Month: July 2021

Ross Douthat on Structural Racism

Brilliant column by Douthat:

What’s really inflaming today’s fights, though, is that the structural-racist diagnosis isn’t being offered on its own. Instead it’s yoked to two sweeping theories about how to fight the problem it describes.

First, there is a novel theory of moral education, according to which the best way to deal with systemic inequality is to confront its white beneficiaries with their privileges and encourage them to wrestle with their sins.

Second, there is a Manichaean vision of public policy, in which all policymaking is either racist or antiracist, all racial disparities are the result of racism — and the measurement of any outcome short of perfect “equity” may be a form of structural racism itself…

The impulses these ideas encourage take different forms in different institutions, but they usually circle around to similar goals. First, the attempt to use racial-education programs to construct a stronger sense of shared white identity, on the apparent theory that making Americans of European ancestry think of themselves as defined by a toxic “whiteness” will lead to its purgation. Second, the deconstruction of standards that manifest racial disparities, on the apparent theory that if we stop using gifted courses or standardized tests, the inequities they reveal will cease to matter… The [latter idea] extends structural analysis beyond what it can reasonably bear, into territory where white supremacy supposedly explains Asian American success on the SAT.

But precisely because they don’t follow from modest and defensible conceptions of systemic racism, smart progressives in the media often retreat to those modest conceptions when challenged by conservatives — without acknowledging that the dubious conceptions are a big part of what’s been amplifying controversy, and conjuring up dubious Republican legislation in response.

Back in 1991, I heard Derrick Bell, one of the founders of Critical Race Theory, defend the importance of making white people more aware of their whiteness, and congratulate himself on persuading some of his students, particularly a Jewish one, think of themselves as white. So at least some of this is deeply ingrained, but the idea that making Americans of European descent more inclined toward white identitarianism is going to have long-term positive consequences is, well, nuts.

I would add one more factor to Douthat’s analysis. As with the 1619 Project and Kendi and Reynolds, Stamped: Racism, Antiracism and You, activist historians and journalists play fast and loose with facts to suit their historical narratives. They also seem impervious to acknowledging, much less correcting, even the most glaring errors when pointed out to them. For example (in honor of Independence Day), no, the American Revolution was not fought primarily to prevent Great Britain from abolishing slavery in the colonies. Those who insist that public schools should teach made-up nonsense as historical fact in service of radical ideologies that most Americans don’t agree with will rightly get political blowback.

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Immigration and the Principles of the Declaration of Independence


DeclarationofIndependence

The Declaration of Independence.

 

 

 

 

 

 

Millions of people around the world know the stirring words of the Declaration of Independence announcing that “all men are created equal” and that they have the rights to “Life, Liberty and the pursuit of Happiness.” But relatively few know that, among the grievances the Declaration enumerates as justification for renouncing allegiance to King George III is the following:

He has endeavoured to prevent the population of these States; for that purpose obstructing the Laws for Naturalization of Foreigners; refusing to pass others to encourage their migrations hither….

This complaint against the King was aimed at a series of royal orders issued in  1772 and 1773, which forbade the colonies from naturalizing aliens, banned the passage of any laws facilitating that purpose, including laws promoting migration, and overrode a North Carolina law exempting immigrants from Europe from taxation for a period of four years.

It’s tempting dismiss this as just a disagreement over policy. But it  actually goes further than that, since it is one of the items on the list of “repeated injuries and usurpations, all having in direct object the establishment of an absolute Tyranny over these States.”

The King’s efforts to restrict immigration to Britain’s American colonies were not just a flawed policy, the Declaration claims, but a step towards the “establishment of an absolute Tyranny.”

Nor was it merely a tyranny over the colonial governments’ supposed right to determine immigration policy for themselves. It was also a tyrannical action towards the would-be immigrants.

Many of the leaders of the American Revolution saw the new nation as a refuge for the oppressed of the world. In his famous General Orders to the Continental Army, issued on the occasion of the end of the Revolutionary War in 1783, George Washington stated that one of the reasons the United States was founded was to create “an Asylum for the poor and oppressed of all nations and religions.” He expressed similar views on other occasions, including writing to a group of newly arrived Irish immigrants that “[t]he bosom of America is open to receive not only the opulent & respectable Stranger, but the oppressed & persecuted of all Nations & Religions.”

Thomas Jefferson, the principal author of the Declaration, similarly wrote, in 1781, that “It [has] been the wise policy of these states to extend the protection of their laws to all those who should settle among them of whatever nation or religion they might be and to admit them to a participation of the benefits of civil and religious freedom.” Other leading Founders expressed similar sentiments, including James Madison and James Wilson, among others.

The idea of accepting immigrants without regard to their national origin and religion was an extension of the more general principle that the United States was founded on the basis of universal liberal principles, not ties of ancestry, culture, or faith.  This is what the Declaration refers to in the famous passage avowing that all men are created equal and have the rights to life, liberty, and the pursuit of happiness.

There can be no such liberty and equality if where people are allowed to live is limited by their parentage and place of birth. Just as the leaders of the Revolution rejected more traditional hereditary aristocracy, their principles were also at odds with what we might today call the hereditary aristocracy of citizenship, under which only those born to the right parents or in the right place have a right to live in the United States, while all others can be excluded for virtually any reason the government might come up with.

The Founders established a Constitution under which, Madison and most others argued, the federal government had no general power to exclude immigrants. When the Federalist Party pushed through the Alien and Sedition Acts of 1798, giving the president broad power to deport immigrants he deemed “dangerous,” Jefferson and Madison denounced the law as both unjust and unconstitutional. They and their allies mobilized such strong resistance to the Alien Friends Act that the federal government never actually managed to deport anyone under it.

When Jefferson became president in 1800, he allowed the Act to expire, and federal immigration policy remained almost completely free of restrictions until the enactment of racially motivated exclusionary laws targeting Chinese immigrants in the 1870s and 1880s. The successful resistance to the Alien Acts was a triumph for liberty and equality that deserves to be far better known than it currently is.

None of this proves that America’s founding generation was free of prejudices against immigrants. The Federalist Party, as noted, sought to use the Alien Friends Act to deport many immigrants, fearing that they might spread French revolutionary ideas to the United States and—perhaps even worse from the Federalist point of view –  support the rival Democratic-Republican Party.

