The Great Depression and the New Deal: The Hell of Good Intentions

 

Proponents of the Austrian School are perhaps unique among the various schools of economic thought that exist today. In contrast to the Keynesians (who support government management of the economy), Austrians are most notable for being highly critical of the role that government plays—in their mind—of causing economic turmoil when they become too involved in trying to manage the free market. Almost without exception, Austrian scholars view governments that are interventionist in relation to a nation’s economy as detrimental to that nation’s economic prosperity.[1] As such, it is no surprise that Austrian economists blame the active role of government championed by Presidents Hoover and Roosevelt for prolonging the Great Depression. Evidence does suggest that if the American government had simply allowed the free market to course-correct on its own, the US economy would have stabilized naturally and in a quicker fashion.[2]

A relatively new school of economic thought, the Austrian school rose to prominence in the twentieth century due to the efforts of Ludwig von Mises and Murray Rothbard. Key pillars of Austrian economic theory include the need to protect private property and the legitimacy of contracts. As proponents of free enterprise and entrepreneurial ventures, they do not support taxes, price controls or nearly any types of business regulation.  In short, scholars of the Austrian school advocate for a total separation of government from the free market.[3]

With this in mind, Austrian economists directly blame the start of the Great Depression on government intrusion into the market. Perhaps most significantly, the Federal Reserve Board’s policies throughout the 1920s in regard to managing interest rates on an increasing number of loans led to the creation of a large monetary bubble. If the bubble had been allowed to “pop” on its own, independent of government intervention, the economic downturn would have been minimized and recovery would have occurred quickly. Instead, and in contrast to its intent, the Federal Reserve allowed for the conditions that created a much larger crash and subsequent depression.[4] Once the market downturn began, a lack of confidence in entrepreneurial actions on the part of business owners also dramatically declined, owing in part to a lack of confidence where future profits are concerned.[5]

President Roosevelt’s New Deal, enacted in response to this economic collapse, is also seen by the Austrian school as having exacerbated the worst effects of the Great Depression. One variable to consider is worker output per capita. At the height of the Great Depression, the production rate of the average worker was down 39 percent from expected levels, and by 1939 this number had risen only slightly, to 27 percent below expected performance.[6] This is significant given how many New Deal programs were enacted to improve labor conditions and efficiency.

Proponents of the Austrian School of economics also believe that the Great Depression did not truly end until the after the Second World War, when the industry was finally returned (mostly) to the private sector. Substantial evidence exists to support this claim. To take one variable to identify the health of the economy as an example, in 1940 unemployment rate was substantially higher than it would have been if the regulations on businesses imposed by President Roosevelt’s New Deal had not been enacted. Going further, unemployment – what President Roosevelt would likely identify as the most important problem to address during his administration – never came close to recovering to pre-crash levels. Despite initial improvement due to huge federal works programs, gains made in employment during the New Deal were artificial and temporary. By 1938, unemployment was on the rise again and at a rate above ten percent.[7]

It should also be noted that in the years immediately following the war, growth in private industries increased for the first time since 1928. This can be measured through an examination of Whole Sale Price Indexes, which show a stagnation regarding the total price of all consumer goods throughout the 1930s.[8] The cause of the eventual increase in prices after the war, according to proponents of the Austrian school, was the result of a concurrent decrease in federal government spending at the end of the war.[9]

To the dismay of scholars in the Austrian tradition, much of what was enacted as a result of the New Deal became far more than just temporary programs created to combat the Depression. Not only are a number of New Deal agencies still in effect today (the Social Security Administration being perhaps the best example), Americans are now more comfortable than ever with government playing an increasingly active role in their lives. This was the conclusion reached by the economist Robert Higgs, who noted that that Americans—as result of progressive measures enacted during the two decades prior to the start of the Great Depression—were conditioned to accept the wave of New Deal programs when they were enacted by President Roosevelt.[10] Furthermore, Higgs also identified a historical trend that when the purported need for government action diminishes (i.e., America recovers from a recession), temporary government programs often become permanent. In short, according to the Austrian school over time the United States increasingly has developed a more mixed economy, one where the needle is pointing away from the free market and towards socialism.[11]

Perhaps it is no surprise, then, when one considers the overwhelming size and scope of the US federal government today, where government debt continues to grow at an exponential rate. All of this, Austrian scholars would argue, is to the detriment of the nation’s economy and to its citizens. The roots of this economic transition can be found in the Great Depression and the subsequent implementation of the New Deal.     

