Much work in the field spatial models has concerned the conditions under which majority rule is stable in a multi-dimensional policy space. Some have suggested that legislative practices such as germaneness rules (Shepsle, 1979; Denzau and Mackay, 1981, 1983; Krehbiel, 1987) and different types of agendas (Shepsle and Weingast, 1984; Banks, 1985; McKelvey, 1986) either induce stability or limit the set of possible outcomes. However, they do not consider how stable the choice of these rules may be. This paper shows how the choice of germaneness rules inherits the instability of the policy space. While the use of any particular germaneness rule limits the set of possible outcomes (Feld and Grofman, 1988), it is shown that the process of choosing these rules is unstable.