Despite his defense of open immigration on many occasions, Thomas Jefferson wrote, in his 1782 Notes on Virginia, that America had reason to fear immigrants from “absolute monarchies,” because “[t]hey will bring with them the principles of the governments they leave, imbibed in their early youth; or, if able to throw them off, it will be in exchange for an unbounded licentiousness, passing, as is usual, from one extreme to another.” As with many later Americans who feared that immigrants would spread harmful political political values, Jefferson did not give sufficient weight to the reality that people fleeing oppressive regimes usually do so precisely because they abhor those governments, not because they want to recreate them elsewhere.

But even in that same passage, Jefferson rejected the idea of barring immigrants from oppressive governments, instead recognizing that “[i]f they come of themselves, they are entitled to all the rights of citizenship.” He merely  “doubt[ed] the expediency of inviting them by extraordinary encouragements.” Later, of course, Jefferson took a more favorable view of the political impact of immigrants—perhaps, in part, because many of them supported him and his party!

As on many other issues, particularly slavery, the Founders didn’t always live up to their own principles when it comes to immigration. The Federalist advocates of the Alien Acts obviously did not. Nor did Congress when it enacted the Naturalization Act of 1790, and limited eligibility for citizenship to those immigrants who were “free white person[s].” Black immigrants were not made eligible for citizenship until 1870. Explicit racial restrictions on naturalization were not fully ended until 1952.

Restrictions on naturalization did not amount to restrictions on immigration itself. Black  immigrants came to the United States in substantial numbers even when many of them were ineligible for  citizenship, beginning with numerous refugees from Haiti in the 1790s. Still, black immigrants in this era suffered severe discrimination, as did native-born free African-Americans (to say nothing of the millions of slaves).

But despite these unjust limitations, the principles of the Declaration of Independence did lead to the establishment of a nation that, for the first century of its history, had very few limitations on immigration, and thus became a refuge for millions of people fleeing poverty and tyranny.

Washington’s vision of a refuge for “the oppressed & persecuted of all Nations & Religions” was never fully achieved. But the early United States did realize it to a astonishingly impressive degree. In some important ways, the early republic was actually more enlightened on these matters than we are today. Our immigration policies bar the vast majority of those seeking refuge from oppression, and even include such perversions as barring escaped slaves on the grounds that the forced labor they performed for terrorist organizations qualifies as “material support for terrorism” rendering them ineligible or asylum.

Jefferson and Washington were not far from the only ones who saw a connection between openness to immigration and America’s founding principles of liberty and equality. The great African-American abolitionist Frederick Douglass made much the same point in an 1869 speech, in which he compared immigration restrictions to racial discrimination, and argued that America must be a “composite nation” open to to people of all races and cultures who wished to settle there.

Abraham Lincoln, who was a strong supporter of open immigration,  also saw the connection between immigrant rights and the Declaration of Independence:

When [immigrants] look through that old Declaration of Independence, they find that those old men say that “We hold these truths to be self-evident, that all men are created equal”; and then they feel that that moral sentiment, taught in that day, evidences their relation to those men… and that they have a right to claim it as though they were blood of the blood, and flesh of the flesh, of the men who wrote that Declaration; and so they are.

The America of Founding era and of Lincoln’s day didn’t fully live up these high ideals. The same remains true even today, in some respects even more so. But, at its best, the nation has indeed been a refuge for the oppressed, and they have been major contributors to its growth and success. Immigrants and natives alike have much to gain from a more consistent adherence to the principles of the Declaration of Independence.

On immigration, as elsewhere, we would do well to heed Lincoln’s admonition that the Declaration “set up a standard maxim for free society which should be familiar to all: constantly looked to, constantly labored for, and even, though never perfectly attained, constantly approximated, and thereby constantly spreading and deepening its influence and augmenting the happiness and value of life to all people, of all colors, every where.”

 

 

 

 

 

 

 

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What the Declaration of Independence Said and Meant

[This year, my annual post celebrating the Fourth of July is drawn from a chapter of Our Republican Constitution: Securing the Liberty and Sovereignty of We the People, and from a short essay on the same topic, The Declaration of Independence and the American Theory of Government: First Come Rights, and Then Comes Government.” It also draws upon Sean Wilentz, No Property in Man: Slavery and Antislavery at the Nation’s Founding]

The Declaration of Independence used to be read aloud at public gatherings every Fourth of July. Today, while all Americans have heard of it, all too few have read more than its second sentence. Yet the Declaration shows the natural rights foundation of the American Revolution, and provides important information about what the founders believed makes a constitution or government legitimate. It also raises the question of how these fundamental rights are reconciled with the idea of “the consent of the governed,” another idea for which the Declaration is famous.

The adoption of the Declaration, and the public affirmation of its principles, led directly to the phased in abolition of slavery in half of the United States by the time the Constitution was drafted as well as the abolition of slavery in the Northwest Territory. The Rhode Island gradual abolition law of 1784 read:

All men are entitled to Life, Liberty, and the Pursuit of Happiness, and the holding Mankind in a State of Slavery, as private property, which has gradually obtained by unrestrained Custom and the Permission of the Law, is repugnant to this Principle, and subversive of the Happiness of Mankind.

Later, the Declaration also assumed increasing importance in the struggle to abolish slavery. It became a lynchpin of the moral and constitutional arguments of the nineteenth-century abolitionists. As one New Yorker opposed to slavery wrote in 1797:

The right of property which every man has to his personal liberty is paramount to all the laws of property…. All I contend for at present is, that no claims of property can ever justly interfere with, or be suffered to impede the operation of that noble and eternal principle, that “all men are endowed by their Creator with certain unalienable rights–and that among these are life, liberty, and the pursuit of happiness.

The Declaration was much relied upon by Abraham Lincoln and many others before him:

Without the Constitution and the Union, we could not have attained the result; but even these, are not the primary cause of our great prosperity. There is something back of these, entwining itself more closely about the human heart. That something, is the principle of “Liberty to all”–the principle that clears the path for all–gives hope to all–and, by consequence, enterprize, and industry to all.

The expression of that principle, in our Declaration of Independence, was most happy, and fortunate. Without this, as well as with it, we could have declared our independence of Great Britain; but without it, we could not, I think, have secured our free government, and consequent prosperity. No oppressed, people will fight, and endure, as our fathers did, without the promise of something better, than a mere change of masters.

The assertion of that principle, at that time, was the word, “fitly spoken” which has proved an “apple of gold” to us. The Union, and the Constitution, are the picture of silver, subsequently framed around it. The picture was made, not to conceal, or destroy the apple; but to adorn, and preserve it. The picture was made for the apple—not the apple for the picture.

The Declaration had to be explained away–quite unconvincingly–by the Supreme Court in Dred Scott. And eventually it was repudiated by some defenders of slavery in the South because of its inconsistency with that institution.

When reading the Declaration, it is worth keeping in mind two very important facts. The Declaration constituted high treason against the Crown. Every person who signed it would be executed as traitors should they be caught by the British. Second, the Declaration was considered to be a legal document by which the revolutionaries justified their actions and explained why they were not truly traitors. It represented, as it were, a literal indictment of the Crown and Parliament, in the very same way that criminals are now publicly indicted for their alleged crimes by grand juries representing “the People.”

But to justify a revolution, it was not thought to be enough that officials of the government of England, the Parliament, or even the sovereign himself had violated the rights of the people. No government is perfect; all governments violate rights. This was well known. So the Americans had to allege more than mere violations of rights. They had to allege nothing short of a criminal conspiracy to violate their rights systematically. Hence, the famous reference to “a long train of abuses and usurpations” and the list that follows the first two paragraphs. In some cases, these specific complaints account for provisions eventually included in the Constitution and Bill of Rights.

In Our Republican Constitution: Securing the Liberty and Sovereignty of We the People, I explain how the Declaration encapsulated the political theory that lead the Constitution some eleven years later. To appreciate all that is packed into the two paragraphs that comprise the preamble to the list of grievances, it is useful to break down the Declaration into some of its key claims.

“When in the Course of human events, it becomes necessary for one people to dissolve the political bands which have connected them with another, and to assume among the powers of the earth, the separate and equal station to which the Laws of Nature and of Nature’s God entitle them, a decent respect to the opinions of mankind requires that they should declare the causes which impel them to the separation.”

This first sentence is often forgotten. It asserts that Americans as a whole (and not as members of their respective colonies) are a distinct “people.” To “dissolve the political bands” revokes the “social compact” that existed between the Americans and the rest of “the People” of the British commonwealth, reinstates the “state of nature” between Americans and the government of Great Britain, and makes “the Laws of Nature” the standard by which this dissolution and whatever government is to follow are judged. “Declare the causes” indicates they are publicly stating the reasons and justifying their actions rather than acting as thieves in the night. The Declaration is like the indictment of a criminal that states the basis of his criminality. But the ultimate judge of the rightness of their cause will be God, which is why the revolutionaries spoke of an “appeal to heaven”—an expression commonly found on revolutionary banners and flags. As British political theorist John Locke wrote: “The people have no other remedy in this, as in all other cases where they have no judge on earth, but to appeal to heaven.” The reference to a “decent respect to the opinions of mankind” might be viewed as a kind of an international public opinion test. Or perhaps the emphasis is on the word “respect,” recognizing the obligation to provide the rest of the world with an explanation they can evaluate for themselves.

“We hold these truths to be self-evident, that all men are created equal, that they are endowed by their Creator with certain unalienable Rights, that among these are Life, Liberty and the pursuit of Happiness. “

The most famous line of the Declaration. On the one hand, this will become a great embarrassment to a people who permitted slavery. On the other hand, making public claims like this has consequences—that’s why people make them publicly. To be held to account. This promise will provide the heart of the abolitionist case in the nineteenth century, which is why late defenders of slavery eventually came to reject the Declaration. And it forms the basis for Martin Luther King’s metaphor of the civil rights movement as a promissory note that a later generation has come to collect.

Notice that the rights of “life,” “liberty” and “the pursuit of happiness” are individual, not collective or group rights. They belong to “We the People”—each and every one. This is not to say that government may not create collective, positive rights; but only that the rights that the next sentence tells us are to be secured by government belong to us as individuals.

What are “unalienable,” or more commonly, “inalienable rights”? Inalienable rights are those you cannot give up even if you want to and consent to do so, unlike other rights that you can agree to transfer or waive. Why the claim that they are inalienable rights? The Founders want to counter England’s claim that, by accepting the colonial governance, the colonists had waived or alienated their rights. The Framers claimed that with inalienable rights, you always retain the ability to take back any right that has been given up.

A standard trilogy throughout this period was “life, liberty, and property.” For example, the Declaration and Resolves of the First Continental Congress (1774) read: “That the inhabitants of the English colonies in North-America, by the immutable laws of nature, the principles of the English constitution, and the several charters or compacts, have the following RIGHTS: Resolved, 1. That they are entitled to life, liberty and property: and they have never ceded to any foreign power whatever, a right to dispose of either without their consent.” Or, as John Locke wrote, “no one ought to harm another in his life, health, liberty, or possessions.”

When drafting the Declaration in June of 1776, Jefferson based his formulation on a preliminary version of the Virginia Declaration of Rights that had been drafted by George Mason at the end of May for Virginia’s provincial convention. Here is how Mason’s draft read:

THAT all men are born equally free and independent, and have certain inherent natural rights, of which they cannot, by any compact, deprive or divest their posterity; among which are, the enjoyment of life and liberty, with the means of acquiring and possessing property, and pursuing and obtaining happiness and safety.

Notice how George Mason’s oft-repeated formulation combines the right of property with the pursuit of happiness. And, in his draft, not only do all persons have “certain . . . natural rights” of life, liberty, and property, but these rights cannot be taken away “by any compact.” Again, these rights each belong to individuals. And these inherent individual natural rights, of which the people—whether acting collectively or as individuals—cannot divest their posterity, are therefore retained by them, which is helpful in understanding the Ninth Amendment’s reference to the “rights…retained by the people.”

Interestingly, Mason’s draft was slightly altered by the Virginia Convention in Williamsburg on June 11, 1776. After an extensive debate, the officially adopted version read (with the modifications in italics):

That all men are by nature equally free and independent, and have certain inherent rights, of which, when they enter into a state of society, they cannot, by any compact, deprive or divest their posterity; namely, the enjoyment of life and liberty, with the means of acquiring and possessing property, and pursuing and obtaining happiness and safety.

This version is still in effect today.

According to historian Pauline Meier, by changing “are born equally free” to “are by nature equally free,” and “inherent natural rights” to “inherent rights,” and then by adding “when they enter into a state of society,” defenders of slavery in the Virginia convention could contend that slaves were not covered because they “had never entered Virginia’s society, which was confined to whites.” Yet it was the language of Mason’s radical draft—rather than either Virginia’s final wording or Jefferson’s more succinct formulation—that became the canonical statement of first principles. Massachusetts, Pennsylvania, and Vermont adopted Mason’s original references to “born equally free” and to “natural rights” into their declarations of rights while omitting the phrase “when they enter into a state of society.” Indeed, it is remarkable that these states would have had Mason’s draft language, rather than the version actually adopted by Virginia, from which to copy. Here is Massachusetts’ version:

All men are born free and equal, and have certain natural, essential, and unalienable rights; among which may be reckoned the right of enjoying and defending their lives and liberties; that of acquiring, possessing, and protecting property; in fine, that of seeking and obtaining their safety and happiness.

Virginia slaveholders’ concerns about Mason’s formulation proved to be warranted. In 1783, the Massachusetts Supreme Judicial Court relied upon this more radical language to invalidate slavery in that state. And its influence continued. In 1823, it was incorporated into an influential circuit court opinion by Justice Bushrod Washington defining the “privileges and immunities” of citizens in the several states as “protection by the Government, the enjoyment of life and liberty, with the right to acquire and possess property of every kind, and to pursue and obtain happiness and safety.”

Justice Washington’s opinion in Corfield (to which we will return), with Mason’s language at its core, was then repeatedly quoted by Republicans in the Thirty-Ninth Congress when they explained the meaning of the Privileges or Immunities Clause of the Fourteenth Amendment, which reads: “No state shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States.” It was this constitutional language that Republicans aimed at the discriminatory Black Codes by which Southerners were seeking to perpetuate the subordination of blacks, even after slavery had been abolished.

“That to secure these rights, Governments are instituted among Men.… “

Another overlooked line, which is of greatest relevance to our discussion of the first underlying assumption of the Constitution: the assumption of natural rights. Here, even more clearly than in Mason’s draft, the Declaration stipulates that the ultimate end or purpose of republican governments is “to secure these” preexisting natural rights that the previous sentence affirmed were the measure against which all government—whether of Great Britain or the United States—will be judged. This language identifies what is perhaps the central underlying “republican” assumption of the Constitution: that governments are instituted to secure the preexisting natural rights that are retained by the people. In short, that first come rights and then comes government.

“…deriving their just powers from the consent of the governed.”

Today, there is a tendency to focus entirely on the second half of this sentence, referencing “the consent of the governed,” to the exclusion of the first part, which refers to securing our natural rights. Then, by reading “the consent of the governed” as equivalent to “the will of the people,” the second part of the sentence seems to support majoritarian rule by the people’s “representatives.” In this way, “consent of the governed” is read to mean “consent to majoritarian rule.” Put another way, the people can consent to anything, including rule by a majority in the legislature who will then decide the scope of their rights as individuals.

But read carefully, one sees that in this passage the Declaration speaks of “just powers,” suggesting that only some powers are “justly” held by government, while others are beyond its proper authority. And notice also that “the consent of the governed” assumes that the people do not themselves rule or govern, but are “governed” by those individual persons who make up the “governments” that “are instituted among men.”

The Declaration stipulates that those who govern the people are supposed “to secure” their preexisting rights, not impose the will of a majority of the people on the minority. And, as the Virginia Declaration of Rights made explicit, these inalienable rights cannot be surrendered “by any compact.” Therefore, the “consent of the governed,” to which the second half of this sentence refers, cannot be used to override the inalienable rights of the sovereign people that are reaffirmed by the first half.

In modern political discourse, people tend to favor one of these concepts over the other—either preexistent natural rights or popular consent—which leads them to stress one part of this sentence in the Declaration over the other. The fact that rights can be uncertain and disputed leads some to emphasize the consent part of this sentence and the legitimacy of popularly enacted legislation. But the fact that there is never unanimous consent to any particular law, or even to the government itself, leads others to emphasize the rights part of this sentence and the legitimacy of judges protecting the “fundamental” or “human” rights of individuals and minorities.

If we take both parts of this sentence seriously, however, this apparent tension can be reconciled by distinguishing between (a) the ultimate end or purpose of legitimate governance and (b) how any particular government gains jurisdiction to rule. So, while the protection of natural rights or justice is the ultimate end of governance, particular governments only gain jurisdiction to achieve this end by the consent of those who are governed. In other words, the “consent of the governed” tells us which government gets to undertake the mission of “securing” the natural rights that are retained by the people. After all, justifying the independence of Americans from the British government was the whole purpose of the Declaration of Independence.

“That whenever any Form of Government becomes destructive of these ends, it is the Right of the People to alter or to abolish it, and to institute new Government, laying its foundation on such principles and organizing its powers in such form, as to them shall seem most likely to effect their Safety and Happiness.”

People have the right to take back power from the government. Restates the end—human safety and happiness—and connects the principles and forms of government as means to this end.

“Prudence, indeed, will dictate that Governments long established should not be changed for light and transient causes; and accordingly all experience hath shewn, that mankind are more disposed to suffer, while evils are sufferable, than to right themselves by abolishing the forms to which they are accustomed.”

Affirms at least two propositions: On the one hand, long-established government should not be changed for just any reason. The mere fact that rights are violated is not enough to justify revolution. All governments on earth will sometimes violate rights. But things have to become very bad before anyone is going to organize a resistance. Therefore, the very existence of this Declaration is evidence that things are very bad indeed.

“But when a long train of abuses and usurpations, pursuing invariably the same Object evinces a design to reduce them under absolute Despotism, it is their right, it is their duty, to throw off such Government, and to provide new Guards for their future security.”

Revolution is justified only if there “is a long train of abuses and usurpations, pursuing invariably the same Object”—evidence of what amounts to an actual criminal conspiracy by the government against the rights of the people. The opposite of “light and transient causes,” that is, the more ordinary violations of rights by government.

“Such has been the patient sufferance of these Colonies; and such is now the necessity which constrains them to alter their former Systems of Government. The history of the present King of Great Britain [George III—Eds.] is a history of repeated injuries and usurpations, all having in direct object the establishment of an absolute Tyranny over these States. To prove this, let Facts be submitted to a candid world.“

What follows is a bill of indictment. Several of these items end up in the Bill of Rights. Others are addressed by the form of the government established—first by the Articles of Confederation, and ultimately by the Constitution.

The assumption of natural rights expressed in the Declaration of Independence can be summed up by the following proposition: “First comes rights, then comes government.” According to this view: (1) the rights of individuals do not originate with any government, but preexist its formation; (2) the protection of these rights is the first duty of government; and (3) even after government is formed, these rights provide a standard by which its performance is measured and, in extreme cases, its systemic failure to protect rights—or its systematic violation of rights—can justify its alteration or abolition; (4) at least some of these rights are so fundamental that they are “inalienable,” meaning they are so intimately connected to one’s nature as a human being that they cannot be transferred to another even if one consents to do so. This is powerful stuff.

At the Founding, these ideas were considered so true as to be self-evident. However, today the idea of natural rights is obscure and controversial. Oftentimes, when the idea comes up, it is deemed to be archaic. Moreover, the discussion by many of natural rights, as reflected in the Declaration’s claim that such rights “are endowed by their Creator,” leads many to characterize natural rights as religiously based rather than secular. As I explain in The Structure of Liberty: Justice and the Rule of Law, I believe this is a mistake.

The political theory announced in the Declaration of Independence can be summed up in a single sentence: First come rights, and then comes government. This proposition is not, as some would say, a libertarian theory of government. The Declaration of Independence shows it to be the officially adopted American Theory of Government.

  • According to the American Theory of Government, the rights of individuals do not originate with any government but pre-exist its formation;
  • According to the American Theory of Government, the protection of these rights is both the purpose and first duty of government;
  • According to the American Theory of Government, at least some of these rights are so fundamental that they are inalienable, meaning that they are so intimately connected to one’s nature as a human being that they cannot be transferred to another even if one consents to do so;
  • According to the American Theory of Government, because these rights are inalienable, even after a government is formed, they provide a standard by which its performance is measured; in extreme cases, a government’s systemic violation of these rights or failure to protect them can justify its alteration and abolition. In the words of the Declaration, “whenever any Form of Government becomes destructive of these ends,” that is the securing of these rights, “it is the Right of the People to alter or abolish it, and to institute new Government, laying its foundation on such principles and organizing its powers in such form, as to them shall seem most likely to effect their Safety and Happiness.”

The original public meaning of the text of the Declaration of Independence is distinct from the original public meaning of the U.S. Constitution. The Constitution, however it is properly interpreted, does not justify itself. To be legitimate, it must be consistent with political principles that are capable of justifying it. Moreover, these same publicly identified original principles are needed inform how the original public meaning of the Constitution is to be faithfully to be applied when the text of
the Constitution is not alone specific enough to decide a case or controversy.

The original principles that the Founders thought underlie and justify the Constitution were neither shrouded in mystery nor to be found by parsing the writings of Locke, Montesquieu, or Machiavelli.

On July 2nd, 1776, the Congress of the United States voted for independence from Great Britain. On July 4th, 1776, it officially adopted the American Theory of Government, which was publicly articulated in the Declaration of Independence.

Happy Independence Day!

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Reflections on the Declaration of Independence and the American Revolution


DeclarationofIndependence

The Declaration of Independence.

 

Over the years, I have written a number of Independence Day pieces. Many of them have obvious continuing relevance to such issues as identity politics, nationalism, immigration, the role of slavery in American history, and others.

In this post, I compile what I hope will be a useful list of links to those works. Enjoy!

“The Declaration of Independence and the Case for Non-Ethnic Secession,” July 4, 2009.

“The Declaration of Independence and the Case for a Polity Based on Universal Principles,” July 4, 2017.

“The Universalist Principles of the Declaration of Independence,” July 4, 2019.

“The Case Against the Case Against the American Revolution,” July 4, 2019. A rebuttal to longstanding claims—advanced by critics on both right and left—that the Revolution did more harm than good

“Slavery, the Declaration of Independence and Frederick Douglass’ ‘What to the Slave is the Fourth of July?'”, July 4, 2020. Douglass’s famous speech sheds light on some of America’s greatest evils—but also on the great good done by the Revolution and Founding.

“Juneteenth and the Universalist Principles of the American Revolution,” June 19, 2021. Why there is no inconsistency in celebrating both July 4 and the abolition of slavery. Indeed, the two are mutually reinforcing.

“Immigration and the Principles of the Declaration of Independence, July 4, 2021.

UPDATE: I have updated the above to include today’s post on immigration and the Declaration.

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Goldman Doubles Down On Oil: Says Ignore OPEC+ Drama, World Desperately Needs Extra 5 Million Bpd To Avoid “Critically Low Inventories”

Goldman Doubles Down On Oil: Says Ignore OPEC+ Drama, World Desperately Needs Extra 5 Million Bpd To Avoid “Critically Low Inventories”

As is well-known by now, the July OPEC+ meeting never concluded as the UAE and Saudi Arabia/Russia failed to overcome their differences, with the former asking for a higher baseline from April 2022 and the latter for an extended commitment through 2022. Picking up on this development Goldman’s commodity strategist Damien Courvalin – who has been extremely bullish oil in recent months – concedes that while this lack of agreement has introduced uncertainty into the OPEC+ production path, its base-case remains “for a gradual increase in production through 1Q22 that would ultimately help meet their preferences, with Brent prices at $80/bbl this summer.”

Looking ahead, Goldman predicts that as negotiations continue, most outcomes (1) still imply higher prices in coming months as the physical market tightens, (2) with higher OPEC+ production than the group discussed needed by the global oil market next year. That said, Goldman warns that price volatility will likely rise – which can be clearly seen in today’s violent reaction which saw WTI surge then slide – with the release of the August OSP the key next catalyst.

But the most important observation in the Goldman note is that OPEC+ drama notwithstanding, the world will still be in trouble unless an additional 5mmb/d in production emerge by year-end, to wit: “while the threat of a new OPEC+ price war is no longer negligible, “its negative price impact would be dampened by a global market starting in a 2.5 mb/d deficit and in need of an extra 5 mb/d in production by year-end to avoid critically low inventories.”

Big picture, Courvalin writes that typical OPEC+ histrionics aside, the differences between both parties seem surmountable as they agree on ramping-up production into year-end with the still high uncertainty for 2022 oil balances making a pledge to any long-term commitment unnecessary today.

Goldman’s base-case therefore remains for a gradual increase in production in 2H21 – slightly larger than that discussed by the group (at a 0.5 mb/d monthly rate – akin to lower compliance), followed by similar increases in production in 1Q22 to finally bring the fall in inventories to an end, at their lowest levels since 2013.

And here a key point: given Goldman’s forecast for rising demand offset by slow global production recovery (largely due to the mothballing of US shale due to ESG), as well as the decline in productive capacity expected from many OPEC+ producers due to under-investment, Goldman believes that “such a path would further allow the UAE, Saudi and Russia to bring production to or near quarterly average records, helping meet all their preferences.”

Always bullish, Courvalin also writes that the recent stalemate has introduced the potential for alternate OPEC+ production paths, and mapping these into Goldman’s pricing model point to c. $3/bbl upside to the bank’s forecast under a delayed production ramp-up scenario and instead $9/bbl downside relative to our forecast in an all out price war and higher quota scenario (as describe further below).

Importantly, and unlike last year, such an “all out price war” remains a low probability outcome in Goldman’s view, with its price impact significantly muted by the current large oil deficit “and a market requiring a 5 mb/d increase in global production by year-end to prevent inventories from collapsing to critically low levels.”

In summary, Goldman continues to expect that its forecast for higher OPEC+ production in 2022 (akin to higher baselines) would justify Brent prices settling at $75/bbl, above market forwards with Dec-22 Brent still trading at $68.6/bbl. At the same time, the binding nature of a physically tight oil market would still warrant higher prices this summer even if higher output is expected next year, as real assets like commodities are not anticipatory and cannot price future supply-demand changes in the face of low inventories.

Finally, Goldman lists the following four likely outcomes from the ongoing OPEC+ standoff:

  • Our base-case. A deal to increase production as discussed last week could still be reached in coming weeks – as proposed this would nearly match our base case for 2H21, with monthly increases of 0.4 mb/d and offsets for a potential increase in Iran exports. We forecast this would take Brent prices to $80/bbl this summer.
  • A deal to ramp-up. Barring a deal in coming weeks, the current OPEC+ agreement would imply August production at July’s level, 0.5 mb/d less supply than our forecasts. If this is made up in September (so a 1 mb/d increase that month), the bullish impact on our forecast would simply be of $1/bbl. If instead, the monthly increases only start in September, with no make-up for the August miss, the bullish impact would be $3/bbl.
  • Higher baseline. As we have argued previously, the UAE’s request for a higher baseline is warranted given its investments in recent years although it is not as bearish as first appears. A new baseline would likely replicate the Saudi and Russia model, based off April 2020 surge product levels. Saudi reached 11.6 mb/d of production that month and was allocated an 11 mb/d baseline. Applied to the UAE, this would imply a 3.6 mb/d baseline vs. 3.17 mb/d currently (with Kuwait’s baseline rising modestly from 2.8 mb/d to 2.95 mb/d and most other countries actually having a lower baseline than currently). Importantly, this would in no way imply that the UAE’s baseline would rise to its stated production capacity, just like Saudi’s baseline is not its productive capacity. If such new baselines are used for August onward – with a similar 0.4 mb/d monthly rate of increase – the net impact on our balances would be 0.55 mb/d extra production going forward, representing only $3/bbl dollars downside relative to our base-case.
  • Price war. If the current impasse leads to an outright price war, we aggressively assume that the main OPEC+ producers return to Apr-20 production levels for 2 months before they agree to either of the scenarios above (which would translate into additive price impacts)[1]. This would represent 3.6 mb/d extra production versus our base-case, which over two months would represent $6/bbl downside to our price forecast. Followed by a deal to increase production gradually but from higher baseline production, for example, this would represent, combined, $9/bbl downside to forecast oil prices. This is a much more limited impact than last year given the large current deficit. While still net bearish relative to spot price levels, our higher summer fair value forecast and the elevated level of Brent put skew still leaves forwards pricing with a non-negligible probability of such an outcome, with Oct-21 Brent options (expiring at the end of August) already pricing in a 31% probability of prices falling to $71/bbl, $9/bbl below our summer forecast, for example.

Tyler Durden
Tue, 07/06/2021 – 12:10

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After a False Abuse Allegation, Child Services Took This Mom’s 3 Children Away


thumb2

Patti Krueger is a stay-at-home mom in Decatur, Illinois. Her husband is a house painter. The couple’s second son, Wyatt, was born in 2017 with severe breathing difficulties.

“He was blue,” says Krueger.

Wyatt spent nine days in neonatal intensive care. Over the next two years his breathing problems necessitated oxygen treatments, tubes in his ears, and four surgeries, according to Krueger.

Some of his treatments were at a nearby hospital in Peoria. Many hospitals today have a Child Abuse Pediatrician (CAP), a doctor on contract with child protective services. Their job is to be on the lookout for child abuse, including abuse other doctors may have missed. While the CAP at this hospital never met Krueger or worked directly with Wyatt, she reviewed his file and accused the mother of Munchausen syndrome by proxy—in other words, causing or faking a child’s illness to get attention.

This CAP’s report was all it took for Illinois’ Department of Child and Family Services to put into place a “safety plan” to remove the Kruegers’ kids. These plans do not require any kind of court order because ostensibly the family “agrees” to it, on pain of potentially having no say over what happens next to their kids. Thus, in March of 2019, when Wyatt was two-years-old and back in the hospital, Krueger’s husband and mother-in-law were in his room when a DCFS worker—and four armed police officers—arrived and ordered them out. They were not allowed back in. Wyatt was alone there for four days while DCFS arranged a foster placement, according to Krueger.

DCFS also came for Wyatt’s older brother, age 3. He had never been away from them before.

But that’s not all: Krueger was also pregnant with their third son at the time. DCFS took him away four hours after she gave birth, according to Krueger.

The family spent 467 days apart. It took an incredible amount of time and money to piece together the evidence that they were not guilty of abuse. In this, they were helped by the Family Justice Resource Center, an Illinois nonprofit founded by Michelle Weidner—a mom who had gone through a similar nightmare ten years earlier. The center helps “families facing wrongful allegations of abuse and neglect, with an emphasis on medically-based allegations,” according to its website.

“They were an answer to our prayers,” says Krueger.

With the help of FJRC, the Kruegers found an attorney in this field, and a well-respected pediatrician to review Wyatt’s files. This doctor found that Wyatt’s illness was not imagined or parent-induced. She also said that genetic testing showing Wyatt had Xia-Gibbs syndrome, a rare disease that causes airway issues. The CAP had shrugged off this possibility.