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[1] The Mises Institute, “What is Austrian Economics?” Accessed February 15, 2023, https://mises.org/what-austrian-economics.

[2] Harold L. Cole, and Lee E. Ohanian. “New Deal Policies and the Persistence of the Great Depression: A General Equilibrium Analysis.” Journal of Political Economy 112, no. 4 (2004): 779, https://doi.org/10.1086/421169.

[3] The Mises Institute, “What is Austrian Economics?”

[4] Eugene N. White, “The Stock Market Boom and Crash of 1929 Revisited.” The Journal of Economic Perspectives (1986-1998) 4, no. 2 (Spring, 1990): 81-2; Raymond Keating, Review of The Politically Incorrect Guide to the Great Depression and the New Deal by Robert P. Murphy, Foundation for Economic Education, December 22, 2010, https://fee.org/articles/the-politically-incorrect-guide-to-the-great-depression-and-the-new-deal.

[5] Hugh Rockoff, Review of A Monetary History of the United States, 1867-1960 by Milton Friedman and Jacobson Schwartz, Economic History Association, accessed February 15, 2023, https://eh.net/book_reviews/a-monetary-history-of-the-united-states-1867-1960.

[6] Harold L. Cole, and Lee E. Ohanian. “New Deal Policies and the Persistence of the Great Depression.”

[7] Gene Smiley, “Recent Unemployment Rate Estimates for the 1920s and 1930s,” Journal of Economic History 43, no. 2 (June 1983): 488, https://www.jstor.org/stable/2120839.

[8] “Wholesale Price Indexes (BLS), by Major Product Groups: 1890 to 1970,” in Bicentennial Edition: Historical Statistics of the United States, Colonial Times to 1970 (Washington D.C.: U.S. Department of Commerce, 1975), 199.

[9] Thomas J. DiLorenzo, “The New Deal Debunked (again).” The Mises Institute, September 27, 2004, https://mises.org/library/new-deal-debunked-again.

[10] Robert Higgs, “Crisis, Bigger Government, and Ideological Change: Two Hypotheses on the Ratchet phenomenon,” Explorations in Economic History 22, no. 1 (1985): 5.

[11] Ibid., 22. 

Ned Jordan and the Rise and Fall of the Jordan Car Company

 

Through the creation of the Jordan Car Company in 1916 and the business’s subsequent rapid growth, car enthusiast and entrepreneur Ned Jordan became emblematic of the level of success businessowners often found during the Roaring ‘20s. Unfortunately for Jordan, the company’s collapse at the end of decade was also representative of the economic turmoil impacting the country at this time. There are a number of reasons to explain Jordan’s meteoric rise and fall, but the first concerns the initial success of the company being assisted by mutual interests that aligned the federal government and business

Perhaps intentionally so, Jordan founded his car company at a time in the United States when conditions were highly advantageous for business because of the actions taken by the Woodrow Wilson Administration. As historian Gabriel Kolko has noted, President Woodrow Wilson was far more pro-business in his actions than most scholars have traditionally given him credit for. Through the creation of the Federal Trade Commission, Wilson and his political allies sought to create an environment that would alleviate any doubts on the part of business owners—especially smaller ones—concerning their future. In essence, the goal was for prospective business owners like Jordan to feel at ease knowing that “prosperity” was “assured” and that “economic freedom” for their companies would be protected at all costs.1 To assist small businesses, the Commission produced pamphlets containing helpful strategies for how to reduce their operating expenses and to otherwise become more “efficient” in their day-to-day practices.2 

The libertarian Murray Rothbard has argued that the “political capitalism” employed by the government during this time period enabled the most influential of individuals in big business to safeguard their own power. While some historians have disagreed, Rothbard and others have contended that the federal government under the Wilson Administration restrained the dangers that free markets posed to the business class in America.3 By reigning in the variance associated with true free markets, the government officials that championed political capitalism sought to simultaneously protect the interests of big business, while also offering a leg up to smaller companies. Ned Jordan had the acumen and wherewithal to ensure he would benefit immensely from this new environment for businesses.

