How Do We Think About Election Disappointment?

The reality of this election day is that tonight the polls will close and the results of all the races will be final. This begs the question, what comes after the election? What are you supposed to do if every proposition that you’ve studied and voted on ends in the opposite outcome from how you voted? What if the candidates you researched and cast your ballot for aren’t voted in? How are you to think about election losses, and what should you do next?

I can’t tell you how many times I have heard this argument in response to election losses: well, my vote doesn’t really matter in California anyway. What is the support for that according to the people who say it? They didn’t win. And so, if they didn’t win the race, whether it’s for a candidate or a proposition or a local measure, then the conclusion reached is: my vote just didn’t matter. While it’s completely true that in California there is an overwhelming majority toward one political party – evidenced by the supermajority split in the Senate and the Assembly – I want to make the argument to you that your vote always matters, no matter what state you live in and whether the majority is with you or not. If 90% of the people in your state vote the same way as you, and you see what you voted for put in place, your vote matters. If 90% of the people in your state vote opposite to you, and you do not see what you voted for put in place, your vote still matters. No election, this election included, is ever a waste, regardless of what comes of it.

Why do I say that so confidently, why do I believe that is the case? Elections are just one component of our democratic process, and one election specifically is just a snapshot in time; it is not the end all, be all, can never be changed, set in stone reality. There are countless examples of times when good propositions didn’t pass, but still acted as a catalyst to change policy in the future. Or examples of people who ran for office and lost, in some cases several times, only to come back and win in the future. Or examples of political movements that faced severe opposition for decades but made change slowly over time. 

To that end, I want to go through many of these examples. I want to tell the stories of men and women who pushed forward change, who faced pushback, setbacks, and struggles, who didn’t even always see the fruit of their labors, and yet who made change one slow, patient, determined, and passionate step at a time. I hope you will walk away from this episode with a greater resolve and a deeper understanding of the reality that however the election ends tonight, you should still engage in politics tomorrow.

Let’s start in 2012 with Proposition 37 in California.

Propositions

Proposition 37 was proposed to require all foods that were genetically modified to be labeled as such, as well as prohibit companies from labeling any GMOs as natural. Two months before the election, the proposition was polling with 61% support. After the election, the proposition did not pass, with just 49% yes and 51% no votes.[1] This was, understandably, a huge loss, especially since it had looked like voters supported the measure through election season. But, while the measure didn’t pass, it actually wasn’t a loss. The New York Times reported, “Instead of quelling the demand for labeling, the defeat of the California measure has spawned a ballot initiative in Washington State and legislative proposals in Connecticut, Vermont, New Mexico and Missouri, and a swelling consumer boycott of some organic or ‘natural’ brands owned by major food companies.” [2] Research professor Charles Benbrook of Washington State University said in his analysis, “The big food companies found themselves in an uncomfortable position after Prop. 37, and they’re talking among themselves about alternatives to merely replaying that fight over and over again.”[3] Proposition 37 sparked debate across the nation and resulted in changes in policy in several states. The effects have rippled all the way to today when the conversation around GMOs and natural foods is more prominent than ever. The most impactful change brought on by this failed proposition was a bill signed into law by President Barack Obama in 2016, which officially requiring the labeling of GMOs on a nationwide level.[4]

 The point of this example is that its supporters probably felt discouraged and surprised when it didn’t pass in 2012, and it could have been easy to think that the changes they wanted to push forward would die with Prop. 37. But the opposite of that happened. Its defeat had the power to change the national policy on GMOs.  

On the other hand, there have been propositions that have passed with negative effects, that later were repealed as public opinion shifted. Take Proposition 47 for a current example. You’ll remember that Prop. 47 was passed by voters in California in 2014, and was followed by subsequent failed attempts to overturn it. As we have discussed in several previous episodes of this show, it lowered the classification and penalties for certain theft and drug crimes from felonies to misdemeanors. During my discussion with Deputy Chief District Attorney Jeff Greeson last week, he shared from a firsthand perspective that when he first read Proposition 47 before it was passed he knew the effects it would have on crime in his counties. The passage of the proposition has prevented district attorneys from being able to effectively prosecute these crimes and has disincentivized police from even arresting the criminals who commit them. In 2020, there was a ballot initiative to repeal the impacts of Proposition 47, but it was voted down by a 38% yes to a staggering 62% no vote.[5] For ten years, Proposition 47 has remained in place as criminal justice has collapsed across the state, worsening the drug and homelessness crises and impacting business owners due to rampant and unmitigated theft. This could seem like a hopeless situation for anyone who disagreed with the measure and who is seeing its downstream effects in real time.

