The decision has been variously interpreted. It can be construed as marking the supremacy of the common law over Parliament by judicial review or only as being another form of statutory interpretation. Noah Feldman suggested that the dispute over the two meanings has its origins in 1930s America, where frustration over judicial review of elements of the New Deal spilled into the academic world. James Kent, in his "Commentaries on American Law", argued that "Bonham's Case" and similar cases meant only that statutes should be given a "reasonable construction". Charles Gray, in the "Proceedings of the American Philosophical Society", argues that Coke, as a judge, never intended to advocate the judicial review of statutes. Bernard Bailyn wrote that "Coke had not meant... 'that there were superior principles of right and justice which Acts of Parliament might not contravene'" and also that by "saying that courts might 'void' a legislative provision that violated the constitution he meant only that the courts were to construe statutes so as to bring them into conformity with recognized legal principles".