In August 1787, directly following the close of the Constitutional Convention (USA), Maryland delegate to this convention, James McHenry, recorded this significant exchange between Benjamin Franklin and Elizabeth Willing Powel:
A lady asked Dr. Franklin: ‘Well Doctor, what have we got, a republic or a monarchy?’
‘A republic’, replied the Doctor, ‘if you can keep it’.”
The lady here alluded to was Mrs. [Elizabeth Willing] Powel of Philad[elphi]a. — McHenry’s footnote in his diary, entry: 18.09.1787.
… [please read below the rest of the article].
Westphal, Kenneth R. 2022. “‘A Republic, If You Can Keep It’.” Social Epistemology Review and Reply Collective 11 (7): 22-32. https://wp.me/p1Bfg0-6Zq.
The author has provided a pdf of selected resources referred to in this article.
🔹 The PDF of the article gives specific page numbers.
How to Keep a Republic or rather: When and How the USA lost its Republic
Consider these concise evidences regarding the character of public education required for republican citizenship, and how in the USA it was always given second place to fiscal considerations, in and outside government. Here I focus on Thomas Jefferson, because he was involved in actual legislation, and left a very rich repository of writings on properly republican public education, and on the political turmoils surrounding it. He was not alone in advocating such education.
1. Thomas Jefferson on Properly Republican Public Education
1.1 Thomas Jefferson, “Bill for the More General Diffusion of Knowledge” (December 1778), §I:
Whereas it appeareth that however certain forms of government are better calculated than others to protect individuals in the free exercise of their natural rights, and are at the same time themselves better guarded against degeneracy, yet experience hath shewn, that even under the best forms, those entrusted with power have, in time, and by slow operations, perverted it into tyranny; and it is believed that the most effectual means of preventing this would be, to illuminate, as far as practicable, the minds of the people at large, and more especially to give them knowledge of those facts, which history exhibiteth, that, possessed thereby of the experience of other ages and countries, they may be enabled to know ambition under all its shapes, and prompt to exert their natural powers to defeat its purposes … whence it becomes expedient for promoting the publick happiness that those persons, whom nature hath endowed with genius and virtue, should be rendered by liberal education worthy to receive, and able to guard the sacred deposit of the rights and liberties of their fellow citizens, and that they should be called to that charge without regard to wealth, birth or other accidental condition or circumstance; but the indigence of the greater number disabling them from so educating, at their own expense, those of their children whom nature hath fitly formed and disposed to become useful instruments for the public, it is better that such should be sought for and educated at the common expense of all, than that the happiness of all should be confined to the weak or wicked[.]
1.2 Speaking of the above bill in his Autobiography, Jefferson reports:
We thought that … a systematical plan of general education should be proposed, and I was requested to undertake it. I accordingly prepared three Bills for the Revisal, proposing three distinct grades of education, reaching all classes. 1st. Elementary schools for all children generally, rich and poor. 2d. Colleges for a middle degree of instruction, calculated for the common purposes of life, and such as would be desirable for all who were in easy circumstances. And 3d. an ultimate grade for teaching the sciences generally, and in their highest degree.
1.3 Jefferson to George Wythe (Paris, 13 August 1786):
If all the sovereigns of Europe were to set themselves to work, to emancipate the minds of their subjects from their present ignorance and prejudices, and that, as zealously as they now endeavor the contrary, a thousand years would not place them on that high ground, on which our common people are now setting out. Ours could not have been so fairly placed under the control of the common sense of the people, had they not been separated from their parent stock, and kept from contamination, either from them, or the other people of the old world, by the intervention of so wide an ocean. To know the worth of this, one must see the want of it here. I think by far the most important bill in our whole code, is that for the diffusion of knowledge among the people. No other sure foundation can be devised, for the preservation of freedom and happiness. If anybody thinks that kings, nobles, or priests are good conservators of the public happiness, send him here. It is the best school in the universe to cure him of that folly. He will see here, with his own eyes, that these descriptions of men are an abandoned confederacy against the happiness of the mass of the people. … Preach, my dear Sir, a crusade against ignorance; establish and improve the law for educating the common people. Let our countrymen know, that the people alone can protect us against these evils, and that the tax which will be paid for this purpose, is not more than the thousandth part of what will be paid to kings, priests and nobles, who will rise up among us if we leave the people in ignorance.
