Transforming the Workplace: The Fair Labor Standards Act

On October 24, 1940, the Fair Labor Standards Act, passed two years earlier, went into effect in the United States. A sweeping reform bill that included provision for a federal minimum wage, weekly limits on working hours, and heavy restrictions on child labor, the act changed the labor market, setting the standards that we abide by now. There has been a call in the last few years for labor reform to adjust the workplace to the world we live in now. So, how did they make it happen in 1938?

A change in labor standards was an election promise by President Franklin D. Roosevelt. Roosevelt began his first term under the shadow of the Great Depression. He signed the National Industrial Recovery Act, hoping to raise wages and create jobs. There were provisions for a shorter work week, a $12 per week minimum wage, and child labor restrictions. Unfortunately, most parts of the bill, including restrictions on child labor, were struck down as unconstitutional by the Republican-dominated Supreme Court at the time. This sentiment trickled down through the circuit courts as well. One judge said, “the so-called Child Labor Amendment . . . will result in the filing, by the coming generations, of the reformatory institutions and prisons beyond their capacity. The failure of parents to teach and compel children to perform reasonable and proper labor while yet young is the prime cause of the wave of crime in this country.”

In 1936, Roosevelt campaigned on labor reform as the basis for his second term. He won the election 523 electoral votes to 8. He felt that this proved the country’s commitment to labor reform. To encourage change, Roosevelt suggested that he might add seats to the Supreme Court to be sure the three branches of legislature were on the same page. Shortly after, conservative Justice Owen Roberts sided with the liberal judges in a case regarding minimum wage. This opened the gate to more legislation moving through the House and Senate regarding minimum wage, child labor, and weekly hour ceilings. Frances Perkins, Roosevelt’s Labor Secretary and the first female member of the cabinet, worked tirelessly to put together labor reform packages that would accomplish what they wanted while still appealing to the Republican members of Congress. What finally convinced Republicans to move the bill through were two Senate seats in Republican strongholds that were lost to pro-labor reform candidates. At this point, many Republican congress members seemed ready to make a deal. The bill that finally made it through in 1938—the Fair Labor Standards Act—provided for a 40-cent-per-hour minimum wage, a 40-hour work week, and a restriction on hiring children under the age of 16.

Learn more here:

  1. https://www.dol.gov/agencies/whd/compliance-assistance/handy-reference-guide-flsa
  2. https://guides.loc.gov/this-month-in-business-history/june/fair-labor-standards-act-signed
  3. https://www.dol.gov/general/aboutdol/history/flsa1938
  4. https://timesmachine.nytimes.com/timesmachine/1939/01/01/96210540.html?pageNumber=7
  5. https://www.washingtonpost.com/history/2021/09/06/40-hour-work-week-fdr/

Return of the King: The Book of the Millennium

On October 20, 1955, the third volume of The Lord of the Rings, entitled Return of the King, was published. Following the publication of the first two volumes, Fellowship of the Ring and The Two Towers, during the previous year, the third book was very popular. However, the series did not explode in notoriety until the 1960s when young adults latched onto the fantastical world and heroic adventures of J.R.R. Tolkien’s Middle Earth. The Lord of the Rings is the best-selling fantasy series of all time. It has even been considered by many as “the book of the millennium.”

J.R.R. Tolkien penned the famous The Lord of the Rings series while working as a professor at Oxford University. In 1937, Tolkien had released his first novel, The Hobbit, as a children’s story. It was incredibly popular, and his publishers looked to him for a sequel. Thus, was The Lord of the Rings born. The 1,100-page book was meant to be one story but was released in three volumes for logistical and financial reasons. Famous poet, W.H. Auden wrote of the series, “If one is to take a tale of this kind seriously, one must feel that, however superficially unlike the world we live in its characters and events may be, it nevertheless holds up the mirror to the only nature we know, our own; in this, too, Mr. Tolkien has succeeded superbly, and what happened in the year of the Shire 1418 in the Third Age of Middle Earth is not only fascinating in A.D. 1954 but also a warning and an inspiration. No fiction I have read in the last five years has given me more joy . . .”

