Professor Michael Ramsey has criticized living constitutionalism on the grounds that there are very few limits on what it could achieve. Ramsey uses Kenneth Jost's argument in favor of the unconstitutionality of the electoral college to argue that a living constitutionalist could believe, "Even something expressly set forth in the Constitution can be unconstitutional if annoying, inconvenient or ill-advised." Likewise, Professors Nelson Lund and John McGinnis have argued that it would be difficult for a living constitutionalist such as Robert Post to object if the US Supreme Court had used its reverse incorporation principle together with the principles of "Reynolds v. Sims" to make the US cte apportioned exclusively based on population and still retained the trust of the American people after doing so.