Were the Founding Fathers "Tolerant" of Islam? [Part I]
[Editor’s Note: This article is the first installment of a two-part critique of an article written by James Hutson, Library of Congress Manuscript Division Chief, on the Founding Fathers’ attitude toward Islam.]
One prominent misconception pertaining to the liberty envisioned by the Founding Fathers of America concerns their intentions with regard to non-Christian religions. Case in point: Manuscript Division Chief of the Library of Congress, James Hutson, wrote an article, titled “The Founding Fathers and Islam” (which routinely receives sanction on Muslim Web sites and blogs [e.g., Amanullah, 2007; Shadia, 2012; “How Did the U.S…?” 2011; Pakistanis…, 2011; Nuha, 2012; The Islam Factor, 2008; Islamic News Updates, 2011]), in which he suggests that
it is clear that the Founding Fathers thought about the relationship of Islam to the new nation and were prepared to make a place for it in the republic…. The Founders of this nation explicitly included Islam in their vision of the future of the republic…[and] would have incorporated it into the fabric of American life (2002, emp. added).
Such expressions as “prepared to make a place for it,” “explicitly included,” and “would have incorporated it” are ambiguous and vague at the least, and misleading at worst. They leave the impression that the Founders were pluralistic and welcomed Islam as a viable, authentic religion that ought to receive society’s equal encouragement and acceptance along with Christianity, further implying that other non-Christian religions, and even the irreligious and atheist, should be given the same consideration. It is disconcerting that such a prominent person in a governmental organization as influential as the Library of Congress would propagate the myth of political correctness to the detriment of the nation and the disparagement of our nation’s Founders. The pervasive propaganda of political correctness has so colored the average American’s perspective that it is commonplace to superimpose current conceptions back onto the Founding era. Nevertheless, the documentary evidence clearly demonstrates that the Founders did not share this “politically correct,” sanitized version of history.
The Founders would not have favored integrating Islam into our schools, government, and other civil institutions. Far from it. In his discussion of freedom of religion in his monumental Commentaries on the Constitution of the United States, Father of American Jurisprudence Joseph Story clarified the meaning of the First Amendment with regard to the priority of Christianity:
[I]t is impossible for those, who believe in the truth of Christianity, as a divine revelation, to doubt, that it is the especial duty of government to foster, and encourage it among all the citizens and subjects….
Indeed, in a republic, there would seem to be a peculiar propriety in viewing the Christian religion, as the great basis, on which it must rest for its support and permanence, if it be, what it has ever been deemed by its truest friends to be, the religion of liberty.
Probably at the time of the adoption of the constitution, and of the amendment to it, now under consideration, the general, if not the universal, sentiment in America was, that Christianity ought to receive encouragement from the state, so far as was not incompatible with the private rights of conscience, and the freedom of religious worship. An attempt to level all religions, and to make it a matter of state policy to hold all in utter indifference, would have created universal disapprobation, if not universal indignation (1833, 44.723-7184.108.40.2065-1868, emp. added).
Indeed, the First Amendment was never intended to “level all religions” (and Islam can hardly be stylized “the religion of liberty”). Story further explained that
the real object of the [First] amendment was not to countenance, much less to advance Mahometanism, or Judaism, or infidelity by prostrating Christianity; but to exclude all rivalry among Christian sects and to prevent any national ecclesiastical establishment which should give to a hierarchy the exclusive patronage of the national government(1833, 3:728, emp. added).