The Lord of the Rings was the first fantasy book of its kind. It included detailed maps, original languages, unique creatures, and alternate history. This is, perhaps, why the books took off as they did. Readers could immerse themselves in a different world, even learning some of Tolkien’s made-up languages. This type of fantasy world has since become very popular, many modern fantasy novels include maps and family trees. The Chairman of the Tolkien Society said, in 2015, that Tolkien created “the archetypal fantasy story with Gandalf, Gollum, hobbits, the Ring now being all-pervasive in popular culture—it’s no wonder that so many authors have followed in his wake.”

Learn more here:

  1. https://www.biography.com/authors-writers/jrr-tolkien
  2. https://www.tolkiensociety.org/2015/10/60th-anniversary-of-the-return-of-the-king/#:~:text=The%20Return%20of%20the%20King%20was%20published%20on%20the%2020,on%2011th%20November%201954.
  3. https://www.tolkienestate.com/writing/the-lord-of-the-rings/
  4. https://timesmachine.nytimes.com/timesmachine/1954/10/31/96504978.html?pageNumber=163

The Conviction of Scarface

On October 17, 1931, Alphonse Capone, legendary mob boss of the Chicago area, was convicted of five counts of federal tax evasion. Capone was a career gangster who, according to the New York Times, went from “the lowly position of a $75-a-week punk for Johnny Torrio, head of Chicago’s gangsterdom and master panderer, to undisputed control of all the illegal sources of revenue in the city and its suburbs.” This career involved violation of prohibition laws, murder, prostitution rings, bribery, and trafficking of narcotics. In the end, Capone was sentenced to 11 years in federal prison.

Al Capone was born in Brooklyn, New York to Italian immigrants. At the age of 14, Capone left school and joined the South Brooklyn Rippers, a teen gang. By 16, he was a member of the Five Points Gang and fell under the tutelage of legendary mob boss, Johnny Torrio. It was around this time while working at a mob-run brothel, Capone got into an altercation with another man and ended up with a knife wound across his cheek. This is what gave him his infamous nickname: Scarface.

In 1919, following a series of violent events, Capone and his family escaped to Chicago where Torrio was working in the Colosimo mob, which ran brothels around the city. The following year, Prohibition was passed, and a new business opportunity opened itself up to the mob. When Colosimo refused to participate in bootlegging, Torrio had him killed. Torrio and Capone teamed up to create the Chicago Outfit, running an incredibly profitable bootlegging business. After Torrio’s retirement, Capone found himself in charge. He expanded the Outfit’s prostitution, bootlegging, and gambling businesses, and through massive bloodshed, expanded the gang’s territory. Throughout it all, Capone avoided jail by paying off city officials and intimidating witnesses.

Capone’s notoriety peaked after the St. Valentine’s Day Massacre, in which seven members of a rival gang were brutally shot outside a Lincoln Park garage. It was around this time that the FBI started investigating Capone. The IRS eventually found evidence that Capone had not paid his federal income taxes for the years between 1924 and 1929. In 1931, he was convicted and sentenced to 11 years in federal prison and fined $50,000. Capone served two years in Atlanta, but when it became clear that he was still able to run the Outfit from prison, he was moved to Alcatraz in 1934. Capone was released in 1939 with dementia, a symptom of his advanced syphilis. He died in Florida in 1947 at the age of 48. Upon the occasion of his death, the New York Times wrote, “Though ‘Scarface Al,’ once Public Enemy No. 1, died in bed in the midst of luxury, his career ended in mental and physical horror. Among the funeral wreaths his old gangster associates will doubtless shower on his bier there should be at least one inscribed, ‘The wages of sin is death.’”

Learn more here:

  1. https://prohibition.themobmuseum.org/the-history/the-rise-of-organized-crime/the-mob-during-prohibition/
  2. https://www.history.com/this-day-in-history/capone-goes-to-prison
  3. https://www.pbs.org/wgbh/americanexperience/features/miami-al-capone/
  4. https://themobmuseum.org/blog/capone-tax-evasion-trial-jury-finds-chicago-mobster-guilty-on-5-of-22-counts/
  5. https://www.britannica.com/biography/Al-Capone
  6. https://timesmachine.nytimes.com/timesmachine/1947/01/27/99268149.html?pageNumber=20
  7. https://archive.nytimes.com/www.nytimes.com/learning/general/onthisday/big/1017.html

1600 Pennsylvania Avenue

On October 13, 1792, George Washington laid the cornerstone for the building that would become the White House. Washington chose the location of the building on Pennsylvania Avenue in Washington D.C. but opened up the design of the house itself to submissions. Architect James Hoban’s design for a Georgian-style mansion was chosen in 1792, and construction started that year. In two centuries since, the White House has been burned down, rebuilt, and renovated. It has seen 44 presidents and their families move in and out and has been the site of countless historic moments and decisions.

