And though Cover acknowledged that it might seem perverse “to seek out a messy and indeterminate end to conflicts
which may be tied neatly together by a single authoritative verdict,” he
nevertheless argued that we should “embrace” a system “that permits tensions
and conflicts of the social order” to be played out in the jurisdictional
structure of the system.44 Thus, Cover’s pluralism, though here focused on
U.S. federalism, can be said to embrace the creative possibilities inherent in
multiple overlapping jurisdictions asserted by both state and non-state entities
in whatever context they arise.