The genius and murkiness of the Constitution

Summary

Throughline – "The Genius and Murkiness of the Constitution"

Host: Rund Abdelfattah
Guest: Heidi Schreck
Release Date: June 30, 2026

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Main Theme / Purpose

This episode of Throughline explores the United States Constitution through the personal lens of playwright and performer Heidi Schreck, best known for her Broadway play "What the Constitution Means to Me." Schreck's journey—from a teenage Constitution debater to a critical adult interrogating the document’s promises and failures—serves as a vehicle to examine the genius, limitations, and ambiguity (the “murkiness”) of America’s foundational text. The episode probes how the Constitution has protected some, failed others, and how its interpretation impacts generations—especially regarding negative versus positive rights and issues of gender, violence, and privacy.

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Key Discussion Points & Insights

Heidi Schreck’s Early Connection to the Constitution

• [00:38] – [01:31] As a teenager in the 1980s, Heidi traveled to debate competitions, giving speeches on the Constitution to earn money (ultimately paying for college this way).
  • “When I was 15 years old, I would travel the country giving speeches about the United States Constitution for prize money.” — Heidi Schreck (as 15-year-old self), [00:48]
• [02:11] Heidi describes the Constitution:
  • “Our Constitution can be thought of as a boiling pot in which we are thrown together in sizzling and steamy conflict to find out what it is we truly believe.” — Heidi Schreck (as 15-year-old self), [02:11]

Reconciling Family History with Constitutional Promises

• [02:37] – [03:12] Discovering her family’s legacy of abuse made her reexamine her faith in the Constitution.
  • “I feel like it’s a document that has produced, protected me, and completely failed me and so many other people in this country.” — Heidi Schreck, [03:12]

How the Constitution Actually Works

• [07:37] – [08:18] Through interviews with constitutional scholars, Heidi learns the Constitution isn’t primarily designed to protect individuals, but to define government power and protect individuals from government overreach (negative rights).
  • “It’s actually not designed to protect us. Right. It’s designed to first outline how government will function...” — Heidi Schreck, [07:37]
  • She finds the Due Process Clause especially meaningful as a teen:
    • “Nor shall any state deprive any person of life, liberty or property without due process of law.” — Heidi Schreck (as 15-year-old self), [08:10]
• [08:25] – [09:54] Discussion of negative vs. positive rights.
  • Negative rights: Protect from government interference (predominate in the U.S. Constitution).
  • Positive rights: Entitlements the government must provide (e.g., healthcare in some countries).
  • “Our Constitution for the most part is full of negative rights.” — Constitutional scholar/expert, [08:54]

Comparative Constitutions and the U.S.’s Place

• [09:22] Modern constitutions (Germany, South Africa) guarantee positive rights and protections for vulnerable citizens.
  • Heidi compares these constitutions to the U.S., highlighting the lack of explicit protections in the latter.

Case Study: Castle Rock v. Gonzales

• [10:06] – [13:09] The 2005 Supreme Court case about police failure to enforce a restraining order, resulting in tragedy for Jessica Gonzales (now Lenahan), illustrates the inadequacy of “negative rights” for real-world protection, especially for women.
  • “They spent very little time talking about Jessica Lenahan as a human being... instead they spent a very long time arguing about the word ‘shall’...” — Heidi Schreck (as 15-year-old self), [13:10]
• [14:26] Some scholars call Castle Rock "the death of the 14th Amendment for women," showing the Constitution can fail to protect against violence.

The Concept of the Penumbra

• [15:11] – [15:47] Heidi becomes fascinated by the term "penumbra," used by Justice Douglas describing the shadowy zone between explicit and implicit rights in the Constitution.
  • “The word itself means the space between, like, the full light and the darkness. … this kind of half light, half dark, very shadowy, murky, murky place.” — Heidi Schreck, [15:31]
• [16:00] – [18:47] Griswold v. Connecticut (1965) uses the Ninth Amendment and “penumbra” language to enshrine a right to privacy, underpinning rights to contraception and later, abortion (Roe v. Wade).
  • “Our Constitution doesn’t tell you all the rights that you have because it doesn’t know.” — Heidi Schreck (as 15-year-old self), [17:07]
  • “Justice William O. Douglas … used the word penumbra in Griswold vs. Connecticut.” — Heidi Schreck, [17:41]
  • The discussion and clips of all-male justices awkwardly debating birth control. “They had to look to this amendment that nobody really understands…” — Heidi Schreck, [19:40]

The Genius and Problem of Ambiguity

• [20:06] – [20:30] The Constitution’s vagueness (or “murkiness”) allows for flexibility and change—its “genius”—but also for inconsistency, leaving some rights in precarious “shadow zones.”
  • “A murky space that leaves so much room for interpretation, which many argue is the very genius of our Constitution.” — Narrator/Producer, [20:06]
  • “People laughed at Douglas for calling it this, but I like it… we are trapped in a penumbra.” — Heidi Schreck (as 15-year-old self), [20:30]

A Changed Relationship to the Constitution

• [21:09] After years of reckoning with these ambiguities, Heidi no longer simply reveres the Constitution as a unifying crucible, but wonders if it might need to be obligated to “actively look out for all of us.”
  • “Maybe we could think of the Constitution as a Constitution that is obligated to actively look out for all of us.” — Heidi Schreck (as 15-year-old self), [21:09]

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Notable Quotes & Memorable Moments

• “Our Constitution can be thought of as a boiling pot in which we are thrown together in sizzling and steamy conflict to find out what it is we truly believe.” — Heidi Schreck (as 15-year-old self), [02:11]
• “I feel like it’s a document that has produced, protected me, and completely failed me and so many other people in this country.” — Heidi Schreck, [03:12]
• “It’s actually not designed to protect us. Right. It’s designed to first outline how government will function...” — Heidi Schreck, [07:37]
• “I just... I've listened to this case so many times, and the thing I notice when I hear the justices speak... they spent very little time talking about Jessica Lenahan as a human being.” — Heidi Schreck (as 15-year-old self), [13:10]
• “The word itself means the space between, like, the full light and the darkness... this kind of half light, half dark, very shadowy, murky, murky place.” — Heidi Schreck, [15:31]
• “Our Constitution doesn’t tell you all the rights that you have because it doesn’t know.” — Heidi Schreck (as 15-year-old self), [17:07]
• “A murky space that leaves so much room for interpretation, which many argue is the very genius of our Constitution.” — Narrator/Producer, [20:06]
• “Maybe we could think of the Constitution as a Constitution that is obligated to actively look out for all of us.” — Heidi Schreck (as 15-year-old self), [21:09]

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Important Timestamps

• [00:38] – Heidi recounts her teenage debate experience
• [02:11] – Constitution as a "boiling pot" metaphor
• [03:12] – Constitution’s ambiguous legacy on Schreck’s life
• [07:37] – Constitution’s primary purpose and negative rights
• [09:22] – Contrast with modern constitutions and positive rights
• [10:06] – [13:09] – Castle Rock v. Gonzales detailed case study
• [15:11] – [15:47] – The idea of constitutional penumbras
• [16:00] – [17:41] – Griswold v. Connecticut, Ninth Amendment, right to privacy
• [20:06] – Constitution’s vagueness: genius and pitfall
• [21:09] – Schreck’s evolved view on the obligations of the Constitution

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Tone and Language

The episode blends personal storytelling and historical analysis, maintaining a reflective, inquisitive, and occasionally wryly humorous tone as modeled by both Schreck and Abdelfattah. Schreck’s language, shaped by her theatrical background, is vivid and metaphoric, especially in her discussion of the “penumbra” and the shadowy spaces within (and beyond) the Constitution.

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Conclusion

By weaving personal narrative with pivotal constitutional history, this episode challenges listeners to interrogate not only the interpretation of the Constitution, but its very architecture—its genius, limitations, and responsibilities in a modern society. The Constitution, as presented by Schreck and Throughline, is less a sacred, fixed text and more a living arena with vast, sometimes perilous, gray areas—penumbras in which Americans continually negotiate their rights, protections, and values.

Transcript

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[Rund Abdelfattah]

This is America in Pursuit, a limited run series from NPR and Throughline. I'm Rund Abdelfattah. Each week we bring you stories about life, liberty and the pursuit of happiness in the US and that began 250 years ago. Today I want to tell you about a woman named Heidi. Heidi Schreck.

[Heidi Schreck]

I am an actor, writer, performer, creator.

[Rund Abdelfattah]

When Heidi was a teenager in the 1980s, she did something not a lot of kids were doing.

[Heidi Schreck (as 15-year-old or narrator)]

When I was 15 years old, I would travel the country giving speeches about the United States Constitution for prize money.

[Rund Abdelfattah]

Heidi loved the Constitution. She believed it was the greatest political document ever written and she was damn good at talking about it. Back then she wore a blue power suit, had very large permed hair, a lot of makeup.

[Heidi Schreck (as 15-year-old or narrator)]

I would travel to big cities like Denver, Fresno. I would win a whole bunch of money, bring it back to put my little safety deposit box for later. I was actually able to pay for my entire college education this way. Thank you. Thank you so much. It was 30 years ago and it was a state school, but thank you.

[Rund Abdelfattah]

That's Heidi on a Broadway stage some years ago performing her hit play, what the Constitution Means to Me. It's a show Heidi wrote about her experience participating in those debate clubs when she was a teenager. For most of the play, Heidi is on stage by herself. She goes back and forth between the current Heidi, a woman in her late 40s, and the 15 year old version of herself. The set is a recreation of the American Legion hall where one of those debates took place decades ago. She stands alone on stage. Behind her is a wall covered with the faces of hundreds of men, framed photographs of competition judges and war veterans.

[Heidi Schreck (as 15-year-old or narrator)]

Our Constitution can be thought of as a boiling pot in which we are thrown together in sizzling and steamy conflict to find out what it is we truly believe. That is why it's such a radical document.

[Rund Abdelfattah]

And it's from this so called radical document from those years spent deliberating over the Constitution that things started to click and to change in Heidi's worldview.

[Heidi Schreck]

I would say the biggest thing that happened was that I learned some things about my family history, but I didn't quite connect it to the Constitution at the time. I didn't know how to make those connections.

[Rund Abdelfattah]

Heidi learned about this legacy of abuse in her family during those years. But it took nearly two decades for her to really start to understand how it all fit together. And in that understanding, all of her ideas about the Constitution were challenged.

[Heidi Schreck]

I don't even know where to begin except to say that the Constitution has profoundly shaped my life. I feel like it's a document that has produced, protected me and completely failed me and so many other people in this country.

[Rund Abdelfattah]

And so she turned that profound engagement with the document into a play to share with thousands of people whose dialogue explores what exactly the Founding Fathers created and meant to create. Back in 1787, a group of magicians

[Heidi Schreck (as 15-year-old or narrator)]

got together on a sweltering summer day in Philadelphia and they wanted to kill each other. But instead, instead they sat down together and they performed a collective act of ethical visualization, or as I like to call it, a spell.

[Rund Abdelfattah]

Today on the show, we're talking about the Constitution of the United States with Heidi Schreck, someone who spent a lot of time sorting through the promises of the Constitution, how it works and how it's impacted subsequent generations of Americans. That's coming up after a quick break.

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[Rund Abdelfattah]

When Heidi Schreck started writing what the Constitution Means to Me, she thought she was writing a lighthearted, comical play, maybe even something fun.

[Heidi Schreck]

You know, one of those, like great movies about like girl debaters that's sort of uplifting and really fun and funny

[Narrator/Producer]

that was the original idea. Take the prompt of the actual contest she used to do as a teenager,

[Rund Abdelfattah]

which was to draw a personal connection

[Narrator/Producer]

between her own life and the Constitution. But do that with the wisdom and hindsight that only adult Heidi could bring to the table.

[Rund Abdelfattah]

Because when she was 15, drawing those

[Narrator/Producer]

personal connections sounded like, you know, I

[Heidi Schreck]

protested my school's ban on girls wearing shorts and that's me expressing my first amendment right.

[Rund Abdelfattah]

And then she decided to take it more seriously.

[Heidi Schreck]

That immediately took me to birth control, that took me to Roe v. Wade, that took me to the 14th Amendment and the 9th Amendment, and then it took me to, to domestic violence. So when I was like, these are all things that have affected my life, why don't I dig into what the Constitution has to say about them, what the Supreme Court has had to say about them. I would say making the play kind of forced a reckoning, maybe because of

[Heidi Schreck (as 15-year-old or narrator)]

my own family history of this kind of violence. I just, I needed to make sense of it. So I talked to several constitutional scholars.

[Constitutional Scholar/Expert]

Heidi learned a few things and part of that learning process was unlearning. She grew up thinking and defending the idea that the Constitution was meant to protect us, the citizens. But then she learned that's not exactly true.

[Heidi Schreck]

It's actually not designed to protect us. Right. It's designed to first outline how government will function, the co, equal branches of government, separation of powers. It's designed to put a system in place and then it's designed to protect us from encroachment by the government. Right. From allowing like tyranny to take over. So it like the due process clause which says the government cannot lock you

[Heidi Schreck (as 15-year-old or narrator)]

up, take your stuff or kill you without a good reason.

[Constitutional Scholar/Expert]

15 year old Heidi loves this clause.

[Heidi Schreck (as 15-year-old or narrator)]

It states, nor shall any state deprive any person of life, liberty or property without due process of law.

[Constitutional Scholar/Expert]

This brings us to another thing Heidi learned from the constitutional scholars. She learned about two kinds of rights,

[Heidi Schreck (as 15-year-old or narrator)]

negative rights and positive rights.

[Constitutional Scholar/Expert]

The due process clause falls into the category of negative rights, rights that protect us from something like the government. While positive rights are active rights rights that the government or other people have to actually provide.

[Heidi Schreck (as 15-year-old or narrator)]

They include things like, like the right to a fair trial to an attorney in some countries, the right to health care.

[Constitutional Scholar/Expert]

Our Constitution for the most part is full of negative rights.

[Heidi Schreck]

And one of the things that I discovered when I was researching the play was I just read a lot of other countries constitutions and I was interested in what modern constitutions look like because ours is the oldest active constitution that's

[Rund Abdelfattah]

because many other countries over time have scrapped their original documents and replaced them with more modern constitutions. South Africa and Germany have both done this.

[Heidi Schreck]

And seeing that constitutions created in the 20th century and constitutions that were created in the wake of genocide, in the wake of great governmental crimes, those constitutions contain positive rights, right, contain active protections for people who say like, they say like we will guarantee that you are a protected class of citizen so that you will not be discriminated against on the basis of race, sex, gender, ability. They say we will guarantee a clean planet. Now, whether these are effective or not is up for debate, but they have active positive rights, things that the government is supposed to do, right to protect you and take care of you as a citizen.

[Rund Abdelfattah]

Heidi first saw how a constitution made up of mostly negative rights, those liberties outlined in the Bill of Rights in our Constitution specifically failed to protect the abused women and her family and thousands of others through the Supreme Court case Castle Rock versus Gonzalez, which is about

[Heidi Schreck]

whether the police are required to enforce restraining orders.

[Supreme Court Justice Antonin Scalia (voice clip)]

This is case number 04278. Town of Castle Rock versus Gonzalez.

[Narrator/Producer]

This is the late Supreme Court Justice Antonin Scalia delivering the majority opinion on June 27, 2005. Despite the nature of the case, Scalia kicked things off with a joke.

[Supreme Court Justice Antonin Scalia (voice clip)]

I thought Castle rock was a 1920s dance, but it's also a town in Colorado.

[Rund Abdelfattah]

Then he cut to the chase.

[Supreme Court Justice Antonin Scalia (voice clip)]

The facts are truly horrible. Jessica Gonzalez, the respondent, sued the town of Castle Rock in federal district court, alleging that the town had violated her rights under the 14th Amendment's due process clause.

[Constitutional Scholar/Expert]

Jessica Gonzalez had three daughters with her husband and a restraining order against him. She filed for one in 1999 after a long history of violence and abuse. A month into that restraining order, her husband kidnapped their three children. Gonzalez called the Castle Rock Police Department for help. It was around 7:30pm when officers came to her house.

[Supreme Court Justice Antonin Scalia (voice clip)]

She showed them the restraining order and asked them to enforce it and return her children. They told her to call back if the children did not return by 10pm

[Constitutional Scholar/Expert]

she called an hour later saying she had heard from her husband and knew where they were.

[Supreme Court Justice Antonin Scalia (voice clip)]

Again, they told her to call if the children were not returned by 10pm

[Constitutional Scholar/Expert]

she called again and again until nearly 1am when she got back in her car and went to the station to file a report. An officer took the report and then went to dinner.

[Supreme Court Justice Antonin Scalia (voice clip)]

Finally, at 3:20am her husband showed up at the police station shooting a semiautomatic handgun. The police shot him dead and discovered in his pickup truck the bodies of all three children whom he had already murdered.

[Narrator/Producer]

Jessica Gonzalez, who's actually now Jessica Lenahan, her maiden name, sued the town of Castlerock for violating her rights under the Due Process clause of the 14th Amendment by refusing to enforce her restraining order and therefore failing to protect her family. Remember, the Due Process clause is a prime example of negative rights, which is

[Heidi Schreck (as 15-year-old or narrator)]

in part how they came to decide that Jessica Lanahan was not entitled to any active or positive protection from the police.

[Narrator/Producer]

She lost.

[Heidi Schreck (as 15-year-old or narrator)]

I. I just. I've listened to this case so many times, and the thing I notice when I hear the justices speak, the thing I notice is that they spend very little time talking about Jessica Lenahan as a human being. They don't talk about her daughters. Instead, they spent a very long time arguing about the word shall, as in the phrase the police shall enforce a restraining order. Scalia ultimately decided that shall did not mean must, which. Which I actually find very confusing because Scalia was a devout Catholic. Some constitutional scholars have called this decision the death of the 14th Amendment for women. It basically shuts down the possibility to look to our federal government, to our Constitution, for protection from physical and sexual violence.

[Rund Abdelfattah]

Castle Rock vs. Gonzalez was a constitutional test that helped adult Heidi understand her own family history in relation to the Constitution in a way she never could have as a teenager, back when she viewed the document essentially as scripture. This ruling brought into clear focus this tug and pull between positive and negative rights, and it shined a bright light on those shadowy rights that lie somewhere in between.

[Heidi Schreck (as 15-year-old or narrator)]

Here I am standing in the light, and there you are sitting in the darkness. And this space between us, this space right here of partial illumination, this shadowy space right here, this is a penumbra.

[Heidi Schreck]

The word itself means the space between, like, the full light and the darkness, right? Or it's actually between the full light and a kind of shadow. So it's this kind of half light, half dark, very shadowy, murky, murky place.

[Rund Abdelfattah]

Penumbra, a kind of metaphor for the juxtaposition of what's explicit and implicit in the Constitution. Heidi discovered and then became obsessed with the word penumbra when learning about another

[Heidi Schreck]

supreme court case, Griswold vs. Connecticut, which is the case that made birth control legal for all people in this country in 1965.

[Constitutional Scholar/Expert]

Pretty late in 1961, Estelle Griswold and Dr. Charles Lee Buxton were arrested for giving information about contraception and writing prescriptions for IUDs to women at a Planned Parenthood in Connecticut. They took their case to the Supreme Court. This is the case where Heidi's favorite parts of the Constitution join hands and take center stage. The due process clause of the 14th

[Heidi Schreck (as 15-year-old or narrator)]

Amendment and the most magical and mysterious amendment of them all, Amendment 9. Amendment 9 says, the enumeration in the Constitution of certain rights shall not be construed to deny or disparage others, retained by the people.

[Heidi Schreck]

Basically, that talks about unenumerated rights. It says, just because a right isn't listed in the Constitution, it doesn't mean you don't have that right.

