text: The Privileges or Immunities Clause, which protects the privileges and immunities of national citizenship from interference by the states, was patterned after the Privileges and Immunities Clause of Article IV, which protects the privileges and immunities of state citizenship from interference by other states. In the "Slaughter-House Cases" (1873), the Supreme Court concluded that the Constitution recognized two separate types of citizenship—"national citizenship" and "state citizenship"—and the Court held that the Privileges or Immunities Clause prohibits states from interfering only with privileges and immunities possessed by virtue of national citizenship. The Court concluded that the privileges and immunities of national citizenship included only those rights that "owe their existence to the Federal government, its National character, its Constitution, or its laws." The Court recognized few such rights, including access to seaports and navigable waterways, the right to run for federal office, the protection of the federal government while on the high seas or in the jurisdiction of a foreign country, the right to travel to the seat of government, the right to peaceably assemble and petition the government, the privilege of the writ of habeas corpus, and the right to participate in the government's administration. This decision has not been overruled and has been specifically reaffirmed several times. Largely as a result of the narrowness of the "Slaughter-House" opinion, this clause subsequently lay dormant for well over a century.


title: Fourteenth Amendment to the United States Constitution

text: In "Saenz v. Roe" (1999), the Court ruled that a component of the "right to travel" is protected by the Privileges or Immunities Clause:


text: Justice Miller actually wrote in the "Slaughter-House Cases" that the right to become a citizen of a state (by residing in that state) "is conferred by "the very article" under consideration" (emphasis added), rather than by the "clause" under consideration.


text: In "McDonald v. Chicago "(2010), Justice Clarence Thomas, while concurring with the majority in incorporating the Second Amendment against the states, declared that he reached this conclusion through the Privileges or Immunities Clause instead of the Due Process Clause. Randy Barnett has referred to Justice Thomas's concurring opinion as a "complete restoration" of the Privileges or Immunities Clause.


text: In "Timbs v. Indiana" (2019), Justice Thomas and Justice Neil Gorsuch, in separate concurring opinions, declared the Excessive Fines Clause of the Eighth Amendment was incorporated against the states through the Privileges or Immunities Clause instead of the Due Process Clause.


text: Due process deals with the administration of justice and thus the due process clause acts as a safeguard from arbitrary denial of life, liberty, or property by the government outside the sanction of law. The Supreme Court has described due process consequently as "the protection of the individual against arbitrary action." In 1855, the Supreme Court explained that, to ascertain whether a process is due process, the first step is to "examine the constitution itself, to see whether this process be in conflict with any of its provisions." In "Hurtado v. California" (1884), the U.S. Supreme Court said:


text: The Due Process Clause has been used to strike down legislation. The Fifth and Fourteenth Amendments for example do not prohibit governmental regulation for the public welfare. Instead, they only direct the process by which such regulation occurs. As the Court has held before, such due process "demands only that the law shall not be unreasonable, arbitrary, or capricious, and that the means selected shall have a real and substantial relation to the object sought to be attained." Despite the foregoing citation the Due Process Clause enables the Supreme Court to exercise its power of judicial review, "because the due process clause has been held by the Court applicable to matters of substantive law as well as to matters of procedure." Justice Louis Brandeis observed in his concurrence opinion in "Whitney v. California", 274 U.S. 357, 373 (1927), that "[d]espite arguments to the contrary which had seemed to me persuasive, it is settled that the due process clause of the Fourteenth Amendment applies to matters of substantive law as well as to matters of procedure. Thus all fundamental rights comprised within the term liberty are protected by the Federal Constitution from invasion by the States."


text: The Due Process Clause of the Fourteenth Amendment applies only against the states, but it is otherwise textually identical to the Due Process Clause of the Fifth Amendment, which applies against the federal government; both clauses have been interpreted to encompass identical doctrines of procedural due process and substantive due process. Procedural due process is the guarantee of a fair legal process when the government tries to interfere with a person's protected interests in life, liberty, or property, and substantive due process is the guarantee that the fundamental rights of citizens will not be encroached on by government. Furthermore, as observed by Justice John M. Harlan II in his dissenting opinion in "Poe v. Ullman", 367 U.S. 497, 541 (1961), quoting "Hurtado v. California", 110 U.S. 516, 532 (1884), "the guaranties of due process, though having their roots in Magna Carta's 'per legem terrae' and considered as procedural safeguards 'against executive usurpation and tyranny', have in this country 'become bulwarks also against arbitrary legislation'." In "Planned Parenthood v. Casey" (1992) it was observed: "Although a literal reading of the Clause might suggest that it governs only the procedures by which a State may deprive persons of liberty, for at least 105 years, since "Mugler v. Kansas", 123 U. S. 623, 660-661 (1887), the Clause has been understood to contain a substantive component as well, one "barring certain government actions regardless of the fairness of the procedures used to implement them." "Daniels v. Williams", 474 U. S. 327, 331 (1986)." The Due Process Clause of the Fourteenth Amendment also incorporates most of the provisions in the Bill of Rights, which were originally applied against only the federal government, and applies them against the states. The Due Process clause applies regardless whether one is a citizen of the United States of America or not.


text: The Supreme Court of the United States interprets the clauses broadly, concluding that these clauses provide three protections: procedural due process (in civil and criminal proceedings); substantive due process; and as the vehicle for the incorporation of the Bill of Rights. These aspects will be discussed in the sections below.


text: Beginning with "Allgeyer v. Louisiana" (1897), the U.S. Supreme Court interpreted the Due Process Clause as providing substantive protection to private contracts, thus prohibiting a variety of social and economic regulation; this principle was referred to as "freedom of contract". A unanimous court held with respect to the noun "liberty" mentioned in the Fourteenth Amendment's Due Process Clause:


text: The 'liberty' mentioned in [the Fourteenth] amendment means not only the right of the citizen to be free from the mere physical restraint of his person, as by incarceration, but the term is deemed to embrace the right of the citizen to be free in the enjoyment of all his faculties, to be free to use them in all lawful ways, to live and work where he will, to earn his livelihood by any lawful calling, to pursue any livelihood or avocation, and for that purpose "to enter into all contracts which may be proper, necessary, and essential" to his carrying out to a successful conclusion the purposes above mentioned.


