Thursday, June 28, 2007
Race Issues
Today the Supreme Court ruled that using race as a basis for school placement is unconstitutional. On the radio here in Seattle, many people were complaining that this new ruling is going to limit 'diversity' and create problems. I am not racist, far from it. I have tried hard to take to heart the words of Dr. Martin Luther King Jr. and judge people not by the color of their skin but by the content of their character. Throughout the history of the world, there have been race issues, humans tend to favor like humans, right or wrong, it happens. The US today has what are likely the best relations between races that the world has ever known, but when people like me who are trying (quite successfully) to look beyond race are being called 'racists' by the minority communities it is a little offensive. What more can I do? Diversity can be good, it can also be bad, but when lawmakers arbitrarily force it on us, it keeps the race wound wide open. We are at a legal point where you cannot discriminate on the basis of race, and I think that is a good thing. But to go any further we have to cross a line where we begin to legislate how people think, and that is a line that we must not cross, because if we do, it will bring resentment and hostility from both sides of the issue and, quite likely, take us back to many of the problems that we had in the 1950's and 60's. It is time to stop legislating, and lets just live for a while being grateful that we are doing better on race issues than any other culture in the history of the world. I think the Supreme Court ruled wisely. Race issues will only stop when we stop making race an issue.
Tuesday, June 26, 2007
The Right to Keep and Bear Arms
The Constitutional Basis For the Individual Right to Bear Arms
Few issues today hold as much passion and conviction as the gun-control debate. In the wake of high-profile tragedies like Columbine and Virginia Tech, the question of why Americans are allowed to own firearms is often asked. The answer to that question is in the second amendment to the Constitution of the United States. Although the Founding Fathers left some ambiguity in the text of the Second Amendment, they also left a clear dialog defining the intent with which they wrote it as well as the reasons that necessitated its existence. Those reason are still, in many respects, valid today. The writings of the Founding Fathers indicate that the individual right to keep and bear arms guaranteed by the Second Amendment was essential for national defense, freedom from tyranny, and self-preservation.
“A well regulated Militia, being necessary for the security of a free state, the right of the people to keep and bear arms shall not be infringed,” reads the language of the amendment. As the Founding Fathers debated and contemplated which rights were to have constitutional guarantee, the right to keep and bear arms is among the first listed. It precedes Habeas Corpus, protection from unreasonable search and seizure, and restrictions on the use of excessive punishment, among others. Despite the fierce and persistent debate regarding its meaning, it is clear that the Founding Fathers intended the Second Amendment as a fundamental individual right.
The first portion of this Amendment states the requirement for a “well regulated Militia.” This phrase seems to cause most of the disparity regarding how the “right to keep and bear arms” is interpreted. Those who oppose armed citizens view the Militia as a state entity, and the “right to keep and bear arms” as a collective, not an individual right. Conversely, those who support armed citizens believe the Militia is made up of private citizens, thereby making the “right to keep and bear arms” an individual right. Law professor Nelson Lund describes these differing viewpoints:
The debate over the original meaning of the Second Amendment has largely focused on the implications of the phrase “a well regulated Militia, being necessary to the security of a free state, . . .” One group of commentators treats the phrase simply as a statement of purpose and maintains that the Second Amendment provides individuals the right to keep and bear arms. Another group maintains that the Second Amendment creates an exclusively collective right—the right of the states to maintain organized military forces (Lund 2).
In a broad sense, it is mostly academics and lawyers who favor the collective right interpretation, while most average citizens favor the individual right interpretation (Lund 2). Even though it is mostly academics and lawyers who are in favor of a collective right, “The popularity of the ‘collective right’ interpretation should be surprising, since it is virtually baseless” (Lund 2).
In order to establish the basis for these two viewpoints, we draw our attention to Article I, section 8 of the Constitution, an Article often cited by those who favor a collective right to bear arms, which reads that Congress has the power:
To provide for calling forth the Militia to execute the Laws of the Union, suppress insurrections and repel invasions;
To provide for organizing, arming, and disciplining, the Militia, and for governing such Part of them as may be employed to the Service of the United States, reserving to the States respectively, the Appointment of the Officers, and the Authority of training the Militia according to the discipline prescribed by Congress.
