posture of ironic detachment. A more radi-
cal alternative, for which other skeptics have opted, is simply to leap
into the flow, to nonjudgmentally merge with the irrational flux within
and without. With either move, however, amoral esthetics and the ap-
peal of immediate gratification tighten their grip upon the mind. In
chapter 7 we will encounter contemporary examples of both of these
strategies with regard to law and legal meaning making generally.

[8]

     Faced with the equally unsavory prospects of amoral passivity and
radical disorder, it is little wonder that a reactionary rationalist im-
pulse has emerged to counter the skeptic's moves.15 Unfortunately,
however, the devoutly to be wished for certainties of the modern En-
lightenment are no more likely to succeed today than they have been
in the past. Indeed, current cultural conditions make it rather more
likely that this nostalgic longing will not be fulfilled. That the prolifer-
ation of the visual mass media and its gratification-enhancing logic
problematize in the very act of addressing the question of objectivity
illustrates the difficulty we face. The more TV newscasters and film
documentarians proclaim "the real," the greater our ontological anxi-
ety becomes. A way out of the impasse between unacceptable ex-
tremes has become an imperative of our time.
     In this book I contend that skeptical postmodernism is fatal to law.
Ultimately, it renders judgment impossible. At the same time, however,
I argue that a return to naive realism fares little better. Such a reaction
to the uncertainties of skepticism fails to provide an adequate re- 
sponse to the immoderate repression (of chance, fate, fury, and desire)
that modern rationality has long exerted. Nor can it do justice to the
disappointed expectations to which modernity's unfulfilled promises 
have led. Simply stated, pining for the certainties of the past ignores
the extent to which the failure of modernity's objectivist, rationalist,
and universalistic program has helped to create postmodern condi-
tions in the first place. Yet I believe that there is a way out of the im-
passe.
     In what follows, I will suggest that there are signs in the culture
around us of an alternative to the Hobson's choice between radical
skepticism on the one hand and nostalgia for the days of the rational
Enlightenment on the other. Another cultural construct is in the mak-
ing, one I call tragic constructivism. It is this form of affirmative post-
modernism that informs my approach to law throughout this book.
In chapter 9 I attempt to flesh out what a tragic constructivist jurispru-
dence might be like. This effort is driven, in significant part, by the
felt need to acknowledge the vicissitudes of the irrational. In seeking
to eschew the immoderate repressiveness of modernity, I strive to
avoid dangerous institutional and psychological forms of distortion
and denial. An example of one such danger, discussed more fully in
chapter 6, is repression through unconscious displacement onto oth-
ers of illicit and thus highly unpalatable impulses and desires. When
law goes pop punitive retribution against the predatory other -- the
"alien" among us, that perennial favorite of film and TV as well as

[9]

"real" law -- becomes easy, perhaps too easy. We see this in the de-
velopment of what I call the jurisprudence of appearances, a form of
legal meaning making that adopts the media's visual logic as its own.
As we will see, the ease of retribution masks significant dangers to law
and society as a whole, especially when the repressed returns -- as it
inevitably does.
     One of the main goals of this book is to expand the ways in which
we think and talk about law. For a long time the law has been under-
stood in terms of written texts. Law students and scholars still spend
most of their time scrutinizing statutory rules and appellate court
opinions. The syllogism, inductive reasoning, and the analogy remain
the prime tools of legal analysis. Meanwhile, other tools of analysis
and persuasion, and other sources of legal meaning, fail to receive the
attention they deserve. The methods of legal storytelling, the strategic
uses of visual technology, and the varieties of legal discourse from
which practitioners must choose in the course of everyday lawyering
are of principal concern to attorneys; yet legal training offers no sys-
tematic account of these vital skills.16
     In short, the historic gap between legal theory and legal practice
remains. Within the precincts of legal academia new insights concern-
ing the role of narrative, culture, and cognition in the meaning-making
process have yet to be absorbed, much less applied to the practical
demands of effective legal persuasion. How people act in the world
on the basis of beliefs and desires,.how they strive to achieve particular
goals, how they meet and overcome obstacles -- all this, set in a dis-
cretely structured sequence in time, is conveyed by narrative. And it is
through narrative that they are subject to influence. Surely, then, it
makes sense to ask: What are the stories and storytelling tools people
typically use to organize their experience and memory of human
events? What kinds of cultural and cognitive models do they rely on
(consciously or otherwise) in their search for truth and justice in par-
ticular cases? Where do these models come from? And what kind of
truth and justice do they produce? Seeking answers to these questions
not only increases our knowledge of law and legal practice; it also
adds new meaning-making tools to the lawyer's toolkit.
     Thinking about law in this way does not teach us to abandon the
study of legal texts. But it does encourage the realization that law is
not autonomous. It is not limited to the words of legislators and
judges and administrative officials alone. Law is everywhere. It is in
law offices in conversations between lawyers and clients, and between
lawyers arguing or negotiating with other lawyers. It's in the minds of