But all hope is not lost, because this election we have Proposition 36 on our ballots, and the Public Policy Institute of California is reporting that an overwhelming 73% of voters are likely to vote yes on the measure![6] That is a long way from the 38% support of a similar measure just four years ago. It would have been easy for proponents of Prop. 36 to look at the widespread support of Prop. 47 – from powerful people like the Governor no less – as well as the defeat of the attempt to overturn it in 2020, and say it isn’t worth it to keep fighting this fight. It isn’t making a difference. Any attempts to make a difference are not effective in the public view. But they didn’t say that, did they? They pushed forward Proposition 36, they have worked to inform the public on why they are seeing smash and grabs, drug overdoses, and discouraged business owners, and they have given a voice to the prosecutors, district attorneys, and victims who are overlooked and facing the implications of bad policy every day. Tonight, they may finally see the fruit of all that labor, but they will continue to persevere regardless because they believe in the mission of saving California from the downward trends it has suffered as a result of lackluster leadership.  

Influential Leaders

It isn’t just propositions that have faced defeat, it’s people too. There have been many influential leaders throughout our history who suffered defeat before victory.

Take Abraham Lincoln. You may not know this, but Honest Abe wasn’t always the well-respected president that many of us know him to be. Before holding the office that he is most famous for, he ran for the U.S. Senate twice – both times he lost. He also ran for the House of Representatives and endured two lost races there as well, before he was finally elected in 1846.[7] Can you imagine running for those positions several times, and not giving up? Many of us would take one loss as a sign that it wasn’t meant to be, but he persevered, and he went on to become known for preserving our country’s union, issuing the Emancipation Proclamation and thus freeing the slaves held in Confederate states, and ultimately appealing to our nation’s greatest values. Just think if he had taken his losses in the Senate and House and chosen to give up on a life in government. Who would have been president during his term? Would they have worked as hard to keep our country together in a time of radical division? Would they have spoken out against slavery? Lincoln didn’t give up after several losses. He didn’t see his work thus far as pointless.

An example closer to our time now is President Reagan, elected to presidential office in 1980. Like Lincoln, his path to the presidency was not linear. While he was successful in achieving the Governor position in California, he ran for President and lost two times before 1980. He lost the Republican nomination to Richard Nixon in 1968, and again lost to Gerald Ford in 1976. It wasn’t until his third run for president that he secured his party’s nomination and went on to win the general election.[8] Again, I can’t imagine one presidential run, let alone three! Yet, he too went on to become a consequential president, known for ending the Cold War with Russia and for his economic policies, part of which reduced the marginal income tax rate from 70% to 28%.[9] President Reagan is just another example that losing one race doesn’t guarantee continued failure in the future, and sometimes it takes multiple attempts to win the highest office in the land.

Political Movements

This idea of perseverance isn’t limited to races each election, but is even more compelling when considering greater political movements across history.

Think of the suffrage movement and the fight for women’s right to vote. Susan B. Anthony, who is best known for leading this movement, was born to a Quaker family who emphasized that all people were equal before God, spoke against slavery, and required education for boys and girls alike.[10] Her early political activism centered around the abolition of slavery and the ratification of the Thirteenth Amendment. But when she began to work as a teacher, her passion for women’s equality was sparked by the reality that male teachers were paid $10 per month, while female teachers were paid just $2.50 per month. This passion led her to become at the forefront of the fight for giving women the right to vote. She even went as far as casting a ballot in the 1872 election, before women were allowed to do so. That act got her arrested, tried, convicted, and fined.[11]

For over 50 years of her life, Susan and other women like her fought for the U.S. Constitution to include them in giving them the right to vote. She inspired later movements, like the protests carried out by the “Silent Sentinels” in 1917. These were silent protests outside of the White House that lasted for over 2 years and resulted in several of their arrests, attacks, and even imprisonment.[12] Finally, in 1920, the nineteenth amendment was ratified, and officially granted women the constitutionally protected right to vote. Susan never saw that result. She died in 1906, just 14 years beforehand.[13] Here’s another picture of resilience, perseverance, and fighting tirelessly for what you believe in regardless of seeing the result. Susan would never see the lasting impact her actions and legacy would leave. She would never know how much her life’s work would move forward women’s equality.

