US History and the New World of Europe - Assignment Example

U.S. History I [HIST 151 Mid-term Examination INDENTIFICATIONS (7) The Puritans: Puritans (advocates of ‘purity’ of worship) were originally English Protestants who found themselves at odds with the Anglo-Catholic format of formal religious observance developed during the reign of Elizabeth I and become even more pronounced under her successors. A number of Puritans emigrated to Holland in the first decade of the 17th century and, thereafter, to the New World. Plymouth Plantation—later commonly denominated ‘Bay Colony’—was initially organized by English Puritan settlers in terms intended to directly reflect the values of Scripture—in large part, the Old Testament—as a counterpoint to those prevailing in Europe. However, it was only a matter of time before the scripture-based constitutional template was challenged (and, to some extent, overcome) by the exigencies of life in the New World. (It should be understood that the first settlement—at Plymouth—occurred in 1620, with the immigrants agreeing among themselves to government under terms established by the Mayflower Compact. However, a more comprehensive constitutional system—the Cambridge Agreement—largely replaced the Compact a decade later and became the defining document of the Bay Colony.) Through the Mayflower Compact (November 1620), the instrument whereby the Puritan settlers in Plymouth Plantation mutually agreed to govern themselves, applied an essentially religious locution to a political end. “[We] solemnly and mutually in the presence of god, and one another, covenant and combine ourselves together into a civil body politic, for out better ordering and preservation…” A covenant, of course, was traditionally restricted to an agreement between God and His chosen people. For the Puritans, its definition was extended to a constitutional agreement uniting the signatories (and, arguably, counting God tacitly among them). The agreement had one distinctly religious objective, but grew out of two quite different immediate causes. The Puritans crossed the Atlantic in company with a number of ‘strangers’ (non-church members), individuals not subject to the authority of the Puritan leadership and, even, arguably a prospective source of sedition. Thus, the language of the Compact, especially its use of the term ‘covenant,’ emphasizes the essential spirituality of the agreement. In addition, the Compact established that the new colony might “enact … such just and equal laws, ordinances, acts … as shall be thought most meet and convenient for the general good of the Colony…” This placed the colonists at implicit odds with the Crown, if only because King James claimed an absolute authority to make and unmake laws for colonial governance. Thus, two basic strains of Puritanism were established. Of the immediate impact, first, Puritans identified their social organization as an agreement in which God was a participant and, second, that among them-selves a measure of democratic equality and fair treatment would prevail. Over the longer term, the Puritans’ Compact established constitutionalism as an underlying structural component of democracy, something genuinely new. (In ancient Greece, for example, democracy often degenerated into mob rule.) Despite the fact that the Puritans conceived of political equality under God as normatively restricted to themselves, their model of polity would eventually find reflection in the Constitution, albeit expressed in much expanded terms. Stamp Act: Enacted by Parliament in January 1765, Stamp Act taxes were excises on all essential legal transactions (e.g., court petitions, harbor entrance and docking, land conveyance, wills) in the colonies. While execution of the tax was in the colonies, the Stamp Act has its origin in domestic British politics. During the period of the Seven Years’ War, the British national debt had risen from 72 million to almost 130 million pounds. Servicing this debt was already causing considerable political unrest in Britain. British Parliamentary leaders were well aware of American opposition to any new taxes, given the bitter and very public reaction to the recently repealed Sugar Act and its economic effects (most notably, a radical reduction in direct American exports to Caribbean and Mediterranean ports, with a consequent diminution in gross income). Lord Grenville, Chancellor of the Exchequer (similar to the American Secretary of the Treasury), faced a particularly difficult problem. He had no constitutional authority to allow the colonists any formal voice in the formulation of official policy. By the same token he (if not that many of his Parliamentary colleagues) understood that some ameliorating gesture toward the colonial assemblies was essential. Grenville chose subterfuge. Instead of an immediate proposal for new taxes, he offered the colonial legislatures the option of taxing themselves to achieve the same goal. American colonial legislatures refused to take up Grenville’s offer. Parliamentary debate on the proposed tax was brief but illuminating. Colonel Isaac Barre, addressing his fellow members on the matter, referred to colonial subjects as “sons of liberty,” that is, men and the offspring of men unhappy with the existing limitations of British government. While Barre did not question the authority of Parliament to pass any such tax act, he questioned the advisability, believing that it would create political problems overshadowing any likely revenue,1 however much