[10]

judges, clerks, bureaucrats, and jurors. And it's on the air -- on televi-
sion, film, and computer screens in court and out. On this view, it is
not enough to do legal theory from the top down based on Kantian
moral universals or utilitarian ("cost/benefit") calculations or some
other comprehensive theoretical system. We also need to proceed from
the bottom up. There is much to be said for unfolding law's norms
from its own forms of discourse, which is to say from patterns of
thought and belief within actual legal practices. This includes discur-
sive practices inside the courtroom (at both trial and appellate, levels)
and elsewhere (in law offices, for example, as well as in the court of
public opinion).17
     To illustrate this more expansive view of the law's field of operation;
I focus in this book not only on judicial discourse, but to an even
greater extent on the words and images advocates use in trial courts
and in the mass media in their effort to win cases18 However, I also
contend that we must go further still. In addition to exploring var-
ious cultural and cognitive sources and localized applications of legal
meaning we must also remain open to law's implicit or hidden mean-
ings. To do this requires a critical sensitivity to the different ways law
masks meaning and power. At the same time, we must attend to the
ways the irrational, subtextual, and symbolic play of rage and desire
flow through law's discursive practices and strategies.19 Meaning
abounds in the unsaid as well as in written, spoken, and visual com-
munication.
     In addition to expanding the way we think and talk about law, I
aim to provide an account of law's current oscillation between en-
chantment and disbelief and the risks that lie at either extreme. Im-
moderate rationality represses immoderately; but its injustice haunts
us when the repressed returns. Radical skepticism, on the other hand,
risks an excess of its own: left unencumbered, its embrace of irratio-
nality leads to law's vanishing point. These are the conditions under
which law goes pop. In responding to this situation it is incumbent
upon us to open our minds to the manifold ways of legal meaning
making. As filmmaker Errol Morris reminds us in The Thin Blue Line,
there are times when law's demand for truth and justice may clash
with the modernist mindset's demand for closure and certainty. Alter-
native narratives of justice may also clamor to be heard. But how will
we hear them if we are not willing to question how a given legal narra-
tive shapes and informs (or represses, disguises, and displaces) our
needs and desires for certainty and closure, or for furious retribution,
illicit gratification, or compassionate and merciful justice?

[11]

     It is with this question in mind that we take up the task of confront-
ing the salient cultural story lines of our time, both familiar and newly
emerging. It is fitting that we do so, so that when faced with violent
conflict and the prospect of law's violent response we may feel sure
enough in our convictions, and in our reasonable doubts.
     The plan of this book is as follows. In chapter 2, I set out more
fully the conditions under which law goes pop. Of particular concern
here is the increasingly problematic status of truth and justice within
the legal system. This is what we see when legal meaning making gives
way to the popular, gratification-based logic of the visual mass media.
Chapter 3 takes a closer look at the role of narrative and the devices
of fiction in the production of legal meaning at trial. Here we see how
discrete storytelling genres, like the mystery and the heroic drama,
produce particular kinds of truth and justice. Illustrations of the dif-
ferent ways in which narrative constructs legal reality are drawn from
cases ranging from closing arguments in the O. J. Simpson case to
Gerry Spence's closing argument before the jury in behalf of Randy
Weaver, who was acquitted on charges arising from the fatal shooting
of a federal marshal in Ruby Ridge, Idaho.
     Chapter 4 moves from the narrative construction of legal reality
as a strategic matter to a symbolic one. Here we explore the richly
overdetermined, often disguised symbolic meanings and unconscious
forces notorious cases typically play out. Anxiety haunts the notorious
case. Indeed, it is the specter of anxiety that makes these cases so
strangely compelling to the public at large. Coming to grips with the
invisible forces at work here is crucial if we are to understand why --
and how -- a particular legal controversy comes to symbolize larger
social, cultural, and psychological conflicts. Deciphering the nature
and effects of this symbolization process is what makes the notorious
case such a useful cultural barometer.
     Chapter 5 examines more closely the implications for law of post-
modern storytelling by focusing on a particular case study. Here we
see how antagonistic modern and postmodern narratives play out,
both in the capital murder case of Randall Dale Adams and in the film
account by Errol Morris that helped set Adams free. In this case study
we begin to see the deleterious effects on law of skeptical postmodern
storytelling. At the same time, however, the analysis also points out
the need for a more affirmative narrative form. Chapter 6 explores
further the implications of skeptical postmodernism, specifically with
respect to litigation public relations (i.e., the art of winning cases in
the court of public opinion) and the jurisprudence of appearances.