The Jordan Car Company also quickly became known for its stylish advertisements that made clever use of Ned Jordan’s lyrical and poetic talents. Unlike his competitors, Jordan saw an opening to appeal to a younger crowd of consumers, especially women. Jordan became the first entrepreneur within the auto industry to place advertisements in women’s magazines, and to do so through the use of color imagery that emphasized his cars’ sex appeal.4 These decisions epitomized the strategy Jordan employed for the company in its early years, which would lead to the company’s value ballooning to over three million dollars by the end of 1923.5 Acting on the company’s success, Jordan decided to launch a bold advertising campaign, with the poetic and stylish poster “Somewhere West of Laramie” at the forefront. The image of a woman at the wheel of a Jordan convertible, driving alongside a horse, would become one of the most famous images of the growing car industry during the 1920s. Absent from this advertisement, and most others released by Jordan, was the mention of mechanical and engineering specifications – details that would be more appealing to men. In their place were lines that allude to a woman’s desire for adventure and to be able to do so in a “graceful” way.6 In this environment, and with a decade of sustained financial prosperity, further expansion and continued profits seemed all but assured.

Unfortunately for Ned Jordan, the success of his company would not last. In 1927 he introduced a new, smaller model, the “Luxury Custom,” which he believed would be a hit with consumers. This proved not to be the case. By 1928, lagging sales, overproduction from previous years, and the additional costs associated with making the new model drained the company of its financial resources.7 To explain Jordan’s decision-making, one economic historian has noted that it is all too common for businessowners to feel the need to increase the scale of their operations and to invest in new products, despite the risks associated with doing so.8 While the specific reasons are often unique to the owner in question, for Jordan it is likely he felt innovation in the company was needed in order to meet the projected demands of consumers, and to thus maintain the company’s continued trajectory of growth. Grabbing hold of a new sector of the market before his competitors did also likely motivated Jordan. Moreover, Jordan was also likely concerned—as successful and driven moguls often are—with enhancing his own personal reputation within the automobile industry.9

The start of the Great Depression made the Jordan Car Company’s financial situation even worse, and by 1931 Ned Jordan had no choice but to cease operations. Jordan’s rise to fame and prosperity during the 1920s was made possible by the favorable economic conditions fostered by the federal government, but ultimately the entrepreneur succumbed to the pressure to maintain the company’s financial standing amidst growing competition.

Notes:

 1. Gabriel Kolko, Triumph of Conservatism (New York: Free Press, 1977), 163.

2. Ibid, 162.

3. Robert L. Bradley and Roger Donway, "Reconsidering Gabriel Kolko: A Half-Century Perspective." The Independent Review 17, no. 4 (Spring 2013): 562.

4. Bradford Wernle, “Jordan Put the Sizzle in the Pitch,” Automotive News 70, no. 5666 (1996): 78.

5. Robert Tate, “Remembering Automotive Pioneer Ned Jordan.” MotorCities: National Heritage Area, October 19, 2022, https://www.motorcities.org/story-of-the-week/2022/remembering-automotive-pioneer-ned-jordan.

6. Ibid.

7. James H. Lackey, The Jordan Automobile: A History (Jefferson, NC: McFarland & Company Inc., 2006), 76-77.

8. Alfred D. Chandler, Scale and Scope: The Dynamics of Industrial Capitalism. (Birmingham: Harvard University Press, 1990), 16-17.

9. Ibid., 16-17.

Comparing the Economic Conditions of Former Slaves in Postbellum Maryland and North Carolina

 

In the late 1930s the federal government, through the Works Progress Administration (WPA), interviewed thousands of black Americans with the goal of documenting their past history as former slaves. A considerable emphasis was also placed in these interviews on learning about how these individuals are currently living.[1] Comparing a small set of these narratives by geographic location has the potential to reveal noteworthy differences in the economic conditions former slaves experienced in the postbellum era.

In this analysis, four narratives will be analyzed: two from Maryland (a border state that remained loyal to the Union) and two from North Carolina (which seceded with the rest of the Upper and Lower South). It is possible that these interviews may shed light on how former slaves were able to preserve through the economic challenges they experienced during Reconstruction. This is important, given that many former slaves were not able to do so. One historian has hypothesized that over one million black Americans experienced disease and illness associated with food insecurity during this time period, with over ten thousand perishing as a result.[2]

Annie Young Henson of Maryland revealed in her interview that upon receiving her freedom at the end of the war, she initially tried to return to her master’s plantation before realizing she could no longer live there. She eventually found work as a flour merchant in Baltimore, earning $6.00 per month (which is the equivalent of roughly $140 today).[3] While Henson did not further elaborate on whether or not this provided her with enough money to live comfortably, this seems highly unlikely.