When the Second Amendment is read with this portion of Article I, one could argue that the Militia spoken of is, in fact, the National Guard, and the Second Amendment protects the states right to maintain such. If one looked no further into the intent of the Founding Fathers, this would seem a strong and logical argument.
The National Guard, as we know it today, is an army, sworn to their respective state, and offered, upon request of Congress, to serve in the common defense. This is consistent with Section 8 of Article I, but the structure and organization the Guard has today did not exist at the time the Bill of Rights was drafted. Rather, it came shortly after the turn of the twentieth century. To understand what the Second Amendment was written to protect, it is not expedient to use the modern definition of a Militia, but the Founding Father’s.
Thomas Jefferson said, “Every able-bodied freeman, between the ages of 16 and 50, is enrolled in the Militia” (216). Describing further the conditions by which this Militia operated he said, “The law requires every Militia-man to provide himself with the arms usual in the regular service” (216). Jefferson’s statement indicates that at the time the Second Amendment was written, the Militia was made up of common citizens who provided their own arms. The Founder’s had been exposed to this type of Militia before.
During the French and Indian War (where many of the Founding Fathers received their military training), when the French, or native tribes loyal to them, would attack a particular settlement, the regular British Army would repel the attack with the assistance of the men who lived in that area. These men brought their own arms and fought under the command of the regular army to defend the settlement. At battle’s end, the men would return to their farms, having shared the burden of defense.
In light of this British template, Article I Section 8 of the Constitution provides Congress with the power to call out the citizens to the common defense, and makes no reference to what we now call the National Guard. To answer any question of how this Militia was to be “well regulated,” we turn to George Washington, who in a speech to Congress on January 8, 1790 said:
To be prepared for war is one of the most effectual means of preserving peace. A free people ought not only to be armed, but disciplined; to which end a uniform and well-digested plan is requisite; and their safety and interest require, that they should promote such manufactories as tend to render them independent on others for essential, particularly for military, supplies (qtd. in Benson 174).
Article I section 8 describes this plan, which is, when the need arises, Congress calls on the citizens to gather up their arms and fight to uphold peace. The Founding Fathers held that the responsibility of national defense fell to the nation’s citizens and consequently those citizens ought to be armed, trained, disciplined, and organized.
Regarding national defense, the writings of the Founding Fathers isolate two threats from which the nation needs defense. The first of these is defense from foreign invasion and the second is defense against tyranny. In an address to Congress on December 8, 1801, illustrating the use of private citizens in the common defense, Thomas Jefferson said:
Uncertain as we must ever be of the particular point in our circumference where an enemy may choose to invade us, the only force which can be ready at every point and competent to oppose them, is the body of neighboring citizens as formed into a Militia. On these, collected from the parts most convenient, in numbers proportional to the invading foe, it is best to rely, not only to meet the first attack, but if it threatens to be permanent, to maintain the defense until regulars may be engaged to relieve them (505).
Jefferson again emphasizes that an armed citizenry constitute the Militia, and that this Militia is the first line of defense against foreign invasion. Illustrating the second threat, defense from tyranny, James Madison, in the Federalist Papers, number XLVI, states:
Besides the advantages of being armed, which the Americans possess over the people of almost every other nation, the existence of subordinate governments, to which the people are attached and by which the militia officers are appointed, forms a barrier against the enterprises of ambition, more insurmountable than any which a simple government of any form can admit of (301).
The words of both Jefferson and Madison illustrate the sentiment forged during the Revolutionary War. During that war, it was the Militias, made up of armed citizens, which successfully defeated the British army (the most powerful in the world). The efficacy of the Militia in overthrowing British tyranny influenced the Founding Fathers to protect the right of the citizens to keep and bear arms from regulation, as any regulation would pose a risk to the freedom and security of the nation and every citizen therein.
Self-defense is not expressly listed in the writings of the Founders as a reason for protecting the right to keep and bear arms; Professor Lund explained that the Founding Fathers did not readily separate self-defense and national defense. This is likely because in the rural conditions that then existed in this country, the idea of limiting individual right to self-defense was unheard of. The Founding Fathers viewed the right to self-defense as more basic than freedom of speech, press, or jury trial, leaving no question that the Second Amendment was also drafted to insure the right to self-defense (Lund 6).
Viewing the Second Amendment in this historical light, the question next turns to what implications a constitutional guarantee for the right to keep and bear arms has today. Some might argue that this right is outdated. There are thousands of firearm related deaths each year and in the wake of tragedies like Columbine and Virginia Tech, do we really need or want an armed populace? The answer, again, is yes. The two stated and one implied reason for the Founding Father’s drafting the Second Amendment are still very valid today, perhaps more valid than they have ever been.
Our regular military forces have historically done a fine job of defending our boarders from foreign attack. However, the nature of war has changed, and what used to be large armies fighting off large armies, is now guerilla warfare and terrorism. While battlefields were once in rural Virginia, the islands of the pacific or the fields of Europe, today’s battles are fought in airplanes over Pennsylvania, the halls of a High School or the college classroom. These battles come without warning, and without the presence of the military or law enforcement, but the citizens are always present for these battles. When the citizens are armed, well trained, and disciplined, they make up the first, and often only, line of defense, refusing to be victims.
Protection from tyranny is the second purpose the Founding Fathers adopted the Second Amendment. James Madison said, “Notwithstanding the military establishments in the several kingdoms of Europe, which are carried as far as the public resources will bear, the governments are afraid to trust the people with arms” (301). His argument concluded with the idea that any government which fears its people with arms, is fast becoming tyrannical (301). Speaking further on our responsibility to recognize and defend against tyranny, Ezra Taft Benson, Former Secretary of Agriculture, said, “The current trend strikes a potentially fatal blow at the concept of the divine origin of our rights, and unlocks the door for an easy entry of future tyranny” (129). History has given many examples of how this trend of complacency toward our rights to bear arms can open the door to tyranny. Here I cite three. First, Hitler disarmed the Jews so that they could not fight back as he began the Holocaust. Second, Fidel Castro disarmed the Cuban people after their revolution, thus allowing his dictatorship to continue. Third, and more recently, Hugo Chavez has turned a disarmed democracy into a Socialist dictatorship in a matter of months. No government can abolish the rights of armed citizens, and disarmed citizens cannot stop a government from taking rights.
The final, implied reason for the right to keep and bear arms is for personal defense. According to the Brady Campaign to Prevent Gun Violence website, there are about 11,000 firearm-related deaths in the United States each year. This number includes all forms of firearm related death, homicide, suicide, accidental and unknown. This is a significant number of people, and the cost of the right to bear arms is called into question. When, however, the whole picture is viewed, the number is less dismal. There are approximately 200 million firearms legally owned by 70 million people in the United States (Schulman 48). Looking at the number of firearm related deaths compared to the number of firearms, the ratio is very low. Supporting this idea, Gary Kleck and Marc Gertz, Criminologists at Florida State University, conducted a study that found that firearms are used between 640,000 and 1.2 million times per year to prevent violent crime (Shulman 38). Firearms are used for self-defense and crime prevention at least 58 times more often than they are used to kill innocent people. We have seen the painful results of both the Columbine and Virginia Tech ‘gun-free zones,’ but we have also seen the how similar tragedies have been averted. An editorial printed in the Investor’s Business Daily reminds us of another school shooting in Virginia:
On Jan. 16, 2002 , a killer stalked the campus of the Appalachian School of Law in Grundy, Va., not far from the site of Monday's massacre at Virginia Tech in Blacksburg. A disgruntled former student killed Law Dean L. Anthony Sutin, associate professor Thomas Blackwell and a student.
Two of the three law students who overpowered Peter Odighizuwa before he could kill more innocent victims were armed. Mikael Gross and Tracy Bridges, seeing the killing spree begin, went to their cars, retrieved their guns and used them to disarm the shooter.
Ordinary people, when armed, have shown the consistent ability to stop crimes and save lives. Because of this power to stop violence and defend freedom, the constitutional right to keep and bear arms is essential to insuring the security of this nation.
As the debate over armed citizens continues, and we as a nation reflect on the tragedies we face in our times, it becomes expedient to remember that the Constitution of the United States guarantees the right of every law-abiding citizen to keep and bear arms to defend the nation, ourselves, and prevent tyranny. The Second Amendment is not outdated and dangerous, but rather a valid and essential protection for our freedom and the safety and security of every American.
References:
Madison, James, Alexander Hamilton, and John Jay. The Federalist Papers. London: Putnam, 1987.