text: Relying on the principle of "freedom of contract" the Court struck down a law decreeing maximum hours for workers in a bakery in "Lochner v. New York" (1905) and struck down a minimum wage law in "Adkins v. Children's Hospital" (1923). In "Meyer v. Nebraska" (1923), the Court stated that the "liberty" protected by the Due Process Clause


text: However, the Court did uphold some economic regulation, such as state Prohibition laws ("Mugler v. Kansas", 1887), laws declaring maximum hours for mine workers ("Holden v. Hardy", 1898), laws declaring maximum hours for female workers ("Muller v. Oregon", 1908), and President Woodrow Wilson's intervention in a railroad strike ("Wilson v. New", 1917), as well as federal laws regulating narcotics ("United States v. Doremus", 1919). The Court repudiated, but did not explicitly overrule, the "freedom of contract" line of cases in "West Coast Hotel v. Parrish" (1937). In its decision the Court stated:


text: The Court has interpreted the term "liberty" in the Due Process Clauses of the Fifth and Fourteenth Amendments in "Bolling v. Sharpe" (1954) broadly:


text: In "Poe v. Ullman" (1961), dissenting Justice John Marshall Harlan II adopted a broad view of the "liberty" protected by the Fourteenth Amendment Due Process clause:


text: Although the "freedom of contract" described above has fallen into disfavor, by the 1960s, the Court had extended its interpretation of substantive due process to include other rights and freedoms that are not enumerated in the Constitution but that, according to the Court, extend or derive from existing rights. For example, the Due Process Clause is also the foundation of a constitutional right to privacy. The Court first ruled that privacy was protected by the Constitution in "Griswold v. Connecticut" (1965), which overturned a Connecticut law criminalizing birth control. While Justice William O. Douglas wrote for the majority that the right to privacy was found in the "penumbras" of various provisions in the Bill of Rights, Justices Arthur Goldberg and John Marshall Harlan II wrote in concurring opinions that the "liberty" protected by the Due Process Clause included individual privacy. The above mentioned broad view of liberty embraced by dissenting Justice John Marshall Harlan II in "Poe v. Ullman" (1961) was adopted by the Supreme Court in "Griswold v. Connecticut".


text: The right to privacy was the basis for "Roe v. Wade" (1973), in which the Court invalidated a Texas law forbidding abortion except to save the mother's life. Like Goldberg's and Harlan's concurring opinions in "Griswold", the majority opinion authored by Justice Harry Blackmun located the right to privacy in the Due Process Clause's protection of liberty. The decision disallowed many state and federal abortion restrictions, and it became one of the most controversial in the Court's history. In "Planned Parenthood v. Casey" (1992), the Court decided that "the essential holding of "Roe v. Wade" should be retained and once again reaffirmed." The Court overruled both "Roe" and "Casey" in "Dobbs v. Jackson Women's Health Organization" (2022). "Dobbs" signals a new era of weakening of the "Allgeyer" Court's understanding of liberty.


text: In "Lawrence v. Texas" (2003), the Court found that a Texas law against same-sex sexual intercourse violated the right to privacy. In "Obergefell v. Hodges" (2015), the Court ruled that the fundamental right to marriage included same-sex couples being able to marry.


text: When the government seeks to burden a person's protected liberty interest or property interest, the Supreme Court has held that procedural due process requires that, at a minimum, the government provide the person notice, an opportunity to be heard at an oral hearing, and a decision by a neutral decision-maker. For example, such process is due when a government agency seeks to terminate civil service employees, expel a student from public school, or cut off a welfare recipient's benefits. The Court has also ruled that the Due Process Clause requires judges to recuse themselves in cases where the judge has a conflict of interest. For example, in "Caperton v. A.T. Massey Coal Co." (2009), the Court ruled that a justice of the Supreme Court of Appeals of West Virginia had to recuse himself from a case involving a major contributor to his campaign for election to that court.


text: While many state constitutions are modeled after the United States Constitution and federal laws, those state constitutions did not necessarily include provisions comparable to the Bill of Rights. In "Barron v. Baltimore" (1833), the Supreme Court unanimously ruled that the Bill of Rights restrained only the federal government, not the states. However, the Supreme Court has subsequently held that most provisions of the Bill of Rights apply to the states through the Due Process Clause of the Fourteenth Amendment under a doctrine called "incorporation".


text: Whether incorporation was intended by the amendment's framers, such as John Bingham, has been debated by legal historians. According to legal scholar Akhil Reed Amar, the framers and early supporters of the Fourteenth Amendment believed that it would ensure that the states would be required to recognize the same individual rights as the federal government; all these rights were likely understood as falling within the "privileges or immunities" safeguarded by the amendment.


text: By the latter half of the 20th century, nearly all of the rights in the Bill of Rights had been applied to the states. The Supreme Court has held that the amendment's Due Process Clause incorporates all of the substantive protections of the First, Second, Fourth, Fifth (except for its Grand Jury Clause) and Sixth Amendments, along with the Excessive Fines Clause and Cruel and Unusual Punishment Clause of the Eighth Amendment. While the Third Amendment has not been applied to the states by the Supreme Court, the Second Circuit ruled that it did apply to the states within that circuit's jurisdiction in "Engblom v. Carey". The Seventh Amendment right to jury trial in civil cases has been held not to be applicable to the states, but the amendment's Re-Examination Clause does apply to "a case tried before a jury in a state court and brought to the Supreme Court on appeal."


text: The Excessive Fines Clause of the Eighth Amendment became the last right to be incorporated when the Supreme Court ruled in "Timbs v. Indiana" (2019) that right to apply to the states.


text: The Equal Protection Clause was created largely in response to the lack of equal protection provided by law in states with Black Codes. Under Black Codes, blacks could not sue, give evidence, or be witnesses. They also were punished more harshly than whites. The Supreme Court in "Strauder v. West Virginia" (1880) said the Fourteenth Amendment not only gave citizenship and the privileges of citizenship to persons of color, it denied to any State the power to withhold from them the equal protection of the laws, and authorized Congress to enforce its provisions by appropriate legislation. In this decision the Supreme Court stated specifically that the Equal Protection Clause was


text: The Equal Protection Clause applies to citizens and non-citizens alike. The clause mandates that individuals in similar situations be treated equally by the law. The purpose of the clause is not only to guarantee equality both in laws for security of person as well as in proceedings, but also to insure the "equal right to the laws of due process and impartially administered before the courts of justice." Although the text of the Fourteenth Amendment applies the Equal Protection Clause only against the states, the Supreme Court, since "Bolling v. Sharpe" (1954), has applied the clause against the federal government through the Due Process Clause of the Fifth Amendment under a doctrine called "reverse incorporation".


text: In "Yick Wo v. Hopkins" (1886), the Supreme Court has clarified that the meaning of "person" and "within its jurisdiction" in the Equal Protection Clause would not be limited to discrimination against African Americans, but would extend to other races, colors, and nationalities such as (in this case) legal aliens in the United States who are Chinese citizens:


text: Persons "within its jurisdiction" are entitled to equal protection from a state. Largely because the Privileges and Immunities Clause of Article IV has from the beginning guaranteed the privileges and immunities of citizens in the several states, the Supreme Court has rarely construed the phrase "within its jurisdiction" in relation to natural persons. In "Plyler v. Doe" (1982), where the Court held that aliens illegally present in a state are "within its jurisdiction" and may thus raise equal protection claims the Court explicated the meaning of the phrase "within its jurisdiction" as follows: "[U]se of the phrase 'within its jurisdiction' confirms the understanding that the Fourteenth Amendment's protection extends to anyone, citizen or stranger, who is subject to the laws of a State, and reaches into every corner of a State's territory." The Court reached this understanding among other things from Senator Howard, a member of the Joint Committee of Fifteen, and the floor manager of the amendment in the Senate. Senator Howard was explicit about the broad objectives of the Fourteenth Amendment and the intention to make its provisions applicable to all who "may happen to be" within the jurisdiction of a state:


text: The relationship between the Fifth and Fourteenth Amendments was addressed by Justice Field in "Wong Wing v. United States" (1896). He observed with respect to the phrase "within its jurisdiction": "The term 'person', used in the Fifth Amendment, is broad enough to include any and every human being within the jurisdiction of the republic. A resident, alien born, is entitled to the same protection under the laws that a citizen is entitled to. He owes obedience to the laws of the country in which he is domiciled, and, as a consequence, he is entitled to the equal protection of those laws. ... The contention that persons within the territorial jurisdiction of this republic might be beyond the protection of the law was heard with pain on the argument at the bar—in face of the great constitutional amendment which declares that no State shall deny to any person within its jurisdiction the equal protection of the laws."