Though George Washington was the president to begin building the White House, he never got the chance to live in it. It took eight years for the building to be built by enslaved people and Scottish stonemasons. James Madison and his wife were the first to move into the building in 1800. In 1814, as part of the War of 1812, British troops set fire to the White House. It took three years to rebuild and be ready for residency again. The next extensive renovation came in 1902 under the direction of President Theodore Roosevelt. He converted the second-floor offices into bedrooms for his six children and began construction on the West Wing to make room for staffers. In the 1940s, the building was found to have major structural problems and was completely rebuilt over the course of four years. The most recent renovation took place in the early 60s when Jackie Kennedy redesigned much of the White House and reawakened public interest in the building by hosting a televised tour.

Thomas Jefferson was the first president to open the White House to the public for tours and that tradition continues today. Over 1.25 million people visit the White House every year. Approximately 400 people work in the White House full-time. Strangely enough, despite all these people coming in and out and the numerous renovations of the building completed over the years, the original cornerstone laid in October 1792 by George Washington and a group of Freemasons has never been found. During the 1940s renovation, President Truman specifically asked construction workers to search for it, but it never turned up. The missing cornerstone remains a historical mystery worthy of a National Treasure movie.

Learn more here:

  1. https://constitutioncenter.org/blog/10-facts-on-the-white-house-anniversary
  2. https://www.trolleytours.com/washington-dc/white-house
  3. https://www.whitehouse.gov/about-the-white-house/the-grounds/the-white-house/
  4. https://www.britannica.com/topic/White-House-Washington-DC/The-White-House-since-1900
  5. https://www.nps.gov/nr/travel/presidents/white_house.html

Spiro Agnew: The Almost President

On October 10, 1973, Vice President Spiro T. Agnew became the first U.S. Vice President to resign his position under duress. An impending criminal conviction combined with pressure from President Richard Nixon, who was himself under investigation, led Agnew to deliver the following statement to Secretary of State Henry Kissinger: “I hereby resign the office of Vice President of the United States, effective immediately.”

Spiro T. Agnew was born in November 1918 in Baltimore, Maryland. He served as an officer in the US Army during WWII. Agnew was a law student at the University of Baltimore and practiced law for about 10 years before beginning his political career. Agnew was voted in as governor of Maryland in 1967. As far as Agnew’s politics went, his have been considered the origin of the Trump GOP. Authors of a book on the subject said that, as a politician, Agnew took on “what decades later would become the holy trinity of targets for Trump’s MAGA movement—the media, coastal elites, and higher education—Agnew went from punchline to patron saint of middle America” (2). In 1968, Richard Nixon chose Agnew as his running partner, and Agnew became more and more popular with a group of radical republicans into his second term as vice president. It certainly seemed that Agnew had the republican nomination for the 1976 presidential election in the bag.

However, in 1973, the US Justice Department began investigating charges of income-tax evasion and bribery during Agnew’s time as Governor of Maryland. Though Agnew aggressively fought the claims of wrong-doing, the evidence soon became undeniable. Agnew had received money in return for awarding high-priced government contracts and had not reported that money on his taxes. By this time, the Nixon administration knew Agnew was unlikely to escape conviction, and Nixon was facing his own criminal indictment for the Watergate Scandal. According to the US line of presidential succession, if both Nixon and Agnew were removed from office by impeachment, House Speaker Carl Albert, democrat, would have taken office. To avoid giving a democrat the job, Nixon’s administration sought to remove Agnew from office and replace him with a suitable successor by pressuring Agnew to resign.

Agnew’s lawyers came to an agreement with the Justice Department that Agnew would plead “nolo contendere,” or no contest, to the charges of tax evasion, and the Justice Department would drop the charges of bribery and extortion against him. Agnew was fined $10,000 and sentenced to three years’ probation. He was disbarred by the state of Maryland the following year. Less than a year after Agnew’s departure from office, President Richard Nixon resigned due to accusations surrounding the Watergate Scandal, ceding the presidency to Agnew’s replacement, Gerald Ford.