the latter might be desired. Barre was prescient. Reaction in North America to Stamp Act taxes was violent, including a mob assault on the house and library of Thomas Hutchinson, comptroller of the currency in Boston. After a brief, if ignominious, history, the Stamp Act was repealed in March 1766. The long-term impact of the Stamp Act was indirect (in the same way, that its predecessor Molasses and Revenue Acts had indirect impacts). The failure of the Act—evidenced by its repeal—pointed to the larger problem of attempts at governing (in this instance by Parliament) without direct input from those directly affected. To a significant extent, the congeries of difficulties engendered was encapsulated in the expression, “no taxation without representation.” (Grenville’s effort at ameliorating the impact of the Act—his political ‘nod’ toward the colonial legislatures—almost certainly had that thought in mind.) In any event, it is possible to find in the failure of the Stamp Act—as in the Intolerable Acts discussed below—at least the hint of an impact on American constitutionalism. The United States Constitution provides that ‘money bills’ (i.e., tax legislation) must originate in the House of Representatives, the legislative house whose membership was directly elected by the people. The Intolerable Acts: Also known as the Coercive Acts (1774), these bills were enacted by Parliament in response to the acts of a Boston mob in destroying a shipment of tea that had been imported under the terms of the 1773 Tea Act. Parliament responded to this offense by passing a number of punitive acts specifically designed to cow the colonial population. They are known to history as the “intolerable acts.” The Quartering Act (1765) was amended in 1774 to permit involuntary quartering of troops on civilian populations.2 The Administration of Justice Act (May 1774) provided that British officials could not be tried in provincial courts for capital crimes, but would rather be tried in Britain for any such offenses. This had the practical effect of allowing venal officials free rein since they could not be held immediately accountable. Responding to the damage caused by the Boston Tea Party, Parliament enacted the Boston Port Bill (June 1774), closing that facility to any use until merchants who suffered financial loss were indemnified. The Massachusetts Government Act (May 1774) effectively repealed the preexisting charter and delivered the colony directly into the hands of the royal governor. In response to these developments, representatives from all the Atlantic littoral colonies (except Georgia) met in Philadelphia’s Carpenter’s Hall from September 5 through October 26, 1774, to consider an appropriate response to the Parliamentary initiatives. The colonies were sharply divided. The Pennsylvania and New York delegations were instructed to seek a pacific resolution with Britain. Other colonies were defensive of their rights but divided on the best means of effecting such a defense. A proposal for a popularly elected “grand council,” representing the interests of all the colonies in dealing with Parliament, had substantial support. However, after the pleas of the Massachusetts delegation, describing in detail the effects of the intolerable acts in that colony, the grand council proposal was shelved. In addition, the colonies agreed to a pact for the non- importation of British goods, to take effect in December 1774 unless Parliament should rescind the Intolerable Acts. No such rescission was forthcoming. And the more pacific goals of the first congress were gravely undermined in April 1775, when fighting between Massachusetts militia and British troops broke out Lexington and Concord. Reverberations from the Intolerable Acts continue to be felt, however indirectly, to this day. The 1787 Constitution included language forbidding the quartering of troops on local populations except in time of war. While today’s national executive may, under very limited circumstances, interfere in the operations of state government (e.g., the 1957 Little Rock, Arkansas, school integration crisis), all aggrieved parties retain inherent rights to access to the courts for redress. And, in a larger sense, both the Articles of Confederation and its successor, the Constitution, the several states were implicitly (yet firmly) understood as antecedent polities, ones that could not be ‘manhandled’ by a superior legislative body (as Parliament had done with the Massachusetts colony in 1774). Declaration of Independence: This document (July 4, 1776) formally obliterated the political links otherwise joining Britain’s American colonies with Britain, itself. Its principal author, Thomas Jefferson, first established the ‘constitutionality’ of the Declaration by adopting wholesale the language of John Locke, the English political philosopher whose writings were directed toward establishing the legitimacy of England’s 1688 Glorious Revolution, the overthrow of James II (an absolutist Catholic monarch) and subsequent enthronement of William of Orange (a Protestant and, at least arguably, a constitutionalist). Thereafter, Jefferson assembled a bill of particulars defining misdeeds ostensibly attributable to George III, Britain’s reigning monarch. Thomas Jefferson, author of the Declaration, was wedded to the political doctrines of John Locke, especially as they were outlined in his Second Treatise of Government (1690).3 Locke favored both a division of government function (between the legislative and royal or executive) as part of the natural order of things, with the legislature supreme and the monarch mandated to faithfully execute the laws. “The great end of men’s entering into society, being the enjoyment of their properties in peace and safety, and the great instrument and means of that being the laws established in that society; the first and fundamental positive law of all commonwealths is the establishing of the legislative power; as the first and fundamental natural law, which is to govern even the legislative itself, is the preservation of the society, and (as far as will consist with the public good) of every person in it. This legislative is not only the supreme power of the commonwealth, but sacred and unalterable in the hands where the community have once placed it (sec 134).” In the Declaration, Jefferson repeatedly points to royal malfeasance, understood in terms of Locke’s understanding of the role and supremacy of the legislature. Among the bill of particulars in the royal indictment, Jefferson states that the King “has refused to pass other Laws for the accommodation of large districts of people, unless those people would relinquish the right of Representation in the Legislature, a right inestimable to them and formidable to tyrants only [par. 5]” and “has dissolved Representative Houses repeatedly, for opposing with manly firmness his invasions on the rights of the people [par. 7].” In effect, Jefferson is equating King George with the deposed King James. Thus, in the logic of the Declaration, if it had been constitutionally permissible to dethrone James II in 1688 because he had usurped the prerogatives of Parliament (and thereby, in so many words, turned himself into an illegitimate tyrant rather than a lawful monarch), it was likewise permissible for the American colonists to do much the same within their own sphere—‘dethroning’ King George (at least insofar as his rule extended to the colonies) because of royal offenses arguably parallel to and commensurate with those of his predecessor, James. It is commonly observed that the Declaration has no legal force, in the sense that the Constitution has legal force. This, however, misunderstands the long-term impact of the Declaration. Among its purposes, as described above, was the establishment of the groundwork of lawful political separation, one based on adherence to underlying, if only tacitly accepted, precepts. This idea of government as social compact subject to the ultimate determination by those affected would find expression in later years in both notions of constitutionalism and the nation’s history. The Constitution’s Tenth Amendment reserves to the states or the people those rights not specifically granted to the Federal government. More ominously, however, the precept underlying unilateral separation would find expression in national crises. John Calhoun’s response to the 1828 and 1832 tariff acts—the right of state nullification, at its own determination, of national legislative acts deemed contrary to the Constitution—was a case in point. And, of course, the secession of the southern states and their reorganization as the Confederacy precipitated the Civil War in 1861. Jefferson’s Declaration may be perceived as an effort to tightly restrict the occasions under which such revolutions might be ‘lawfully’ undertaken. But the precedent ultimately proved arguably to be otherwise. Articles of Confederation: The Articles of Confederation4 formally established a loose federation of the American colonies (including provision for the admission of Canada, should it so choose) then engaged in the War of the Revolution. In constitutional terms, it established a polity that was something more than a treaty alliance of sovereign republics, yet considerably less than a unified nation. The Articles permitted the uninterrupted flow of free citizens (other than “paupers, vagabonds, and fugitives from justice”), but authorized import duties on chattels brought into any state [Art. IV]. In effect, individual states, at least in theory, could use import taxes to pay for its operations or retire its existing debt.5 Delegates to Congress were appointed by state legislatures and served at the pleasure of their respective legislatures (subject to recall and replacement) [Art. V]. Thus, delegates were effectively ambassadors of state governments engaged in negotiation with other delegates, rather than representatives empowered to act with full volition. This ambassadorial function was emphasized by the fact that each state had one vote [Art V], with no consideration of the relative importance of the larger states (e.g., Virginia, New York). By the same token, certain powers regularly associated with fully sovereign republics were denied the several states under the Articles. Article VI provided that (1) “no state … shall send any embassy to, or receive any embassy from, … any king, prince, or state”; (2) “No two or more states shall enter into any treaty, confederation, or alliance whatever between them, without the consent of the United States…”6; (3) the peacetime strength (upper limit) of state naval forces—whose validity is a function of state defense—shall be determined by Congress, although each state was required to maintain an adequate militia; (4) “no state shall engage in any war with the consent of the United States … [unless facing immediate foreign attack or native Indian uprising]”; and (5) the expenses associated with the common defense are to be paid from a common fund with contributions allocated to the several states based on the value of real property. (This, again, points to the wartime character of the Articles.) The ultimate impact of the Articles was found in their inherent weaknesses. The several states simply could not function as semi-independent nations, without damaging the interests of others in the compact. And, by the same token, they could not function internationally as independent states, if only because they lacked the assets (and often the manpower) to do so. There were specific components in the Articles that found expression in the successor Constitution. Interstate compacts are lawful, but Congress must first approve them. (It might even be argued that constitutional language establishing the Supreme Court as a venue of first instance in those cases in which a state was a party to a suit amounts to a nod in the direction of state sovereignty as it was originally understood under the Articles.) More sadly, the Constitution’s language allowing for forcible return of escaped slaves was taken almost verbatim from the Articles, although the framers looked to the eventual withering away of slavery, given the twenty limitation on the import of such persons. Shays’ Rebellion: In the mid-1780s, the Massachusetts government enacted tax legislation to pay the state’s foreign debt and placed much of the burden on rural farmers. (Voting power was largely in the hands of wealthy merchants and traders. In effect, they transferred the general tax burden to those least able to pay.) These yeomen farmers regularly had little access to specie—much of the economy of western Massachusetts was a function of barter, with small amounts of currency becoming available at harvest time. In order to secure the revenue, tax collectors seized defaulters’ properties and imprisoned those unable or unwilling to pay. In response, Daniel Shays, a Revolutionary War infantry captain, organized a tax rebellion. Its members resorted to arson, seizing arsenals, and arresting would-be tax collectors. The rebellion was only put down with the greatest of difficulty and the outcome was more of a truce than a defeat. Shays’ uprising caused considerable alarm throughout the country and provided the immediate impetus for a constitutional convention that might find a solution for the underlying problems.7 Two provisions of the new Constitution were in direct response to Shays’ Rebellion. The Constitution forbade imprisonment for debt and preexisting state debts were subsumed under the new government. More indirectly, language in the Constitution (Article IV) provided that Congress shall assure each state a republican form of government. This, very indirectly, may be interpreted as intended to prevent (or at least discourage) the arbitrary manner of taxation undertaken by Massachusetts and having precipitated the Rebellion. Resort to organized violence in response to arguably unacceptable government behavior would occur from time to time during the course of American history. The establishment of the Ku Klux Klan during the post-bellum Reconstruction period is arguably a case in point (if a shameful one). Marbury v. Madison: This Supreme Court decision established judicial review, the principle that the Supreme Court should be the final arbiter in determining whether Acts of Congress and actions of the executive are consonant with the language of the Constitution. This was accomplished through the resolution of an otherwise obscure suit at law brought by a Maryland businessman, William Marbury, requesting the Supreme Court issue a writ of mandamus to Secretary of State James Madison, requiring the latter to deliver to Marbury an already signed and sealed appointment as justice of the peace (JP) for the District of Columbia.8 Marbury had already exhausted other means of redress before appealing to the court.9 In coming to a decision, Marshall had to address the issues of Marbury’s right to his commission as a JP; Marbury’s right to seek redress through the courts in the event that he had a the right to the said appointment; the right of the president to place limits on his agents (executive privilege); and, the crucial point, the constitutional authority of the Court to issue a writ of mandamus (a court order that the executive branch would almost certainly ignore, claiming executive privilege). After disposing of the first two matters,10 Marshall addressed the matter of mandamus and, in so doing, set the course of the Supreme Court for the next two centuries. The statutory language of the Judiciary Act of 1789 was quite clear. At issue was its constitutionality. While Congress may determine the reach of the appellate jurisdiction of the Court, its original jurisdiction is expressly determined by the Constitution. “In all cases affecting ambassadors, other public ministers and consuls, and those in which a state shall be party, the Supreme Court shall have original jurisdiction. In all the other cases before mentioned, the Supreme Court shall have appellate jurisdiction, both as to law and fact, with such exceptions, and under such regulations as the Congress shall make.”11 Given the express language of the Constitution, the Court had no authority to issue a writ of mandamus except in a case of original jurisdiction (which Marbury was determined not to be). Marshall continued, “It is a proposition too plain to be contested, that the Constitution controls any legislative act repugnant to it.”12 As noted at the outset, the Court’s decision in Marbury