text: The Supreme Court also decided whether foreign corporations are also "within the jurisdiction" of a state, ruling that a foreign corporation which sued in a state court in which it was not licensed to do business to recover possession of property wrongfully taken from it in another state was "within the jurisdiction" and could not be subjected to unequal burdens in the maintenance of the suit. When a state has admitted a foreign corporation to do business within its borders, that corporation is entitled to equal protection of the laws but not necessarily to identical treatment with domestic corporations.


text: In "Santa Clara County v. Southern Pacific Railroad" (1886), the court reporter included a statement by Chief Justice Morrison Waite in the decision's headnote:


text: This dictum, which established that corporations enjoyed personhood under the Equal Protection Clause, was repeatedly reaffirmed by later courts. It remained the predominant view throughout the twentieth century, though it was challenged in dissents by justices such as Hugo Black and William O. Douglas. Between 1890 and 1910, Fourteenth Amendment cases involving corporations vastly outnumbered those involving the rights of blacks, 288 to 19.


text: In the decades following the adoption of the Fourteenth Amendment, the Supreme Court overturned laws barring blacks from juries ("Strauder v. West Virginia", 1880) or discriminating against Chinese Americans in the regulation of laundry businesses ("Yick Wo v. Hopkins", 1886), as violations of the Equal Protection Clause. However, in "Plessy v. Ferguson" (1896), the Supreme Court held that the states could impose racial segregation so long as they provided similar facilities—the formation of the "separate but equal" doctrine.


text: The Court went even further in restricting the Equal Protection Clause in "Berea College v. Kentucky" (1908), holding that the states could force private actors to discriminate by prohibiting colleges from having both black and white students. By the early 20th century, the Equal Protection Clause had been eclipsed to the point that Justice Oliver Wendell Holmes, Jr. dismissed it as "the usual last resort of constitutional arguments."


text: The Court held to the "separate but equal" doctrine for more than fifty years, despite numerous cases in which the Court itself had found that the segregated facilities provided by the states were almost never equal, until "Brown v. Board of Education" (1954) reached the Court. In "Brown" the Court ruled that even if segregated black and white schools were of equal quality in facilities and teachers, segregation was inherently harmful to black students and so was unconstitutional. "Brown" met with a campaign of resistance from white Southerners, and for decades the federal courts attempted to enforce "Brown"s mandate against repeated attempts at circumvention. This resulted in the controversial desegregation busing decrees handed down by federal courts in various parts of the nation. In "Parents Involved in Community Schools v. Seattle School District No. 1" (2007), the Court ruled that race could not be the determinative factor in determining to which public schools parents may transfer their children.


text: In "Plyler v. Doe" (1982) the Supreme Court struck down a Texas statute denying free public education to illegal immigrants as a violation of the Equal Protection Clause of the Fourteenth Amendment because discrimination on the basis of illegal immigration status did not further a substantial state interest. The Court reasoned that illegal aliens and their children, though not citizens of the United States or Texas, are people "in any ordinary sense of the term" and, therefore, are afforded Fourteenth Amendment protections.


text: In "Hernandez v. Texas" (1954), the Court held that the Fourteenth Amendment protects those beyond the racial classes of white or "Negro" and extends to other racial and ethnic groups, such as Mexican Americans in this case. In the half-century following "Brown", the Court extended the reach of the Equal Protection Clause to other historically disadvantaged groups, such as women and illegitimate children, although it has applied a somewhat less stringent standard than it has applied to governmental discrimination on the basis of race ("United States v. Virginia" (1996); "Levy v. Louisiana" (1968)).


text: The Supreme Court ruled in "Regents of the University of California v. Bakke" (1978) that affirmative action in the form of racial quotas in public university admissions was a violation of Title VI of the Civil Rights Act of 1964; however, race could be used as one of several factors without violating of the Equal Protection Clause or Title VI. In "Gratz v. Bollinger" (2003) and "Grutter v. Bollinger" (2003), the Court considered two race-conscious admissions systems at the University of Michigan. The university claimed that its goal in its admissions systems was to achieve racial diversity. In "Gratz", the Court struck down a points-based undergraduate admissions system that added points for minority status, finding that its rigidity violated the Equal Protection Clause; in "Grutter", the Court upheld a race-conscious admissions process for the university's law school that used race as one of many factors to determine admission. In "Fisher v. University of Texas" (2013), the Court ruled that before race can be used in a public university's admission policy, there must be no workable race-neutral alternative. In "Schuette v. Coalition to Defend Affirmative Action" (2014), the Court upheld the constitutionality of a state constitutional prohibition on the state or local use of affirmative action.


text: "Reed v. Reed" (1971), which struck down an Idaho probate law favoring men, was the first decision in which the Court ruled that arbitrary gender discrimination violated the Equal Protection Clause. In "Craig v. Boren" (1976), the Court ruled that statutory or administrative sex classifications had to be subjected to an intermediate standard of judicial review. "Reed" and "Craig" later served as precedents to strike down a number of state laws discriminating by gender.


text: Since "Wesberry v. Sanders" (1964) and "Reynolds v. Sims" (1964), the Supreme Court has interpreted the Equal Protection Clause as requiring the states to apportion their congressional districts and state legislative seats according to "one man, one vote". The Court has also struck down redistricting plans in which race was a key consideration. In "Shaw v. Reno" (1993), the Court prohibited a North Carolina plan aimed at creating majority-black districts to balance historic underrepresentation in the state's congressional delegations.


text: The Equal Protection Clause served as the basis for the decision in "Bush v. Gore" (2000), in which the Court ruled that no constitutionally valid recount of Florida's votes in the 2000 presidential election could be held within the needed deadline; the decision effectively secured Bush's victory in the disputed election. In "League of United Latin American Citizens v. Perry" (2006), the Court ruled that House Majority Leader Tom DeLay's Texas redistricting plan intentionally diluted the votes of Latinos and thus violated the Equal Protection Clause.