It is imperative that we not misconstrue the Founders’ strong emphasis on religious freedom and tolerance as an indication that they viewed all religion as legitimate or conducive to the principles of the Republic. Their central concern was “disestablishment,” i.e., preventing the federal government from establishing one Christian sect as the state religion. Their idea of “freedom of religion” was first and foremost freedom to pursue the Christian religion unhindered by the federal government, and only secondarily freedom to practice non-Christian religion. This truth is verified by the discussions surrounding the wording of the First Amendment. George Mason—who has gone down in American history as the Father of the Bill of Rights—proposed the following wording: “All men have an equal, natural and unalienable right to the free exercise of religion, according to the dictates of conscience; and that no particular sect or society of Christians ought to be favored or established by law in preference to others” (as quoted in Rowland, 1892, 1:244, emp. added). While Mason’s proposal did not make the final cut, it nevertheless establishes the historical context of the Founders’ discussion, demonstrating that their concern was first and foremost for the free exercise of the Christian religion. Using similar terminology, Mason had previously crafted The Virginia Declaration of Rights—the very document which influenced both Thomas Jefferson’s wording of the Declaration of Independence as well as James Madison’s draft of the Bill of Rights that was added to the federal Constitution. Article XVI reads:
That religion, or the duty which we owe to our Creator, and the manner of discharging it, can be directed only by reason and conviction, not by force or violence, and therefore all men are equally entitled to the free exercise of religion, according to the dictates of conscience; and that it is the mutual duty of all to practise Christian forbearance, love, and charity towards each other (Mason, 1776, emp. added).
To the Founders, “tolerance” was not to be equated with approval or agreement, let alone encouragement that would imply an equal place should be made for non-Christian religion in government, schools, etc. The Founders were no more willing to encourage Islam than they were interested in encouraging the spread of atheism, paganism, or Native American religion. [NOTE: Atheists, though few in number at the time in America, were not allowed to serve as witnesses in court—see Story, 1851, 2:8-9; Swift, 1796, 2:238.] For example, the Father of our country, George Washington, delivered a speech to the Delaware Indian chiefs on May 12, 1779: “You do well to wish to learn our arts and ways of life, and above all, the religion of Jesus Christ. These will make you a greater and happier people than you are. Congress will do everything they can to assist you in this wise intention” (15:55, emp. added). Far from encouraging the superstitious idolatry of much of Native American religion, the Founders (including the Congress!) urged Indians to convert to Christianity. The same may be said for all other non-Christian ideologies—including the inherently godless economic philosophies of socialism, Marxism, fascism, and atheistic communism. Indeed, their words and actions denigrate such thought systems. They believed that non-Christian philosophies and religions were false and ultimately detrimental to genuine liberty.
James Iredell, a U.S. Supreme Court judge appointed by George Washington, articulated this point succinctly in 1788 in the debates on the wording of the Constitution:
But it is objected that the people of America may perhaps choose representatives who have no religion at all, and that pagans and Mahometans may be admitted into offices.... But it is never to be supposed that the people of America will trust their dearest rights to persons who have no religion at all, or a religion materially different from their own (Elliot, 1836, 4:194, emp. added).
Samuel Johnston, governor of North Carolina and member of the Constitution ratifying convention in 1788, likewise felt confident that Muslims should not, and hopefully would not, be allowed to become mainstream in American politics and public institutions—except in only two cases:
By Alexisrael - Own work, CC BY-SA 3.0, https://commons.wikimedia.org/w/index.php?curid=31345949
It is apprehended that Jews, Mahometans, pagans, &c., may be elected to high offices under the government of the United States. Those who are Mahometans, or any others who are not professors of the Christian religion, can never be elected to the office of President or other high office, but in one of two cases. First, if the people of America lay aside the Christian religion altogether, it may happen. Should this unfortunately take place, the people will choose such men as think as they do themselves. Another case is, if any persons of such descriptions should, notwithstanding their religion, acquire the confidence and esteem of the people of America by their good conduct and practice of virtue, they may be chosen. I leave it to gentlemen’s candor to judge what probability there is of the people’s choosing men of different sentiments from themselves (Elliot, 4:198-199, emp. added).
Constitution signer Richard Dobbs Spaight echoed the same prevailing sentiment:
As to the subject of religion…[n]o power is given to the general government to interfere with it at all…. No [Christian—DM] sect is preferred to another. Every man has a right to worship the Supreme Being in the manner he thinks proper. No test is required. All men of equal capacity and integrity are equally eligible to offices…. I do not suppose an infidel, or any such person, will ever be chosen to any office unless the people themselves be of the same opinion (Elliot, 1836, 4:208, emp. added).