[12]

Here we see the corrosive impact on law's quest for legitimacy when
lawyers and judges alike converge on popular media images as a basis
for public persuasion. The Supreme Court's historic decision to allow
state criminal trials to be televised serves as an ironic example of the
special dangers television poses for law.
     Chapter 7 takes a broader look at current cultural manifestations
of radical skepticism by shifting from legal to popular representations
of law, justice, and the legal system in general. This popular cultural
analysis ultimately points the way to law's vanishing point: the final
breakdown of any coherent construction of self and of social or legal
reality. In this way, it underscores the urgent need for an alternative
to radical skepticism. With this need in mind, the chapter closes by
examining possible cultural signs of an affirmative counterforce to dis-
enchantment. Chapter 8 develops these suggestions further, tracing
the affirmative dimension of rhetorical enchantment back to the Soph-
ists of ancient Athens and to Sir Philip Sidney's eloquent defense, in
the Elizabethan period, of law's affinity with poetry and the fictional
method. Here I suggest that myth and rhetoric provide us with the
tools we need to reconceptualize such core modernist notions as uni-
versal reason, the autonomous self, the objectivist ideal, and the domi-
nance of linear causation.
     Chapter 9 concludes these explorations by proffering a tragic con-
structivist jurisprudence. Here I attempt to unite the tragic wisdom
of ancient Greek drama with the insights of traditional rhetoric and
postmodern constructivism. I also seek to concretize and humanize
this synthesis by seizing upon the example provided by a contempo-
rary film: the 1996 masterpiece Red, the final work of Krzysztof Kies-
lowski and his law-trained cowriter Krzysztof Piesiewicz. This en-
chanting and complex account of chance encounters, surging fury,
illicit desire, and the transformative power of compassion serves as a
parable of law, truth, and justice in the postmodern era. I believe that
it suggests an approach to law that resists systemic distortion and the
leaching out of authenticity in the face of radical skepticism. Perhaps
it points to a path beyond the dangers we face when law goes pop.

[13]

ENDNOTES

1. Truman Capote pioneered the "nonfiction novel" with In Cold Blood
(1965). Norman Mailer brilliantly followed suit with The Executioner's Song
(1979). For a discussion of the blurred line between fact and fiction in docu-
mentary film, see Bill Nichols, Representing Reality (Bloomington: Indiana
University Press, 1991).

2. According to Vico, "Once it was the glory of jurisprudence to apply
fictions in order to square acts of equity with the law; today, it is that, through
liberal interpretations, just laws measure up to the facts:' Giambattista Vico,
On the Study Methods of Our Time, trans. Donald Phillip Verene (Ithaca:
Cornell University Press, 1990 [1709]), 59. However, as every beginning law
student soon learns, legal fictions remain in abundance.

3. See Sir Philip Sidney, An Apology for Poetry or The Defence of Po
etry, ed. Geoffrey Shepherd (London: Thomas Nelson and Sons Ltd., 1969
[1595]). See also Kathy Eden, Poetic and Legal Fiction in the Aristotelian
Tradition (Princeton: Princeton University Press, 1986).

