ABSTRACT
Although hard to imagine from our current vantage point, “the Constitution included no presumption that legislative activities should be open to the press.” 1 Members of the Constitutional Convention recognized the diffi culty of making decisions under watchful eyes and closed their doors to the public and the press. James Madison did take notes, but refused to publish them until after the death of all participants. 2 Since early newspapers were largely partisan organs, the fear of infl aming public opinion was legitimate.
