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The Case Against Judicial Review, by David Cobb
Introduction
"Judicial Review" is not a term familiar to most Americans, but it should be. The concept is a profoundly important operational underpinning of the United States legal system. Anyone working to make this country a more peaceful, just, ecologically sustainable, and democratic place should be eager to examine this basic doctrine.
In a nutshell, judicial review is the power of a court to review the actions of executive or legislative bodies to determine whether the action is consistent with a statute, a treaty or the U.S. Constitution. In its most basic expression, it is the authority of the unelected Supreme Court to declare acts of elected members of Congress or the elected President unconstitutional. (Of course, the current occupant of the White House was never elected, but rather installed in what can only be described as a judicial coup d'etat).
It is important to recognize that there is absolutely no explicit reference to the concept of judicial review in the Constitution itself. Proponents of judicial review merely infer that power from Article III of the Constitution which states: "The judicial Power of the United States, shall be vested in one Supreme Court... and shall extend to all Cases... arising under this Constitution..."
The inference that this flimsy language somehow grants our Supreme Court the power to define the parameters of the Constitution seems tenuous at best and may come close to contradicting the specific language of that document. Specifically, the Tenth Amendment states: "The powers not delegated to the United States by the Constitution, nor prohibited by it to the States, are reserved for the States respectively, or to the people." Additionally, why is it that if the Court has the legitimate authority to declare acts of Congress unconstitutional, that power was used so sparingly in the early decades of the country's history?
Judicial review is an undemocratic extension of the undemocratic nature of the Constitution itself, a document protecting the rights of property over the rights of people. Given that the Constitution was drafted by a small number of people who met behind closed doors, the fact that a small number of unelected judges overrule citizen initiatives or laws passed by legislative bodies is not very surprising.
Warnings of Jefferson and Lincoln
The Court first exercised the power of judicial review in the 1803 case of Marbury vs. Madison. The decision caused an uproar, leading Thomas Jefferson to express his deep reservations about the principle. He wrote: "To consider judges as the ultimate arbiters of all constitutional questions is a very dangerous doctrine indeed, and one which would place us under the despotism of an oligarchy. Our judges are as honest as other men, and not more so. They have, with others, the same passions for party, for power, and for privilege. But their power [is] the more dangerous, as they are in office for life, and not responsible to elective control." Jefferson cautioned that judicial review would make the Constitution nothing but "a mere thing of wax in the hands of the Judiciary, which they may twist and shape into any form they please."
It was not until 1856, in the repugnant case of Dred Scott vs. Sanford, that the Court invalidated a second federal law. In this instance, it was a provision of the Missouri Compromise that prohibited slavery from expanding into federal territories. In overturning this provision the Court proclaimed that people of African descent could never be citizens of this country under any circumstance, whether slaves or not. The Court specifically held that all persons of African descent were "beings of an inferior order, and altogether unfit to associate with the white race, either in social or political relations, and so far inferior that they had no rights which the white man was bound to respect." As reprehensible as the Court's decision was, it was merely an affirmation of the tenor of Article IV, Section 2 of the original Constitution which held that escaped slaves were not free people but had to be returned to their masters and, hence, were property.
This case caused Abraham Lincoln to speak out against judicial review during his first inaugural address. He said: "The candid citizen must confess that if the policy of the Government upon vital questions affecting the whole people is to be irrevocably fixed by decisions of the Supreme Court, the people will have ceased to be their own rulers, having to that extent practically resigned their Government into the hands of that eminent tribunal."
"The candid citizen must confess that if the policy of the Government upon vital questions affecting the whole people is to be irrevocably fixed by decisions of the Supreme Court, the people will have ceased to be their own rulers, having to that extent practically resigned their Government into the hands of that eminent tribunal."
ÐAbraham Lincoln
I recognize that many people, including friends and allies with whom I often agree, have a positive view of the United States Supreme Court. Notwithstanding the odious decision of Dred Scott, they point to the 1954 case of Brown vs. Board of Education and the subsequent civil rights cases as examples of the Court doing justice by overturning Jim Crow segregation laws.
But it is important to remember that the Brown decision actually overturned the prior Supreme Court decision of Plessy vs. Ferguson, which held the odious doctrine of "Separate but Equal" to be constitutionally acceptable. And the current Supreme Court used judicial review earlier this year in Parents Involved in Community Schools vs. Seattle School District to overturn school desegregation plans in Seattle and Louisville, basically gutting the venerable Brown decision.
