Principled Conservatism: The CARES Act and the Lone Voice

Virginia Law & Business Review, Forthcoming

19 Pages Posted: 10 Jul 2020 Last revised: 17 Aug 2020

Date Written: July 5, 2020


The Coronavirus Aid, Relief and Economic Security (CARES) Act was the largest spending bill passed by Congress and enacted into law in American history. This Article concludes that despite all of the criticism he has endured, Congressman Massie's lone voice calling for a vote for over $2 trillion in government spending will be remembered years from now as a beacon and clarion call for fiscal and principled conservatives. The Article also examines two prior historical instances which involved a lone voice in the United States House of Representatives: Congresswoman Jeannette Rankin's lone vote against a declaration of war with Japan in 1941 and Congresswoman Barbara Lee's lone vote against the war in Afghanistan in 2001. Both the lone votes of Congresswoman Ranking and Congresswoman Lee illustrate that taking a principled, highly unpopular stance at the risk to one's political career in the United States House of Representatives can result in a positive, long-term legacy. This Article predicts Congressman Massie's lone voice will be viewed in the same lens in the future.

Suggested Citation

Marzen, Chad G., Principled Conservatism: The CARES Act and the Lone Voice (July 5, 2020). Virginia Law & Business Review, Forthcoming, Available at SSRN: or

Chad G. Marzen (Contact Author)

Florida State University ( email )

College of Business
Tallahassee, FL 32306
United States

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