text: Before "United States v. Cruikshank", 92 U.S. 542 (1876) was decided by United States Supreme Court, the case was decided as a circuit case (Federal Cases No. 14897). Presiding of this circuit case was judge Joseph P. Bradley who wrote at page 710 of Federal Cases No. 14897 regarding the Fourteenth Amendment to the United States Constitution:


text: The above quote was quoted by United Supreme Court in "United States v. Harris", 106 U.S. 629 (1883) and supplemented by a quote from the majority opinion in "United States v. Cruikshank", 92 U.S. 542 (1876) as written by Chief Justice Morrison Waite:


text: Individual liberties guaranteed by the United States Constitution, other than the Thirteenth Amendment's ban on slavery, protect not against actions by private persons or entities, but only against actions by government officials. Regarding the Fourteenth Amendment, the Supreme Court ruled in "Shelley v. Kraemer" (1948): "[T]he action inhibited by the first section of the Fourteenth Amendment is only such action as may fairly be said to be that of the States. That Amendment erects no shield against merely private conduct, however discriminatory or wrongful." The court added in "Civil Rights Cases" (1883): "It is State action of a particular character that is prohibited. Individual invasion of individual rights is not the subject matter of the amendment. It has a deeper and broader scope. It nullifies and makes void all State legislation, and State action of every kind, which impairs the privileges and immunities of citizens of the United States, or which injures them in life, liberty, or property without due process of law, or which denies to any of them the equal protection of the laws."


text: Vindication of federal constitutional rights are limited to those situations where there is "state action" meaning action of government officials who are exercising their governmental power. In "Ex parte Virginia" (1880), the Supreme Court found that the prohibitions of the Fourteenth Amendment "have reference to actions of the political body denominated by a State, by whatever instruments or in whatever modes that action may be taken. A State acts by its legislative, its executive, or its judicial authorities. It can act in no other way. The constitutional provision, therefore, must mean that no agency of the State, or of the officers or agents by whom its powers are exerted, shall deny to any person within its jurisdiction the equal protection of the laws. Whoever, by virtue of public position under a State government, deprives another of property, life, or liberty, without due process of law, or denies or takes away the equal protection of the laws, violates the constitutional inhibition; and as he acts in the name and for the State, and is clothed with the State's power, his act is that of the State."


text: There are however instances where people are the victims of civil-rights violations that occur in circumstances involving both government officials and private actors. In the 1960s, the United States Supreme Court adopted an expansive view of state action opening the door to wide-ranging civil-rights litigation against private actors when they act as state actors (i.e., acts done or otherwise "sanctioned in some way" by the state). The Court found that the state action doctrine is equally applicable to denials of privileges or immunities, due process, and equal protection of the laws.


text: The critical factor in determining the existence of state action is not governmental involvement with private persons or private corporations, but "the inquiry must be whether there is a sufficiently close nexus between the State and the challenged action of the regulated entity so that the action of the latter may be fairly treated as that of the State itself." "Only by sifting facts and weighing circumstances can the nonobvious involvement of the State in private conduct be attributed its true significance."


text: The Supreme Court asserted that plaintiffs must establish not only that a private party "acted under color of the challenged statute, but also that its actions are properly attributable to the State." "And the actions are to be attributable to the State apparently only if the State compelled the actions and not if the State merely established the process through statute or regulation under which the private party acted."


text: The rules developed by the Supreme Court for business regulation are that (1) the "mere fact that a business is subject to state regulation does not by itself convert its action into that of the State for purposes of the Fourteenth Amendment," and (2) "a State normally can be held responsible for a private decision only when it has exercised coercive power or has provided such significant encouragement, either overt or covert, that the choice must be deemed to be that of the State."


text: Under Article I, Section 2, Clause 3, the basis of representation of each state in the House of Representatives was determined by adding three-fifths of each state's slave population to its free population. Because slavery (except as punishment for crime) had been abolished by the Thirteenth Amendment, the freed slaves would henceforth be given full weight for purposes of apportionment. This situation was a concern to the Republican leadership of Congress, who worried that it would increase the political power of the former slave states, even as such states continued to deny freed slaves the right to vote.


text: On January 31, 1866, the House of Representatives voted in favor of a proposed constitutional amendment that would reduce a state's representation in the House in proportion to which that state used "race or color" as a basis to deny the right to vote in that state. The amendment failed in the Senate, partly because radical Republicans foresaw that states would be able to use ostensibly race-neutral criteria, such as educational and property qualifications, to disenfranchise the freed slaves without negative consequence. So the amendment was changed to penalize states in which the vote was denied to male citizens over twenty-one for "any" reason other than participation in crime. Later, the Fifteenth Amendment was adopted to guarantee the right to vote could not be denied based on race or color.


text: The first reapportionment after the enactment of the Fourteenth Amendment occurred in 1873, based on the 1870 census. Congress appears to have attempted to enforce the provisions of Section 2, but was unable to identify enough disenfranchised voters to make a difference to any state's representation. In the implementing statute, Congress added a provision stating that A nearly identical provision remains in federal law to this day.


text: Despite this legislation, in subsequent reapportionments, no change has ever been made to any state's Congressional representation on the basis of the Amendment. Bonfield, writing in 1960, suggested that "[t]he hot political nature of such proposals has doomed them to failure." Aided by this lack of enforcement, southern states continued to use pretexts to prevent many blacks from voting until the passage of the Voting Rights Act of 1965.


text: In the Fourth Circuit case of "Saunders v Wilkins" (1945), Saunders claimed that Virginia should have its Congressional representation reduced because of its use of a poll tax and other voting restrictions. The plaintiff sued for the right to run for Congress at large in the state, rather than in one of its designated Congressional districts. The lawsuit was dismissed as a political question.


text: Some have argued that Section 2 was implicitly repealed by the Fifteenth Amendment, but the Supreme Court acknowledged Section2 in later decisions.


text: In "Minor v. Happersett" (1875), the Supreme Court cited Section2 as supporting its conclusion that the right to vote was not among the "privileges and immunities of citizenship" protected by Section 1. Women would not achieve equal voting rights throughout the United States until the adoption of Nineteenth Amendment in 1920.


text: In "Richardson v. Ramirez" (1974), the Court cited Section2 in holding that Section 1's Equal Protection Clause does not prohibit states disenfranchising felons.


text: In "Hunter v. Underwood" (1985), a case involving disenfranchising black misdemeanants, the Supreme Court concluded that the Tenth Amendment cannot save legislation prohibited by the subsequently enacted Fourteenth Amendment. More specifically the Court concluded that laws passed with a discriminatory purpose are not excepted from the operation of the Equal Protection Clause by the "other crime" provision of Section 2. The Court held that Section2 "was not designed to permit the purposeful racial discrimination [...] which otherwise violates [Section]1 of the Fourteenth Amendment."


text: Abolitionist leaders criticized the amendment's failure to specifically prohibit the states from denying people the right to vote on the basis of race.


text: Section 2 protects the right to vote only of adult males, not adult females, making it the only provision of the Constitution to explicitly discriminate on the basis of sex. Section2 was condemned by women's suffragists, such as Elizabeth Cady Stanton and Susan B. Anthony, who had long seen their cause as linked to that of black rights. The separation of black civil rights from women's civil rights split the two movements for decades.