[Heidi Schreck (as 15-year-old or narrator)]

The fact is, there was no way for the framers to put down every single right we have. I mean, the right to brush your teeth. Yes, you've got it. But how long do we want this document to be? Think about it for a moment. Our Constitution doesn't tell you all the rights that you have because it doesn't know.

[Heidi Schreck]

And I love that amendment because it does speak to the, like, living, breathing nature of the document. And also, it's just a very weird, mysterious thing. Like everything else is rather concrete and it's very confusing. This Amendment.

[Heidi Schreck (as 15-year-old or narrator)]

Justice William O. Douglas, the great Supreme Court justice, when he Talked about Amendment 9, he used the word penumbra in Griswold versus Connecticut.

[Heidi Schreck]

I read about how that case was partially decided with the help of the ninth Amendment, as was Roe v. Wade, with this idea that, like, okay, we don't know. Given. Given the tools we have with this Constitution, we don't know how to say exactly that like, a person is entitled to use birth control or a person is entitled to have an abortion. So we're going to locate it in this right to privacy, which is not enumerated in the Constitution. Exactly. But we're going to say it's like it's there. It lives there in the shadow of the Constitution as a result of other rights that were enumerated. Right. So it's like this very, very murky reasoning.

[Heidi Schreck (as 15-year-old or narrator)]

And this. This is when William O. Douglas brought out his beautiful penumbra metaphor. This is when he said one thing our Constitution surely guarantees is the right to privacy, and that this allows a woman to put in an IUD as

[Narrator/Producer]

long as she's married. Anyway, at this point in the play, Heidi pulls up a clip from the Griswold case of the nine justices, all men attempting to discuss birth control.

[Supreme Court Justice Antonin Scalia (voice clip)]

It's probably only true with respect to some, but some get by under the term feminine hygiene and others. I just don't know about, but they are. They are all sold in Connecticut drugstores on one theory or another. Is there anything on the record to indicate

[Rund Abdelfattah]

the one of the first rates

[Supreme Court Justice Antonin Scalia (voice clip)]

Connecticut vis a vis the states that don't have such laws.

[Heidi Schreck]

I really found it fascinating that first of all that the justices who at the time were nine men, had to look to this amendment that nobody really understands and decide that they found, you know, the right to birth control or the right for a pregnant person to have autonomy over their own body. That they found that in this, in the shadows of the Constitution, I guess in this like murky, murky space, a

[Narrator/Producer]

murky space that leaves so much room for interpretation, which many argue is the very genius of our Constitution. The intentional vagaries allow for flexibility, but this very nature of the document may at times protect its citizens, but at other times it fails them, leaving some of our basic rights hanging in the balance.

[Heidi Schreck (as 15-year-old or narrator)]

People laughed at Douglass for calling it this, but I like it. I think it's a helpful way to think about the Constitution and also maybe about our lives. I mean, here we are stuck between what we can see and what we can't. We are trapped in in a penumbra.

[Constitutional Scholar/Expert]

As a teenager, Heidi really believed in the Constitution. But after a decade of writing and performing this play, something flipped. Heidi could no longer ignore all the imperfections.

[Heidi Schreck (as 15-year-old or narrator)]

Maybe it's not helpful to think of the Constitution as a crucible in which we're all battling it out together, in which we go in front of a court of nine people to negotiate for our basic human rights. Maybe, maybe we could think of the Constitution as a Constitution that is obligated to actively look out for all of us

[Supreme Court Justice Antonin Scalia (voice clip)]

Foreign.

[Rund Abdelfattah]

That's it for this week's show. If you want to hear the full length episode with Heidi, check out the Shadow of the Constitution and join us next week when we look at the story of America through music.

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You can look at any point in American history and understand what was happening

[Rund Abdelfattah]

through the the sounds that were developing at that time. That's next week. Don't miss it. This episode was produced by Kiana Moghadam and edited by Christina Kim and Julia Redpath with help from the Throughline production team. Music by Ramtin Adablouei and his band Drop Electric. Special thanks to Julie Kane, Irene Noguchi, Beth Donovan, Casey Miner and Lindsay McKenna. I'm Rund Abdelfattah. Thanks for listening.

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