In an impressive and important article, Rights Against Rules: The Moral Structure of American Constitutional Law, Matthew Adler maintains that constitutional rights are “rights against rules: they protect citizens against the legislative enactment and judicial application of particular rules (rules with wrong act-type predicates); they do not provide guarantees that citizens can perform any particular sorts of actions free of governmental interference.”Matthew D. Adler, Rights Against Rules: The Moral Structure of American Constitutional Law, 97 MICH. L. REV. 1 (1998). As Adler writes: