By Bruce P. Frohnen.

From Rome, through the Italian and German city-states, to the Dutch experience and the conflicts that shaped constitutional monarchy in Britain, and most importantly for us, the colonial agreements, peoples, and social order that produced our Constitution, law has been essential to self-government. And law, for a self-governing people, must be ordered under a constitution that is itself law. Those who serve in a republican government must be of the people and answerable to them. This cannot be unless the Constitution—the agreed upon structures and rules for making rules—have the force of law, such that they can (and will) be enforced against the governors as well as the governed. Only in this way can respect for law become fully ingrained in the republic, and only such respect can breed meaningful public cooperation among people with varying interests, beliefs, and connections, enabling them to uphold common laws focused on their common good.

The conviction that there is no sovereign whose will is above law allowed peoples to forge constitutional order; it enabled Americans, among others, to channel and limit political power and conflict. Constitutional structures with the force of law provided public but non-governmental space so that the people might govern themselves through social, cultural actions forging and enriching traditional institutions, beliefs, and practices. There is a deeper, religious grounding to self-government captured by Willmoore Kendall and George Carey’s explication of America’s central “symbol” of self-understanding as a virtuous people deliberating under God. That symbol embodies an understanding of reality itself as bounded by laws of right and wrong which free peoples work to recognize and put into action within their specific circumstances. This understanding allowed reasonable men to organize political power, through law, in ways that support rather than command or replace the natural associations in which people learn to govern their emotions and appetites and serve common goods. In America the result was a compound republic of layered authorities leaving room for substantial individual and local liberty within an ordered polity. Whatever the flaws of any specific republic, it was free in that its people governed themselves in pursuit of good lives.

For decades, Philip Hamburger has been writing penetrating analyses of Americans’ descent from citizens of a constitutional republic to subjects, not of a soft, but of a “sinister” despotism. His most recent work, Purchasing Submission: Conditions, Power, and Freedom, is a kind of murder mystery that could be subtitled “Death by Bribery.” In it he tells how a self-conceived knowledge elite has used the federal government to give subsidies and other forms of largesse to persons, groups, and even states, accompanied by increasingly intrusive and onerous “conditions.” Over time, the beneficiaries have become ever more submissive to the demands of their supposed benefactors. The result has been fatal to our Constitution, which has been replaced by, in Hamburger’s words, “a strange mode of governance, in which Americans sell their constitutional freedoms—including their self-governance, due process, and speech—for a mess of pottage.”

The system of anti-constitutional conditions Hamburger dissects in Purchasing Submission builds off earlier deviations from constitutional government he has described in previous works. His Separation of Church and State details that false doctrine’s origins in bigotry and bad faith, as well as its support for an individualism hostile to constitutional government. Liberal Suppression: Section 501(c)(3) and the Taxation of Speech, shows how the cultural shift toward atomistic individualism empowered the government to seize control over charitable and religious associations, effectively ejecting them from political life in the name of “democracy.” Is Administrative Law Unlawful? is a devastating critique of Progressive claims to a constitutional basis for our administrative state and its channels of power. He picks up the theme of unchecked administrative power in a very short work, The Administrative Threat, in which he details for a broader audience the essential absolutism of administrative governance as well as its very concrete denial of constitutional freedoms guaranteed to Americans, including due process rights and trial by jury.

The bulk of Hamburger’s work focuses on the development of false doctrines and practices that have undermined our constitutional republic. His primary purpose seems to be reminding lawyers of the Constitution’s structural nature, that structure’s necessity for maintaining self-government, and lawyers’ duty to uphold the Constitution. His Law and Judicial Duty lays out the duties of lawyers, and especially judges, in a free government to uphold the law of the land, including the Constitution. That work, to which I turn toward the end of this essay, deals with a crucial element of a more general constitutional morality which must guide public officials and those who elect them if a constitutional republic is to survive, or be resuscitated. Here I will use capsule reviews of several of Hamburger’s books, culminating in Purchasing Submission, to lay out what I believe is a consistent and powerful argument about our constitutional decline and the structural requirements of self-government. 