Dennis Simms, also of Maryland, recalled that many of his fellow slaves chose to work for their former master after obtaining freedom. Simms displayed a certain sense of pride at what he reported as continuous good luck and good health. While Simms was vague about details, he claimed to still be working despite his old age.[4] Perhaps it can be said that he preferred the daily routine associated with consistent labor, but it seems more likely that Simms continued to work because in order to provide for his daily needs.

Henry Bobbitt and Adeline Crump, former slaves from North Carolina, reported in separate interviews that they had lived in the state their whole lives. They also suggested that since being freed they continued to live in impoverished conditions, making do only through charity and/or the help of family. Bobbitt was especially critical of Abraham Lincoln when asked about the former president. In his interview he claimed that Lincoln acted without considering the consequences of what black Americans–now set free but without knowledge or the means to care of themselves–would be able to do next. After he gained his freedom Bobbitt could not find stable work, and he usually slept at night in the woods or–if allowed–in the barns of generous farm owners.[5] 

Crump recalled a similar experience of escaping slavery. She remarked that her former master was a good man, and that she and many other blacks wanted to stay with him after being freed but were prevented from doing so. While Crump’s interview is lacking key details, she did mention that after the death of her husband “many years” ago, she worked relentlessly to be able to take care of her children.[6] Most notably, she indicated she had been relying on “charity” for “a long time” in order to meet her basic needs.[7]

While not explicitly mentioned by any of the four interview subjects, their poor economic conditions are possibly the result of never having the opportunity to own land and property of their own. In Durham County, North Carolina got example, in 1900—35 years after the abolition of slavery—only 9% of farms were owned by black Americans.[8] It is logical, then, why former slaves felt they were perpetually in need of assistance from the federal government and from charity.

As a final point, it should be noted that despite living in poverty, none of the four former slaves complained in their interviews about their present situation. This could be due to a willingness on their part to avoid a confrontational interview, or perhaps to a certain resignation and acceptance that nothing they say–in the twilight of their lives–is likely to change anything.

The results of this study suggest a certain uniformity in the harsh living conditions experienced by all former slaves, regardless of their location. No significant differences were found between the two individuals studied North Carolina and their counterparts from Maryland. To verify this claim, though, additional narratives need to be analyzed. One recent scholar has lamented that nearly all former slaves during this time period were “illiterate” and lived in “destitute” conditions.[9] As a result, very few historical artifacts are available today to tell the full story of the economic hardship they experienced.[10] The interviews conducted by the WPA during the 1930s provide a small but important glimpse into the economic lives of former slaves, and as such merit further examination by historians.

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[1] "Slave Narrative Collection of the Federal Writers' Project," in The American Mosaic: The African American Experience, ABC-CLIO, 2023, accessed January 25, 2023, https://africanamerican2-abc--clio-com.eu1.proxy.openathens.net/Collections/Display/2280163?sid=1573828&sTypeId=5.  

[2] Durham Food History, “Sharecropping, Black Land Acquisition, and White Supremacy (1868-1900),” https://wfpc.sanford.duke.edu/north-carolina/durham-food-history/sharecropping-black-land-acquisition-and-white-supremacy-1868-1900/, accessed January 25, 2023. 

[3] "Maryland: Annie Young Henson Narrative," in The American Mosaic: The African American Experience, ABC-CLIO, 2023, accessed January 26, 2023, https://africanamerican2-abc--clio-com.eu1.proxy.openathens.net/Collections/Display/2280163?sid=1583821&sTypeId=5. 

[4] "Maryland: Dennis Simms Narrative," in The American Mosaic: The African American Experience, ABC-CLIO, 2023, accessed January 25, 2023, https://africanamerican2-abc--clio-com.eu1.proxy.openathens.net/Collections/Display/2280163?sid=1583830&sTypeId=5. 

[5] "North Carolina: Henry Bobbitt Narrative," in The American Mosaic: The African American Experience, ABC-CLIO, 2023, accessed January 26, 2023, https://africanamerican2-abc--clio-com.eu1.proxy.openathens.net/Collections/Display/2280163?sid=1653640&sTypeId=5. 