Learn more here:

  1. https://www.britannica.com/biography/Spiro-Agnew
  2. https://www.washingtonpost.com/made-by-history/2023/04/10/there-is-precedent-trumps-indictment-spiro-agnew/
  3. https://archive.nytimes.com/www.nytimes.com/learning/general/onthisday/big/1010.html

Tokyo Rose: American Scapegoat

On October 6, 1949, an American woman named Iva Toguri d’Aquino was the seventh person to be convicted of treason in the United States. She was sentenced to 10 years in federal prison and fined $10,000 for her crimes. What exactly was her crime? Broadcasting a radio show to American troops during WWII.

Iva Ikuko Toguri was born in Los Angeles in 1916. Her parents were immigrants from Japan who had settled in California. Toguri attended school, earned her degree from UCLA, and worked with her father in his shop. A normal American girl, Toguri soon found herself living a nightmare when, in 1941, she traveled to Japan to visit her aunt. Before she could return home to the US, Japanese troops attacked Pearl Harbor, and Toguri found herself stuck in Japan, far from her family, who had been forced into an internment camp.

As she waited out the war, Toguri got a job as a typist at Radio Tokyo where she met Australian POW Major Charles Cousens. He and several other captured Allied soldiers had been brought to Radio Tokyo to be the voices of a Japanese propaganda show intended to discourage US troops posted in the Asia Pacific area. Cousens asked Toguri to be an announcer on the show, Zero Hour. She and dozens of other women who announced on the show became collectively known as “Tokyo Rose” by US troops who listened to it. However, the announcers of the show claimed to be trying to sabotage the propaganda program. Toguri repeatedly joked with her listeners that the show was Japanese propaganda, saying, “Be on your guard, and mind the children don’t hear!”

As the war ended, the US media set its sights on now-married Iva Toguri d’Aquino. Two reporters traveled to Japan, promising d’Aquino money for an exclusive interview. Desperately in need of funds, she agreed to the interview. Once her name was published by the American media, the government moved in to investigate. d’Aquino’s name became synonymous with treason, and years of American upset and aggression were heaped upon her. A year’s investigation yielded no evidence that her show was anything other than “innocuous entertainment.”

It was unfortunate then, that famous radio host, Walter Winchell, was unwilling to let it go. He continued to insist that charges of treason be brought against her. In 1949, the government capitulated to pressure from the media and American public and brought her case to trial. Despite people who testified on her behalf, she was declared guilty, sentenced to a decade in federal prison, and stripped of her American citizenship.

d’Aquino served about six years in prison before being released on good behavior. She fought the government’s deportation efforts and moved to Chicago. In 1976, two of the key witnesses from her 1949 trial came forward to say they were pressured into giving false testimony against d’Aquino. Shortly after, the jury foreman from d’Aquino’s trial said that the jury was pressured by the judge to deliver a guilty verdict. In 1977, President Gerald Ford pardoned Iva d’Aquino and restored her citizenship.

In the decades since the Tokyo Rose debacle, many reasons have been given for the obvious scapegoating of d’Aquino. There were certainly politics, racial discrimination, sexual discrimination, and media bias at play. Iva herself said, “I supposed they found someone and got the job done; they were all satisfied. It was eeny, meeny, miney, and I was moe.”

Learn more here:

  1. https://www.fbi.gov/history/famous-cases/iva-toguri-daquino-and-tokyo-rose
  2. https://www.history.com/news/how-tokyo-rose-became-wwiis-most-notorious-propagandist
  3. https://prologue.blogs.archives.gov/2010/10/06/the-orphan-called-tokyo-rose/
  4. https://www.law.umich.edu/special/exoneration/Pages/casedetailpre1989.aspx?caseid=332
  5. https://onlinelibrary.wiley.com/doi/10.1111/j.1468-0424.2010.01584.x
  6. https://www.seattletimes.com/nation-world/broadcaster-made-tokyo-rose-role-infamous-in-war/

The Great Dissenter

On October 2, 1967, Thurgood Marshall was sworn in as the first African-American justice on the Supreme Court. Marshall was nominated to the position by President Lyndon B. Johnson following a storied legal career in which Marshall fought tirelessly for racial justice. During his 24 years on the bench, Marshall never gave up on his ultimate goal: equality for all.