4. The more general cultural phenomenon at work here has been vari-
ously referred to as the emergence of "the society of the spectacle" (see Guy
Debord, The Society of Spectacle [New York: Zone Books, 1995]), the disso-
lution of reality into the "simulacrum" (see Jean Baudrillard, Fatal Strategies
[London: Pluto Press, 1990]), and the "television context of no context"
[George W S. Trow, Within the Context of No Context [New York: Atlantic
Monthly Press, 1997]). See also Paul Virilio, The Aesthetics of Disappearance
(New York: Semiotext(e), 1991).

5. See, for example, Alexis de Tocqueville, Democracy in America, ed.
J. Mayer and M. Lerner (New York: Anchor, 1966), 254. According to
Tocqueville, "The jury is both the most effective way of establishing the
people's rule and the most efficient way of teaching them how to rule:" See
also Norman J. Finkel, Commonsense Justice (Cambridge: Harvard Univer-
sity Press, 1995), 337: "Rooted in a legal history far older than the US. Con-
stitution, the jury, the conscience of the community speaks .... In calling the
law to follow the path of the community, we are not urging it to heed majorit-
arian, transitory, ignorant, or unprincipled sentiment. We are asking it to ac-
knowledge what it may have forgotten or lost sight of: the deeper roots of
justice:" See also Jeffrey Abramson, We, The Jury (New York: Basic Books,
1994), 250: "The direct and raw character of jury democracy makes it our
most honest mirror, reflecting both the good and the bad that ordinary people
are capable of when called upon to do justice."

6. Upon occasion the United States Supreme Court has noted the limits
of common sense with respect to the lawful (albeit counterintuitive) demands
of constitutional principle. For example, in Jackson v. Denno, 378 US. 368,
382 (1964) the Court acknowledged the difficulty lay jurors face in choosing
between a criminal defendant's factual guilt, based upon a trustworthy con-
fession, and his legal guilt, which requires that the confession also be volunta-
rily made, which is to say, untainted by police coercion. As the majority
states, "That a trustworthy confession must also be voluntary if it is to be
used at all generates natural and potent pressure to find it voluntary. Other
wise the guilty defendant goes free."

7. In the words of novelist Richard Ford, it is as if the act of expressing
an opinion has become "merely a spasmodic way to intensify a passing mo-
ment -- a now -- by making an act one performs seem to matter when in fact
it doesn't." As we will see in chapter 2, what Ford is describing here is akin
to Andy Warhol's prescient pop insight regarding the growing sense of dereal-
ization, or the inauthenticity of our being in the world. As I will contend
further on, this degeneration of lived experience, this leaching out of self
authenticity, is a hallmark of postmodern hyperreality, a condition wherein
"the real" is increasingly made up of media-constructed signs referring to
other media-constructed signs. Ford describes the situation this way:
What I'm talking about are the ways in which that series of present
moments we describe collectively as our real lives is made insignificant,
made ignoble or forgettable, made hellish or made in essence non-
existent by all sorts of forces outside our brains, yet forces whose exis-
tence we may have complicity with .... [T]he higher valuation placed
on my immediate attention by others?vendors let's call them -- is ac-
companied by or perhaps even causes a lower valuation to be placed
on it by me.
Richard Ford, "Our moments have all been seized," New York Times, Week
in Review, 27 December 1998, 9. One may discern a resonance here with
Walter Benjamin's concern about our loss of the "unique aura" of the object
and the person. See Walter Benjamin, "The work of art in the age of mechani-
cal reproduction," in Illuminations (New York: Schocken Books, 1969). An-
ticipating what we recognize today as the culture of celebrity, Benjamin
writes: "The film responds to the shriveling of the aura with an artificial
build-up of the `personality' outside the studio. The cult of the movie star,
fostered by the money of the film industry, preserves not the unique aura of
the person but the `spell of the personality,' the phony spell of a commodity"
(Benjamin, Illuminations, 231). Paul Auster's searing image of the detective
trapped in the mystery of his own unraveling identity, where even the crime --
much less its solution --seems to be missing, speaks to our uneasy familiarity
with a smaller-than-life counterpart to the larger-than-life figure of the celeb-
rity. See Paul Auster, The New York Trilogy (New York: Penguin, 1994).