In Separation of Church and State Hamburger details the false doctrines used to extract and bar religion from American public life. Our Constitution banned federal interference with state and local religious practices. These practices differed in many ways but maintained a common emphasis on religion’s centrality to the life of the community, and sometimes included local or state religious establishments. The Constitution merely sought to keep the federal government from interfering with state traditions regarding religious liberty and self-government. The radical separationist doctrine of the seventeenth-century radical Roger Williams, borrowed briefly by Thomas Jefferson for its political utility, played no role in our constitutional governance. But the phrase “separation of church and state” took on a new life during nineteenth-century debates over public funding for parochial schools. As Hamburger shows, this new iteration was rooted specifically in anti-Catholic prejudice and a foolish faith in the cultural power of a thin religiosity tending from its very inception to make religion little more than a handmaiden of “good policy.” Initially aimed only at barring public support for Catholic schools (on the grounds that Catholics owe allegiance to a “foreign prince,” namely the Pope) separation of church and state soon undermined the purpose and structure of our Constitution. 

The demand that “church and state” (as if each were a unitary entity) be separated began with the belief that religion could be kept in the school and public square in the form of general, vaguely Protestant formulae and traditional community activities. It spawned the radical anti-religious corruption of our Constitution that stripped our schools of meaningful education as well as prayer and our public square of any common standards or meaning. In the process it took away the people’s right to organize their own communities, including their common observance of religious customs and rites, and undermined the people’s understanding and practice of self-government.

Liberal Suppression shows the massive impact of separationism on American culture, society, and ultimately our Constitution. Hostility toward one group (Catholics) quickly devolved into a marked hostility toward any authority residing in a partial grouping, be it a religious community or other voluntary association. Couched as a defense of American democracy, a socially intolerant individualism reshaped America’s unwritten constitution, and with it the people’s ability to uphold their written Constitution. 

As Hamburger notes, “democracy”

became a political and philosophic code word for the sort of society that so many liberals sought—a society in which individuals stood alone in relation to government. Although this individuality may initially sound liberating, it came (as Tocqueville understood) with an enervating equality—to be precise, an equal weakness in relation to government. Americans traditionally overcame this equal weakness through their voluntary associations, but this became increasingly difficult when the speech of such bodies was condemned as the ‘propaganda’ and ‘influence’ of antidemocratic and thus ‘subversive’ organizations.

This enervating individualism came to dominate as liberalism grew from a minority position within a society made up of natural, local associations into a dominant orthodoxy. Voluntary associations came to be seen as subsidiary units to the state that must conform to the tenets of the national, democratic faith if they are to be tolerated. 

From before the Founding into the twentieth century, nonprofits’ essential character as associations meant, under our traditional, common law, that their incomes, like their property and activities in general, are not appropriate objects of taxation. But today nonprofits must submit to rules barring them from a wide variety of expressive activities central to their purposes, lest they suffer crushing financial penalties. Section 501(c)(3) of the Internal Revenue Code, painted as the grant of tax benefits to nonprofits, forces these associations to give up their rights to speech, petition, and religious liberty merely so that they might be left alone. In effect, 501(c)(3) is a government protection racket aimed at suppressing expressive activities challenging liberal orthodoxy.

In Is Administrative Law Unlawful? Hamburger explains how our administrative state, from its origins in the Progressive movement, grew as a means of working around our constitutional structure. Separation of church and state and the individualism it spawned had degraded republican politics from the common pursuit of a decent, virtuous life of self-government within a multiplicity of associations into a generic tool for securing various specific “good things.” This soon translated into the demand that government “fix” seemingly every problem and injustice political actors could think of. In this light, the Constitution was no longer a higher law helping citizens maintain their way of life, but a set of poorly designed mechanisms producing a “deadlock of democracy” frustrating the will of an abstract “sovereign” people.

Our Constitution of limited, enumerated, and separated powers within a federal republic was not designed to facilitate governmental action. It was designed to protect Americans’ liberties by limiting government power in both its scope and its methods. Republics are, in their essence, the self-governance of the people through law. Thus, the Constitution, as the highest law, settles the means by which the government may legally act. Its structures by nature limit our federal government to the exercise of specific, enumerated powers, principally through lawmaking in the legislature and adjudication in the courts. Such limited, constitutional government, prioritizing as it does the right of the people to grant or refuse their consent to changes in governmental structure, became highly inconvenient for those seeking to address various problems (real and imagined) in American economic, political, and social life. Progressives were unable or unwilling to secure the authority to regulate American life through constitutional amendments and unwilling to take the time, trouble, and political responsibility of enacting detailed laws where the Constitution made some of that power approachable. And so they proposed, and government functionaries pushed through, legislation simply “delegating” vast realms of power to the various agencies they created in contempt of the law of the Constitution. 

The resulting administrative state is doubly unconstitutional. First, it denies constitutionally guaranteed procedural rights to those prosecuted by agencies enforcing their own edicts on businesses, local associations, and individual persons. Second, it denies the American people the right and power to govern themselves by granting or refusing their consent to a vast expansion of governmental power over their daily lives. 

The administrative state is a collection of new avenues of power outside the Constitution. No longer are laws made only by the people’s representatives in the legislature. No longer are disputes adjudicated under these laws only by constitutionally established courts providing full constitutional rights and procedures. These tasks increasingly fall to unelected bureaucrats effectively answerable to no one. 

Convinced they cannot survive without the administrative state, Americans seem unhappy with the arbitrary methods and faux processes accorded them by various bureaucracies. Hamburger points out that such tyrannical practices are of a piece with the unconstitutional grounding of the administrative state and its character as a series of arbitrary, extra-constitutional avenues of power. Administrative government by its nature is rule by edict. It cannot be made amenable to the structures of a constitutional republic.

Purchasing Submission analyzes the final, capstone element in our fundamentally non- or post-constitutional regime. Here the federal government rules society and its component parts through “agreements” conditioning federal largesse on recipients’ surrender of their rights to self-government. Among the most obvious exercises of this unconstitutional power was the federal government’s threat during the 1980s to withhold Department of Transportation funds from states that failed to raise the minimum drinking age to 21. Every state eventually complied. Good policy or not, the means used to achieve it were, in effect, extortion. Washington essentially told states, “Raise your minimum drinking age or else that highway money we’ve been giving you, on which you’ve come to rely, will disappear.” 

The drinking age example hardly represents the only or most damaging misuse of the federal government’s supposed power to attach unrelated conditions to its spending. Federal grants in aid to the states, which now make up 30% of their budgets, have strings attached that force states to accept federal control over resource management, city planning, manpower planning, and enforcement planning. Health and Human Services funding has been extended, followed by threats of retroactive repayments unless state universities and other entities institute pre-licensing reviews censoring inconvenient political and scientific opinions. Education Department funding for state public schools has been so compromised by demands for various expensive and harmful race, sex, and sexuality-based programs, along with kangaroo courts to hear Title IX claims, that at least one state (Tennessee) is actively considering simply refusing all of it. Perhaps most damaging (and the subject of Liberal Suppression) the federal government has used tax subsidies (and the threat to retroactively take them back) to force church and other charitable institutions to withdraw from public debates, silencing once powerful voices influencing public policy and cultural debates.

This system of submission is justified as “voluntary” because entities seeking money or other benefits controlled by the federal government formally agree to the conditions—the network of strings attached. The “deals” are deemed constitutionally permissible because they are not openly coerced. In fact, however, the deals often are coerced, as when broadcasters must apply for licenses the government has chosen to deem its own property or those seeking to build on their own property are forced to comply with demands on how and how much they will develop it. 

As Hamburger points out, conditions generally are not related to the goods provided and so are, in effect, regulations that are imposed contrary to our law and Constitution. When, for example, the government chooses to purchase an airplane, it properly conditions payment on the airplane meeting its specifications. But when it demands that universities receiving federal funding agree to establish boards to pre-approve (and disapprove) research projects and meet a host of other conditions, the federal government is regulating without warrant. And when the FCC dictates programming decisions or local governments (often following federal guidelines) require that property owners cede control over part of their land they also are regulating—sometimes directly violating the Fifth Amendment by “taking” property for public use without compensation. 

In some instances, the federal government might gain the right to impose regulations similar to these conditions or restrictions, if it were to go to the trouble of passing laws doing so. But using conditions to in effect buy the right to dictate citizens’ behavior is contrary to law; it establishes an extra constitutional avenue of power by which the federal government can control people’s lives. All this is made worse by the fact that the use of a multitude of “agreements” to establish regulatory regimes saps the will of the people to join together to oppose the policy being implemented, thereby allowing the government to achieve ends it could not achieve through open and above-board constitutional means. Both the means and the results are unconstitutional. Hamburger quotes the Supreme Court decision in U.S. v. Butler, stating that, where Congress has “no power to enforce its commands,” it “may not indirectly accomplish those ends by taxing and spending to purchase compliance.” Such conduct subverts the powers reserved to the states and the people, stifling our constitutional system of localized self-government. Given that the federal government is using states and other entities to do its regulatory bidding, its agencies are the authors of those acts, and so those acts ought, legally and constitutionally, to be prohibited as beyond their authority.

