According to Coleman, it is none other than the Congress itself—if and when the Congress should later be presented with valid ratifications from the required number of states—which has the discretion to arbitrate the question of whether too much time has elapsed between Congress' initial proposal of that amendment and the most recent state ratification thereof assuming that, as a consequence of that most recent ratification, the legislatures of (or conventions conducted within) at least three-fourths of the states have ratified that amendment at one time or another.

The Coleman ruling—which modified the high Court's earlier 1921 dictum in Dillon v. Gloss—held that the question of timeliness of ratification is a political and non-justiciable one, leaving the issue to the discretion of Congress.

Thus it would appear that the length of time elapsing between proposal and ratification is irrelevant to the validity of the amendment.

Declared ratified on May 7, 1992, it had been submitted to the states for ratification on September 25, 1789, an unprecedented time period of 202 years, 7 months and 12 days.

[2] The Coleman decision has been described as reinforcing the political question doctrine which is sometimes espoused by Federal courts in cases wherein the court deems the matter at hand to be properly assigned to the discretion of the legislative branch of the Federal government.