8. See, for example, James Boyd White, When Words Lose Their Meaning
(Chicago: University of Chicago Press, 1984), 267:
The law is best regarded not so much as a set of rules and doctrines or
as a bureaucratic system or an instrument for social control but as a
culture, for the most part a culture of argument. It is a way of making
a world with a life and a value of its own.
See also Rosemary J. Coombe, The Cultural Life of Intellectual Properties:
Authorship, Appropriation, and the Law (Durham, N.C.: Duke University
Press, 1998); Carol J. Clover, Our Trial: Movies and the Adversarial Imagi-
nation (Princeton: Princeton University Press, forthcoming); and John Denvir,
ed., Legal Reelism: Movies as Legal Texts (Urbana: University of Illinois
Press, 1996).

9. Pioneering works on the role of culture in the production of legal mean-
ing include: Clifford Geertz, Local Knowledge (New York: Basic Books,
1983) and Michel Foucault, Discipline and Punish (Harmondsworth: Pen-
guin, 1977). See also Austin Sarat and Thomas R. Kearns, Law in the Do-
mains of Culture (Ann Arbor: University of Michigan Press, 1998); Patricia
Ewick and Susan S. Silbey, The Common Place of Law: Stories from Every-
day Life (Chicago: University of Chicago Press, 1998); and Alison Young,
Imagining Crime (London: Sage, 1996).

10. The conceptual history of the "image" is rich and varied. It ranges
from the Platonic and neo-Platonic, Italian Renaissance concept of the visual
image as a symbol of suprasensible luminosity (see E. H. Gombrich, "Icones
Symbolicae, the visual image in neo-Platonic thought," Journal of the War-
burg and Courtauld Institutes 11 [1948]: 163, 167?73; and Ivan Illich, In the
Vineyard of the Text [Chicago: University of Chicago Press, 1993]) to the
post-Newtonian concept of the image as that which is illuminated from with-
out (see W J.T Mitchell, Iconology: Image, Text, Ideology [Chicago: Uni-
versity of Chicago Press, 1986], 16, 37-40), to the psychoanalytic concept of
the "narcissistic image" and the death of the self (see Pierre Legendre, Law
and the Unconscious, ed. Peter Goodrich [New York: St. Martin's Press,
1997), 215), to a plethora of filmic theorizations, including Barthes's evoca-
tion of the image's "flicker of illumination" in a "cave of myths" (see Roland
Barthes, "On cinemascopes," Jouvert 3, no. 3 [1999]), Metz's psychoanalytic
approach to film's invisible unconscious processes (see Christian Metz, The
Imaginary Signifier [Bloomington: Indiana University Press, 1982] ), and
more recently Grodal's holistic analysis of the way prototypical film genres
trigger the cognitive and affective models we use in everyday life (see Torben
Grodal, Moving Pictures: A New Theory of Film Genres, Feelings and Cog-
nition [Oxford: Clarendon Press, 1999]), to name only a few. See generally Da-
vid Bordwell and Noel Carroll, Post-Theory: Reconstructing Film Studies
(Madison: University of Wisconsin Press, 1996). For the sake of simplicity
and convenience, in this book I use "image" to stand for any contrived visual
production -- including photography, film, and the electronically or digitally
produced audiovisual constructs of television and computers.

11. See Richard Lanham, The Electronic Word (Chicago: University of
Chicago Press, 1993), 5: "Look THROUGH a text and you are in the familiar
world of the Newtonian interlude, where facts were facts, the world was re-
ally `out there,' folks had sincere central selves, and the best writing style
dropped from the writer as `simply and directly as a stone falls to the ground,'
precisely as Thoreau counseled. Look AT a text, however, and we have decon-
structed the Newtonian world into Pirandello's and yearn to `act naturally."'

12. On the general breakdown of the Enlightenment project, see Alasdair
MacIntyre, After Virtue (Notre Dame, Ind.: University of Notre Dame Press,
1981), and Richard J. Bernstein, Beyond Objectivism and Relativism (Phila-
delphia: University of Pennsylvania Press, 1983). On the emergence of the
"constructed" or "narrative" self, see Donald Spence, Narrative Truth and
Historical Truth (New York: W W. Norton & Co., 1982); Jerome Bruner,
Acts of Meaning (Cambridge: Harvard University Press, 1990); and Jerome
Bruner and David A. Kalmar, "Narrative and metanarrative in the construc-
tion of self," in Self-Awareness: Its Nature and Development, ed. Michael
Ferrari and Robert J. Sternberg (New York: Guilford Press, 1998).

