Historian David E. Kyvig has argued that the Supreme Court in "Hollingsworth" adopted the position put forward by Attorney General Lee, although Kyvig published that argument several years prior to the 2005 article in the "Texas Law Review". Kyvig suggests that the Court adopted Lee's position. However, Kyvig does not explain which of Lee's specific arguments were adopted by the Court or how the language in the Court's opinion explains the primary issue in the case: the scope of Article V and the scope of Article I, Section 7, Clause 3 and the interplay (if any) between the two provisions.