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The Human Subject in American Constitutional History

Sandra F. VanBurkleo
 

On June 6, 1918, Virginia Woolf noted in her diary that she had "seen Alix today" -- meaning Alex Sargant-Foster -- and had invited her to dinner. "I think the faintest ray of dawn is observable on the pitchy black of her horizon," she wrote. "She is able to conceive the possibility of one day finding some book to read. She has tried Bertie's mathematics, relinquished it, but did not altogether dismiss my suggestion of legal history. She wants to work at something that matters to no one; & will never be used, seen, or read, & can be done for no more nor less than 3 hours a day."(1)

Why did Woolf assume that legal history "matters to no one"? That it would "never be used, seen, or read"? The quick-and-dirty answer, as you know, is that legal historians -- close cousins of economists and other purveyors of "dismal sciences" -- tend to think primarily about cases, doctrines, the mechanics of law practice, institutional arrangements. Benjamin Wright really did write an entire book about the contract clause, which I, for one, read in a graduate seminar. Books like that don't end up as Main Selections for the History Book Club.

I don't want to offer yet another talk about tensions between law and history. We've all heard quite enough of that -- and I'm not persuaded in any case that the dilemma as presently framed goes to the heart of the matter. In a general way, we all know -- some of us approve, some don't -- that constitutional historians, even more completely than historians of private law, typically fail to bridge the gap between that 'brooding omnipresence in the sky' and the people who authorize and experience law, government, freedom. Human beings aren't missing altogether: textbooks certainly include numerous references to "the people," to "the constituent power," "slaves," "citizens," and so on. They include an ever-increasing number of references to previously excluded individuals or classes (free blacks, unionists, indigenous peoples, Frederick Douglass, Susan B. Anthony), although typically as parties to cases or advocates of constitutional emendation and change. And, sometimes, scholars put ordinary people, their consciousness of freedom, their experiences of governmental constraint, center stage. Don Nieman's Promises to Keep begins virtually every chapter with a concrete tale of a human being or group mobilizing in self-defense; Linda Kerber's 'No Constitutional Right to be Ladies' seamlessly weaves biography and human agency into the book's analytical fabric.

Still, I don't need to tell this audience that these are exceptions to a deeply juridified, homogenizing scholarly practice. It is no accident that judicial biography -- despite its celebration of Great Men at Law -- continues to be viewed as a step-child, an orphan, something no graduate student would undertake for a dissertation without long, hard talks with her advisor. (Hence, no modern biography of Roger Taney, for heaven's sake). Most of the time, the subjects of our discipline continue to be, not particular human beings making and participating in constitutional culture along with judges and congressmen, but the structures, functions, utterances, and trajectories of "the state," and especially of the nation's highest court -- a host of elegant, deeply impersonal formalities that "the people" own but rarely occupy. We do not include McCulloch v. Maryland in textbooks and lectures, in other words, primarily because we want to talk about the cashier of the Baltimore branch bank or the legislators responsible for BUS taxation -- or even because hundreds of Americans in places like Tennessee and Kentucky thought that the republic would collapse if the Court had its way. Instead, many -- perhaps most -- teachers of constitutional history characterize McCulloch as a particularly fine example of John Marshall's defense of federal energy in relations with states. Some of us would add, as a kind of political-social (that is to say, extra-constitutional) postscript, that Marshall's targets in 1819 were state legislators determined to 'kill' the Second Bank, that Spencer Roane attacked Marshall in the Richmond Enquirer, that Marshall rejoined, and so forth. But this is an add on, a supplement -- definitely extra-constitutional.

Where are "the people" -- indeed, where can "the people" hope to be -- in such a narrative? Let's assume for the moment that we're all historians, and that our students sign up primarily for history courses, not for law courses. In the term "constitutional history," after all, 'history' is the noun and 'constitutional' the modifier. From this vantage point, the "missing persons" phenomenon is actually fairly interesting. For historians supposedly have special, primary expertise in human agency and human experience -- unlike political scientists and lawyers, who specialize in the study of systems, structures, doctrines. Herbert Muller, for instance, termed the "whole enterprise of civilization" a "rare human creation, a triumph of mind and will"; impersonal forces, he thought, "work only through the ideas and beliefs of men."(2) Yet, very often, being more responsive to "people" calls to mind nothing more than new sentences about minorities or women; we don't imagine rethinking those technically brilliant, wholly 'internal' lectures about Roger Taney's spin on the commerce clause -- that is to say, the master narrative itself.

