By the early nineteenth century, the ancient remedy of deodands had largely fallen into desuetude. Many argue that impeachment has fallen into desuetude. For many years commentators thought that "Diehr" overruled "Flook" or reduced it to innocuous desuetude. The doctrine of desuetude has not historically been favoured in the common law tradition. In Scotland, non-use is not the same as desuetude. Desuetude does not apply to requirements of the United States Constitution.