ABSTRACT. Sparks explores the question of how the penal realm intersects with the cultural and the political, and of what we mean by each of those terms when we use them together. Andrews and Bonta hold that treatment be delivered in a style and mode that is consistent with the ability and learning style of the offender. Dworkin argues that political and legal concepts have a deep structure that determines what these terms really mean. Patterson urges that we recognize that law is "a practice of argument" and that various forms or "modalities" of argument constitute its "grammar".