 If she had given up the fight because she wasn’t seeing the progress she wanted, or because getting a woman’s right to vote added to the constitution seemed like too lofty of a goal, then she wouldn’t have blazed the trail for the women who came after her. I might not be able to vote today. I stand on her shoulders, and on the shoulders of so many brave women who dedicated their lives to achieving rights and privileges that they would never have themselves.  

Of course, there are so many other movements like this that we could discuss. The civil rights movement lasted roughly 14 years.[14] Nelson Mandela fought apartheid in South Africa for 40 years, including 27 years he spent in prison.[15] Malala Yousafzai had her right to education taken away by the Taliban in Pakistan when she was just 11 years old; she spoke out against them, advocating for their equal right as human beings to learn. She was shot in the head at just 15 years old, but survived; and what did she do upon surviving an attack like that? She didn’t stop; she advocated even more for women’s rights.[16] Could you imagine sitting in a prison cell for 27 consecutive years like Nelson Mandela, or enduring a life-threatening, brutal attack like Malala, yet continuing on in the fight? How hopeless must it have felt to sit in a prison cell for over two decades, but it would not break Mandela. How terrifying it must have been to speak out again, knowing that there were many dangerous men who wanted you dead, but it would not silence Malala.

These are all stories that remind us that change has never been fast. It has never happened overnight, not with the really important issues. It has been a slow fight, built upon by several people who would never see the end result. Political change has required strength and perseverance, not discouragement at the first sign of setback or failure. Yet, it has not been impossible. And those who have failed refused to end their legacies that way. It was only through pressing on that they were able to effect real change in the world.

The American Legacy

The reality is that as an American, whether native born or through naturalization, these ideals are what make up your heritage. Our founding fathers were no strangers to defeat, difficulty, and loss. They were faced with the reality of creating a new world, breaking away from an empire to start an experiment. In hindsight we can look at their actions and marvel, but think about their perspective as it was happening. Think about what it must have been like for them as they couldn’t see the future and all that our country would become. The great experiment was not guaranteed to work; there were times when it seemed it would certainly fail before it even got started. Yet, they pressed on, and they built the foundations for what our country is today.

Men like Patrick Henry, who was at the very forefront of discontent with how Britain was treating the colonists. He led the protests against the Stamp Act, and resolved that colonists, who would later become Americans, should only be taxed by their representatives. He was a key member of the First Continental Congress, and is most famous for his line, “Give me liberty or give me death!”[17] He made the case before the Virginia Convention, rallying Virginians to oppose Britain’s invasion of their colony. He acknowledged that they were facing a formidable opponent, but in his view, they had no other choice than to fight for what they believed in – which was their freedom. Listen to a few excerpts from the speech before he gets to his famous line:

“If we wish to be free-- if we mean to preserve inviolate those inestimable privileges for which we have been so long contending--if we mean not basely to abandon the noble struggle in which we have been so long engaged, and which we have pledged ourselves never to abandon until the glorious object of our contest shall be obtained--we must fight! I repeat it, sir, we must fight!”[18]

He goes on to address those who might say that the fight is too hard, or too hopeless, or too unrealistic:

“They tell us, sir, that we are weak; unable to cope with so formidable an adversary. But when shall we be stronger? Will it be the next week, or the next year? Will it be when we are totally disarmed, and when a British guard shall be stationed in every house? Shall we gather strength by irresolution and inaction? Shall we acquire the means of effectual resistance by lying supinely on our backs and hugging the delusive phantom of hope, until our enemies shall have bound us hand and foot? Sir, we are not weak if we make a proper use of those means which the God of nature hath placed in our power.”[19]

Is that not still relevant to us today? Our fight is more ideological today than it is physical, but how often do we hear the defeatist mentality that the vote doesn’t go our way, or that our values are just slipping away in society, or that we can’t really make any sort of difference in a state like California because it’s too far gone? Instead, we should be encouraging each other with the very same cries that Patrick Henry used 250 years ago. When we will be stronger and more equipped to push forward good legislation and push back against bad legislation? Will it be the next election? Will it be once our state is supremely opposed to our values and our commonsense ideals? Will we make effective change by throwing up our hands and refusing to engage because we didn’t like the outcomes of one election?

If Patrick Henry could be resolved to fight in the face of a resolution that would change the colonists’ entire world, then surely, we can take heart when we face opposition, failure, and negative outcomes.