text: Soon after losing the Civil War in 1865, states that had been part of the Confederacy began to send "unrepentant" former Confederates (such as the Confederacy's former vice president, Alexander H. Stephens) to Washington as Senators and Representatives. Congress refused to seat them and drafted Section 3 to perpetuate, as a constitutional imperative, that any who violate their oath to the Constitution are to be barred from public office.


text: Section 3 disqualifies from federal or state office anyone who, having taken an oath as a public official to support the Constitution, subsequently engages in "insurrection or rebellion" against the United States or gives "aid and comfort" to its enemies.


text: Section 3 does not specify how it is to be invoked, but Section 5 says Congress has enforcement power. Accordingly, Congress enforced Section 3 by enacting the Enforcement Act of 1870, the pertinent portion of which was repealed in 1948; there is still a current federal statute () that was initially part of the Confiscation Act of 1862 (and revised in 1948), disqualifying insurrectionists from federal office. Moreover, each house of Congress can expel or members for insurrection or other reasons, although it is uncertain whether more votes may be required to expel than to exclude. A further way that Congress can enforce Section 3 is via impeachment, and even prior to the adoption of the Fourteenth Amendment Congress impeached and disqualified federal judge West Humphreys for insurrection.


text: At the urging of President Ulysses S. Grant, in 1872 Congress passed the Amnesty Act, which removed the disqualification from all but the most senior Confederates.


text: In 1898, as a "gesture of national unity" during the Spanish–American War, Congress passed another law broadening the amnesty.


text: Since Reconstruction, Section 3 has been invoked only once: it was used to block Socialist Party of America member Victor L. Berger of Wisconsinconvicted of violating the Espionage Act for opposing US entry into World War Ifrom assuming his seat in the House of Representatives in 1919 and 1920.


text: Berger's conviction was overturned by the Supreme Court in "Berger v. United States" (1921), after which he was elected to three successive terms in the 1920s; he was seated for all three terms.


text: On January 10, 2021, Nancy Pelosi, the Speaker of the House, formally requested Representatives' input as to whether to pursue Section 3 disqualification of outgoing President Donald Trump because of his role in the January 6 United States Capitol attack.


text: Unlike impeachment, which requires a supermajority to convict, disqualification under Section 3 would only require a simple majority of each house of Congress.


text: The Section 3 disqualification could be imposed by Congress passing a law or a nonbinding resolution stating that the January 6 riot was an insurrection, and that anyone who swore to uphold the Constitution and who incited or participated in the riot is disqualified under Section 3.


text: Some legal experts believe a court would then be required to make a final determination that Trump was disqualified under Section 3.


text: A state may also make a determination that Trump is disqualified under Section 3 from appearing on that state's ballot.


text: In addition to state or federal legislative action, a court action could be brought against Trump seeking his disqualification under Section 3.


text: On January 11, 2021, Representative Cori Bush (D-MO) and 47 cosponsors introduced a resolution calling for expulsion, under Section 3, of members of Congress who voted against certifying the results of the 2020 US presidential election or incited the January 6 riot. Those named in the resolution included Republican Representatives Mo Brooks of Alabama and Louie Gohmert of Texas, who took part in the rally that preceded the riot, and Republican Senators Josh Hawley of Missouri and Ted Cruz of Texas, who objected to counting electoral votes to certify the 2020 presidential election result.


text: After Representative Madison Cawthorn (R-NC) declared his intent to run for re-election in 2022, a group of North Carolina voters from Cawthorn's district filed a lawsuit alleging that a speech he gave immediately prior to the Capitol attack incited it, and, therefore, Section 3 disqualified him from holding federal office. A federal judge entered a preliminary injunction in favor of Cawthorn, citing the Amnesty Act of 1872; however, on May 24, 2022, an appeals court ruled that this law applied only to people who committed "constitutionally wrongful acts" before 1872. A similar challenge, which a federal court declined to block, was filed against Marjorie Taylor Greene (R-GA) and heard in April 2022 in Atlanta. Greene sued to strike down the law that allowed contesting her eligibility as unconstitutional.


text: Otero County, New Mexico commissioner Couy Griffin was barred from holding public office for life in September 2022 by District Court Judge Francis Mathew who found his participation as the leader of the Cowboys for Trump group during the attack on the Capitol was an act of insurrection under Section 3. This is the first conviction under Section 3 since 1869 (save the previously mentioned overturned conviction).


text: Section 4 confirmed the legitimacy of all public debt appropriated by the Congress. It also confirmed that neither the United States nor any state would pay for the loss of slaves or debts that had been incurred by the Confederacy. For example, during the Civil War several British and French banks had lent large sums of money to the Confederacy to support its war against the Union. In "Perry v. United States" (1935), the Supreme Court ruled that under Section4 voiding a United States bond "went beyond the congressional power."


text: The debt-ceiling crises of 2011 and 2013 raised the question of what is the President's authority under Section 4. During the 2011 crisis, former President Bill Clinton said he would invoke the Fourteenth Amendment to raise the debt ceiling if he were still in office, and force a ruling by the Supreme Court. Some, such as legal scholar Garrett Epps, fiscal expert Bruce Bartlett and Treasury Secretary Timothy Geithner, have argued that a debt ceiling may be unconstitutional and therefore void as long as it interferes with the duty of the government to pay interest on outstanding bonds and to make payments owed to pensioners (that is, Social Security and Railroad Retirement Act recipients). Legal analyst Jeffrey Rosen has argued that Section4 gives the President unilateral authority to raise or ignore the national debt ceiling, and that if challenged the Supreme Court would likely rule in favor of expanded executive power or dismiss the case altogether for lack of standing. Erwin Chemerinsky, professor and dean at University of California, Irvine School of Law, has argued that not even in a "dire financial emergency" could the President raise the debt ceiling as "there is no reasonable way to interpret the Constitution that [allows him to do so]." Jack Balkin, Knight Professor of Constitutional Law at Yale University, opined that like Congress the President is bound by the Fourteenth Amendment, for otherwise, he could violate any part of the amendment at will. Because the President must obey the Section4 requirement not to put the validity of the public debt into question, Balkin argued that President Obama would have been obliged "to prioritize incoming revenues to pay the public debt, interest on government bonds and any other 'vested' obligations. What falls into the latter category is not entirely clear, but a large number of other government obligations—and certainly payments for future services—would not count and would have to be sacrificed. This might include, for example, Social Security payments."


text: The opinion of the Supreme Court in "The Slaughter-House Cases", 83 U.S. (16 Wall.) 36 (1873) stated with a view to the Reconstruction Amendments and about the Fourteenth Amendment's Section5 Enforcement Clause in light of said Amendent's Equal Protection Clause:


text: Section 5, also known as the Enforcement Clause of the Fourteenth Amendment, enables Congress to pass laws enforcing the amendment's other provisions. In "Ex Parte Virginia" (1879) the U.S. Supreme Court explained the scope of Congress' §5 power in the following broad terms: "Whatever legislation is appropriate, that is, adapted to carry out the objects the amendments have in view, whatever tends to enforce submission to the prohibitions they contain, and to secure to all persons the enjoyment of perfect equality of civil rights and the equal protection of the laws against State denial or invasion, if not prohibited, is brought within the domain of congressional power." In the "Civil Rights Cases" (1883), the Supreme Court interpreted Section5 narrowly, stating that "the legislation which Congress is authorized to adopt in this behalf is not general legislation upon the rights of the citizen, but corrective legislation." In other words, the amendment authorizes Congress to pass laws only to combat violations of the rights protected in other sections.