Stated simply, civil rights victories were not won by eloquent lawyers making refined legal arguments in the courts. They required the sustained education, agitation and perspiration of committed citizens willing to engage in protracted struggles against ruling elites.
I appreciate that many people are understandably nervous about what might happen to constitutional protections in the chaotic worlds of practical politics and everyday life. But it is up to all of us, "We the People," to take responsibility for protecting our liberties. Guarding them is not, nor should it be, the exclusive preserve of judges.
Protecting Our Own Rights and Liberties
The Constitution belongs to us collectively as we act in political dialogue with one another Ð whether in an official or activist capacity or in the course of our day-to-day activity. A strong case can be made that an engaged and active citizenry will be more effective at protecting our civil liberties than the courts. This was certainly true in the "humanization" of the Constitution throughout our history. Social movements have brought about the addition of amendments to that document, including the first ten, the Bill of Rights, establishing protections absent in the original document.
The lack of citizen initiative was evident during the very real and serious threats to people's liberties during the "communist scare" of the 1950s. When Senator Joseph McCarthy persecuted political dissidents many honorable Americans were lulled into inaction, believing that the judicial branch would step in and declare McCarthy's actions unconstitutional.
In the course of the Lochner Era (roughly 1900 Ð1937) the Supreme Court used judicial review to strike down 170 state and federal labor laws attempting to make working conditions more fair and just. During this time the Supreme Court declared unconstitutional laws limiting the number of hours bakers could work (Lochner vs. New York, 1905), outlawing child labor in factories employing children under 14 (Hammer vs. Dagenhart, 1918), and mandating a minimum wage (Adkins vs. Children's Hospital, 1923).
In Freedom's Law: The Moral Reading of the American Constitution (1976), legal scholar Ronald Dworkin spells it out: "...On controversial and profound questions of political morality that philosophers, statesmen, and citizens have debated for many centuries, the people and their representatives simply have to accept the deliverances of a majority of the justices, whose insight into these great issues is not spectacularly special." And this from an acknowledged defender of judicial review!
But let's move beyond support or opposition to judicial review based on whether we support or oppose the outcome of particular decisions. The sobering reality is that judicial review is politically illegitimate. The fundamental premise of this government is that all legitimate political power resides with the people. By allowing a ridiculously small number of unelected, unaccountable, appointed-for-life judges to dictate what is constitutionally acceptable or unacceptable is to disenfranchise ordinary citizens and to utterly ignore the principles of self-governance and political equality.
We have come to treat the Constitution as something beyond our competence, something whose meaning should be decided by judges, assisted by a cadre of trained lawyers and academics. This servility to a lawyerly elite is a troublesome and dangerous departure from the proud heritage of freedom-loving revolutionaries. America's founding generation celebrated the central role of "the people" in supplying government with its energy and direction.
Indeed, we must never forget that there was and is a violence associated with the founding of this country Ð violence perpetrated against indigenous peoples of the continent, against human beings brought in chains as slaves, against women. But these offenses were not addressed by a group of judges issuing rulings. On the contrary, judicial opinions usually justified and legalized the injustice.
The most noble sentiment underlying the American Revolution is the belief that we are capable of governing ourselves Ð that we do not need Kings, Masters or Judges to decide our fate. According to Larry Kramer, author of The People Themselves, American revolutionaries considered the notion of "Popular Sovereignty" more than an empty abstraction, more than a mythic philosophical justification for government. The idea of "the people" was more than a flip rhetorical gesture to be used on the campaign trail. Ordinary Americans once exercised active control over their Constitution.
The constitutionality of governmental action was met with vigorous public debate and contention, the outcome of which might be greeted with celebratory feasts and bonfires or belligerent resistance. The Constitution remained, fundamentally, an act of popular will Ð the people's charter, made by the people. Ordinary people were responsible for seeing that it was properly interpreted and implemented. People of earlier generations took that responsibility seriously.
So the question for us is whether "We the People" today are willing and able to do the same?
After all, properly understood, "We the People" are the government. So let's be the government.
To order a Democracy Insurgency Movement packet, contact POCLAD at people@poclad.org or call 508-398-1145.