Let me be clear: I am not urging that structures, doctrines, the narrative of the federation's growth and development, should be junked. We all know better. Organic law, the Congress, the Court occupy a large part of the arena within which experiences of government and freedom happen. Rather, I mean to say, first, that constitutional historians tend -- even more completely than our comrades in legal history -- to unify, homogenize, and reify every part of their subject; and second, that this rule-seeking architecture of mind leads many of us variously to treat "the people" either as passive receivers and containers of legal events (supplying so-called "context"), or simply as vehicles who bring disputes into a constitutional court, where judges and lawyers marginalize and then erase them. As a consequence, we don't think deeply about the layering, the complexity, the messiness, so much a part of both constitutionalism and human consciousness of it. Very commonly, in fact, we relegate unsightly or unruly matters to fields on the other side of a bright line drawn around recognizably 'constitutional' forms and institutions. "Social history," "women's history," "political history" supposedly treat culture, liberty poles, rights consciousness, the contests for control of constitutional meanings that Dirk Hartog once called "constitutions of aspiration"; constitutional history does not treat these things. As a result, we fail to attract to constitutional history many undergraduates who are not interested in law school. Equally troubling, we fail to convey law's moral content to pre-law students -- its origins in human life and thought, its capacity for both cruelty and social improvement. We also put ever-greater distance between ourselves and the writers of survey textbooks, who do little more than recycle stale paragraphs about Marbury and the Fourteenth Amendment.

What about the "government-and-liberty" part of the subject? One of the most consistently fascinating things about our field is the extraordinary, ongoing power of both legal formalism and systems analysis in shaping the subject and its analytical objectives. Those seemingly irresistable forces have inspired a sprawling literature about law and history that I intend for the most part to ignore.(3) Beneath those pressures and their irresistibility, though, is a frame of mind (I sometimes think, especially when reading my H-Law postings, that too many of us are wanna-be lawyers) that we need to explore at some length. It is a view shaped very powerfully by more than a few misconceptions about the common law.

Why "misconceptions"? Contrary to the rather mindless, rule-seeking behavior of law students headed for the bar exam, and certainly contrary to the impulse underlying searches for the (presumably unitary and homogenous) intentions of various framers and founders, the vast collection of texts and judicial utterances that comprise "constitutional law" are layered rather than one-dimensional, discordant rather than unitary. Good lawyers certainly know this. Adam Czarnota and Martin Krygier once called this phenomenon "layered complexity." Legal systems, they noted, consist not only of rules and principles, but also of higher order understandings, received techniques (matters necessarily of human memory, and therefore to some extent irrational), constellations of values, shared as well as diverse ways of perceiving reality, which are pervasive and themselves deeply layered in complex, decisive ways.(4)

Why, then, do constitutional historians -- not unlike historians of ideas, whose internal controversies greatly resemble out own -- pay lip service to varieties of "social" or "political" drapery, yet continue to situate governmental forms and unity-seeking abstractions at the center of the analysis? Is there no difference between constitutional history, and constitutional law practiced using old material, so that the past furnishes a supply of cases for continual re-argument? Even Willard Hurst, for all of his concern about the anti-democratic character of appellate law practice, thought that legal institutions and the "social values embodied in law developed within the context of demanding ideals of constitutionalism" which, apparently all by themselves, "pressed legal agencies and their formal processes into rich involvement with institutions and patterns of individual and group experience" -- which, in turn, gave social meaning to law.(5)