It wasn’t just him, it was Samuel Adams – who was instrumental in organizing the Boston Tea Party, making him a target of British suspicion and anger,[20] it was John Adams – who pushed forcefully for independence from the British, sparking debate with those who wanted to take a more moderate approach to Britain’s overreach,[21] it was John Hancock – who signed the Declaration of Independence first, even though his prominence and wealth gained him threats from the British and had the potential to strip away his privileges,[22] it was Thomas Paine – who wrote Common Sense to appeal to the common people that reforming the British system was not enough, independence from it entirely should be their aim,[23] it was George Washington – who let the Continental Army during the Revolutionary War, facing intense challenges like they did at Valley Forge, lacking food, medicine, and facing defeat, while resolving in the most dire of circumstances to be even better prepared and further motivated to stand strong against the British,[24] it was James Madison – who is known as the father of the constitution, yet who in the process of writing it faced intense scrutiny and partnered together with Alexander Hamilton and John Jay to defend the constitution to the public and sway the public opinion toward ratifying the document,[25] and speaking of Alexander Hamilton, it was Hamilton – who faced intense opposition to his view of a strong national government and his proposal for establishing a national bank, yet who established the basis for our economic system as we know it today.[26] The list just goes on and on and on of story after story of bravery and determination despite clear and present danger, obstacles, and pushback.

 To use a phrase that I used earlier: these are the shoulders that we stand on. These are the men who came before us and established our country. We must uphold their legacy, because it is our legacy, the American legacy.

The point is that when we are staring failure and disappointment directly in the face, it is not the time to shrink back and give up; it is the time to stand firm. The reason that we know the names of all the people I’ve mentioned today is exactly because they were facing failure, they were facing impossible situations, they did incur setbacks. Yet, what made them so great, what wrote them into the history books and the hearts and minds of the public, is precisely that they did hard things, and they didn’t give up no matter how hard it became. It is not just a given that everyone will agree with us or that election results will go our way. We expect it to be easy, but just like all those who came before us, we have to put in the hard work of changing hearts and minds and swaying public opinion to understand why we advocate for the policies that we do. We have to do that persuading while keeping in mind one again that real change takes time. It takes resolve, it takes grit, it takes perseverance, and you might not even see the end result. But it doesn’t mean that the fight isn’t worth it.

Overall Point

What is my point in all these stories? My point is that tonight we will see a President elect, we will see winners of races across the country and in our state, and we will see the outcomes of propositions that we have been studying together for months. Some of those outcomes may be positive, they may be what you voted for. Certainly, there will be others that turn out to be the opposite of what you were hoping for. But even if every person or measure you voted on results in the opposite outcome, I want to challenge you that your vote was not wasted. I want to challenge you that your voice does matter, even in the state of California. I want to challenge you that the impact of the exercise of your civil responsibilities is much further reaching than obtaining the desired outcomes of one election. You are part of a bigger process, a democratic system, that extends further out than just the next year, or two years, or four years. You cannot get discouraged, because there is far, far more work to be done.

To the Christian

Specifically to the Christian, you can face the results of today’s election with boldness, courage, and peace because we serve a God who is providential over all things, who cares deeply about the details of your life and the lives of those around you, and who has promised that He will never leave you or forsake you. He sees your faithfulness in seeking the good of the community, city, and state around you, and even when the results do not go the way we hope, He is still working all things together for our good. He is the God who, according to Isaiah 40, brings princes to nothing. Isaiah 40:17 says, “All the nations are as nothing before him, they are accounted by him as less than nothing and emptiness.” His power is great, His reach is vast, but His hand is loving, and His heart is good. Stand firm to push back the tides of evil, advocate for the good of your family, your neighbor, your country; but then, surrender the outcomes to His wise and loving Providence, trusting that no matter what the days ahead hold, He will bring you through them. He has purpose in every election, the outcome of every race, every person who holds the office of President, and every disappointment you may feel when it seems that His hand is absent. Think today on the words of Charles Spurgeon: “God is too good to be unkind and He is too wise to be mistaken. And when we cannot trace His hand, we must trust His heart.”

I have one more example to share with you, specifically to bolster the faith of the Christian and the resolve of the church to keep engaging in politics after today.

Roe v. Wade

We recently watched as one of the most controversial, landmark cases decided by the Supreme Court was just overturned: Roe v. Wade. In 1973 the Supreme Court established abortion as a fundamental right, implicit in the constitution’s fourteenth amendment.[27] This made abortion legal on a national level – something that was celebrated by pro-abortion activists but represented a devastating moment in history for Christians across the country. For those of us who oppose abortion, the goal has always been to work to persuade the public and each state of the reality and significance of life from the moment of conception, and then to change policy across the nation to protect and preserve those unborn lives. A sweeping, national legalization of abortion was nothing short of crushing.

