Unanimously weaving a tangled web: Walters, Robinson, Title VII, and the need for holistic statutory interpretation

in this Comment, David A. Forkner and Kent M. Kostka demonstrate that drama tic changes in the American label market since the passage of Title VII in 1964 require a new approach to statutory interpretation. Forkner and Kostka criticize the various interpretive methodologies that courts and scholars have used, focusing on two recent Supreme Court Title VII decisions. They c onclude that a "holistic" approach, drawing on the strengths of other canon s of interpretation, is a better method of interpreting the statutory langu age of Title VII in a continually evolving labor market.