Surely the curious resilience of reification and homogenization has something to do with historians' internalization of 'legal thinking,' or at least what passes for it. Not coincidentally, human beings (excepting perhaps the judges, whose degree of personal influence, I should remind you, is a point of scholarly disputation) come to be squeezed out of the picture. Nobody said it better than Leonard Levy. "The common law," he observed in the concluding chapter of his biography of Lemuel Shaw, "knew society only as so many John Does and Richard Roes, which is to say that it had scant regard for society collectively. Social and economic problems were reflected in the common law merely as conflicts of personal interest between contending parties. They might possess an unequal status and power; their case might involve great and grave social interests. But to the common law, indifferently neutral and ... generally oblivious to public policy, the parties were theoretically interchangeable personalities to be dealt with on equal terms and with scant regard for others."(6)

Part of what's missing, then, is an appreciation for what Clifford Geertz calls "legal sensibility" -- that is, the shifting ways in which a society creates and generates rules, the constitutive aspects of a legal system, its distinctive and ever-changing "method and manner of conceiving decision situations so that settled rules can be applied to decide them."(7) Americans, for example, have constituted "the state" very differently over time; various gatekeepers -- some of them distinctly unmodern -- have controlled access to basic rights and liberties. Yet, until very recently, historians were virtually blind to the shifting sites of public power, the content of state constitutions, or the community-centered, locally-sanctioned responsibilities of domestic governments. In nineteenth-century America, for example, federal courts and Congress were invisible to most Americans, most of the time. Yet citizens and non-citizens regularly experienced (or were denied experiences of) the rule of law, freedom, and 'the state.' It is simply false to conclude, from the evidence derived solely from federal policy, that (to give some examples) liberty of speech, freedom of assembly, or the right of locomotion didn't register on the constitutional Geiger counter. They did. But we need to look in the right place. Household heads (barons) governed women, children, and servants, at the behest of formal governments; plantation masters governed African-Americans, again as agents of state and municipal governments. Husbands, fathers, masters, even presiding officers at reform society conventions, regularly and powerfully shaped the liberty prospects of dependents and constituents. A woman's ability to visit relatives or make a public speech, a slave's ability to stroll in the woods or write a letter, rested with domestic governors; a wife's capacity to exercise constitutional rights to property depended upon the generosity of state legislators, local judges, and male relatives. In the 1850's, Antoinette Brown and many other prominent women, sometimes in company with black male abolitionists, found themselves tossed out of lecture halls for daring to mount the podium; upper-class women went on the lecture circuit to eliminate "padlocks on our lips," as one woman put it.(8)

Well into the 1860's, women's rights activists situated speech and press freedom dead center on their constitutional agenda, in some cases ahead of political freedom. They complained loudly and repeatedly of unconstitutional 'takings' of their property, apparently for the crime of marriage. They spoke the language of republican constitutionalism with fluency and wielded it to great good effect. Are their agitations a chapter in "social history"? Or in constitutional history differently conceived? Do we really need a ruling by the Marshall Court before we can say that explicit demands for access to the First Amendment -- indeed, that men and women, blacks and whites, experienced constitutionalism very differently -- merit inclusion in texts and lectures?

What about people like Antoinette Brown, whose exchanges with constituted authority permanently altered American constitutional culture? With important exceptions, constitutional historians continue to ignore human agency beyond key actors on benches and in Congress; we speak instead of amorphous classes -- "the people" (the constituent power, "the citizenry"), "slaves," "women," "aliens," and so on -- much as I've done every time I presume to speak for all of us ("we"). As Karl Joachim Weintraub once said of Saint Augustine, constitutional historians exhibit remarkably little interest in developing a "conception of the interplay of a self," or of selves, formed in a "specific world," working "back upon the world by partially making it [their] own, changing it in terms of what it has become by having interacted with it."(9)