[6] "North Carolina: Adeline Crump Narrative," in The American Mosaic: The African American Experience, ABC-CLIO, 2023, accessed January 26, 2023, https://africanamerican2-abc--clio-com.eu1.proxy.openathens.net/Collections/Display/2280163?sid=1653655&sTypeId=5. 

[7] Ibid. 

[8] Durham Food History, “Sharecropping, Black Land Acquisition, and White Supremacy (1868-1900).”

[9] Douglas A Blackmon, Slavery by Another Name: The Re-Enslavement of Black Americans from the Civil War to World War II (New York: Doubleday, 2008), 9.

[10] Ibid.

Visit the Historic Heublein Tower in Simsbury, CT

 

    For anyone visiting central Connecticut and the beautiful Farmington Valley, one will see in the skyline looking towards Hartford one of the most striking and unique features: Heublein Tower, sitting atop a small mountain ridge that overlooks the state capital. The 50-meter tower is named after Gilbert Heublein, who emigrated as a young boy from Germany in the 1850s. Once he reached adulthood, Heublein quickly became wealthy by playing a leading role in his father’s growing company, which notably introduced the famous A-1 Steak Sauce to the United States. Additional wealth came to the Heublein family from liquor, which remained in high demand until the Prohibition Era.[1]

    As a young man in 1876, Heublein went for a walk along Talcott Mountain ridge with his fiancé, and both were captivated by the views offered at the summit of the mountain. It was at that moment that Heublein promised his fiancé he would build a “castle” there for her. The rest as they say, is history. Heublein would go on to buy the necessary land, and after decades of work and planning, the first main structure of the tower was complete in 1914, with the surrounding buildings and all interior rooms completed in 1929. The jewel of the tower was the top floor—known as the ‘Observation Deck’—which the Heublein’s used to host glamorous parties. Heublein died in 1937 at the age of eighty-eight, and for many years after that the tower remained unoccupied. Eventually Heublein’s grandson chose to sell the tower to the Hartford Times, a prominent Connecticut newspaper, in 1943.[2]

    Once owned by the Hartford Times, the tower became a prime location for social events catering to the wealthy and the elite. Arguably the most significant event in the tower’s history occurred in the early 1950s, when General Dwight D. Eisenhower—hero of World War II—was hosted at a Republican Party gathering led by Prescott Bush (father of George H.W. Bush and grandfather of George W. Bush). As the 1952 Presidential Election approached, Eisenhower was highly coveted by both Democrats and Republicans to be their official party nominee. Persuaded by Bush and the other Connecticut Republicans gathered at the tower, Eisenhower accepted.[3]

    In subsequent years, the tower was used less and less for social gatherings, and eventually the declining Hartford Times sold the tower to a group of real estate developers, who intended to building luxury homes along the ridge overlooking the capital. Eventually the State of Connecticut, through its Department of Energy and Environmental Protection (DEEP), stepped in to buy the tower and the surrounding land in 1966 in order to create Talcott Mountain State Park. After years of restoration and renovation, Heublein Tower and the park were finally opened to the public in 1974, and in 1983 they were added to the National Register for Historic Places.[4]

    Today, visitors who make the short hike to the tower can view the tower as it existed when the Hueblein’s lived there. Many of the rooms in the tower—adorned with period-era furniture and decorations—now serve as a small museum for visitors. In addition to taking in the breathtaking views of the gorgeous Farmington Valley from the top of the tower, residents and tourists to the region can learn more about the full history of the tower, the Heublein family, and life in Connecticut during the early 20^th century.[5]

[1] “Heublein Tower History,” Friends of Heublein Tower, accessed August 3, 2022, https://friendsofheubleintower.org/about-the-heublein-tower/heublein-tower-history/; Andrew Lehmann, “Heublein Tower,” Atlas Obscura, May 23, 2015, https://www.atlasobscura.com/places/heublein-tower.

[2] Bill Ryan, “Tower of Romance, Tower of History,” New York Times, January 31, 1999, https://www.nytimes.com/1999/01/31/nyregion/tower-of-romance-tower-of-history.html; Friends of Heublein Tower, “Heublein Tower History.”