Implicit in all three of these Founders’ observations is the fact that Christianity was the underlying belief system on which the Republic was poised. The Founders were unanimous in their desire that the Constitution provide no pretext for governmental interference in the free exercise of the Christian religion by the citizenry. So the only way that atheism or Islam could ever make headway in America’s social and civil institutions is if the people themselves abandon their Christian values. Tragically, their words were prophetic.
WHAT THEY MEANT BY "RELIGOUS FREEDOM"
The Founders’ idea of religious freedom was actually quite simple and sensible—in contrast with the self-contradictory and inconsistent view of today’s vacuous notions of tolerance and political correctness. The facts show that the mass of the Founders, with few exceptions, believed that the Christian worldview and Christian principles must be the foundation of the Republic (see, for example, the 15 proclamations issued by the Continental Congress from 1775 to 1783 in Miller, 2009). Consequently, their view of religious freedom and tolerance amounted essentially to the prevention of religious persecution. Those who practiced no religion or a non-Christian religion could come to America and not be persecuted for the simple reason that the bulk of the Founders and the mass of American citizens embraced Christian principles that forbid persecuting one’s fellowman (e.g., Matthew 5:38-47; Luke 6:27-36).
The Founders had felt the sting of persecution in their disagreement with the state religion (i.e., the Church of England). They were well familiar with their mother country’s long history of religious oppression, depending on whether a Catholic or a Protestant monarch was on the throne. The Founders’ “forefathers” were the pilgrims who fled England specifically on account of religious persecution. Hence, the Founders and Framers wanted the new Republic to dispense with such coercion—in complete harmony with the nature of God Himself, who created humans to be freewill agents who make their own decisions with regard to their eternal destiny. Further, because the Founders had grown up in an environment that promulgated Christian principles, they understood and embraced Jesus’ admonition to treat others the way they themselves wished to be treated (Matthew 7:12). Thomas Jefferson’s query posed to the ambassador of Tripoli reflects this principle: “We took the liberty to make some inquiries concerning the grounds of their pretensions to make war upon nations who had done them no injury, and observed that we considered all mankind as our Friends who had done us no wrong, nor had given us any provocation” (“Letter from the…,” 1786, emp. added). To the Founders, permitting non-Christian peoples to live in our country without persecution was not tantamount to “celebrating diversity” or endorsing what they considered to be false religion. Rather, doing so was first and foremost an affirmation of their desire that all peoples be allowed to pursue happiness without governmental intrusion or coercion.
TWO CRITICAL EXCEPTIONS
However, we must hasten to emphasize that the Founders placed two important qualifications on religious tolerance. First, religious toleration extended only so far as the religion in question did not engage in a practice that is deemed by Christian standards to be immoral. For example, in a case that went all the way to the Pennsylvania Supreme Court in 1815, The Commonwealth v. Sharpless, the defendant was convicted for displaying in his home an obscene painting of a man and woman in an “indecent posture”—an offense against Christian morality (1815). Likewise, in a number of Supreme Court cases, instances of Mormon polygamy were prosecuted as violations of Christian morality—though the defense argued that the practice was justifiable on the grounds of freedom of religion (e.g., Reynolds v. United States, 1879; Murphy v. Ramsey, 1885; Davis v. Beason, 1890). The Founders never envisioned the First Amendment providing sanction for any behavior that is deemed by Christian standards to be immoral or “licentious.” Yet, now that Islam is making significant encroachments into American society, with its brazen advocacy of polygamy (Surah 4:3; cf. 4:24-25,129; 23:6; 30:21; 70:30), the erosion of Christian morality and the appalling ignorance of the founding principles among the population will inevitably sanction such immorality under the guise of tolerance and “religious freedom.”