Setting aside the possibility that such talk really belongs in 'social history': why do human beings with different, contributory, or contrary stories to tell come to be portrayed as environmental, "contextual" noise -- as a necessary distraction surrounding but distinguishable from the "real" juridified primary subject or "text"? Do historians generally cling to a unitary, usually white and male master narrative basically to hold off the spectre of radical subjectivism -- as if those were the only choices? Whatever the cause, we have come, often reluctantly, to recognize the existence of alternative witnesses and story-tellers, but still treat them as aliens possessed of incompatible or extra-constitutional cultures. "Slaves," presumptively steeped in the culture of the quarters rather than in the culture of constitutionalism, are regularly named, but rarely granted a constitutional history of their own -- that is, a page on which to describe their experiences of freedom, mastership, state governments, as agents and subjects. Black experiences of constitutional government, after all, happened before, after, and all around the Amistad case, well beyond the range of movie cameras; race (and gender) powerfully cut across the sovereign individual's right to personal security, or to a jury trial by peers. Yet the "slave" is most often an object of someone else's story. Working men demonstrated in public squares to secure ballots for all white men without reference to property or class; for the most part, their contributions to constitutional change have been unremarked. Women enter the scene, basically, only with the Supreme Court's ruling in Myra Bradwell's case, and typically as prescient advocates of modernity -- as champions of universal suffrage, Roe v. Wade, workplace equality, and ERA.

We tend, in other words, to demand compliance with the official story as a condition for permanent residence in the Big House. Susan B. Anthony and Margaret Sanger have House privileges because of the "Anthony Amendment" and Griswold v. Connecticut; despite Socialism, Eugene Debs unwittingly contributed to the development of the commerce clause and so merits a paragraph. Elizabeth Cady Stanton, Mother Jones, Paulina Wright Davis, Mary Church Terrell, and thousands of anti-suffragists followed different drummers, never appeared before the Supreme Court, and so inhabit other extra-constitutional narratives ("black history," "women's history," "political history"). To borrow Robert Berkhofer's words, contrary or supplementary voices "do not cross" the master narrative so much as "fall in line" with it.(10)

Still, as Eric Foner points out in his elegant history of American freedom,(11) it is the special genius of American culture to permit and even encourage disputation; a central feature of our constitutional history has been the contested character of virtually every term, concept, and symbol in the constitutional lexicon. Many years ago, E. H. Carr -- a communist, to be sure -- noted that "progress in human affairs" had come about "mainly through the bold readiness of human beings ... to present fundamental challenges in the name of reason to the current way of doing things."(12) But whose stories might we agree to include alongside Marshall, Taney, and other familiar figures in a reconstituted "constitutional history"? Let me lay out some possibilities, only half in jest:

STORY # 1: In 1819, the Marshall Court ruled in Dartmouth College v. Woodward that the state of New Hampshire could not transform a private charter into a public one without violating the contract clause. Joseph Story offered a concurring opinion which said, among other things, that certain corporations (e.g., banks) were "private" entities, and so off limits to legislative meddling unless the original charter reserved the legislature's right to meddle. In Kentucky and Tennessee, Dartmouth created a firestorm. Suddenly, the ruling had nothing to do with a college, or even with the contract clause; rather, Relief partisans argued that Joseph Story (not Marshall) aimed to curtail legislatures' ordinary remedial powers and to attack recent bank charter revocations. Within days, legislators passed resolutions condemning judicial "tyranny," enacted laws affirming legislative authority across a broad range of heads, and moved to curtail the review powers of the United States Supreme Court. As a result of Dartmouth, in other words, both Kentucky and Tennessee basically declared war on the federal judiciary -- a war that persisted (with occasional fuel added to the fire) until at least 1826. How much of this story belongs in a constitutional history textbook?