Peterson, Merrill D. ed. Thomas Jefferson: Writings. New York: Literary Classics of the United States, 1984
Benson, Ezra Taft. An Enemy Hath Done This. Salt Lake City: Parliament, 1969.
Lund, Nelson. “The Second Amendment, Political Liberty, and the Right to Self-Preservation.” Alabama Law Review 39 (1987): 103-130.
Schulman, J. Neil. Stopping Power: Why 70 Million Americans Own Guns. Santa Monica: Synapse-Centurion, 1994.
Brady Campaign to Prevent Gun Violence. Home Page. 29 Apr. 2007.
“Unarmed and Dangerous.” Investor’s Business Daily. 19 Apr. 2007. 04 May 2007.
The Constitution of the United States.
The Second Amendment to the Constitution in the Bill of Rights.
Few issues today hold as much passion and conviction as the gun-control debate. In the wake of high-profile tragedies like Columbine and Virginia Tech, the question of why Americans are allowed to own firearms is often asked. The answer to that question is in the second amendment to the Constitution of the United States. Although the Founding Fathers left some ambiguity in the text of the Second Amendment, they also left a clear dialog defining the intent with which they wrote it as well as the reasons that necessitated its existence. Those reason are still, in many respects, valid today. The writings of the Founding Fathers indicate that the individual right to keep and bear arms guaranteed by the Second Amendment was essential for national defense, freedom from tyranny, and self-preservation.
“A well regulated Militia, being necessary for the security of a free state, the right of the people to keep and bear arms shall not be infringed,” reads the language of the amendment. As the Founding Fathers debated and contemplated which rights were to have constitutional guarantee, the right to keep and bear arms is among the first listed. It precedes Habeas Corpus, protection from unreasonable search and seizure, and restrictions on the use of excessive punishment, among others. Despite the fierce and persistent debate regarding its meaning, it is clear that the Founding Fathers intended the Second Amendment as a fundamental individual right.
The first portion of this Amendment states the requirement for a “well regulated Militia.” This phrase seems to cause most of the disparity regarding how the “right to keep and bear arms” is interpreted. Those who oppose armed citizens view the Militia as a state entity, and the “right to keep and bear arms” as a collective, not an individual right. Conversely, those who support armed citizens believe the Militia is made up of private citizens, thereby making the “right to keep and bear arms” an individual right. Law professor Nelson Lund describes these differing viewpoints:
The debate over the original meaning of the Second Amendment has largely focused on the implications of the phrase “a well regulated Militia, being necessary to the security of a free state, . . .” One group of commentators treats the phrase simply as a statement of purpose and maintains that the Second Amendment provides individuals the right to keep and bear arms. Another group maintains that the Second Amendment creates an exclusively collective right—the right of the states to maintain organized military forces (Lund 2).
In a broad sense, it is mostly academics and lawyers who favor the collective right interpretation, while most average citizens favor the individual right interpretation (Lund 2). Even though it is mostly academics and lawyers who are in favor of a collective right, “The popularity of the ‘collective right’ interpretation should be surprising, since it is virtually baseless” (Lund 2).
In order to establish the basis for these two viewpoints, we draw our attention to Article I, section 8 of the Constitution, an Article often cited by those who favor a collective right to bear arms, which reads that Congress has the power:
To provide for calling forth the Militia to execute the Laws of the Union, suppress insurrections and repel invasions;
To provide for organizing, arming, and disciplining, the Militia, and for governing such Part of them as may be employed to the Service of the United States, reserving to the States respectively, the Appointment of the Officers, and the Authority of training the Militia according to the discipline prescribed by Congress.
When the Second Amendment is read with this portion of Article I, one could argue that the Militia spoken of is, in fact, the National Guard, and the Second Amendment protects the states right to maintain such. If one looked no further into the intent of the Founding Fathers, this would seem a strong and logical argument.
The National Guard, as we know it today, is an army, sworn to their respective state, and offered, upon request of Congress, to serve in the common defense. This is consistent with Section 8 of Article I, but the structure and organization the Guard has today did not exist at the time the Bill of Rights was drafted. Rather, it came shortly after the turn of the twentieth century. To understand what the Second Amendment was written to protect, it is not expedient to use the modern definition of a Militia, but the Founding Father’s.