13. See Friedrich Nietzsche, The Will To Power, ed. Walter Kaufmann
(New York: Vintage, 1968 [1887-88]), 9?82.

14. Pauline Marie Rosenau has also discerned a "skeptical" as well as an
"affirmative" type of postmodernism in her excellent survey of a complex
field, Post-Modernism and the Social Services (Princeton: Princeton Univer-
sity Press, 1992). For an example of the nostalgia for Enlightenment values
within the legal culture, see Daniel A. Farber and Suzanna Sherry, Beyond
All Reason: The Radical Assault on Truth in American Law (Oxford: Oxford
University Press, 1997).

15. As Professor Linda Meyer notes,
Our fear of the uncertainty inherent in our modern discovery that we
do not live in a stable cosmos, but in time and in a "world," precipitates
ever more desperate attempt's to keep things ordered, to keep judges
under control .... Prediction, rationalization, and control are also
coming into vogue within areas of legal doctrine. Instead of defining
due care in tort law as reasonableness, we define it as economic effi-
ciency?as what sanctions are necessary in order to control behavior
and organize energy effectively. Contracts is no longer about honor or
promises, but about regulating or deregulating behavior to produce
economically efficient distributions of capital. Tax law is not seen as
determining what we owe for the common weal after accounting for
any contributions to it we have already made (like giving to charity, or
raising children), but as a collection of "incentives" to "cause" talk of
"regulation:' Evolution, biology, sociology, economics, and psychiatry
are harnessed to provide better predictive models and achieve more ef
fective regulation of human behavior.
     In criminal law, traditionally restricted to punishing responsible
actors, the change is most striking of all. We are becoming less interested
in mens rea, and more interested in controlling crime. For example,
when the news reports that a felon who has served his sentence commits
yet another heinous crime, we direct our outrage not at the felon, but at
the system that failed to protect us. "Crime" itself may come tQ be re-
placed by "dangerousness" as we concentrate more on incapacitation
than on righting wrong, aiming our sights at predicting and controlling .
rather than chastening or reconciling or grieving. [Footnotes omitted.]
Linda Ross Meyer, "Is practical reason mindless?" Georgetown Law Journal
86 (1998): 647, 667, 672.

16. See Richard K. Sherwin, "What we talk about when we talk about
law," New York Law School Law Review 37 (1992): 9-53. See generally the
collection of essays in "Lawyering theory symposium: Thinking through the
legal culture," New York Law School Law Review 37 (1992): 55-258.

17. The work of Anthony G. Amsterdam, Jerome Bruner, Neal Feigenson,
Austin Sarat, Philip Bobbitt, and Dennis Patterson, among others, reflects this
kind of localized, practice-oriented approach. See, for example, Anthony G.
Amsterdam and Randy Hertz, "An analysis of closing arguments to a jury,"
New York Law School Law Review 37 (1992): 55; Jerome Bruner, Acts of
Meaning; Neal Feigenson, Legal Blame: How We Think and Talk About Ac-
cidents (Washington, D.C.: American Psychological Association, 2000);
Austin Sarat and William L. E Felstiner, Divorce Lawyers and Their Clients:
Power and Meaning in the Legal Process (New York: Oxford University
Press, 1995); Philip Bobbitt, Law's Fate (Oxford: Oxford University Press,
1982); and Dennis Patterson, Law & Truth (Oxford: Oxford University
Press, 1996). Law, in this more expansive view, extends beyond formal legal
institutions. As Ewick and Silbey note, "Legality is constituted through every
day actions and practices:" In this sense, legal consciousness may be under
stood as a dynamic cultural process in which individuals "draw from and con-
tribute to legality." Ewick and Silbey, The Common Place of Law, 43, 247.

18. For a pathbreaking example of this kind of interdisciplinary analysis
that focuses on appellate caselaw, see Anthony G. Amsterdam and Jerome
Bruner, Minding the Law (Cambridge: Harvard University Press, 2000).

19. See, for example, Peter Goodrich, Oedipus Lex (Berkeley: University
of California Press, 1995), and Law in the Courts of Love (London: Rout-
ledge, 1996).