Court Decision is "Pearl Harbor for American Democracy"
New Coalition Responds to Citizens United Decision with a Call to Amend the U.S. Constitution to Overrule the Supreme Court's Activist Expansion of Corporate "Rights"
FOR IMMEDIATE RELEASE, Jan. 21, 2010
Contact: (202) 642-1848 or additional coalition contacts below
www.MovetoAmend.org
Washington, DC-After justices on the U.S. Supreme Court ruled in favor of corporate "rights" in the Citizens United case, a new national coalition of diverse public interest, community, and business organizations responded with a bold call to overrule the decision and amend the Constitution to restore the power of people over corporations, beyond election law. A complete list of the "Move to Amend" Steering Committee is attached; and a list of other groups and people who have endorsed this new campaign is available at the coalition's new website:
"This decision was Pearl Harbor for American democracy," said Ben Manski, Executive Director of Liberty Tree and a lawyer helping to lead the coalition. "Decades of judicial activism culminating in today's decision have eroded the power of 'We the People' to govern ourselves and so our move to amend the Constitution is not limited to the powers of the Federal Election Commission but focuses on the broader implications of the decision."
"We are inspired by historic social movements that recognized the necessity of altering fundamental power relationships," added Riki Ott, the Director of Ultimate Civics and a marine toxicologist whose activism was galvanized by the Exxon Valdez spill. "America has progressed through ordinary people joining together-from the Revolutionaries to Abolitionists, Suffragists, Trade Unionists, and Civil Rights activists through to today."
"In this decision, a handful of unelected judges have revealed their agenda to expand the influence of corporations at the expense of the rights of individuals, and it will not stand the test of time," said Lisa Graves, Executive Director of the Center for Media and Democracy and former Chief Counsel to the Senate Judiciary Committee and Deputy Assistant Attorney General. "Corporations aren't people and simply don't deserve the same rights as people; we have to work together to put people before corporations."
"The movement we are launching is a long-term effort to make the U.S. Constitution more democratic," noted David Cobb, the Director of the Program on Corporations Law & Democracy and an attorney helping to lead the coalition. "We are a diverse coalition with deep roots in communities nationwide. We recognize that amending the Constitution to restore the power of the people over corporations will not be easy, but we know correcting the Supreme Court is imperative to the progress of our nation."

FOR MORE INFORMATION, contact the Move to Amend Steering Committee:
Ben Manski, Liberty Tree (www.libertytree.org), (202) 642-1848, Manski@LibertyTreeFDR.org
Riki Ott, PhD, Ultimate Civics (www.ultimatecivics.org), (907) 424-3915, otter2@ak.net
Lisa Graves, Center for Media and Democracy (www.prwatch.org), (608) 260-9713, lisa@prwatch.org
David Cobb, Program on Corporations Law & Democracy (www.poclad.org), (707) 362-0333, david@duhc.org
George Friday, National Director of Independent Progressive Politics Network (www.ippn.org) (862) 668-8172, ippn@igc.org
Greg Coleridge, Northeast Ohio American Friends Service Committee (www.afsc.net) (330) 928-2301, gcoleridge@afsc.org
Marybeth Gardam, Women's International League for Peace & Freedom Corporations vs. Democracy Committee Leadership Team (www.wilpf.org), (515) 210-7928, mbgardam@gmail.com
Kaitlin Sopoci-Belknap, Democracy Unlimited of Humboldt County (www.duhc.org) (707) 269-0984, kaitlin@duhc.org
Nancy Price, Alliance for Democracy (www.thealliancefordemocracy.org) (781) 894-1179 or (530) 758-0726, nancytprice@juno.com
David Swanson, After Downing Street, (202) 329-7847, david@davidswanson.org
Jeff Milchen, ReclaimDemocracy.org, 406-582-122, Jeff@ReclaimDemocracy.org
The Spirit of Change, by Greg Coleridge
Barack Obama was awakened during the night following his latest Democratic Party Presidential debate. Two ghosts stood before him. "We are the spirits of Samuel Adams and William Lamb."
"Who?" Obama asked in a daze, unsure if he was hallucinating from lack of sleep.
"We're the ghosts of real change."
"I am the spirit of Samuel Adams, a revolutionary for American liberty and promoter of the Declaration of Independence."
"And I am the spirit of William Lamb, a founder of the U.S. Populist movement in the 1880s-1890s, supporter of the Omaha Platform, and organizer of the People's Party."