Meanwhile, Krueger, a recovering addict, underwent weekly drug tests, even though her OB-GYN wrote a letter saying she was fine. She also undertook a psychiatric evaluation administered by a state-approved psychologist (but paid for by the Kruegers), which found her to be of sound mind and not inclined to abuse a child. That was a turning point, she told the American Bar Association Center on Children and the Law:

After a year of being accused of having Munchausen by Proxy, after a year of being accused of being mentally ill, you start to ask yourself, am I as crazy as they think I am? The testing took three days and that was my biggest turning of relief, that I was not going to let these guys make me doubt myself.

During all this, Krueger and her husband were allowed to visit with their children every Tuesday and Thursday from 9:00 to 11:00 a.m., “with someone sitting with us,” says Krueger. “We weren’t even allowed to take them to the bathroom.” The Kruegers were also not allowed to call their kids.

The children screamed and cried just about every time they were put in the car to leave. When COVID-19 hit, they all met on Zoom—again, with a caseworker watching, according to Krueger.

What did it take to convince the state that this entire case had no merit? In the end, $60,000 in legal fees and expert testimony—money the Kruegers’ parents had been saving for retirement.

“And if it cost us this much, I can only imagine what it cost the state,” says Krueger.

On July 8, 2020, a family court judge read the evidence and vacated all orders. The children were finally allowed to come home.

Overwhelmed, Krueger turned right around and started volunteering at the Family Justice Resource Center. Over the past year she has helped reunite four families falsely accused of child abuse. She was honored last month as an FJRC “Family Reunification Hero.”

But the Kruegers did not emerge unscarred. They have mounted cameras throughout their home so that if one of their boys hurts himself, there would be proof it wasn’t child abuse. Understandably, the boys have terrible anxiety. If the kids aren’t warned that pizza is coming, hearing the doorbell sends them running to hide.

“Before this happened, we did not believe DCFS was capable of ripping families apart,” says Krueger. “We thought they helped people.” Her husband had been abandoned by his parents at age three; child services found him and his brother a loving foster home. The Kruegers still believe child services has important work to do, but the system clearly needs stronger guardrails.

The family is now pushing for the legislature to reform the state’s child protection laws, as Texas just did. In that state, if parents are accused of abuse based on a medical report, they can now request a second opinion from a specialist in the relevant field. In a case like the Kruegers’, that means the parents would be able to consult a respiratory doctor, and child services would have to submit this testimony before getting a court order to take a child into custody.

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Dean Of Howard University Under Fire For Defending Cosby

Dean Of Howard University Under Fire For Defending Cosby

Authored by Jonathan Turley,

We recently discussed the ruling of the Pennsylvania Supreme Court overturning the conviction of Bill Cosby. While the Court differed on what errors warranted such action, all of the justices agreed that the trial was fundamentally flawed. Indeed, it was a disgrace and Cosby could sue for malicious prosecution.  Yet, the incoming dean of Howard University’s fine arts college, Phylicia Rashad, is under attack for declaring her support for Cosby.

Rashad played Bill Cosby’s TV wife on “The Cosby Show.” 

Fortune reported that there are calls for her resignation.

Rashad tweeted “FINALLY!!!! A terrible wrong is being righted – a miscarriage of justice is corrected!”

Update: Rashad issued a profuse apology and deleted the tweet.

Some have questioned, according to CNBC, “how she might handle sexual assault allegations in her role as dean.”

However, many of us were critical of the trial and it was an injustice. That is why it was overturned by the Pennsylvania Supreme Court. That does not mean that Cosby is innocent. I do not believe he was innocent given his incriminating depositions. However, as I said in a prior posting, Bill Cosby is the ultimate example that you do not have to be entirely innocent to be wrongly convicted.

The prior prosecutor did not believe that he could convict Cosby on the evidence available. He instead promised not to prosecute to effectively force Cosby into giving four civil depositions. Even a guilty person can be the victim of a miscarriage of justice. Many believe Cosby is innocent. Many of us believe he is guilty. However, he was denied a fair trial and that made this a miscarriage of justice, as declared by the state Supreme Court.

Rashad responded to the calls for her resignation by insisting that she will fight for the survivors of sexual assault.

Her resignation would be a terrible mistake. I know little about Dean Rashad beyond her television career. However, a resignation would yield to the growing cancel culture on our campuses.  She has every right to express her support for Cosby and considerable justification in describing this trial as a miscarriage of justice.  She and I may disagree about the merits of these claims from 50 women, but higher education thrives on a diversity of such viewpoints.

Update: We are not sure this will help but Bill Cosby called on Howard University to support Rashad’s freedom of speech after she expressed support for him when his sexual assault conviction was overturned.

In a statement, Cosby also lashed out at the media, comparing journalists to the rioters who stormed the Capitol in January.

“Howard University you must support ones Freedom of Speech (Ms. Rashad), which is taught or suppose to be taught everyday at that renowned law school, which resides on your campus,” Cosby said in a statement provided to NPR by his spokesman Andrew Wyatt.

“This mainstream media has become the Insurrectionists, who stormed the Capitol,” Cosby continued in his statement.

“Those same Media Insurrectionists are trying to demolish the Constitution of these United State of America on this Independence Day.”

Cosby concluded by saying, “WE THE PEOPLE STAND IN SUPPORT OF MS. PHYLICIA RASHAD” in all caps.

Tyler Durden
Tue, 07/06/2021 – 11:50

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After a False Abuse Allegation, Child Services Took This Mom’s 3 Children Away


thumb2

Patti Krueger is a stay-at-home mom in Decatur, Illinois. Her husband is a house painter. The couple’s second son, Wyatt, was born in 2017 with severe breathing difficulties.

“He was blue,” says Krueger.

Wyatt spent nine days in neonatal intensive care. Over the next two years his breathing problems necessitated oxygen treatments, tubes in his ears, and four surgeries, according to Krueger.

Some of his treatments were at a nearby hospital in Peoria. Many hospitals today have a Child Abuse Pediatrician (CAP), a doctor on contract with child protective services. Their job is to be on the lookout for child abuse, including abuse other doctors may have missed. While the CAP at this hospital never met Krueger or worked directly with Wyatt, she reviewed his file and accused the mother of Munchausen syndrome by proxy—in other words, causing or faking a child’s illness to get attention.