[3] Ryan, “Tower of Romance;” Friends of Heublein Tower, “Heublein Tower History.”

[4] Ryan, “Tower of Romance;” Friends of Heublein Tower, “Heublein Tower History.”

[5] Lehmann, “Heublein Tower.”

Phillis Wheatley: Honoring George Whitefield

On March 5, 1770, the famous traveling preacher George Whitefield passed away at the age of 55. Perhaps more well-known than any other man in the colonies at the time of his death, Whitefield, by virtue of his impeccable oratorical skills he displayed during his sermons, was a seminal figure of the period in American history known as the Great Awakening. Originally born in Great Britain and also ordained there as a minster, Whitefield made numerous trips to the colonies, where as a preacher he traveled up and down the Atlantic coast, spreading the message of revival in as many places and to as many people as he could. Often, Whitefield’s outdoor revivals were attended by thousands of people at a time. By the time of his death in 1770, Whitefield had been delivering sermons throughout the colonies for thirty years and in so doing had aided the colonies in understanding the importance of upholding their natural rights.[1]

Throughout the course of his travels in the colonies, Whitefield became close friends with Benjamin Franklin. In particular, Franklin liked that Whitefield’s sermons imparted a strong message of living faithfully and with virtue. While Franklin would never become the devout evangelical Christian that Whitefield was, the founding father was impressed with the famous preacher, and over the course of many years the two men became close friends.[2]

It should be noted that Whitefield was somewhat unique in regard to his contributions during the Great Awakening revivals in that he intentionally catered to people of all ages, social classes, and denominations. This can be seen in a moving tribute of Whitefield that was written in the form of a poem by a 17-year-old slave girl named Phillis Wheatley, shortly after the preacher’s death. (In subsequent years Wheatley would be emancipated by her owners, and gain national recognition for her writing.) Wheatley’s poem is full of admiration for Whitefield and the great influence he had on the nation. She wrote that now that Whitefield has passed away “We hear no more the music of thy [Whitefield’s] tongue,” which “inflame[d] the soul, and captivate[d] the mind.”[3] Wheatley further exclaimed that “When his [Whitefield’s] Americans were burden’d sore” it was Whitefield who encouraged the masses to find God, to air all grievances and “complaints in His kind bosom.”[4] Wheatley was so taken with Whitefield’s ability to spread the word of God that she compared his efforts to that of Jesus Christ. She proclaimed Whitefield “was no less than God’s co-equal son” for influencing so many Americans to become more devout Christians.[5]

With this evident comparison to Jesus Christ, God’s son, Wheatley was certainly engaging in hyperbole. Nonetheless, she clearly wanted her audience to understand the power impact that the colonies’ most famous traveling preacher had on her. Moreover, it is clear that Wheatley’s laudatory poem about Whitefield was emblematic of the man’s unwavering commitment to following God’s true principles, and to using his talents of oratory to spread God’s word for all to hear. 

Source List:

Kidd, Thomas. God of Liberty: A Religious History of the American Revolution. New York: Basic Books, 2010.

Morgan, Edmund S. Ben Franklin. New Haven: Yale University Press, 2002.

Phillis. “An elegiac poem, on the death of that celebrated divine, and eminent servant of Jesus Christ, the late reverend, and pious George Whitefield.” Boston: Sold by Ezekiel Russell in Queen-Street, and John Byles, in Marlboro-Street, 1770. Sabin Americana: History of the Americas, 1500-1926. https://link.gale.com/apps/doc/CY0103367922/SABN?u=vic_liberty&sid=bookmark-SABN&xid=c79602f5&pg=1.

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[1] Thomas Kidd, God of Liberty: A Religious History of the American Revolution (New York: Basic Books, 2010), 21, 33-34.

[2] Edmund S. Morgan, Ben Franklin (New Haven: Yale University Press, 2002), 59-60.

[3] Phillis, “An elegiac poem, on the death of that celebrated divine, and eminent servant of Jesus Christ, the late reverend, and pious George Whitefield,” (Boston: Sold by Ezekiel Russell in Queen-Street, and John Byles, in Marlboro-Street, 1770), Sabin Americana: History of the Americas, 1500-1926, https://link.gale.com/apps/doc/CY0103367922/SABN?u=vic_liberty&sid=bookmark-SABN&xid=c79602f5&pg=1.

[4] Ibid.

[5] Ibid.