The bonds of the Constitution have been broken by officials intent on using the federal government to co-opt states, as well as the multitude of other associations in which Americans once governed themselves, to pursue their own designs. These officials have forged

an alignment of federal, state, local, educational, corporate, and other private bureaucracies. It is an unbroken wall of power that discourages legal and political resistance and renders private life vulnerable. By imposing aligned policies, it homogenizes institutions and eventually the people, ultimately consolidating government and society, so that little remains outside the federal imperium except in name.

As this new system has been constructed, our Constitution has been reduced from the higher law its framers intended and the people ratified to a mere agreement effectively manipulated and constantly “renegotiated” by members of a separate “knowledge class.” This class is effectively above the law. Its members need not abide by the rules that go along with the power to coerce; they simply negotiate, from a position of insurmountable strength, with those they seek to control. And they need not negotiate with everyone they seek to control; a series of deals with particular states, corporations, or other entities will render effective, common opposition to their accession of power untenable. Thus, from a government of limited authority structured to promote and mediate among flourishing associations, our republic has descended into a seemingly chaotic yet comprehensive web of powers emanating from a multitude of agencies over which the people have no meaningful control. 

Whether in the academy, on the bench, or in their corporate and government offices, today’s elites celebrate their victory over constitutional law. They emphasize “function” over form and structure, insisting that policy outcomes are all that really matter. Their bowdlerized concern to uphold “justice as fairness” has left them incapable of understanding the importance of legal and political structure in maintaining a free, well-ordered society. But, as Hamburger notes, even the individual rights that functionalists spend so much time lauding are by nature structural.

Constitutional rights are not merely personal claims; more broadly, they are legal limits on government. Indeed, constitutional rights secure private spheres of freedom, such as religion and speech, precisely by confining public power. And this is no surprise, for rights were adopted as structural limits on power. The Constitution initially sketches out the confined extent of federal authority with the broad brushstrokes of enumerated powers, and then it pencils in more detailed limits with rights. The rights, in other words, are further limits on the powers. 

Rights protect spheres of self-governance—some individual, more associational, all building upon the very structures which judges, administrators, and legislators have broken or sidelined in pursuit of an ever-expanding power to remake the world to suit their own tastes. When the structures are compromised or evaded, so are the rights, and so is the ability of Americans to govern themselves in a free republic.

In Purchasing Submission, Hamburger spells out the conflict of visions underlying the federal government’s breakout from the Constitution. One side values structure and limits on government to facilitate primarily social human action. The other sees the Constitution as a set of more-or-less wise and always negotiable guidelines to be used for concrete ends. One sees in the clear language of the Constitution a limitation on the federal government’s authority, limiting it to the wielding of specific powers, with the spending authority itself limited to action within those enumerated areas and aimed at common, national rather than regional goods. The other sees only the nation, which is to be rendered more uniform through national regulation—often aimed at one state or region for political reasons or to make everyone “more equal”—justified by abstract ideals independent of any pre-existing law. One is the vision of a republican people. The other is the vision of the central government and of the anointed knowledge class that claims the right to run it.

Citing Richard Cappalli, Hamburger points out that

The America envisioned by the federal government, is ‘bureaucratic and rationalistic. It values symmetry in the ordering of public institutions, universalism as the guiding principle of public programs…; efficiency in the conduct of public business and professionalism in public personnel.’ In contrast, state and local America has been ‘traditional rather than rationalistic.’ It ‘conducts public business in ways that vary from one locale to another, through institutions and processes that have developed largely through custom and habit and are nowhere highly systematic.’ And it places less value on ‘professionalism in personnel’ than on ‘identification with the local community.’

The vision of state and local America once was the vision of Americans in general. It was the vision of a self-governing people. But how can a people govern itself once the Constitution has been degraded from the highest law of the land into a set of provisions followed, twisted, or ignored as dictated by the will of the governors and the “deals” they strike with various subjects? Obviously, it cannot. And here we see the necessary connection between structure and virtue.