Thomas Jefferson said, “Every able-bodied freeman, between the ages of 16 and 50, is enrolled in the Militia” (216). Describing further the conditions by which this Militia operated he said, “The law requires every Militia-man to provide himself with the arms usual in the regular service” (216). Jefferson’s statement indicates that at the time the Second Amendment was written, the Militia was made up of common citizens who provided their own arms. The Founder’s had been exposed to this type of Militia before.
During the French and Indian War (where many of the Founding Fathers received their military training), when the French, or native tribes loyal to them, would attack a particular settlement, the regular British Army would repel the attack with the assistance of the men who lived in that area. These men brought their own arms and fought under the command of the regular army to defend the settlement. At battle’s end, the men would return to their farms, having shared the burden of defense.
In light of this British template, Article I Section 8 of the Constitution provides Congress with the power to call out the citizens to the common defense, and makes no reference to what we now call the National Guard. To answer any question of how this Militia was to be “well regulated,” we turn to George Washington, who in a speech to Congress on January 8, 1790 said:
To be prepared for war is one of the most effectual means of preserving peace. A free people ought not only to be armed, but disciplined; to which end a uniform and well-digested plan is requisite; and their safety and interest require, that they should promote such manufactories as tend to render them independent on others for essential, particularly for military, supplies (qtd. in Benson 174).
Article I section 8 describes this plan, which is, when the need arises, Congress calls on the citizens to gather up their arms and fight to uphold peace. The Founding Fathers held that the responsibility of national defense fell to the nation’s citizens and consequently those citizens ought to be armed, trained, disciplined, and organized.
Regarding national defense, the writings of the Founding Fathers isolate two threats from which the nation needs defense. The first of these is defense from foreign invasion and the second is defense against tyranny. In an address to Congress on December 8, 1801, illustrating the use of private citizens in the common defense, Thomas Jefferson said:
Uncertain as we must ever be of the particular point in our circumference where an enemy may choose to invade us, the only force which can be ready at every point and competent to oppose them, is the body of neighboring citizens as formed into a Militia. On these, collected from the parts most convenient, in numbers proportional to the invading foe, it is best to rely, not only to meet the first attack, but if it threatens to be permanent, to maintain the defense until regulars may be engaged to relieve them (505).
Jefferson again emphasizes that an armed citizenry constitute the Militia, and that this Militia is the first line of defense against foreign invasion. Illustrating the second threat, defense from tyranny, James Madison, in the Federalist Papers, number XLVI, states:
Besides the advantages of being armed, which the Americans possess over the people of almost every other nation, the existence of subordinate governments, to which the people are attached and by which the militia officers are appointed, forms a barrier against the enterprises of ambition, more insurmountable than any which a simple government of any form can admit of (301).
The words of both Jefferson and Madison illustrate the sentiment forged during the Revolutionary War. During that war, it was the Militias, made up of armed citizens, which successfully defeated the British army (the most powerful in the world). The efficacy of the Militia in overthrowing British tyranny influenced the Founding Fathers to protect the right of the citizens to keep and bear arms from regulation, as any regulation would pose a risk to the freedom and security of the nation and every citizen therein.
Self-defense is not expressly listed in the writings of the Founders as a reason for protecting the right to keep and bear arms; Professor Lund explained that the Founding Fathers did not readily separate self-defense and national defense. This is likely because in the rural conditions that then existed in this country, the idea of limiting individual right to self-defense was unheard of. The Founding Fathers viewed the right to self-defense as more basic than freedom of speech, press, or jury trial, leaving no question that the Second Amendment was also drafted to insure the right to self-defense (Lund 6).
Viewing the Second Amendment in this historical light, the question next turns to what implications a constitutional guarantee for the right to keep and bear arms has today. Some might argue that this right is outdated. There are thousands of firearm related deaths each year and in the wake of tragedies like Columbine and Virginia Tech, do we really need or want an armed populace? The answer, again, is yes. The two stated and one implied reason for the Founding Father’s drafting the Second Amendment are still very valid today, perhaps more valid than they have ever been.
Our regular military forces have historically done a fine job of defending our boarders from foreign attack. However, the nature of war has changed, and what used to be large armies fighting off large armies, is now guerilla warfare and terrorism. While battlefields were once in rural Virginia, the islands of the pacific or the fields of Europe, today’s battles are fought in airplanes over Pennsylvania, the halls of a High School or the college classroom. These battles come without warning, and without the presence of the military or law enforcement, but the citizens are always present for these battles. When the citizens are armed, well trained, and disciplined, they make up the first, and often only, line of defense, refusing to be victims.