But pro-lifers have not given up. Pregnancy centers across the country have continued their work to support mothers facing unplanned pregnancies through counseling, free baby supplies like clothing, diapers, and furniture, and encouragement through each woman’s unique story. Activist groups have continued their work to change public opinion on abortion and expose the radical dangers it poses to women, let alone the babies. They didn’t give up, even as they had to look at the reality that their work would be limited until something changed on a national level. And in 2022, it did.

On June 24, 2022, in Dobbs v. Jackson Women’s Health Organization, the Supreme Court reversed the Roe v. Wade ruling and attached precedent, arguing that the decision made 50 years prior was “an abuse of judicial authority” – something that legal experts had been saying since its passage.[28] The point of this example is to stop and ask ourselves, how easy would it have been on January 22, 1973, for pro-life activists and Christians across the United States to throw up their hands and say the work that we are doing doesn’t matter? How hopeless would it have seemed to ever reach a goal of abolishing abortion, when the highest court in our country just legalized it on a sweeping level across all 50 states? Would it really feel like the work they were doing was making a difference, or would it seem like the outcome of the Supreme Court’s decision was validation that their work didn’t matter? Just think about the fact that there are many pro-life people alive in 1973 when the Roe decision went into effect who did not live to see it overturned in 2022. They would never see the fruit of their conversations with others, their support of time and money to their local pregnancy centers, their attendance at annual walk for life events, and their prayers for change on the national scale. But just because they never saw the result, does that mean it wasn’t worth it? That it didn’t make a difference? That they should have walked away from the cause entirely?

The answer is a resounding no. They set the foundation for the court ruling. They have saved many lives in the process. They have rallied churches and organizations and the hearts and minds of citizens across America, all to be better equipped to pushback against the pro-abortion view and to prioritize children and families through the protection of the most innocent and vulnerable people group among us: the unborn. While there is still more work to be done and more progress to be made on the issue, the work of pro-lifers has never been in vain, and now they have greater capability to continue making real changes in each state.

That should inspire you, and it should inspire you because it should remind you that change is real and possible, regardless of whether you can see it coming or not. Change might take 5 years or 50 years; it might be something you never get to witness in your lifetime. But you don’t engage in politics just to see the desired outcome, you engage in politics because your politics are shaped by your values, and ultimately by the gospel. You cannot NOT engage, because issues like abortion today are theological and spiritual issues. They transcend the idea that church is separate from government. You engage in politics to display the heart of God to the world, and to bring our government and our culture back to the values He outlines for us in His Word.

Closing Thoughts

In conclusion, I hope for each and every one of you reading this that you can watch the election results roll in tonight and tomorrow, and regardless of the outcome say with certainty that your vote mattered, that there is still more work to be done, and that you are more compelled and determined than ever to participate in that work. And to that end, our work here on The California Conversation is not done! We are just getting started! There is so much more to cover as we begin to look at legislation currently in effect in our state and set to go into effect come 2025. I cannot wait to continue this journey with you all as we work together to be informed, to persuade those around us of our values and convictions, and to restore our state.

 
Refernences:

[1] Ballotpedia. “California Proposition 37, Mandatory Labeling of Genetically Engineered Food Initiative (2012) - Ballotpedia,” n.d. https://ballotpedia.org/California_Proposition_37,_Mandatory_Labeling_of_Genetically_Engineered_Food_Initiative_(2012).

[2] Strom, Stephanie. “Genetic Changes to Food May Get Uniform Labeling.” The New York Times, January 31, 2013. https://www.nytimes.com/2013/02/01/business/food-companies-meet-to-weigh-federal-label-for-gene-engineered-ingredients.html.

[3] Ibid.

[4] Downey Brand LLP. “GMO Labeling: Coming Soon to California and the Rest of the Country | Downey Brand LLP,” August 24, 2016. https://www.downeybrand.com/publications/gmo-labeling-coming-soon-to-california-and-the-rest-of-the-country/.

[5] Ballotpedia. “California Proposition 20, Criminal Sentencing, Parole, and DNA Collection Initiative (2020) - Ballotpedia,” n.d. https://ballotpedia.org/California_Proposition_20,_Criminal_Sentencing,_Parole,_and_DNA_Collection_Initiative_(2020).