A second exception that clarifies the notion of religious freedom is seen in the Founders’ insistence that religious freedom did not extend to any action that would bring physical harm to self or other citizens. Actions like Buddhist priests setting themselves on fire in the street, or temple priestesses providing sexual services to devotees, or brothels, or businesses that peddle pornography would not have been tolerated by the Founders under the guise of “freedom of religion” (Commonwealth v. Nesbit, 1859). That means that Islam’s fifteen hundred yearlong historical propensity for engaging in street violence, suicide bombing, and the execution of those who refuse to submit to Allah—actions that are endemic to Islam and the Quran (e.g., Surah 47:4)—are not to be tolerated as protected religious practice. The number of incidents in America of Islamic “honor killings” is mounting (“Missouri Couple…,” 1991; Schoetz, 2008; Thompson, 2011; Tang, 2011; Myers, 2011; Daily Mail…, 2012)—a natural by-product of political correctness, a misunderstanding of the principle of religious freedom, and the loss of the average American’s commitment to Christian morality. Religious freedom notwithstanding, the Founders were wary of any infiltration of the nation’s institutions by “Mahometans” in light of their religious inclinations toward physical violence (cf. Miller, 2005).
With these observations in mind, what is one to make of Hutson’s allusions to incidents in which the Founders seemingly manifested “inclusive” sentiments? Consider the following point-by-point examination of each document cited by Hutson as proof of his claim regarding the Founders. First, the importation of Muslim slaves into the colonies offers no support whatsoever to the idea that the Founders were “prepared to make a place” for Islam in the Republic—any more than they sought to accommodate the pagan animism of African slaves or the polytheism of Native Americans. Hutson admits as much when he concedes that “there is no evidence that the Founders were aware of the religious convictions of their bondsmen.”
Second, the toleration proposed by John Locke in his A Letter Concerning Toleration has, as its context, first and foremost, the toleration that ought to be extended by Christian sects to each other. While he certainly advocates that the same civil rights be extended to Jews, pagans, and “Mahometans”—he articulates several very clearly defined exceptions. Specifically, in a section dealing with those whom the civil magistrate cannot tolerate, he pinpoints:
Those whose religious opinions are contrary to “those moral rules which are necessary to the preservation of civil society” (1796, p. 53);
The religion that “teaches expressly and openly, that men are not obliged to keep their promise” (p. 54);
“[T]hose that will not own and teach the duty of tolerating all men in matters of mere religion…and that they only ask leave to be tolerated by the magistrate so long, until they find themselves strong enough to [seize the government]” (p. 55);
All those who see themselves as having allegiance to another civil authority (p. 56). Specifically, Locke gives the example of the Muslim who lives among Christians and would have difficulty submitting to the government of a “Christian nation” when he comes from a Muslim country where the civil magistrate was also the religious authority. Locke notes that such a person would have grave difficulty serving as a soldier in his adopted nation (cf. the 2009 Fort Hood shooting spree by a Muslim soldier who shouted, “Allahu Akbar” as he opened fire, killing 13 and wounding 32; see Stewart, 2010).
“[T]hose are not at all to be tolerated who deny the being of a God” (p. 56).
Four of these five exceptions inarguably describe Muslim behavior across the world since the inception of Islam. Indeed, what Hutson fails to divulge is that much of Locke’s discussion of religious intolerance (manifested primarily by Catholicism during periods of English history) resembles the very intolerance that typically characterizes Islamic countries around the world.
Hutson further alleges that Thomas Jefferson adopted Locke’s view of toleration (which, as just noted, was not an endorsement or encouragement of Islam), “in demanding recognition of the religious rights of the ‘Mahamdan.’” While it is true that Jefferson championed religious rights for all men, he did so with the same reservations and exceptions set forth by Locke. Evidence of his view of Islamic aggression is seen in his revulsion of the Muslim terrorism that characterized the Barbary States leading up to and during his presidency. His “intolerant” response was to send the U.S. Marines against them (Miller, 1997). It is true that, in his autobiography, Jefferson stated that the Virginia Act for Establishing Religious Freedom was “meant to comprehend, within the mantle of its protection, the Jew and the Gentile, the Christian and Mahometan, the Hindoo, and infidel of every denomination” (1821, p. 40). Yet, even that document verifies the clearly Christian orientation of the assemblage of Founders who passed it, and the distinction they made between religious toleration versus incorporating non-Christian religion into the fabric of America’s civil institutions. The statute begins:
An Act for establishing religious Freedom.