This CAP’s report was all it took for Illinois’ Department of Child and Family Services to put into place a “safety plan” to remove the Kruegers’ kids. These plans do not require any kind of court order because ostensibly the family “agrees” to it, on pain of potentially having no say over what happens next to their kids. Thus, in March of 2019, when Wyatt was two-years-old and back in the hospital, Krueger’s husband and mother-in-law were in his room when a DCFS worker—and four armed police officers—arrived and ordered them out. They were not allowed back in. Wyatt was alone there for four days while DCFS arranged a foster placement, according to Krueger.

DCFS also came for Wyatt’s older brother, age 3. He had never been away from them before.

But that’s not all: Krueger was also pregnant with their third son at the time. DCFS took him away four hours after she gave birth, according to Krueger.

The family spent 467 days apart. It took an incredible amount of time and money to piece together the evidence that they were not guilty of abuse. In this, they were helped by the Family Justice Resource Center, an Illinois nonprofit founded by Michelle Weidner—a mom who had gone through a similar nightmare ten years earlier. The center helps “families facing wrongful allegations of abuse and neglect, with an emphasis on medically-based allegations,” according to its website.

“They were an answer to our prayers,” says Krueger.

With the help of FJRC, the Kruegers found an attorney in this field, and a well-respected pediatrician to review Wyatt’s files. This doctor found that Wyatt’s illness was not imagined or parent-induced. She also said that genetic testing showing Wyatt had Xia-Gibbs syndrome, a rare disease that causes airway issues. The CAP had shrugged off this possibility.

Meanwhile, Krueger, a recovering addict, underwent weekly drug tests, even though her OB-GYN wrote a letter saying she was fine. She also undertook a psychiatric evaluation administered by a state-approved psychologist (but paid for by the Kruegers), which found her to be of sound mind and not inclined to abuse a child. That was a turning point, she told the American Bar Association Center on Children and the Law:

After a year of being accused of having Munchausen by Proxy, after a year of being accused of being mentally ill, you start to ask yourself, am I as crazy as they think I am? The testing took three days and that was my biggest turning of relief, that I was not going to let these guys make me doubt myself.

During all this, Krueger and her husband were allowed to visit with their children every Tuesday and Thursday from 9:00 to 11:00 a.m., “with someone sitting with us,” says Krueger. “We weren’t even allowed to take them to the bathroom.” The Kruegers were also not allowed to call their kids.

The children screamed and cried just about every time they were put in the car to leave. When COVID-19 hit, they all met on Zoom—again, with a caseworker watching, according to Krueger.

What did it take to convince the state that this entire case had no merit? In the end, $60,000 in legal fees and expert testimony—money the Kruegers’ parents had been saving for retirement.

“And if it cost us this much, I can only imagine what it cost the state,” says Krueger.

On July 8, 2020, a family court judge read the evidence and vacated all orders. The children were finally allowed to come home.

Overwhelmed, Krueger turned right around and started volunteering at the Family Justice Resource Center. Over the past year she has helped reunite four families falsely accused of child abuse. She was honored last month as an FJRC “Family Reunification Hero.”

But the Kruegers did not emerge unscarred. They have mounted cameras throughout their home so that if one of their boys hurts himself, there would be proof it wasn’t child abuse. Understandably, the boys have terrible anxiety. If the kids aren’t warned that pizza is coming, hearing the doorbell sends them running to hide.

“Before this happened, we did not believe DCFS was capable of ripping families apart,” says Krueger. “We thought they helped people.” Her husband had been abandoned by his parents at age three; child services found him and his brother a loving foster home. The Kruegers still believe child services has important work to do, but the system clearly needs stronger guardrails.

The family is now pushing for the legislature to reform the state’s child protection laws, as Texas just did. In that state, if parents are accused of abuse based on a medical report, they can now request a second opinion from a specialist in the relevant field. In a case like the Kruegers’, that means the parents would be able to consult a respiratory doctor, and child services would have to submit this testimony before getting a court order to take a child into custody.

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Looters Ransack Bagram Airbase After US Sneaks Out In Middle Of Night

Looters Ransack Bagram Airbase After US Sneaks Out In Middle Of Night

The United States has wound down its ‘forever war’ in Afghanistan by essentially sneaking off from its largest base there in the middle of the night, reportedly without so much as informing the local Afghan commander. 

The somewhat shocking method of departure which immediately left Bagram a “ghost base” – as some are already calling it – was bluntly described by Associated Press as follows: “The U.S. left Afghanistan’s Bagram Airfield after nearly 20 years by shutting off the electricity and slipping away in the night without notifying the base’s new Afghan commander, who discovered the Americans’ departure more than two hours after they left, Afghan military officials said.”

What’s more is that it caught local Afghan forces so off guard that looting immediately resulted the moment the unsecured base was left devoid of Americans. 

The Afghan commander for the area had only initially heard “rumors” of an impending US exit from the airfield, but then soon realized it was already an accomplished fact.

And then the following almost unbelievable scene played out, capping off America’s longest running war in history: 

Before the Afghan army could take control, the airfield, barely an hour’s drive from the Afghan capital Kabul, was invaded by a small army of looters, who ransacked barrack after barrack and rummaged through giant storage tents before being evicted, according to Afghan military officials.

“At first we thought maybe they were Taliban,” said Abdul Raouf, a soldier of 10 years. He said the the U.S. called from the Kabul airport and said “we are here at the airport in Kabul.”

Bagram Air Base in Afghanistan, via AP

It happened days ago but is only just now coming to light, with one Afghan soldier cited by AP as saying, “In one night, they lost all the goodwill of 20 years by leaving the way they did.” More details now emerging are as follows:

The sudden darkness was like a signal to the looters, he said. They entered from the north, smashing through the first barrier, ransacking buildings, loading anything that was not nailed down into trucks.

On Monday, three days after the US departure, Afghan soldiers were still collecting piles of rubbish that included empty water bottles, cans and empty energy drinks left behind by the looters.

Abandoned vehicles left by the Americans:

Via EPA

Despite growing Taliban momentum nationwide amid a serious escalation in attacks on national forces, the Afghan government believes it can hold the sprawling and heavily fortified airbase, which is also home to a prison which holds mostly Taliban-linked inmates. 

The abrupt and under cover of night US departure has reportedly sparked widespread anger among Afghan security forces.

Afghan soldier at abandoned Bagram base, via AFP

Should the Taliban soon threaten Kabul, believed by many analysts to be a likelihood if not near certainty, the group will probably eye overrunning Bagram first to be used as a strategic launching point toward the Afghan capital.

Tyler Durden
Tue, 07/06/2021 – 11:30

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