1.4 About Jefferson’s education bill, William Wirth observed:
Among other wise and highly patriotick bills which are proposed, there is one for the more general diffusion of knowledge. After a preamble [§I], in which the importance of the subject to the republic is most ably and eloquently announced, the bill proposes a simple and beautiful scheme, whereby science (like justice under the institutions of our Alfred) would have been “carried to every man’s door.” Genius, instead of having to break its way through the thick opposing clouds of native obscurity, indigence and ignorance, was to be sought for through every family in the commonwealth; the sacred spark, wherever it was detected, was to be tenderly cherished, fed and fanned into a flame; its innate properties and tendencies were to be developed and examined, and then cautiously and judiciously invested with all the auxiliary energy and radiance of which its character was susceptible. What a plan was here to give stability and solid glory to the republick! If you ask me why it has never been adopted, I answer, that as a foreigner, I can perceive no possible reason for it, except that the comprehensive views and generous patriotism which produced the bill, have not prevailed throughout the country, nor presided in the body on whose vote the adoption of the bill depended. I have new reason to remark it, almost every day, that there is throughout Virginia, a most deplorable destitution of public spirit, of the noble pride and love of country. Unless the body of the people can be awakened from this fatal apathy; unless their thoughts and their feelings can be urged beyond the narrow confines of their own private affairs; unless they can be strongly inspired with the publick zeal, the amor patriœ of the ancient republick, the national embellishment and the national grandeur of this opulent state, must be reserved for very distant ages (Wirth 1803, 82–3; Letter ix).
Retitled “An act, directing the mode of appointing aldermen”, and re-introduced (12 June 1780) as amended by the Virginia House of Delegates, the bill again passed the House (21 Dec. 1785), but both times was voted down by the Senate. Madison later reported to Jefferson (4 Dec. 1786) that the Senate found the costs objectionable. Subsequently, the Virginia Assembly passed an “Act to Establish Public Schools” (1796), which provided only for primary schools, and left entirely to the aldermen of each county, borough or corporation to decide whether to establish such schools.
Objections to the costs of public education echoed loudly through US history ever after, which demonstrates the penny wisdom and pounds, nay tons upon tons of foolishness reigning in a polity devoid of properly republican public education. What Wirth observed in Virginia has held sway since: ‘deplorable destitution of public spirit’. Editorial notes in PTJ hail Jefferson’s bill for apparently fostering a ‘natural aristocracy’, a common idea in the USA about Jefferson’s views, which entirely neglects Jefferson’s ardent concern for all the common people (per ¶¶1.1, 1.3, 1.4): to provide as much sound education to each, as each can master, so as to serve the republic, whether as an informed citizen, or in a suitable public office.
2. Jefferson’s Subsequent Re-Affirmation Of Republican Public Education
2.1 In his Autobiography, Jefferson looks back to four main bills he and his fellow revisers of Virginia’s legal code submitted, including that for the diffusion of knowledge, recalling:
I considered four of these bills, passed or reported, as forming a system by which every fibre would be eradicated of ancient or future aristocracy; and a foundation laid for a government truly republican. The repeal of the laws of entail would prevent the accumulation and perpetuation of wealth in select families, and preserve the soil of the country from being daily more and more absorbed in mortmain. The abolition of primogeniture, and equal partition of inheritances, removed the feudal and unnatural distinctions which made one member of every family rich, and all the rest poor, substituting equal partition, the best of all Agrarian laws. The restoration of the rights of conscience relieved the people from taxation for the support of a religion not theirs; for the establishment was truly of the religion of the rich, the dissenting sects being entirely composed of the less wealthy people; and these, by the bill for a general education, would be qualified to understand their rights, to maintain them, and to exercise with intelligence their parts in self-government; and all this would be effected, without the violation of a single natural right of anyone individual citizen. To these, too, might be added, as a further security, the introduction of the trial by jury, into the Chancery courts, which have already ingulfed, and continue to ingulf, so great a proportion of the jurisdiction over our property.
2.2 His recollection accords entirely with his letter to John Adams (28 October 1813):
At the first session of our [state] legislature after the Declaration of Independence, we passed a law abolishing entails. And this was followed by one abolishing the privilege of primogeniture, and dividing the lands of intestates equally among all their children, or other representatives. These laws, drawn by myself, laid the axe to the root of pseudo-aristocracy. And had another, which I proposed, been adopted by the legislature, our work would have been complete. It was a bill for the more general diffusion of learning. This proposed to divide every county into wards of five or six miles square, like your townships, to establish in each ward a free school for reading, writing, and common arithmetic, to provide for the annual selection of the best subjects from these schools, who might receive at the public expense a higher degree of education at a district school, and from these district schools to select a certain number of the most promising subjects, to be completed at a university where all the useful sciences should be taught. Worth and genius would thus have been sought out from every condition of life, and completely prepared by education for defeating the competition of wealth and birth for public trusts.
2.3 Jefferson’s views on gradually ending slavery not withstanding, Jefferson later wrote the following to Robert Pleasants, who advocated emancipation (27 August 1796):
… the establishment of the plan of emancipation if it should precede I am not prepared to decide. If it should precede, I would refer to your consideration whether the plan you propose is adequate to the object. I apprehend that private liberalities will never be equal but to local and partial effects. I venture therefore to suggest what alone can, in my opinion, accomplish the general object. Among the laws proposed in what was called the Revised code printed in 1784 was a bill entitled “for the more general diffusion of knowledge.” This bill was much approved, [and] was taken from [the] bundle and printed for public consideration when it was first reported. I believe that it would now be [as] generally approved, and needs only to be brought into view again to be adopted. This might be effected by petitions from the several counties to the assembly to take that bill into consideration. Very small alterations would make it embrace the object of your paper, it’s effect would be general, and the means for carrying it on would be certain and permanent. Permit me therefore to suggest to you the substitution of that as a more general and certain means of providing for the instruction of the slaves, and more desireable as they would in the course of it be mixed with those of free condition. Whether, for their happiness, it should extend beyond those destined to be free, is questionable. Ignorance and despotism seem made for each other. I am, with perfect esteem Dear Sir Your friend & servt — Th: Jefferson
2.4 Jefferson reiterated the key republican aims of education to Charles Yancey (6 January 1816):
Dear Sir … the literary fund is a solid provision, unless lost in the impending bankruptcy. if the legislature would add to that a perpetual tax of a cent a head on the population of the state, it would set agoing at once, and for ever maintain a system of primary or ward schools, and an university where might be taught in it’s highest degree every branch of science useful in our time & country: and it would rescue us from the tax of toryism, fanaticism, & indifferentism to their own state which we now send our youth to bring from those of New England. if a nation expects to be ignorant & free, in a state of civilisation, it expects what never was & never will be. the functionaries of every government have propensities to command at will the liberty & property of their constituents. there is no safe deposit for these but with the people themselves; nor can they be safe with them without information. where the press is free and every man able to read, all is safe ….
3. The Early Ascendancy of Commerce Over Properly Republican Public Education
The route towards properly republican public education became vexed ever after when Hamilton organised the first political party, known as Federalists, who advocated a much more vigorous national government, dedicated to fostering commerce and industry. It dominated US politics from 1789 to 1801. This led those more loyal to Jefferson’s republicanism to become known as ‘Republicans’. Jefferson won the presidential election in 1800. Jefferson commented on the development or political parties in a letter to John Wise (12 February 1798):
Two political Sects have arisen within the U. S. the one believing that the executive is the branch of our government which the most needs support; the other that like the analogous branch in the English Government, it is already too strong for the republican parts of the Constitution; and therefore in equivocal cases they incline to the legislative powers: the former of these are called federalists, sometimes aristocrats or monocrats, and sometimes tories, after the corresponding sect in the English Government of exactly the same definition: the latter are stiled republicans, whigs, jacobins, anarchists, disorganizers, etc. these terms are in familiar use with most persons.
Add to this political division three further institutional features of the USA: senates (upper houses, federal or state) are so structured as to foster vetos; whereas funding for education is entirely at the local district level, whilst curricula for primary and secondary education are set by each state. These institutional features result in permanent preference for Hamilton’s Federalists, even if this preference later (well after Lincoln) came to dominate the ‘Republican’ party. The democratic republic of the USA envisioned by Jefferson and many other founders has been thwarted, by exactly the means and narrow attitudes Jefferson sought to supplant through properly republican public education.
Without such concerted, inclusive public education, we are confronted by exactly the circumstance Hannah Arendt noted about 20th century fascism (whether ‘right’ or ‘left’ wing):
Totalitarian movements are possible wherever there are masses who for one reason or another have acquired the appetite for political organization. Masses are not held together by a consciousness of common interest and they lack that specific class articulateness which is expressed in determined, limited, and obtainable goals. The term masses applies only where we deal with people who either because of sheer numbers, or indifference, or a combination of both, cannot be integrated into any organization focussed on common interest, into political parties or municipal governments or professional organizations or trade unions. Potentially, they exist in every country and form the majority of those large numbers of neutral, politically indifferent people who never join a party and hardly ever go to the polls.
It was characteristic of the rise of the Nazi movement in Germany and of the Communist movements in Europe after 1930 that they recruited their members from this mass of apparently indifferent people whom all other parties had given up as too apathetic or too stupid for their attention. The result was that the majority of their membership consisted of people who never before had appeared on the political scene. This permitted the introduction of entirely new methods into political propaganda, and indifference to the arguments of political opponents; these movements not only placed themselves outside and against the party system as a whole, they found a membership that had never been reached, never been “spoiled” by the party system. Therefore they did not need to refute opposing arguments and consistently preferred methods which ended in death rather than persuasion, which spelled terror rather than conviction. They presented disagreements as invariably originating in deep natural, social. or psychological sources beyond the control of the individual and therefore beyond the power of reason. This would have been a shortcoming only if they had sincerely entered into competition with other parties; it was not if they were sure of dealing with people who had reason to be equally hostile to all parties.
The success of totalitarian movements among the masses meant the end of two illusions of democratically ruled countries in general and of European nation-states and their party system in particular. The first was that the people in its majority had taken an active part in government and that each individual was in sympathy with one’s own or somebody else’s party. On the contrary, the movements showed that the politically neutral and indifferent masses could easily be the majority in a democratically ruled country, that therefore a democracy could function according to rules which are actively recognized by only a minority. The second democratic illusion exploded by the totalitarian movements was that these politically indifferent masses did not matter, that they were truly neutral and constituted no more than the inarticulate backward setting for the political life of the nation. Now they made apparent what no other organ of public opinion had ever been able to show, namely, that democratic government had rested as much on the silent approbation and tolerance of the indifferent and inarticulate sections of the people as on the articulate and visible institutions and organizations of the country. Thus when the totalitarian movements invaded Parliament with their contempt for parliamentary government, they merely appeared inconsistent: actually, they succeeded in convincing the people at large that parliamentary majorities were spurious and did not necessarily correspond to the realities of the country, thereby undermining the self-respect and the confidence of governments which also believed in majority rule rather than in their constitutions (Arendt 1958, 311–2).
Her observation holds true again today, in several nations, including that self-proclaimed beacon of freedom for which Jefferson developed his sound, necessary educational programme, without which proper public oversight of government officials and proper public recognition and assessment of the inevitable social, political, economic effects of the sociological law of unintended consequences are impossible – a circumstance highly advantageous to those who willing seek their own presumptive benefits, whether individual or factional, disregarding the core principle of proper individual and group conduct: above all, do no harm!
In fine, any genuine republic must legislate and properly fund the civic right to a properly republican public education, of the kind Jefferson advocated. I have presented these issues historically to indicate our long-standing negligence, if not subversion, of these core requirements of just government. It is thus no surprise that concerned scholars in various fields and regions have been highlighting Jefferson’s educational philosophy, and also Arendt’s penetrating account of the origins of 20th-century totalitarianism. As for Jefferson’s appeal to natural human rights, the required core rights, including the right to properly republican public education, can be identified precisely and justified robustly, independently of metaphysical or theological issues.
Kenneth R. Westphal, firstname.lastname@example.org, Member, Academia Europaea. https://ae-info.org/; Westphal, K.R.: ORCiD: 0000-0001-6039-760X; web: https://ae-eu.academia.edu/KennethWestphal.
References and Abbreviations*
*(where used, other citations by author (date); I have sought widely accessible editions & sources.)
Boyd, Julian, Charles Cullen, John Catanzariti, Barbara Oberg, and James McClure, eds. 1950–. The Papers of Thomas Jefferson, 45 + 15 vols. (to date). Princeton: Princeton University Press.