established judicial review. In at least some instances this would amount to disguised legislating from the bench (as was arguably the case with court decisions relating to the Civil Rights cases of the 1960s and, more recently, the spate of affirmative action cases). Viewed at a larger scale, the history of the Court can be understood in terms of what its membership considered the appropriate reach of judicial review—largely concerned with contracts and commerce during the first century of the Republic, a restraining factor in responding to social legislation during the first decades to the 20th century, and much the opposite a generation later. ESSAY QUESTION What motivated Europeans to establish settlements in the New World? What made it possible for them to undertake those settlements? Introduction Any appreciation of the various colonization models employed by European powers in the New World ultimately depends on an understanding of the factors that encouraged the first of the modern exploration efforts. Access to the riches of the Orient was almost entirely within the province of the Ottoman Empire, which, in effect, charged a massive transit tax on spices originating in the Far East.13 In order to redress this politico-geographical imbalance, Portugal, fronting on the Atlantic, initiated an exploration effort directed toward the west coast of Africa. Under the auspices of Prince Henry of Portugal, known to history as Henry the Navigator, Portuguese mariners began a series of expeditions, annually proceeding ever further south, along the West African coast. They established the first regular coastal fortifications, which eventually would facilitate the slave trade to the Americas. However, the format for Iberian involvement in the Americas was already established. Sugar was already a commodity in great demand—it had been a European luxury item since the time of the Roman Empire—and both Spain and Portugal were growing this labor-intensive product on coastal islands. African slaves were in demand to work the sugar cane fields, an occupation that would encourage their capture and exploitation for the next four centuries. The pattern of exploitation already having been established, the Columbian discoveries of a New World would open up opportunities to sea-faring nations with easy access to the Atlantic14 to take advantage of the same. Background In order to provide for a reasonable division of prospective spoils, late 15th century Vatican politics allowed for the division of the “unknown” non-Christian world between the two major ocean-going powers, Spain and Portugal. The north-south longitude established by the 1494 Treaty of Tordesillas was the demarcation, with Portugal having exclusive rights to the west. Thus the eastern bulge of South American became Portuguese-speaking Brazil, with the remainder of Latin America belonging to Spain. The more northerly powers did not recognize the Tordesillas agreement, although they were unable to penetrate South America to any significant degree.15 The situation was different in the Caribbean, where small island chains were particularly vulnerable to both sea-borne attack as well as support from home countries. The Spanish experience in the New World What is particularly remarkable about the Spanish penetration and conquest of so much of America was its accomplishment by so few men. Indeed, it was Spain’s policy not to encourage significant settlement by her subjects in the New World. Instead, government remained a function of bureaucrats dispatched from Madrid for that purpose.16 From the Spanish perspective, the primary purpose of the American colonies was to provide their wealth to Spain. African slavery proved essential to these economic ventures. The Native Americans proved to have no significant resistance to European diseases and died in enormous numbers. This is evident in the demographics of the Caribbean and the northern coast of South America (Venezuela and Colombia) today. Africans, largely accustomed to the major old world microbial and viral killers—small pox, yellow fever, dysentery, and the like—could prevail, albeit with catastrophic losses. The Native Americans often died in such numbers that some tribal groups (e.g., the Carib) ceased to exist. The only country in which a significant native population survived was Mexico, thus making it in the 17th century the only nation in the region to have a very small African population. However, it is estimated that the total population of Mexico in 1620 was little more than a million. When Cortez arrived in 1519 it was somewhere between 25 and 40 million. Smallpox was the principal killer. However, the residual population was enough to perform the agricultural labor and, more important from the European perspective, extract the precious metals that were exported to Spain. A practical long-term outcome of this colonial policy was the existence of a relatively small white aristocracy governing much larger Native American, African and mulatto populations.17 The English experience in the New World The English colonization was further north and thus not particularly amenable to the sugar and coffee production that were the mainstays of the Spanish and Portuguese colonies. However, the English settlers in Virginia would begin the production of, and promote the export of, a native product, tobacco, which would eventually prove to be a major source of income. (It is beyond the purview of this essay to consider the English ventures in the Caribbean, if