Thurgood Marshall was born in Maryland in 1908. He was the son of a railroad porter and an elementary school teacher and the grandson of an enslaved person. He was incredibly bright and graduated from college with honors. When applying to law school, Marshall received a rejection from the University of Maryland based solely on his race. After earning his law degree at Howard University, Marshall came back to the University of Maryland, this time to sue the university for violating the Fourteenth Amendment by denying admission based on race. He won.

Marshall won several more high-profile cases, striking down laws and policies that allowed for racial discrimination in housing and schools. In 1938, Marshall became Chief Counsel of the NAACP. His most well-known legal victory is that of Brown v. Board of Education. Through this case, segregation in public schools was deemed unconstitutional. After winning this case, Marshall became a circuit judge and U.S. Solicitor General before becoming a Supreme Court Justice.

As a Supreme Court Justice, Justice Marshall championed affirmative action, the right to privacy, and a woman’s right to choose, the same rights that have been struck down by the Supreme Court in recent years. During his years on the court, Justice Marshall was often referred to as “The Great Dissenter,” and the necessity of dissension might be his greatest legacy. In a commencement address that Justice Marshall gave at the University of Virginia in 1978: “Where you see wrong or inequality or injustice, speak out, because this is your country. This is your democracy. Make it. Protect it. Pass it on.”

Learn more here:

  1. https://www.britannica.com/biography/Thurgood-Marshall
  2.  https://naacp.org/find-resources/history-explained/civil-rights-leaders/thurgood-marshall
  3. https://www.tmcf.org/about-us/who-we-are/justice-thurgood-marshall/
  4. https://www.aclu-mn.org/en/news/making-black-history
  5. https://timesmachine.nytimes.com/timesmachine/1993/01/25/008893.html?login=email&auth=login-email&pageNumber=56

The Birth of the U.S. Army

On September 29, 1789, the First Congress of the United States passed an act that allowed for the establishment of the United States Army. Though the Continental Army had fought during the revolution and was officially established under the Articles of Confederation, it wasn’t until 1789 that the Army of the United States of America as we know it existed.

During the course of the Revolutionary War, it is estimated that approximately 230,000 men served as members of the Continental Army. Once the war ended, the Framers of the Constitution thought it important that the U.S. have a standing army to protect it from any number of outside threats. When these men wrote the Constitution, they said, “The Congress shall have Power . . . To raise and support Armies.” This would be checked by the executive branch as the president would be the Commander in Chief of that army.

By September 29, 1789, the last day of their first session, the First Congress had still not written any legislation regarding the army. President George Washington was insistent that they do so. He wrote a letter to Congress saying, “I am particularly anxious it should receive an early attention as circumstances will admit; because it is now in our power to avail ourselves of the military knowledge disseminated throughout the several States by means of the many well instructed Officers and soldiers of the late Army.” Congress passed the act that day, writing: “An act to recognize and adapt to the Constitution of the United States, the establishment of the troops raised under the resolves of the United States in Congress assembled.”

At the time that the U.S. Army was established in 1789, it is estimated they had about 800 members. Now it is estimated that the U.S. Army has approximately 450,000 personnel. The U.S. Army also has the highest amount of military spending in the world: approximately 800 billion U.S. dollars each year.  

Learn more here:

  1. https://constitution.congress.gov/browse/essay/artI-S8-C12-1/ALDE_00013670/#:~:text=Article%20I%2C%20Section%208%2C%20Clause,than%20two%20Years%3B%20.%20.%20.&text=3%20Joseph%20Story%2C%20Commentaries%20on,United%20States%201187%20(1833).
  2. https://www.britannica.com/topic/The-United-States-Army
  3. https://www.statista.com/topics/2171/armed-forces-of-the-united-states/#dossier-chapter2
  4. https://www.loc.gov/item/today-in-history/september-29/#:~:text=Finally%2C%20on%20September%2029%2C%201789,Constitution%20of%20the%20United%20States.
  5. https://constitutioncenter.org/blog/on-this-day-congress-officially-creates-the-u-s-army

Here’s the Story: A Pop Culture Phenomenon

On September 26, 1969, the first episode of acclaimed television show “The Brady Bunch” appeared on ABC. While most of us now are familiar with the Bradys and can probably sing at least one verse of their iconic theme song, the show was actually not very popular during its original five seasons. It wasn’t until the late 70s, when the show was in reruns, that children and teens became infatuated with this ideal American family. What was it about the Bradys that drew such a dedicated fan base almost a decade after its original airing?