Lipscomb, Andrew A. Ed.-in-Chief. 1903–. The Writings of Thomas Jefferson, Library Edition, 20 vols. Washington, D.C., The Thomas Jefferson Memorial Association. (This first edition is often cited as ‘Library Edition’; a second edition appeared in 1907, designated the ‘Definitive Edition’. Volumes from this latter edition are indicated by ‘de’, following WTJ.)
National Archives (USA). Founders Online: https://founders.archives.gov/documents/. (Most urls are permanent (purl), provisional urls are noted.)
Jefferson, Thomas. 1798. ‘A Letter of Jefferson on the Political Parties, 12.02.1798’. The American Historical Review 3.3 (1898):488; http://doi.org/10.2307/1833690; to John Wise; PTJ 30:98–100; FO: https://founders.archives.gov/documents/Jefferson/01-30-02-0066; (not in WTJ).
Dickinson, John. 1768. Letters from a Farmer in Pennsylvania. Philadelphia.
Honeywell, Roy. 1931. Educational Work of Thomas Jefferson. Cambridge, MA: Harvard University Press.
Knox, Samuel. 1799. An Essay on the Best System of Liberal Education, Adapted to the Genius of the Government of the United States. Maryland: General Assembly; Warner & Hanna.
Madison, James. 1973. Robert A. Rutland and William M.E. Rachal, eds. The Papers of James Madison, 53 vols. Chicago, The University of Chicago Press (to 1977); from 1978: Charlottesville, VA: University of Virginia Press.
Rudolph, Frederick. 1965. Essays on Education in the Early Republic. Cambridge, Mass. & London, Harvard University Press; rpt. Berlin: deGruyter, 2013.
Rush, Benjamin. 1806. Essays, Literary, Moral & Philosophical, 2nd ed. Philadelphia, T. & W. Bradford.
Virginia [state of], General Assembly. 1784. Report of the Committee of Revisors appointed by the General Assembly of Virginia in MDCCLXXVI. Published by order of the General Assembly and printed by Dixon & Holt, in the city of Richmond [VA], November 1784.
Wirth, William. 1804. The British Spy: or, Letters, to a Member of the British Parliament, written during a tour through the United States, by a Young Englishman of Rank. Newburyport, the Repertory Office. (Published anonymously, Wirth’s authorship soon became well known.)
II. Selected Histories
Brown, Richard, 1999. The Strength of a People: The Idea of an Informed Citizenry in America, 1650–1870. Chapel Hill, NC: University of North Carolina Press.
Cremin, Lawrence. 1970. American Education: The Colonial Experience, 1607–1783. Harper & Row; rpt. 1988.
Dexter, Edwin Grant. 1904. A History of Education in the United States. New York: Macmillan.
Geiger, Roger L. 2014. The History of American Higher Education: Learning and Culture from the Founding to World War II. Princeton, NJ, Princeton University Press.
Pangle, Lorraine Smith and Thomas L. Pangle. 1993. The Learning of Liberty: The Educational Ideas of the American Founders. Kansas City: University Press of Kansas.
III. Contemporary Studies
Arendt, Hannah. 1958. The Origins of Totalitarianism, 2nd enlarged ed. Cleveland & New York: Meridian Books (World Publishing Co.).
Arthur, James. 2019. Virtues in the Public Sphere: Citizenship, Civic Friendship and Duty. Oxon & New York: Routledge.
Blum, Lawrence and Zoë Burkholder. 2021. Integrations: The Struggle for Racial Equality and Civic Renewal in Public Education. Chicago: University of Chicago Press.
Curren, Randall. forthcoming. ‘Children of the Broken Heartlands: Rural Isolation and the Geography of Opportunity’. Social Theory and Practice.
Curren, Randall, ed. 2022. Handbook of Philosophy of Education. London: Routledge.
Curren, Randall. 2020. ‘Civic Friendship’. Jubilee Centre for Character and Virtues: University of Birmingham. https://www.jubileecentre.ac.uk/2934/projects/civic-virtues-through-service-to-others.
Curren, Randall. 2019. ‘Populism and the Fate of Civic Friendship’. In Virtues in the Public Sphere: Citizenship, Civic Friendship and Duty edited by James Arthur, 92–107. Abingdon, UK.
Curren, Randall, 2000. Aristotle on the Necessity of Public Education. Lanham, MD: Rowman & Littlefield.
Curren, Randall, and Charles Dorn, 2018. Patriotic Education in a Global Age. Chicago, University of Chicago Press.