only because they were not settlement colonies in the generally accepted sense of the word. However, the English were particularly envious of the Spanish holdings in the region—as were France and the Netherlands—with their lucrative production of sugar and coffee. Thus, as a result of continuous warfare and depredation, such productive islands as Jamaica, Hispaniola and Curacao fell to the northern European interlopers, no doubt much to the chagrin of their Spanish opponents.) As a practical matter, England lacked the wealth to subsidize any colonies established in the Americas; they were expected to support themselves.18 And, as luck would have it, the eastern coast of North America, unlike Mexico and Peru, was devoid of precious metals. The northern country was cold in winter and not particularly productive during the rest of the year, given the agricultural practices of early 16th century England. However, such an area could serve a purpose that had no comparable parallel in the Iberian states. Following the English reformation, England had a number of religiously dissident groups. American colonies for these dissidents could serve a multiple purpose: they would remove them from the immediate English environment and, furthermore, by their presence in the new world, would preclude further Spanish expansion northward. Thus, Catholics settled Maryland. Puritans and Congregationalists established settlements in New England. And Quakers established themselves in Pennsylvania. It was only in the southern English colonies (Virginia and South Carolina) that significant numbers of established church members predominated. Eventually, these various English colonies flourished precisely because they established integrated economies not unlike those in northern Europe. The Iberian colonies remained attached to the production and export of commodities. If one were to draw an historic parallel to explain the long-term impact of such economic activity on wealth development, it would be the regional differences in the United States between the slave-holding southern states and the “free soil” parts of the country. The primary economic activity of the southern states was commodity export (primarily raw cotton, although rice and tobacco were also significant earners). They did not develop an industrial infrastructure—there was no purpose in having one—because income was derived by translating coerced labor into exportable commodities. The northern states developed major cities and an industrial base. Even as early as the 1830s, it was evident that “free soil” yeoman farmers were, per capita, substantially more prosperous than their southern counterparts. The French experience in the New World The French experience in the New World differed in a number of crucial areas from both the English and the Spanish. The intensely centralized French government of the 17th century expected any popular French settlement in the New World to reflect the already existing political values of the mother country. This had the practical effect of restricting immigration to the Saint Lawrence River valley19, although France, at the time, enjoyed a huge population advantage over both England and Spain. Had the French government been less overbearing, it is likely that there would have been a much larger French migration to North America and, as a consequence, a considerably more formidable New France. The primary French interest in Canada was the fur trade. In a sense, France had an economic interest similar to that of Spain in Mexico and South America—extraction of wealth for transfer to the mother country. Also like Spain, French explorers, though few in number, performed almost incredible feats of long-range exploration through much of the North American continent. France established claims to huge tracts of North America but, as noted above, did not make a commensurate effort to reinforce that claim with a settler population. The end result was the loss of Canada (to Britain) and Louisiana (to Spain), as a consequence of defeat in the Seven Years War.20 French activity in the Caribbean pretty much replicated that of the other European powers in that area. Haiti was France’s most valuable possession. During the 18th century it was the world’s largest producer of sugar and coffee, taxes on the import of which into metropolitan France provided a substantial fraction of the Paris government’s revenue. Works cited in the preparation of these answers Agreement between the settlers at New Plymouth (1620), Avalon Project, Lillian Goldman Law Library/Yale University Law School, 1909 [avalon.law.yale.edu/17th_century/mayflower.asp] The Coercive [Intolerable] Acts, U.S. History [online], 2007 Quartering Act of 1765 (as amended in 1774) [www.ushistory.org/declaration/related/q74.htm] Boston Port Act (1774) [www.usconstitution.net/bostonportact.html] Administration of Justice Act (1774) [www.usconstitution.net/adminjustact.html] John Locke, The second treatise of government (1690), Constitution Society, May 2002 [www.constitution.org/jl/2ndtreat.htm] Summary of the 1765 Stamp Act, Colonial Williamsburg Foundation, 2009 [americanrevwar.homestead.com/files/stamp.htm] U.S., Archives, Declaration of Independence (1776) [www.earlyamerica.com/earlyamerica/freedom/doi/text.html] U.S., Archives, Articles of Confederation and Perpetual Union, 1781 [www.usconstitution.net/articles.html] U.S., Supreme Court, Marbury v. Madison, 1803 [www4.law.cornell.edu/supct/.../USSC_CR_0005_0137_ZS.html] Read More