STORY #2: In 1845, the Connecticut Supreme Court of Errors heard the appeal of Shaw v. Shaw, involving a divorce petition originally brought by Emeline Shaw against her husband, Daniel. In 1844, after about three years' cohabitation, Emeline had "left the bed and board of her husband" to live "separate from him, with her mother." Chief Judge Williams noted that she was a "woman of an irritable temperament" and "in delicate and feeble health." Daniel apparently "made use of abusive and obscene language to her," calling her (among other terms) an "old imp of hell" and "an ugly devil." As the court put it, though her health made it "improper" and dangerous for her to "have sexual intercourse with him," he "unreasonably objected," and "refused to suffer her to occupy a separate bed." At least twice, he "took her, by force, from the bed of her daughter" and "compelled her to occupy a bed with himself." He accused her of having illicit relations with other men and repeatedly forced her to "remain with him in bed against her wishes and remonstrances," even though it was "injurious to her health so to do." Daniel refused to let Emeline leave the house to visit relatives, and "unreasonably" barred his mother-in-law from visiting. For these reasons, she had fled, eventually filing for divorce on the ground of "habitual intemperance" and "intolerable cruelty." Judge Williams disagreed. Given Emeline's sour disposition and desertion, cruelty had to be of the sort "not to be borne." Surely Daniel's language was "vulgar, obscene, harsh." But he had been "jealous of his wife"; his behavior, while heinous, could be understood by other men. Locking people in and out of the house was "certainly harsh, if not cruel" -- but a husband had "the right to say who shall be admitted to his house" and to "regulate the intercourse of his wife," and Emeline had threatened to leave. Wrote the judge, although "the fancies of a jealous man are as ungovernable as those of a madman, and often show themselves as suspicious of their best friend," the "unreasonable exercise of the authority of a husband ... has never been held to be that kind of cruelty, which would authorize a separation." Nor was Daniel's claim of "marital rights, against the wishes ... of his wife" intolerably cruel: Emeline could not claim that "he intended to injure her, or did injure her" by forcing her to sleep with him -- only that his behavior might have killed her. While forced sex had been "injurious to her health, and endangered it," Williams could not say that Daniel "knew this would be the consequence," and so he refused the divorce. To what extent is Daniel's governance of Emeline's body a matter of constitutional concern?

STORY #3: Because ordinary methods had not succeeded in recruiting President Woodrow Wilson and other prominent federal politicians to suffragism, the National Woman's Party (with allied organizations) decided to try the resistance techniques used to good effect in England. In 1917, women began to misbehave. Picketers ringed the White House, threatening to unhinge Wilson's peace talks with bluntly-worded picket signs (e.g., "Kaiser Wilson"). After a boisterous 1918 suffrage parade in the nation's capitol, NWP women burned copies of presidential speeches as well as their own messages to Congress in a ceremony at the White House. Said one message: "This is a war for self-government among all the peoples of the world as against the arbitrary choices of self-constituted masters." A Washington correspondent said in early 1917 that he had "seen no more impressive sight" than the "spectacle" of White House picketing: "[T]o see a thousand women -- young women, middle-aged women, and old women ... marching in a rain that almost froze as it fell; to see them standing and marching and holding their heavy banners ... against a wind that was half a gale -- hour after hour, until their gloves were wet and their clothes soaked through ... was a sight to impress even the jaded senses of one who has seen much ...." Others, however, accused demonstrators of sabotaging both the war effort and Woodrow Wilson's credibility in Europe; the president himself said that the timing was "not opportune" and the demands too strident. Mobs jeered the picketers, and constables hauled them off to jail. When arrested and incarcerated for obstructing traffic, Alice Paul and others went on hunger strikes, only to be manhandled, forcibly fed, and occasionally put in solitary confinement. Beyond Washington, NWP organizers confronted repeated attempts to silence circuit-riding speakers. In Dallas, Texas, just as the United States prepared to enter the war, NWP speaker Maud Younger and several companions met with what suffragist Inez Haynes Irwin called "the cry of 'Treason'" -- in her judgment, an "incredible" development "in these days of free speech." As Irwin told the story, NWP organizers in Texas could not engage a hall or hotel room for Younger; the mayor refused to allow her to hold a street meeting. When she "offered to submit her speech for censorship," city officials "refused her even that." In Tennessee, agents of the War Association and Home Defense League supposedly went "to all hotels, or meeting -places, to ask them not to rent rooms for Miss Younger's meetings, and to mayors to request them not to grant permits for street meetings." At least one woman, Sue White of Jackson, Tennessee -- editor of the NWP newspaper The Suffragist -- decided to support the lecture series, not because she agreed with speakers' positions, nor even to secure "equal suffrage," but because the visitors had been denied "freedom of speech, which is not only essential to our cause but to every other step in human progress." In the end, organized labor came to the rescue: Chattanooga union members offered NWP orators their hall. In Knoxville, a labor leader "saw at once that it was a free speech fight" and resolved that "Labor would make the fight for the suffragists." NWP speakers spoke from the courthouse steps, fully expecting "to be shot"; deputies barricaded the building while "eighty armed Union men" guarded the speakers White House pickets and NWP speakers. Do we include such attempts to suppress political dissent in constitutional history textbooks alongside Abrams and Schenk? Or not? The Supreme Court, after all, is absent.