[6] Sheeler, Andrew. “Polls Show California Proposition 36 Passing by a Landslide. Do They Tell the Whole Story?” The Sacramento Bee, October 28, 2024. https://www.sacbee.com/news/politics-government/capitol-alert/article294548259.html.

[7] “Abraham Lincoln Brings Lessons About Succeeding After Failure | Henry Ford College,” November 10, 2017. https://www.hfcc.edu/news/2017/abraham-lincoln-brings-lessons-about-succeeding-after-failure#:~:text=Lincoln%20ran%20for%20the%20U.S.,The%20failures%20deepened%20his%20resolve.

[8] Cannon, Lou. “Ronald Reagan: Life in Brief | Miller Center.” Miller Center, October 4, 2016. https://millercenter.org/president/reagan/life-in-brief.

[9] Ibid.

[10] National Women’s History Museum. “Biography: Susan B. Anthony,” n.d. https://www.womenshistory.org/education-resources/biographies/susan-b-anthony.

[11] Ibid.

[12] National Archives. “Woman Suffrage and the 19th Amendment,” June 2, 2021. https://www.archives.gov/education/lessons/woman-suffrage#:~:text=Most%20notably%2C%20the%20NWP%20organized,dismissed%20all%20charges%20against%20them.

[13] “Biography: Susan B. Anthony.”

[14] Zapata, Christian. “Civil Rights Movement Timeline - Timeline & Events | HISTORY.” HISTORY, February 27, 2024. https://www.history.com/topics/black-history/civil-rights-movement-timeline.

[15] Blakemore, Erin. “How Nelson Mandela Fought Apartheid—and Why His Work Is Not Complete.” History, July 17, 2020. https://www.nationalgeographic.com/history/article/nelson-mandela-fought-apartheid-work-not-complete#:~:text=Over%20the%20next%2095%20years,of%20reconciliation%20and%20majority%20rule.

[16] Malala Fund. “Malala’s Story | Malala Fund,” n.d. https://malala.org/malalas-story.

[17] George Washington’s Mount Vernon. “Patrick Henry,” n.d. https://www.mountvernon.org/library/digitalhistory/digital-encyclopedia/article/patrick-henry.

[18] “Avalon Project - Patrick Henry - Give Me Liberty or Give Me Death,” n.d. https://avalon.law.yale.edu/18th_century/patrick.asp.

[19] Ibid.

[20] Lawler, Sean. “Samuel Adams (1722-1803).” Boston Tea Party Ships, August 27, 2021. https://www.bostonteapartyship.com/samuel-adams.

[21] Commonwealth of Massachussets. “John Adams, Architect of American Government.” Mass.gov, n.d. https://www.mass.gov/guides/john-adams-architect-of-american-government#-john-adams-.

[22] Onion, Amanda. “John Hancock - Signature, Person & Independence | HISTORY.” HISTORY, June 29, 2023. https://www.history.com/topics/american-revolution/john-hancock#section_4.

[23] Jack Miller Center. “Thomas Paine’s Common Sense - Jack Miller Center,” July 12, 2024. https://jackmillercenter.org/our-work/resources/thomas-paines-common-sense.

[24] George Washington’s Mount Vernon, “Valley Forge,” n.d., https://www.mountvernon.org/library/digitalhistory/digital-encyclopedia/article/valley-forge#:~:text=During%20the%20winter%20of%201777,head%20of%20the%20Continental%20Army.

[25] The Library of Congress. “James Madison and the Federal Constitutional Convention of 1787 | Articles and Essays | James Madison Papers, 1723-1859 | Digital Collections | Library of Congress,” n.d. https://www.loc.gov/collections/james-madison-papers/articles-and-essays/james-madison-and-the-federal-constitutional-convention-of-1787/#:~:text=The%20federal%20Constitution%20was%20eventually,Congress%20in%20its%20first%20year.

[26] Holloway, Carson. “Alexander Hamilton and American Progressivism | the Heritage Foundation.” The Heritage Foundation, n.d. https://www.heritage.org/political-process/report/alexander-hamilton-and-american-progressivism.

[27] Brennan Center for Justice. “Roe V. Wade and Supreme Court Abortion Cases,” July 26, 2024. https://www.brennancenter.org/our-work/research-reports/roe-v-wade-and-supreme-court-abortion-cases.

[28] Totenberg, Nina. “Supreme Court Overturns Roe V. Wade, Ending Right to Abortion Upheld for Decades.” NPR, June 24, 2022. https://www.npr.org/2022/06/24/1102305878/supreme-court-abortion-roe-v-wade-decision-overturn.