In 2005, an article in the "Texas Law Review" by Seth B. Tillman theorized that it may be incorrect to interpret "Hollingsworth" as holding that constitutional amendment resolutions need not be presented to the President for possible veto. This notwithstanding that the Court—in decisions issued in the twentieth century—itself has adopted that interpretation of its prior decision in "Hollingsworth". Tillman did not suggest that "Hollingsworth" was wrongly decided, but only that its scope (as originally understood) might have been narrower than commonly thought today.