Whereas, Almighty God hath created the mind free; That all attempts to influence it by temporal punishments or burthens, or by civil incapacitations tend only to beget habits of hypocrisy and meanness, and therefore are a departure from the plan of the holy author of our religion, who being Lord, both of body and mind yet chose not to propagate it by coercions on either, as was in his Almighty power to do… (Jefferson, 1786, emp. added).
Pray tell, to whom was Jefferson and his colleagues referring when they referred to “the holy author of our religion”? Unquestionably, they were referring to Jesus Christ, the Author of the Christian religion (see Miller, 2008). This statute once again simply underscores the fact that, while the Founders advocated toleration of non-Christian religions, they themselves recognized the reality and priority of the Christian religion and would not have endorsed any statute that would have relegated Christianity to a position of equal validity with other ideologies. They would not have wanted their pronouncements to be misconstrued to promote the inculcation of false religious systems or “infidelity” into the civil institutions of the United States—including all levels of government, our courts, and our schools.
Hutson’s citation of Richard Henry Lee as corroboration of pluralism or political correctness is contextually dispelled by the fact that, though opposed to the establishment of a state religion, he, along with Patrick Henry, “were advocates of a proposition to make every man contribute something to the support of the Christian religion, as the only sure basis of private and public morality” (Lee, 1825, 1:237, emp. added). The very letter from whence Hutson drew his quotation, written by Lee to James Madison on November 26, 1784, articulates the point that Lee favored citizen support of the Christian religion by means of a tax, noting that religion is “the guardian of morals” (Lee, 1914, 2:304-305; Nelson, 2001, p. 297). Further, throughout his life he avowed belief in the divine origin of the Christian religion and considered its morality to be the necessary foundation of the Republic (Lee, 1914, 1:248).
Appointed by Congress to a committee (along with Samuel Adams and Daniel Roberdeau) to prepare a proclamation to thank God for America’s military victories, Lee is believed to be the penman of the proclamation that was issued by the Continental Congress on November 1, 1777. The proclamation requested that God forgive Americans of their sins “through the merits of Jesus Christ” and that He would “prosper the Means of Religion, for the promotion and enlargement of that Kingdom, which consisteth ‘in Righteousness, Peace and Joy in the Holy Ghost’” (Journals of…, 9:854-851). The quotation within the proclamation is taken from Romans 14:17. This is also the man who, in a letter to Continental Congress president Henry Laurens on October 15, 1779, noted that “our holy religion teaches us to pray ‘Lead us not into temptation’”—a reference to Christianity and Matthew 6:13 (Lee, 1914, 2:162). Such organic utterances serve to clarify, define, and limit the Founders’ view of liberty and “tolerance.”
Look, once again, at the Virginia Act (p. 33). Extending religious tolerance to non-Christian religions is juxtaposed with “temporal punishments,” “civil incapacitations,” and “coercions.” This fact, again, proves that “religious freedom”—as envisioned by the Founders—referred to freedom from interference and persecution by human government. And, again, ironically, Islam’s history verifies its intolerance of non-Islamic religions. The only rational conclusion to be drawn from these facts is that the Founders, if they were living today, would see the encroachments of Islam into America as a fundamental and insidious danger to the religious liberty they championed.