Protection from tyranny is the second purpose the Founding Fathers adopted the Second Amendment. James Madison said, “Notwithstanding the military establishments in the several kingdoms of Europe, which are carried as far as the public resources will bear, the governments are afraid to trust the people with arms” (301). His argument concluded with the idea that any government which fears its people with arms, is fast becoming tyrannical (301). Speaking further on our responsibility to recognize and defend against tyranny, Ezra Taft Benson, Former Secretary of Agriculture, said, “The current trend strikes a potentially fatal blow at the concept of the divine origin of our rights, and unlocks the door for an easy entry of future tyranny” (129). History has given many examples of how this trend of complacency toward our rights to bear arms can open the door to tyranny. Here I cite three. First, Hitler disarmed the Jews so that they could not fight back as he began the Holocaust. Second, Fidel Castro disarmed the Cuban people after their revolution, thus allowing his dictatorship to continue. Third, and more recently, Hugo Chavez has turned a disarmed democracy into a Socialist dictatorship in a matter of months. No government can abolish the rights of armed citizens, and disarmed citizens cannot stop a government from taking rights.
The final, implied reason for the right to keep and bear arms is for personal defense. According to the Brady Campaign to Prevent Gun Violence website, there are about 11,000 firearm-related deaths in the United States each year. This number includes all forms of firearm related death, homicide, suicide, accidental and unknown. This is a significant number of people, and the cost of the right to bear arms is called into question. When, however, the whole picture is viewed, the number is less dismal. There are approximately 200 million firearms legally owned by 70 million people in the United States (Schulman 48). Looking at the number of firearm related deaths compared to the number of firearms, the ratio is very low. Supporting this idea, Gary Kleck and Marc Gertz, Criminologists at Florida State University, conducted a study that found that firearms are used between 640,000 and 1.2 million times per year to prevent violent crime (Shulman 38). Firearms are used for self-defense and crime prevention at least 58 times more often than they are used to kill innocent people. We have seen the painful results of both the Columbine and Virginia Tech ‘gun-free zones,’ but we have also seen the how similar tragedies have been averted. An editorial printed in the Investor’s Business Daily reminds us of another school shooting in Virginia:
On Jan. 16, 2002 , a killer stalked the campus of the Appalachian School of Law in Grundy, Va., not far from the site of Monday's massacre at Virginia Tech in Blacksburg. A disgruntled former student killed Law Dean L. Anthony Sutin, associate professor Thomas Blackwell and a student.
Two of the three law students who overpowered Peter Odighizuwa before he could kill more innocent victims were armed. Mikael Gross and Tracy Bridges, seeing the killing spree begin, went to their cars, retrieved their guns and used them to disarm the shooter.
Ordinary people, when armed, have shown the consistent ability to stop crimes and save lives. Because of this power to stop violence and defend freedom, the constitutional right to keep and bear arms is essential to insuring the security of this nation.
As the debate over armed citizens continues, and we as a nation reflect on the tragedies we face in our times, it becomes expedient to remember that the Constitution of the United States guarantees the right of every law-abiding citizen to keep and bear arms to defend the nation, ourselves, and prevent tyranny. The Second Amendment is not outdated and dangerous, but rather a valid and essential protection for our freedom and the safety and security of every American.
References:
Madison, James, Alexander Hamilton, and John Jay. The Federalist Papers. London: Putnam, 1987.
Peterson, Merrill D. ed. Thomas Jefferson: Writings. New York: Literary Classics of the United States, 1984
Benson, Ezra Taft. An Enemy Hath Done This. Salt Lake City: Parliament, 1969.
Lund, Nelson. “The Second Amendment, Political Liberty, and the Right to Self-Preservation.” Alabama Law Review 39 (1987): 103-130.
Schulman, J. Neil. Stopping Power: Why 70 Million Americans Own Guns. Santa Monica: Synapse-Centurion, 1994.
Brady Campaign to Prevent Gun Violence. Home Page. 29 Apr. 2007.
“Unarmed and Dangerous.” Investor’s Business Daily. 19 Apr. 2007. 04 May 2007.
The Constitution of the United States.
The Second Amendment to the Constitution in the Bill of Rights.
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