STORY #4: In Calvin Trilling's brilliant essay collection, Killings, he describes an Appalachian community in which landowners can murder trespassers without fear of penalty. In past time, citizens apparently decided that a person walking without permission across another person's tobacco field had relinquished all right to personal security. The local police will not arrest such shooters, on the ground that killings in defense of property are justifiable. Is this an example of an alternative, customary constitutional regime? Or is it merely a good story?

Indeed, which of these 'good stories' belong in the text? And how would we decide? It may be that constitutional historians ignore messes like these because they rightly perceive that opening one such door might lead to opening many more. At issue is the unity and coherence of the master narrative. How can we direct the choir when the singers have different scores, sing in different keys, and don't even perform in the same auditorium? In the seemingly innocuous turn from structures and functions of government to human experiences of government, the post-modern nightmare comes home to roost. How many 'constitutions of aspiration' can we fit onto the page before it tears?

On the other hand: business as usual cannot restore the vitality that characterized constitutional history during the late New Deal, when political scientists 'discovered' the politics inherent in law, or in the 1960's, when a handful of scholars decided to reclaim and renovate the history profession's old flagship for a new day. Whether we like it or not, the practice of history nowadays requires engagement with the richness and dissonance of American society and culture. I take this to be a sign, not of political faddishness, but of collective maturity: it takes a certain amount of courage to deliberately let go of the reins. Despite important contributions, "forensic history" and much of the so-called "new constitutional history" evades our most pressing difficulty -- the need to confront constitutionalism's embeddedness in culture, social process, and consciousness without attracting and succumbing to charges of irrelevance. There is nothing wrong with claiming to be different from everyone else -- only in claiming to be impervious to social process. As Robert Cover once explained, "legal meaning is created by simultaneous engagement and disengagement, identification and objectification." Historians basically describe and analyze the "process of human action stretched between vision and reality";(13) there is no compelling reason to exempt constitutional historians from that mandate -- no more than we would exempt economic historians, who sometimes prefer to write internal accounts of the development of monetary theory, thereby avoiding "layered complexity" and shifting "sensibilities."

To its credit, relativism -- by which I mean openness to complexity, multiplicity, messiness, and uncertainty -- is an honest position: law never has brooded in a truly omnipresent way. Constitutional historians bear the mark not only of legal thinking, but also of a perceived burden of public trust: to 'forget' the traditional constitutional narrative is in a sense to jeopardize national cohesion -- which, I think, is why the very idea of altering the story or alienating title to all or part of the narrative raises such fierce opposition and causes ranks to close. Joyce Appleby and her co-authors put it this way: "Having chosen to knit themselves together as a people with the propositions of liberal democracy, Americans initially turned their history into a record of national cohersion";(14) any move to the contrary smacks of treason. Hence, the long-lived attachment to what can only be called unreconstructed scientific history. Practitioners -- I don't exempt myself -- still yearn to believe (in Peter Gay's words) that "the tree in the woods of the past fell in only one way," and that we know (or can learn) what it was.(15) Many of us genuinely regret the absence of what Henry Adams called "some basis of faith in general principles, some theory of progress of civilization which is outside and above all temporary questions of policy."(16) Nevertheless, as Dominick LaCapra said of the long-standing contest between the history of ideas and intellectual history, we should consider moving away from the notion of "history as a reconstruction of the past" bounded by a canon of received texts, toward an idea of history as "a dialogue or conversation with the past," bounded by the testimony of many speakers operating in multiple arenas -- if only to admit all of the people to full citizenship.(17)