Obama was puzzled. "You're both dressed funny, but more to the point, why are you here?"
"We've come to talk. You, Clinton, even McCain, speak constantly about 'change'. We've watched your debates, read news on your light screens, and ..."
"Light screens? Do you mean televisions and computers?"
"Ah yes, that's what you call them. Anyway, all you candidates talk about is who will bring change to this country: real change, fundamental change, policy change to address unmet needs and give citizens more power."
"Sounds especially like me," Obama said assuredly.
"We're not so sure," said the ghosts in unison. "We believe political change in our times was more profound than anything being proposed now."
And so Sam, Lamb and "Bam", advocates from three turbulent periods in U.S. history, huddled to discuss political change.
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SAM: I agitated for the greatest change in the history of our nation, political independence from Great Britain. The Declaration of Independence, passed on July 4, 1776, presented a lengthy list of "repeated injuries and usurpations" by the British government and asserted that the 13 colonies were "Free and Independent States."
LAMB: Weren't you a signer?
SAM: Yes, one of 56 signers of the Second Continental Congress, a revolutionary, illegal body.
BAM: Did the British consider you and your ilk "terrorists"?
SAM: A renegade if not worse, in part for supporting the Declaration. I said in 1776, "Is not America already independent? Why not then declare it."1 The power and inspiration of the Declaration were these unequivocal assertions: "All Men are created equal and endowed by their creator with certain unalienable Rights That to secure these Rights, Governments are instituted among Men, deriving their just Powers from Consent of the Governed [and] whenever any Form of Government becomes destructive of these Ends it is the Right of the People to alter or abolish it, and to institute new Government [in fact] it is their Duty to throw off such Government, and to provide new Guards for their future Security."
The essence of the document, revolutionary then and now, was the conviction that people can and should be governingåÁVnot kings, popes or generals.
British rule could not be "reformed." The King's army and crown corporations could not be made accountable to the public. They all had to be replaced, so I worked for revolutionary change, for a system of self-rule.
LAMB: The Declaration was an inspiration to us Populists. But be honest, Sam, sixty-nine percent of the Declaration's signers held colonial office under England. Many who supported both it and the revolution were colonial lawyers, landowners and merchants, including you, who only wanted independence from Great Britain to impose their own brand of political and economic control. Following the revolution, did you not say, "In monarchy the crime of treason may admit of being pardoned or lightly punished, but the man who dares rebel against the laws of a republic ought to suffer death"?2
SAM: I did?
LAMB: Yup.
SAM: Still, I opposed the British Stamp Act, helped organize the Boston Tea Party and the Committees of Correspondence, colonists who organized into small groups to share information and mobilize the public.
LAMB: You were a great communicator, organizer and agitator Sam, but it was selective. Your instigation of mob protests was directed only at British rule and wealth, not the consolidation of power by colonial elites. This omission carried over to the Declaration, which ignored inequalities of property, and I ask, "How could people have equal rights, with stark differences in wealth?"3 The Declaration was a form of manipulation to focus anger and attention only on British rule.
BAM: While the Declaration is as inspirational as many of my speeches, there are several glaring omissions, notably independence for black slaves, women and native people. The draft of the Declaration included a grievance against the King for transporting slaves but was removed before adoption. Native people were called "the merciless Indian Savages..." and there was no room for women in "All men are created equal."
LAMB: Change during your period, Sam, was not as dramatic as during my lifetime. I helped organize the largest and most elaborate democratic mass movement in US history: Populism. It was a mass democratic insurgency among "plain people"åÁVfarmers and urban workersåÁVto respond to the impoverishment of millions of farmers and workers by banks, railroads, and the consequences of economic and political centralization.
BAM: I haven't heard much about the Populists.
LAMB: Most people of your day haven't. We've been largely erased from history books. 0nly our "spirits" remain.
The Populists sought to create a democratic movement to counter the hierarchical culture of the day. It was "a new way of looking at society, a way of thought representing a shaking off of individual forms of deference individual self-respect and collective self-confidence class consciousness growing political sensibility the mass expression of a new political vision."4
BAM: Now I see why there's not much known in our culture about you people.