“The Brady Bunch” was created by Sherwood Schwartz, who was also the creator of the famous 1960s sitcom, “Gillian’s Island.” Apparently, Schwartz got the idea for the show when reading an article in the Los Angeles Times that said that in 1966, “30 percent of marriages involved children from a previous relationship.” Schwartz wrote the pilot and submitted it to several networks who weren’t sure about a television show with such an unfamiliar premise. Shortly after, however, the movie Yours, Mine, and Ours starring Lucille Ball and Henry Fonda premiered and became a hit. After its success, ABC picked up Schwartz’s pilot with a similar premise and began filming the first season.

The show, in which Carol Martin and Mike Brady get married and bring their six children (her three girls: Marcia, Jan, and Cindy and his three boys: Greg, Peter, and Bobby) to live in a beautiful home in an LA suburb, revolved around the children and the pitfalls they faced in the process of growing up. During the years it originally aired (1969-1974), critics did not have great things to say about the show, claiming it was too cheesy. After its cancellation, ABC began rerunning the episodes on weekday afternoons. Children and teens who were just getting home from school gathered around the television set to watch. An article in Entertainment Weekly from the 90s suggests that the show resonated so deeply with this group because “the show was a picture of stability while Vietnam and the sexual revolution rocked the rest of the world. While our real-life parents were splitting up at an alarming rate, those goody-goody Bradys were telling us a shameless lie about family life. We desperately believed it. Most of all, this was the family that the latchkey kids came home to every day after school, the family we could always count on.”

In the 50 years since the Bradys appeared on television, many television shows featuring unique family structures have become national treasures, including “Full House,” “Modern Family,” “Gilmore Girls,” and “The Fresh Prince of Bel-Air.” What television executives learned from the Bradys and then applied to these other shows is that we love to see a family that takes a difficult situation and makes it good and funny and wholesome.

Learn more here:

  1. https://www.history.com/news/brady-bunch-origins-facts
  2. https://www.history.com/this-day-in-history/the-brady-bunch-premieres
  3. https://www.encyclopedia.com/media/encyclopedias-almanacs-transcripts-and-maps/brady-bunch
  4. https://ew.com/article/1992/05/29/brady-bunch-made-history/

The Bill of Rights: Two Amendments That Didn’t Make the Cut

On September 25, 1789, the original draft of the Bill of Rights was proposed and accepted by Congress. The first draft, written by James Madison, contained 12 amendments, though only 10 were ratified by the states in the end. Do you know what the two unratified amendments were?

Bill of Rights, 1791 post treatment 00306_2003_001

The original first amendment stipulated that a congressional district cannot have more than 50,000 residents. While this amendment was passed by the First Congress, it was not ratified by the states nor was it passed in the centuries since. If the amendment was passed today, the House of Representatives would have to have over 6,000 members (1).

The original second amendment outlined when Congress could change their pay. The amendment would require any pay change to happen after the election, essentially allowing citizens to approve or disapprove of any pay changes during the election. While this amendment was not originally ratified by the states, it finally became the 27th Amendment in 1992.

The ability to make changes to the Constitution was important to founding father Thomas Jefferson. In a letter he wrote to James Madison on September 6, 1789 (who was at the time, in the process of penning the Bill of Rights), Jefferson said, “The question whether one generation of men has a right to bind another, seems never to have been started either on this or our side of the water . . . it may be proved that no society can make a perpetual constitution, or even a perpetual law. The earth belongs always to the living generation. They may manage it then, and what proceeds from it, as they please, during their usufruct . . . every constitution then, and every law, naturally expires at the end of 19 years. If it be enforced longer, it is an act of force, and not of right (4). While Jefferson’s suggestion was not incorporated, the founding fathers did allow Congress to add amendments to the Constitution beginning with the original 10.

Learn more here:

  1. https://www.senate.gov/about/origins-foundations/senate-and-constitution/congress-submits-first-amendments-to-states.htm
  2. https://constitutioncenter.org/blog/when-congress-passed-the-original-12-amendments-in-the-bill-of-rights
  3. https://www.archives.gov/milestone-documents/bill-of-rights
  4. https://founders.archives.gov/documents/Madison/01-12-02-0248