Especially in Law and Judicial Duty, Hamburger touches upon the deeper sources of our unconstitutional condition. For many decades, judges in the United States recognized that they had a sacred duty to decide any dispute coming before them according to the law of the land. Laws and even constitutions were parts of that law of the land and were to be interpreted, not according to abstract ideals (let alone the policy preferences of the judges) but according to traditional norms and understandings to throw light on the specific terms written in any statute. “Judicial review” is largely a misunderstanding of judges’ traditional duty to decide conflicts among various laws (including between laws and constitutions) so as to vindicate the superiority of some laws over others—most importantly the will of the legislature representing the people as a whole (the Constitution) over the will of any lesser body. 

American judges, as officials within a constitutional republic, had a moral duty to uphold the Constitution in its letter, spirit, and structure. This meant they were to exercise judgment rather than will. Likewise, members of Congress and of the Executive branch recognized their moral duty to obey the law they made or executed, including the Constitution that laid out their powers and the limits of those powers. The highest law of the land, the Constitution, sets forth a structure as well as specific rules. An official within that government, then, was obliged to carry out the proper functions of his office and to work within that structure to defend it from incursions and misuses by other officials. This was the constitutional morality on which our republic relied until it was eroded and eventually dismissed in pursuit of unconstitutional power.

If the judges, or any other person or body, are above the law, in the end there can be no law, but only the will of those who hold power. Sometimes the law seems impossible to uphold in given circumstances, or simply has nothing to say on a specific subject. But only those with the character necessary to recognize and follow their duty to uphold law will meet such circumstances with the attitude and skill necessary to maintain the coherence and authority of the system of laws on which we all depend for social order. The hubris of lawmaking through “judicial review,” of setting up channels of power outside the Constitution in an administrative state, and of bullying states, associations, and individual persons into exchanging their right to self-government for federal largesse or leniency allows officials to consider themselves masters rather than servants of the law of the land. It has degraded their character and made them, not the masters of the Constitution, but simply more pieces of netting within a comprehensive and overlapping but ultimately incoherent web of power.

Hamburger’s structural understanding of the Constitution, and of republican constitutionalism more generally, is that of its framers and was once understood by lawyers, judges, and people in positions of political power as well as by the people themselves. It has become a distinctly minority position. But Hamburger has devoted the bulk of his career to spelling it out and showing its accuracy through historical and textual analysis, and to showing the debilitating consequences of its loss. The contemporary fixation on emotion and various utopian and dystopian visions (from socialist dreams to pandemic and climate change nightmares) have not only further concentrated power but blinded ever more people to the connection between order in the soul and order in the commonwealth.

Nevertheless, virtue and structure are related in politics because both concern the proper ordering of powers, motivations, procedures, and goals. This is why the notion of judicial duty is so central to Hamburger’s body of work. What others of us more generally term constitutional morality is the recognition of our duty to uphold and protect the law of the land. This involves self-control, even self-denial, and recognition that one is placed within a multiplicity of authorities—whether legislative, executive, and judicial or familial, religious, and cultural—all of which have rightful calls on our loyalty and service. The task of reconstituting our republic must, then, involve the restoration of balance and restraint as well as responsibility and a return of powers to where they belong.

Restoring the republic, if it remains possible at this late stage, would entail a recovery of character among the people. It also would require recovering a structural understanding of the Constitution that gives priority to order and limitations on power rather than the drive to use power to make our world more “fair.” It would prioritize freedom within natural associations above any freedom from the various harms and tragedies of life the national government claims it can secure for us. More than anything, it would prioritize self-government over efficient or even effective government, if by “effective” one means the ability to quickly impose the will of the governors, however derived.

The task’s difficulty would be great, in part because many of the things done by the federal government under the current regime are, or at least seem, good. Even many of the specific restraints imposed by conditions seem like good ideas to many. For example, Hamburger points out several dehumanizing sets of conditions involving recipients of federal needs-based support. These include the requirement that many welfare recipients “consent” to warrantless searches of their homes. Such conditions are justified as a means of preventing bad conduct, protecting the programs, and tailoring services to those in need. But should we really be approving situations that place the government in such control over the lives and rights of Americans, whatever their financial situation? One would think that other forms of support for the poor, such as providing paid work opportunities rather than government hand-outs-with-strings, would be more conducive to maintaining a free people with compassion. Other, more local solutions involving direct, personal involvement also once provided help consistent with republican virtues and could do so again. If a thing cannot be done by government within the structure of the Constitution then it ought not to be done by government.