LAMB: The creation of this democratic movement for revolutionary change was achieved in sequential steps: forming organizations, recruitment, education, and political action. State farmers Alliances were the original organizing base. I organized over 100 sub-alliances in Texas alone and eventually the National Farmers Alliance. We recruited through large-scale Populist-sponsored farmers cooperatives and I was the Texas Alliance's first purchasing and traveling agent. Hundreds of newsletters and 40,000 "lecturers" were disseminated throughout Texas. We educated members continually, our version of the Committees of Correspondence, Sam. Collective political action bridging farmers and laborers was achieved through the Populist Party, which I helped launch.
SAM: This still doesn't sound very revolutionary, pal. You weren't talking about overthrowing the government.
BAM: Promoting major change through a political party is my goal, too.
LAMB: It was revolutionary, Sam, and there is a difference, Bam, between Populist goals and yours.
Populists constantly talked about "the coming revolution" through ballots not bullets. Revolution meant creating a "third party of the industrial millions" and overthrowing the two party system. We saw many elections as rigged and the electoral college as undemocratic. We tried to bring the corporate state under popular control through democratic politics.5
As fellow Populist Tom Watson said, "It's useless to ask Congress to help us, just as it was folly for our forefathers to ask for relief from the tea tax; they revolted and so should we."6
The unifying platform for Populist revolution, the "Second Declaration of Independence," was the Omaha Platform. The 4000 delegates to the first People's Party Convention in Omaha, Nebraska, adopted it on July 4, 1892åÁV116 years after the first Declaration.7
SAM: Where's Nebraska?
LAMB: Later Sam. The Omaha Platform, like the Declaration, spoke to the grievances and demands for major change within the context of its time.
BAM: What did it say? Perhaps I should include elements of it in the Democratic Party platform if I'm the Presidential candidate.
LAMB: The Omaha Platform's Preamble states:
"The conditions which surround us best justify our cooperation; we meet in the midst of a nation brought to the verge of moral, political, and material ruin. Corruption dominates the ballot box, the Legislatures, the Congress, and touches even the ermine of the bench. The people are demoralized; most of the States have been compelled to isolate the voters at the polling places to prevent universal intimidation and bribery. The newspapers are largely subsidized or muzzled, public opinion silenced, business prostrated, homes covered with mortgages, labor impoverished, and the land concentrating in the hands of capitalists."8
BAM: Sounds like something Dennis Kucinich would say!
LAMB: The Omaha Platform was a culmination of ideas and strategies from farmers and workers over a six-year period. Like the Declaration, it listed both grievances and fundamental prescriptions.
The platform called for abolishing the national banking system giving private banks control over money and credit; public ownership or control of the railroads, telegraph and telephone in the interests of the people; a federal graduated income tax; prohibition of alien land ownership; direct election of US Senators; the citizen initiative, referendum and recall; the secret ballot; and maybe most creatively, adoption of a "sub-treasury" system to expand currency based not on gold or silver but on agricultural products.
SAM: Still, many of these changes were "reformist." What's so radical about direct election of Senators if the Senate is part of a political system favoring a small number of elites?
LAMB: Some of our planks were less radical than others. The Progressives, those who followed the Populists, pushed for the more modest measures. Some eventually became law. Other proposals were more substantial, such as public control of banks, railroads and telephones. The goal of its financial sections, the key portions of the Platform, were radical: to transfer control of the monetary system from the nation's corporate banks and return it "in the name of the whole people," to the U.S. Treasury.9
All our demands, however, sought to shift the balance of power, economic and political, toward "plain people." These changes were as revolutionary in our time as forcing the British out of the colonies in yours.
Changes advocated by the Populists, however, transcended its political platform and cooperative buying and selling programs. The crux of Populism was creating a democratic culture. Populists attempted to build a cooperative community or commonwealth within the framework of American capitalism, one that put people at the center of the political and economic decisions affecting their lives. It became a movement culture that was understood, accepted and lived by millions of citizens.10
Progressives didn't go that far. After the Populists were defeated in 1896, those who sought change accepted the corporate state and tried merely to temper its worst abuses through the creation of "regulatory" laws and agencies. This is the political and economic model you, Bam, and others working for "change" are stuck with today.
SAM: The Populists failed in the end. It was hardly revolutionary if it didn't yield much change.
LAMB: True, we didn't win. Elements of the Omaha Platform are now law, but there is no cooperative, democratic culture. Isn't the same true of the Declaration and those who worked for true self-governance in 1776? Its essence of a government operating with the "consent of the governed" has not been realized. Today, those claiming that We the People have not only a right but a duty to revolt if unalienable rights are not secured would be called "extremists," even "terrorists" and treated accordingly.