text: In "Katzenbach v. Morgan" (1966), the Court upheld Section 4(e) of the Voting Rights Act of 1965, which prohibits certain forms of literacy requirements as a condition to vote, as a valid exercise of Congressional power under Section5 to enforce the Equal Protection Clause. The Court ruled that Section5 enabled Congress to act both remedially and prophylactically to protect the rights guaranteed by the amendment. However, in "City of Boerne v. Flores" (1997), the Court narrowed Congress's enforcement power, holding that Congress may not enact legislation under Section5 that substantively defines or interprets Fourteenth Amendment rights. The Court ruled that legislation is valid under Section5 only if there is a "congruence and proportionality" between the injury to a person's Fourteenth Amendment right and the means Congress adopted to prevent or remedy that injury.


text: In the final years of the American Civil War and the Reconstruction Era that followed, Congress repeatedly debated the rights of black former slaves freed by the 1863 Emancipation Proclamation and the 1865 Thirteenth Amendment, the latter of which had formally abolished slavery. Following the passage of the Thirteenth Amendment by Congress, however, Republicans grew concerned over the increase it would create in the congressional representation of the Democratic-dominated Southern States. Because the full population of freed slaves would now be counted for determining congressional representation, rather than the three-fifths previously mandated by the Three-Fifths Compromise, the Southern States would dramatically increase their power in the population-based House of Representatives, regardless of whether the former slaves were allowed to vote. Republicans began looking for a way to offset this advantage, either by protecting and attracting votes of former slaves, or at least by discouraging their disenfranchisement.


text: In 1865, Congress passed what would become the Civil Rights Act of 1866, guaranteeing citizenship without regard to race, color, or previous condition of slavery or involuntary servitude. The bill also guaranteed equal benefits and access to the law, a direct assault on the Black Codes passed by many post-war states. The Black Codes attempted to return ex-slaves to something like their former condition by, among other things, restricting their movement, forcing them to enter into year-long labor contracts, prohibiting them from owning firearms, and preventing them from suing or testifying in court.


text: Although strongly urged by moderates in Congress to sign the bill, President Andrew Johnson vetoed it on March 27, 1866. In his veto message, he objected to the measure because it conferred citizenship on the freedmen at a time when 11 out of 36 states were unrepresented in the Congress, and that it discriminated in favor of African-Americans and against whites. Three weeks later, Johnson's veto was overridden and the measure became law. Despite this victory, even some Republicans who had supported the goals of the Civil Rights Act began to doubt that Congress really possessed constitutional power to turn those goals into laws. The experience also encouraged both radical and moderate Republicans to seek Constitutional guarantees for black rights, rather than relying on temporary political majorities.


text: More than seventy proposals for an amendment were drafted. In an extensive appendix to his dissenting opinion in "Adamson v. California" (1947), Justice Hugo Black analyzed and detailed the statements made by "those who framed, advocated, and adopted the Amendment" and thus shed some light on the history of the amendment's adoption. In late 1865, the Joint Committee on Reconstruction proposed an amendment stating that any citizens barred from voting on the basis of race by a state would not be counted for purposes of representation of that state. This amendment passed the House, but was blocked in the Senate by a coalition of Radical Republicans led by Charles Sumner, who believed the proposal a "compromise with wrong", and Democrats opposed to black rights. Consideration then turned to a proposed amendment by Representative John A. Bingham of Ohio, which would enable Congress to safeguard "equal protection of life, liberty, and property" of all citizens; this proposal failed to pass the House. In April 1866, the Joint Committee forwarded a third proposal to Congress, a carefully negotiated compromise that combined elements of the first and second proposals as well as addressing the issues of Confederate debt and voting by ex-Confederates. The House of Representatives passed "House Resolution 127, 39th Congress" several weeks later and sent to the Senate for action. The resolution was debated and several amendments to it were proposed. Amendments to Sections 2, 3, and4 were adopted on June 8, 1866, and the modified resolution passed by a 33 to 11 vote (5 absent, not voting). The House agreed to the Senate amendments on June 13 by a 138–36 vote (10 not voting). A concurrent resolution requesting the President to transmit the proposal to the governors of the states was passed by both houses of Congress on June 18.


text: The Radical Republicans were satisfied that they had secured civil rights for blacks but were disappointed that the amendment would not also secure political rights for blacks; in particular, the right to vote. For example, Thaddeus Stevens, a leader of the disappointed Radical Republicans, said: "I find that we shall be obliged to be content with patching up the worst portions of the ancient edifice, and leaving it, in many of its parts, to be swept through by the tempests, the frosts, and the storms of despotism." Abolitionist Wendell Phillips called it a "fatal and total surrender". This point would later be addressed by the Fifteenth Amendment.


text: On June 16, 1866, Secretary of State William Seward transmitted the Fourteenth Amendment to the governors of the several states for its ratification. State legislatures in every formerly Confederate state, with the exception of Tennessee, refused to ratify it. This refusal led to the passage of the Reconstruction Acts. Ignoring the existing state governments, military government was imposed until new civil governments were established and the Fourteenth Amendment was ratified. It also prompted Congress to pass a law on March 2, 1867, requiring that a former Confederate state must ratify the Fourteenth Amendment before "said State shall be declared entitled to representation in Congress."


text: If rescission by Ohio and New Jersey were illegitimate, South Carolina would have been the 28th state to ratify the amendment, enough for the amendment to be a part of the Constitution. Otherwise, only 26 states ratified the amendment out of the needed 28. Ohio and New Jersey's rescissions (which occurred after Democrats retook the states legislature) caused significant controversy and debate, but as this controversy occurred ratification by other states continued:


text: On July 20, 1868, Secretary of State William H. Seward certified that if withdrawals of ratification by New Jersey and Ohio were illegitimate, then the amendment had become part of the Constitution on July 9, 1868, with ratification by South Carolina as the 28th state. The following day, Congress declared New Jersey's recession of the amendment "scandalous", rejected the act and then adopted and transmitted to the Department of State a concurrent resolution declaring the Fourteenth Amendment to be a part of the Constitution and directing the Secretary of State to promulgate it as such, thereby establishing a precedent that a state cannot rescind a ratification. Ultimately, New Jersey and Ohio were named in the congressional resolution as having ratified the amendment, as well as Alabama, making 29 states in total.


text: On July 27, Secretary Seward received the formal ratification from Georgia. The following day, July 28, Secretary Seward issued his official proclamation certifying the adoption of the Fourteenth Amendment. Secretary Seward stated that his proclamation was "in conformance" to the resolution by Congress, but his official list of States included both Alabama and Georgia, as well as Ohio and New Jersey. Ultimately, regardless of the legal status of New Jersey's and Ohio's rescission, the amendment would have passed at the same time because of Alabama and Georgia's ratifications.


