On March 11, 2014, the European Commission, the executive body of the European Union (EU), adopted a new framework [3] to strengthen the rule of law in the EU.  Designed to address “systemic threats to the rule of law,” according to the press release [4], “the new . . . framework will be complementary to infringement procedures . . . and to the so-called 'Article 7 procedure' of the Lisbon Treaty which . . . allows for the suspension of voting rights in case of a ‘serious and persistent breach’ of EU values by a Member State.”  Additionally, the framework “establishes an early warning tool allowing the Commission to enter into a dialogue with the Member State concerned to prevent the escalation of systemic threats to the rule of law.”