Hutson points to George Washington’s suggestion that Muslims be exempted from a Virginia bill that provided for taxes for Christian worship—a move that certainly indicates toleration, but hardly implies “inclusion” or “incorporation” into the fabric of American life. Likewise, Washington’s welcoming “Mahometans” as workers on his Mount Vernon estate says nothing about his views regarding whether Islam should be encouraged or promoted in tandem with Christianity. In fact, in the letter Hutson cites, in which Washington was looking to hire a “House Joiner and Bricklayer” for his estate from a group of Palatine (German) tradesmen, in addition to “Mahometans,” he specifically included “Jews or Christians of any Sect, or they may be Atheists” (Washington, 1784). His inclusion of Jews, Muslims, and atheists proves he did not intend to make a statement about “tolerance” or who are fit citizens in a Republic. A more accurate assessment of Washington’s sentiments in that regard is seen in the General Orders he
issued to the Continental Army from Headquarters at Valley Forge on Saturday, May 2, 1778:
While we are zealously performing the duties of good Citizens and soldiers we certainly ought not to be inattentive to the higher duties of Religion. To the distinguished Character of Patriot, it should be our highest Glory to add the more distinguished Character of Christian (1778, emp. added).
[to be continued]
Amanullah, Shahed (2007), “Muslims in Government: The Founding Fathers and Islam,” Altmuslim.com, January 3, http://www.patheos.com/blogs/altmuslim/2007/01/the_founding_fathers_and_islam/.
Commonwealth v. Nesbit (1859), Pa. 398; 1859 Pa. LEXIS 240.
The Commonwealth v. Sharpless (1815), 2 Serg. & Rawle 91; 1815 Pa. LEXIS 81.
Daily Mail Reporter (2012), “Man Who Murdered His Daughters in Shocking Muslim ‘Honour Killing’ is Working as a New York City Cab Driver,” May 30, http://www.dailymail.co.uk/news/article-2152369/Yaser-Said-Man-murdered-daughters-shocking-Muslim-honour-killing-working-New-York-City-cab-driver.html.
Davis v. Beason (1890), 133 U.S. 333; 10 S. Ct. 299; 33 L. Ed. 637; 1890 U.S. LEXIS 1915.
Elliot, Jonathan, ed. (1836), Debates in the Convention of the State of North Carolina, On the Adoption of the Federal Constitution (Washington, D.C.: Taylor & Maury), second edition, http://memory.loc.gov/ammem/amlaw/lwed.html.
Green, Steven (2010), The Second Disestablishment (New York: Oxford University Press).
“How Did the U.S. Founding Fathers View Islam?” (2011), IslamiCity.com, Article Ref: IC1103-4605, April 6, http://www.islamicity.com/articles/Articles.asp?ref=IC1103-4605.
Hutson, James (2002), “The Founding Fathers and Islam: Library Papers Show Early Tolerance for Muslim Faith,” Information Bulletin, Library of Congress, May, http://www.loc.gov/loc/lcib/0205/tolerance.html.
The Islam Factor (2008), November 2, http://islamfactor.org/index.php?showtopic=3354.
Islamic News Updates (2011), April 6, http://groups.yahoo.com/group/IslamicNewsUpdates/message/9254.
Jefferson, Thomas (1786), Act for Establishing Religious Freedom, http://www.virginiamemory.com/online_classroom/shaping_the_constitution/doc/religious_freedom.
Jefferson, Thomas (1821), Autobiography (New York: Library of America), http://etext.virginia.edu/etcbin/toccer-new2?id=JefAuto.xml&images=images/modeng&data=/texts/english/modeng/parsed&tag=public&part=all.
Journals of the Continental Congress, 1774-1789 (1904-1937), ed. Worthington C. Ford, et al. (Washington, D.C.: Government Printing Office), Library of Congress, http://memory.loc.gov/ammem/amlaw/lwjc.html.
Lee, Richard Henry (1914), Letters of Richard Henry Lee, ed. James Ballagh (New York: Macmillan).
Lee, Richard (1825), Memoir of the Life of Richard Henry Lee (Philadelphia, PA: H.C. Carey & I. Lea).