text: The inclusion of Ohio and New Jersey has led some to question the validity of the rescission of a ratification. The inclusion of Alabama and Georgia has called that conclusion into question. While there have been Supreme Court cases dealing with ratification issues, this particular question has never been adjudicated. On October 16, 1868, three months after the amendment was ratified and part of the Constitution, Oregon rescinded its ratification bringing the number of states that had the amendment actively ratified to 27 (for nearly a year), but this had no actual impact on the US Constitution or the 14th Amendment's standing.


text: Since Ohio and New Jersey re-ratified the Fourteenth Amendment in 2003, all U.S. states that existed during Reconstruction have ratified the amendment.


title: Joel McHale

text: Joel Edward McHale (born November 20, 1971) is an American actor, comedian, and television host. He is best known for hosting "The Soup" (2004–2015) and his role as Jeff Winger on the NBC sitcom "Community" (2009–2015). He has performed in the films "Spider-Man 2" (2004), "" (2011), "Ted" (2012) and "The Happytime Murders" (2018). He also starred in the short-lived CBS sitcom "The Great Indoors" (2016–2017), hosted a reboot of "Card Sharks" (2019–2021), and portrayed the superhero Sylvester Pemberton / Starman on the show "Stargirl" (2020–2022). In 2020, he hosted a special aftershow interviewing key subjects from the Netflix documentary series "Tiger King" and voiced Johnny Cage in the direct-to-video martial arts film "" (2020), a role he reprised in the sequel "" (2021). He also voices X-PO in "Lego Dimensions" (2015–2017) and The Scientist in "Fortnite" (2021–present).


title: Joel McHale

text: McHale was born in Rome on November 20, 1971, the son of Jack McHale, who worked as the Dean of Students at Loyola University's Rome Center, and his wife Laurie. His father is American and is from Chicago, while his mother is Canadian and a native of Vancouver. McHale is of Irish and Norwegian descent, and was raised Catholic. He grew up on Mercer Island, Washington, and briefly lived in Haddonfield, New Jersey, before returning to Mercer Island. He attended Mercer Island High School. He received a bachelor's degree in history from the University of Washington in 1995, and was briefly in the Theta Chi fraternity but left it because he "couldn't stand it."


title: Joel McHale

text: McHale was recruited to be on the University of Washington's rowing team, but later joined its football team. Though most of his teammates received athletic scholarships, he was a walk-on who played tight end for two years on the scout team without appearing in an actual game. He was part of the "Almost Live!" cast, a local sketch comedy television show produced by Seattle's KING-TV. From 1993 to 1997, he was a member of the improv comedy group at Unexpected Productions, participating in "Theatersports!" at the Market Theater located in Pike Place Market in downtown Seattle. He received an MFA from the Professional Actors Training Program at the University of Washington.


title: Joel McHale

text: In 2004, McHale began hosting "The Soup", a satirical weekly television show on the E! television network. Throughout the show, he takes the audience through the oddities and ridiculous happenings of the week in television. He frequently appears as a co-host on "Loveline". He has been a judge on "Iron Chef America". He was involved in the American version of the British TV show "The IT Crowd". McHale made a guest appearance on the finale of "Last Comic Standing"s sixth season, when he recapped the show's events in his typical format of jokes made popular on "The Soup". He made an appearance as a guest judge on "RuPaul's Drag Race" season 11, episode 4, "".


title: Joel McHale

text: McHale was the host at the 2014 White House Correspondents' Association annual dinner. He hosted the 2011 Independent Spirit Awards and the 2015 ESPY Awards. In 2016, he appeared as an occasional co-host alongside Kelly Ripa in the ABC morning show "Live with Kelly". McHale hosted the 43rd People's Choice Awards on January 18, 2017 and the 2017 Webby Awards on May 15, 2017. McHale hosted video game developer and publisher Ubisoft's press conference at E3 2010.


title: Joel McHale

text: In January 2018, it was announced that he would be receiving his own talk show on Netflix in February. "The Joel McHale Show with Joel McHale" combined celebrity guests, pre-taped sketches and video clips in a half-hour series that focused on pop culture and news from around the world. On August 17, 2018, it was announced that Netflix had canceled the show after 19 episodes, reportedly due to low viewership.


title: Joel McHale

text: On April 8, 2019, TVLine reported that McHale would host a revival of the game show "Card Sharks" for ABC. The revival would premiere on June 12 of that year, running for two seasons and 21 episodes until July 7, 2021. The iteration was canceled in April 2022.


title: Joel McHale

text: Beginning March 27, 2020, McHale co-hosts "The Darkest Timeline" podcast with former "Community" co-star Ken Jeong; the podcast was created in response to the ongoing COVID-19 pandemic. Also in 2020, he hosted an after-show special of the Netflix documentary series "Tiger King". With Jeong, they became the new hosts of Fox's New Year's Eve special "New Year's Eve Toast & Roast". The second edition was canceled due to the quickly rising cases of Omicron variant in the COVID-19 pandemic.


title: Joel McHale

text: After earning his master's degree in acting, McHale moved to Los Angeles and landed small roles in "", "", and "Will & Grace". He played a TV reporter in the biopic "Lords of Dogtown". He guest-starred as a cast member on the NBC improv comedy show "Thank God You're Here" during the pilot episode and had a guest role on an episode of "Pushing Daisies". McHale appeared in "Spider-Man 2" in a small role as Mr. Jacks, a bank manager.


title: Joel McHale

text: McHale has a long association with Circle X Theatre, where he has done several plays. McHale was a weekly guest on "The Adam Carolla Show" and "Mickey and Amelia", and occasional guest on "Opie and Anthony". He occasionally appeared on "Countdown with Keith Olbermann" in a humor sequence closing the show.


title: Joel McHale

text: McHale starred in the sitcom "Community", which premiered in fall 2009, and continued to host "The Soup". McHale made an appearance on the first episode of the fifth season of "Tosh.0". He played Rex in "Ted" (2012) and had a short guest stint on the FX show "Sons of Anarchy". He played a police officer in the supernatural horror film "Deliver Us from Evil". McHale appeared in 3 episodes between the tenth and eleventh seasons of "The X-Files" in 2016 and 2018, respectively.


title: Joel McHale

text: McHale played the lead role in the CBS sitcom "The Great Indoors", which began airing in the fall of 2016. The series was cancelled on May 13, 2017, due to low ratings.


title: Joel McHale

text: In 2018, McHale was cast in the recurring role of Chris on the second season of the Netflix horror-comedy series "Santa Clarita Diet".


title: Joel McHale

text: In December 2018, it was announced that McHale was cast as Sylvester Pemberton, the Golden Age Starman in the DC Universe and The CW series "Stargirl". After sporadic appearances in its first two seasons, he was upgraded to series regular for the third.


