In his forthcoming Alabama Law Review article, "Congress in the Mouth of a Lawyer," Professor Chad Squitieri, Director of the Separation of Powers Institute at Catholic Law, challenges the common assumption that only the House and Senate make federal law. He argues that because the Constitution requires the House and Senate to make law in concert with the President, loose references to the lawmaking "Congress" should be understood as implicitly referencing a broader lawmaking process that includes the President in addition to the House and Senate. In doing so, Squitieri draws on a historical parallel to England—where the English constitutional theorist A.V. Dicey explained that "Parliament means, in the mouth of a lawyer . . . the King, the House of Lords, and the House of Commons." Squitieri then explains how focussing on a more legally precise definition of the lawmaking "Congress" can offer important payoffs in the field of statutory interpretation.