“Letter from the American Peace Commissioners (Thomas Jefferson & John Adams) to John Jay” (1786), The Thomas Jefferson Papers Series 1. General Correspondence. 1651-1827, Library of Congress, March 28, http://hdl.loc.gov/loc.mss/mtj.mtjbib001849.
Locke, John (1796), A Letter Concerning Toleration (Huddersfield, England: J. Brook), http://tinyurl.com/Locke-John-google.
Mason, George (1776), The Virginia Declaration of Rights, Library of Congress, http://www.loc.gov/exhibits/treasures/trt006.html.
Miller, Dave (2005), “Violence and the Quran,” Apologetics Press, http://apologeticspress.org/APContent.aspx?category=8&article=1491.
Miller, Dave (2008), The Silencing of God (Montgomery, AL: Apologetics Press).
Miller, Dave (2009), Christ and the Continental Congress (Montgomery, AL: Apologetics Press).
Miller, Nathan (1997), The U.S. Navy, A History (Annapolis, MD: Naval Institute Press), third edition.
“Missouri Couple Sentenced to Die in Murder of Their Daughter, 16” (1991), The New York Times, December 20, http://www.nytimes.com/1991/12/20/us/missouri-couple-sentenced-to-die-in-murder-of-their-daughter-16.html.
Murphy v. Ramsey (1885), 114 U.S. 15; 5 S. Ct. 747; 29 L. Ed. 47; 1885 U.S. LEXIS 1732.
Myers, Amanda (2011), “Arizona ‘Honor Killing’: Iraqi Immigrant Sentenced to 34½ Years in Prison for Running Over, Killing Daughter,” The Huffington Post, April 15, http://www.huffingtonpost.com/2011/04/15/arizona-honor-killing-iraqi-immigrant-sentenced_n_849999.html.
Nelson, John (2001), A Blessed Company (Chapel Hill, NC: The University of North Carolina Press).
Nuha (2012), http://nuha38317.blogspot.com/2012_01_01_archive.html.
Pakistanis for Peace (2011), https://pakistanisforpeace.wordpress.com/tag/george-washington/.
Reynolds v. United States (1879), 98 U.S. 145; 25 L. Ed. 244; 1878 U.S. LEXIS 1374; 8 Otto 145.
Rowland, Kate Mason (1892), The Life of George Mason, 1725–1792 (New York: G.P. Putnam’s Sons), http://chnm.gmu.edu/revolution/d/270/.
Schoetz, David (2008), “Daughter Rejects Marriage, Ends Up Dead,” ABC News, July 7, http://abcnews.go.com/US/story?id=5322587&page=1.
Shadia, Mona (2012), “Islam’s Influence on the Founding Fathers,” Muslim Council of America Foundation, http://muslimcouncilofamerica.org/islams-influence-on-the-founding-fathers/.
Stewart, Phil (2010), “Fort Hood Shooting Was Terrorism, U.S. Says,” Reuters, January 15, http://www.reuters.com/article/2010/01/15/us-usa-shooting-pentagon-idUSTRE60E5TA20100115.
Story, Joseph (1833), Commentaries on the Constitution of the United States (Boston, MA: Hilliard, Gray, & Co.).
Story, Joseph (1851), Life and Letters of Joseph Story, ed. William Story (Boston, MA: Charles Little & James Brown).
Swift, Zephaniah (1796), A System of the Laws of the State of Connecticut (Windham, CT: John Byrne).
Tang, Terry (2011), “Faleh Hassan Almaleki Guilty: Jury Convicts Iraqi Immigrant For ‘Honor Killing’,” The Huffington Post, February 22, http://www.huffingtonpost.com/2011/02/22/iraqi-immigrant-guilty-honor-killing_n_826840.html.
Thompson, Carolyn (2011), “Jury Convicts New York TV Executive of Beheading Wife,” Associated Press, February 8, http://www.foxnews.com/us/2011/02/07/closing-arguments-begin-new-york-beheading-murder-trial/#ixzz28kCe5EYz.