Rejecting conditions often would undermine administrative programs many see as essential, but which themselves are unconstitutional. Conditions keep administrators from constantly having to make new rules or engage in endless litigation. But this problem, too, would be answered by a more modest federal government, with a legislature that took the time and resources for itself to write full, detailed laws rather than hand the job over to bureaucrats. Such legislation, combined with a renewed understanding that most of the business currently done at the federal level belongs with the states or the people would prevent most litigation from ever starting. How? By redirecting governmental energies to their constitutional channels and providing more space for informal, social, cultural, and private economic action to resume their proper places in our lives.

This is not a recipe for chaos or government-by-corporations. Large corporations would have less power under constitutional governance because they would have fewer means by which to secure subsidies and various other favors and programs of protection for their interests. From the early railroads to the juggernauts of the era, government subsidies and administrative carve outs have built the giants that have undermined the people’s economic well-being and self-government. Without the pressures of federal conditions and mandates, state and local governments could again be means of self-government, enabling the people to pursue their overlapping common goods.

As to the means of recovery, Hamburger points especially to the common law doctrine holding some contracts, including contracts with the government, void on grounds of “public policy.” Currently mere cover for the prejudices of particular judges, this ancient doctrine once protected traditional elements of republican government, including the separation of powers and federalism, from being undermined by (real or specious) private agreements. As Hamburger notes, 

The Constitution is a public policy that rises above mere conditions, whether stipulated by Congress or agencies. The Constitution establishes the government’s power to regulate and adjudicate—respectively, through acts of Congress and judgments of the courts—and it is against the Constitution’s public policy for government, by means of regulatory conditions, to create alternative mechanisms for binding regulation and adjudication.

Public policy—our traditional order and priorities as a people—also favors federalism, and so the federal government is not authorized, through law, delegation, or agreement, to “commandeer the states, defeat their laws, and otherwise undermine their separate sovereignty and their people’s freedom of self-government.” Important rights, of the parties to any agreement or of the people as a whole, have been protected, historically, on public policy grounds. In terms of federalism, for example, states have a right to govern themselves and the people have a right to govern themselves in their states, through their own state representatives. Such essential interests are intended to be protected by the Constitution—including through limits on federal spending and the limits of the supremacy clause, which, while upholding the power of federal law, does not extend this status to mere regulations, let alone agreements.

Perhaps part of the solution would be a resuscitation of an old understanding of the term “inalienable rights.” A right that is not alienable may be seen as one no person can rightfully give up, or bargain away in any agreement. In a republic, rights are not merely trumps or claims belonging to individuals. Rights protect everyone, especially in their right to self-government as a people. The goal, after all, is not some unattainable, abstract, and atomistic “autonomy” of the individual. It is self-government as part of a free people.

Hamburger has constructed a compelling argument, with abundant evidence to back up his claims about the structural demise of our constitutional republic. In so doing he also has given us much to consider regarding whether and how our republic might be reconstituted. At this stage one (or at least this reviewer) wonders what Hamburger would make of the use of the Fourteenth Amendment—intended to extend certain fundamental rights and protections to the freedmen after the Civil War—to establish a civil rights state. The degradation of the Constitution from a structure of self-government into a tool of government action aimed at subjecting a free people to officials’ own unchecked power clearly was accomplished in part through the manipulation of “rights talk” and the misdirection of popular concern away from integrating freedman into our self-governing people and toward construction of mechanisms establishing universal control over individual persons’ behavior and life chances. How and why this occurred seems a subject worthy of further study.

Bruce P. Frohnen is Professor of Law at Ohio Northern University College of Law. He has served as Charles Evans Hughes Professor of Jurisprudence at Colgate University, Thomas Bahnson and Anne Bassett Stanley Professor of Ethics and Integrity at the Virginia Military Institute, Visiting Scholar at the Johns Hopkins School of Advanced International Studies, Legislative Aide to a United States Senator, and Senior Fellow at Liberty Fund, Inc.

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