Dean, John. 2007. Broken Government: How Republican Rule Destroyed the Legislative, Executive and Judicial Branches. New York, Viking.
Dean, John. 2006. Conservatives without Conscience. New York, Viking.
Dewey, John. 1930. Individualism: Old and New. New York: Minton, Balch & Co.
Ketcham, Ralph. 1987. Individualism and Public Life: A Modern Dilemma. Oxon: Basil Blackwell.
Levitsky, Steven and Daniel Ziblatt. 2018. How Democracies Die. New York: Penguin, Random House.
Wagoner, Jennings. 2004. Jefferson and Education. Charlottesville, VA, Thomas Jefferson Foundation.
Westphal, Kenneth R. 2020. Hegel’s Civic Republicanism: Integrating Natural Law with Kant’s Moral Constructivism. New York & London, Routledge.
Westphal, Kenneth R. 2018. ‘Higher Education & Academic Administration: Current Crises Long Since Foretold’. Social Epistemology Review and Reply Collective 7 (1): 41–47. (Updated version on author’s website.)
Westphal, Kenneth R. 2016a. ‘Back to the 3 R’s: Rights, Responsibilities & Reasoning’. SATS – Northern European Journal of Philosophy 17.1:21–60. https://doi.org/10.1515/sats-2016-0008.
Westphal, Kenneth R. 2016b. How Hume and Kant Reconstruct Natural Law: Justifying Strict Objectivity without Debating Moral Realism. Oxford: The Clarendon Press.
Wiebe, Robert H. 1995. Self-Rule: A Cultural History of American Democracy. Chicago: University of Chicago Press.
 Records of McHenry’s report, both published and from his diary, follow below, pt. iii (p. 9ff).
 See Rudolph 1965.
 PTJ, 2:526; TJW 199–200; EWTJ, 199. (The complete bill is reproduced in each of these sources, starting with the page indicated.) See Virginia General Assembly (1784), bill no. 79, ch. lxxix (pp. 53–5).
 PTJ, 10:243–5; WTJ de 1:70–1; FO: https://founders.archives.gov/documents/Jefferson/98-01-02-1756; ‘early access’ link.
 PTJ 10:244–5; WTJ 5:396–7; FO: https://founders.archives.gov/documents/Jefferson/01-10-02-0162.
 PJM 9:189–92; FO: https://founders.archives.gov/documents/Madison/01-09-02-0096.
 I use ‘¶’ (paragraph) for internal cross references, leaving ‘§’ to quoted texts.
 See Virginia, General Assembly 1784.
 WTJ de 1:73–4; FO: https://founders.archives.gov/documents/Jefferson/98-01-02-1756; ‘early access’ link.
 In his Autobiography, referring to bills introduced in 1796 to the Virginia Assembly, Jefferson wrote: ‘The bill on the subject of slaves, was a mere digest of the existing laws respecting them, without any intimation of a plan for a future and general emancipation. It was thought better that this should be kept back, and attempted only by way of amendment, whenever the bill should be brought on. The principles of the amendment, however, were agreed on, that is to say, the freedom of all born after a certain day, and deportation at a proper age. But it was found that the public mind would not yet bear the proposition, nor will it bear it even at this day. Yet the day is not distant when it must bear and adopt it, or worse will follow. Nothing is more certainly written in the book of fate, than that these people [i.e. Negro slaves] are to be free; nor is it less certain that the two races, equally free, cannot live in the same government. Nature, habit, opinion have drawn indelible lines of distinction between them. It is still in our power to direct the process of emancipation and deportation, peaceably, and in such slow degree, as that the evil will wear off insensibly, and their place be, pari passu, filled up by free white laborers. If, on the contrary, it is left to force itself on, human nature must shudder at the prospect held up’. (WTJ de 1:72–3; FO: https://founders.archives.gov/documents/Jefferson/98-01-02-1756; ‘early access’ link.)
 Viz., Virginia General Assembly 1784.
 PTJ 29:177–8; FO: https://founders.archives.gov/documents/Jefferson/01-29-02-0135. (Not in WTJ .)
 PTJ, 9:330–1; WTJ 14:383–4; FO: https://founders.archives.gov/documents/Jefferson/03-09-02-0209.
 Jefferson 1798.
 This same strategy I use also in Westphal 2018.
 See Westphal 2016, 2020; cf. Curren 2000.
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