As to the dread subjectivism and its supposed close relation, relativism: in 1957, Herbert Muller wrote these remarkable sentences. "...[T]he admission of a principle of relativity and uncertainty," he insisted, "should not be simply depressing. It does not destroy all possibility of knowledge and judgment. Rather, it is the outcome of comprehensive knowledge, and the means to further knowledge of ... history. ... It enables wiser choices among the possibilities open to us -- among goods that are no less real because they are relative, and that are more relevant than arbitrary absolutes. Above all, this principle encourages a positive faith in positive values: of liberality, breadth of spirit, hospitality to new ideas, willingness to adventure, humility in admitting one's own fallibility and the limitations of the human mind -- ... If these are not the highest values, none are more essential to the hopes of world order and peace. They also entail obvious dangers, of confusion, halfheartedness, demoralization, despair. One cannot be confident that mankind is yet ready or able to surrender the ancient illusion of certainty in its idealisms. Nevertheless, this illusion intensifies the confusion and dismay of our times. It obscures the actual uncertainty in which men have always lived and which they take for granted in daily life. ... [W]e doubtless suffer from too much doubt. But we are likely to suffer much more because too many men are too sure of themselves."(18)
 

NOTES

1. Virginia Woolf, The Diary of Virginia Woolf, Vol. 1, 1915-1918 (London: Hogarth Press, 1977): 152.

2. Herbert Muller, The Uses of the Past: Profiles of Former Societies (New York 1957): 36.

3. See the exemplary, if dated, collection of essays in Kermit Hall, ed., Main Themes in United States Constitutional and Legal History (New York 1987).

4. Adam Czarnota and Martin Krygier, "Revolutions and the Continuity of European Law," in Zenon Bankowski, ed., Revolutions in Law and Legal Thought (Aberdeen, Scotland, 1991): 90.

5. J. Willard Hurst, "Legal Elements in United States History," Perspectives in American History, 5 (1971): 349.

6. Leonard Levy, The Law of the Commonwealth and Chief Justice Shaw (Cambridge, MA, 1957): 316.

7. Clifford Geertz, Local Knowledge: Further Essays in Interpretive Anthropology (New York, 1983): 215.

8. For "padlocks" and other fairly typical references to abridgments of speech freedom, see E. C. Stanton, et al., eds., History of Woman Suffrage , Vol. I (New York 1881): 38, 82-85, 95, 206, 152-53, 160, 184, 218, 476.

9. Karl Joachim Weintraub, The Value of the Individual: Self and Circumstance in Autobiography (Chicago, IL: University of Chicago Press, 1978): 48.

10. Robert Berkhofer, Beyond the Great Story: History as Text and Discourse (Cambridge, MA: Harvard/Belknap, 1995): 179.

11. Eric Foner, The Story of American Freedom (New York, 1999).

12. Edward Hallett Carr, What Is History? (New York, 1961, repr. 1972): 207.

13. Robert Cover, Narrative, Violence, and the Law: The Essays of Robert Cover (Ann Arbor, MI, 1992, ed. Martha Minow): 144. With the exception of Trilling, the material used in the preceding 'stories' can be found in Sandra F. VanBurkleo, "Belonging to the World": Women's Rights and American Constitutional Culture (Oxford, forthcoming).

14. Joyce Appleby, Lynn Hunt, and Margaret Jacobs, Telling the Truth About History (New York 1994): 156.

15. Peter Gay, quoted in Robert Berkhofer, Beyond the Great Story: History as Text and Discourse (Cambridge, MA, 1995): 48.

16. Henry Adams, quoted in John Clive, Not By Fact Alone: Essays on the Writing and Reading of History (New York 1989): 182.

17. Dominick LaCapra, Rethinking Intellectual History: Texts, Contexts, Language (Ithaca, NY, 1983): 61.

18. Muller, Uses of the Past: 43-44.

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