BAM: A fundamental shortcoming of the Populists was their excluding blacks. Populist structures and members were often racist. In fact, many who call themselves "Populists" in recent times hold racist beliefs.
LAMB: That's a sad truth. The radical dream of early Alliance founders in Texas was to create an interracial farmer-labor coalition. Alliance lecturers organized many black Alliances which led to the Colored Farmers' National Alliance. Nevertheless, internal and external racism impeded social unity, economic cooperation, and electoral victory.
*************************
BAM: The change I speak of today is tied to offering real hope. I believe we can make government better, more responsive to people. We can control special interests and restore faith and trust in public officials. Hillary Clinton believes much the same. Even McCain supported campaign finance reform.
I believe we can make health care universal, increase labor and environmental provisions of NAFTA and other trade agreements, temporarily suspend home foreclosures, begin immediately to bring some troops home from Iraq, and strengthen ethics in government. This is a small part of my progressive change agenda that I can create with the support of voters. Clinton supports many of the same programs.
Other former Democratic Party candidates were even more radical. John Edwards spoke out against corporate power. Dennis Kucinich promoted a single-payer health care system, eliminating the role of insurance corporations all together, and called for undoing NAFTA.
My vision of change will be fueled if economic conditions worsen for Americans.
LAMB: Nothing you or any other Presidential candidate suggests will reduce corporate constitutional rights and powers or promote people's self-governance.
With due respect, Bam, deep change was never brought about by those in positions of power. It occurs when people act together in insurgent movements. And insurgent movements are not a function of hard times, but of insurgent cultures. Difficult times crush people. Insurgent cultures provide real hope and make possible those processes of organizing, recruiting, educating and politicizing that create and sustain change.11
BAM: How can you say this? My messages of change and hope are drawing record numbers to my campaign. People are inspired, energized, empowered.
LAMB: True. But don't mistake attraction to your campaign with behaviors necessary for a healthy democracy. As Populism declined, little stood in the way of growing political and economic concentration. Democratic aspirations were replaced by mass resignation and plenty of escape into consumerism, entertainment and drugs.
You and your message fill a void only because people of your time do not know and have never experienced an authentic insurgency movement for self-governance. Not just to end a war, expand civil rights or create environmental protections, but a movement affirming individual and collective self-confidence in seeking real political and economic democracy.
SAM: Bam, missing in your and other presidential candidates' analysis is the larger issue of how the power and authority of "We the People," as promoted in the Declaration and Preamble of the U.S. Constitution, has been usurped.
LAMB: By the wealthy class and business corporations, I might add. We need changed rules not only changed faces.
SAM: That's what I thought the Declaration tried to do in 1776.
LAMB: And the Omaha Platform 116 years later, in 1892.
BAM: Do you two realize that 116 years after 1892 is this year, 2008?
LAMB: Rather than working for the adoption of a single national declaration or platform at this time, The Program on Corporation, Law and Democracy (POCLAD) urges decentralized, participatory gatherings to study the Declaration of Independence and Omaha Platform, along with democracy campaigns and cooperative programs from current grassroots organizations. They've collected it all in a Democracy Insurgency Movement packet. This will add another seed to those already sown across the country, one that may lead to a "Third Declaration of Independence" and genuine governance by "consent of the governed."
BAM: It sounds like a dream, like my experience tonight.
LAMB: A dream? It all depends on the people and their determination to create real change.
*************************
Greg Coleridge is a POCLAD principal and works for the Northeast Ohio American Friends Service Committee.
Endnotes:
1. Charles A. Beard and Mary R. Beard, History of the United States, New York: The Macmillan Company, 1949, p. 140.
2. Howard Zinn, A People's History of the United States, New York: Harper & Row Publishers, 1980, p. 94.
3. Zinn, p. 73.
4. Lawrence Goodwyn, The Populist Moment, A Short History of the Agrarian Revolt in America, Oxford: Oxford University Press, p. 33.
5. Ibid, p. 124.
6. Ibid, p. 88.
7. Ibid, p. 277.
8. The Omaha Platform.
9. Goodwyn, op. cit., p. 93.
10. Ibid., p. 164-5.
11. Ibid., p. 61.
To order a Democracy Insurgency Movement packet, contact POCLAD at people@poclad.org or call 508-398-1145.