title: Joel McHale

text: McHale has been a regular guest panelist on "The Masked Singer". He first guested in episode four of the first season, then in two episodes of season 2 and episode 8 of season 3. In season 4, he was a guest panelist in episodes 3 and 4, on his first appearance performing Robin Thicke's "Blurred Lines" as the "Robin" (wearing a cut-out face of Robin Thicke). He went on to be a guest panelist in the third episode of season 5 and episode 7 of season 6.


title: Joel McHale

text: McHale married Sarah Williams in July 1996. They live in the Hollywood Hills with their two sons, Isaac and Eddie. In a 2018 interview on Dax Shepard's podcast "Armchair Expert", McHale revealed he was dyslexic, having discovered this when his two sons were diagnosed.


title: Joel McHale

text: McHale has said that he developed an interest in watches after stylist Jose Camilo got him a Ritmo Mundo watch, which also prompted McHale to buy a Bell & Ross military watch. He now owns 12 watches.


title: Joel McHale

text: He attends a Presbyterian church and has been supportive of the LGBT community; while performing at the Durham Performing Arts Center, he wore a handmade gay-rights shirt, talked about the bathroom law passed weeks prior, said he was donating all proceeds to the LGBTQ Center of Durham, and would not perform in the state again until the law was overturned. McHale, along with several of his "Community" castmates, made a campaign video in support of Joe Biden in October 2020 titled "Human Beings for Biden."


title: Joel McHale

text: In 2021, McHale has shown his support for the Children's Tumor Foundation, an organization dedicated to raising awareness for and treating Neurofibromatosis. Some other charities and foundations that McHale has supported include DoSomething.org, Elton John AIDS Foundation, Friar's Foundation, Jonsson Cancer Center Foundation, Make-A-Wish Foundation, Motion Picture & Television Fund, Noreen Fraser Foundation, Screen Actors Guild, The FEED Foundation, The Trevor Project, and UNICEF.


title: A Court of Thorns and Roses

text: A Court of Thorns and Roses is a new adult fantasy novel series by American author Sarah J. Maas, beginning with the novel of the same name, released in May 2015. The story follows the journey of mortal Feyre Archeron after she is brought into the faerie lands of Prythian for murdering a faerie, and the epic love story and fierce struggle that follows after she enters the fae lands.


title: A Court of Thorns and Roses

text: The series is a "New York Times" Best Seller and has been optioned by Hulu for a television series adaptation by Ronald D. Moore.


title: A Court of Thorns and Roses

text: Maas initially intended the series as a retelling of the fairy tales "Beauty and the Beast", "East of the Sun and West of the Moon", and "Tam Lin". These tales inspired the finished series, though it was not ultimately a dedicated retelling.


title: A Court of Thorns and Roses

text: She began writing "A Court of Thorns and Roses" in early 2009, with the first draft taking about five weeks to complete.


title: A Court of Thorns and Roses

text: "A Court of Mist and Fury"s first draft was written entirely in a split point of view between Feyre and Rhys. The second book went through multiple name changes, including "A Court of Wind and Stone", "A Court of Calm and Fury", "A Court of Stars and Smoke", "A Court of Wings and Stars", "A Court of Venom and Silver" and "A Court of Stars and Frost".<ref name="newsletter-05/03/2016"></ref> Like the first novel, the second is based upon multiple fairy tales and myths, including Hades and Persephone, where the Greek mythology inspired characters such as Rhysand and Feyre and their home in the Night Court. Other fairy tale inspirations include Hansel and Gretel, which spawned the character of the Weaver, and the Book of Exodus, which loosely inspired parts of the backstory for Miryam and Drakon.


title: A Court of Thorns and Roses

text: The final cover of "A Court of Wings and Ruin" was designed by Adrian Dadich, with the dress pictured on the cover originally designed by Charlie Bowater and later adapted by Dadich.


title: A Court of Thorns and Roses

text: On July 12, 2016, "Entertainment Weekly" reported that Maas was writing five new books for the series, which would include two novellas and three further novels which would be set before and after the first trilogy.


title: A Court of Thorns and Roses

text: In 2020, the series was reprinted and published by Bloomsbury with new illustrated covers. "A Court of Thorns and Roses" has existed in the gray area between Young Adult and New Adult fiction since the publication of the first book. At the time "A Court of Thorns and Roses" was published, the New Adult categorization hadn’t caught on the way publishers hoped it would. Maas agreed to publish the book as YA so long as her editor didn't censor any of the sexual content. The "A Court of Thorns and Roses" series is now firmly classified as New Adult.


title: A Court of Thorns and Roses

text: "A Court of Thorns and Roses" was optioned by Jo Bamford's and Piers Tempest's Tempo Productions in November 2015. The producers revealed in 2018 they had hired Rachel Hirons to work as the movie's screenwriter.


title: A Court of Thorns and Roses

text: In March 2021, it was announced that "A Court of Thorns and Roses" series had been opted for a television adaptation by 20th Television for Hulu. The series is set to be developed by Ronald D. Moore alongside Maas. In an interview with "The New York Times", Maas confirmed that she was developing the project with the writers and the showrunner as the executive producer of the adaptation.


title: Ashley Benson

text: Ashley Victoria Benson (born December 18, 1989) is an American actress, model, and singer. She is known for her role as Hanna Marin in the teen mystery-drama series "Pretty Little Liars" (2010–2017). Benson has starred in films, including "" (2007), "Christmas Cupid" (2010), "Spring Breakers" (2012), "Ratter" (2015), "Chronically Metropolitan" (2016), "Her Smell" (2018), and "Private Property" (2022). She has received various accolades, including four Teen Choice Awards, a Young Hollywood Award, as well as three People's Choice Award nominations.


title: Ashley Benson

text: Benson was born on December 18, 1989, in Anaheim Hills, California to parents Shannon and Jeff Benson. She has an older sister, Shaylene.


title: Ashley Benson

text: Benson began dancing competitively at age three, studying ballet, jazz, tap and hip hop. She began singing in choirs and musicals at a young age, performing a solo at her church at age four. When she was eight years old she signed with Ford Models, and appeared in a number of print ads.


title: Ashley Benson

text: Benson made her big screen debut with a bit part in the 2004 comedy "13 Going on 30". She starred as Carson in "" (2007), the fourth installment of the "Bring It On" franchise. The role required her to both overcome her fear of heights to perform the cheerleading stunts, and to end her contract with "Days of our Lives":


title: Ashley Benson

text: She recalled working on a film set instead of a soap opera set "definitely weird", because she would spend days working on one or two scenes, whereas on the "Days of Our Lives" set, she filmed two or three episodes a day. For "Bring It On: In It to Win It", she had to attend cheerleading practice, which was "hard for [her], because [she is] afraid of heights." Nonetheless, she was "glad" to do her own stunts, even though she "wasn't expecting it to be so hard."


title: Ashley Benson

text: In 2008, she appeared in the Lifetime original film "", where she played head cheerleader Brooke Tippit, a character loosely inspired by Karrissa Theret of the Fab Five. The film is based on a true story which took place at McKinney North High School in Texas. She became good friends with her onscreen mother Tatum O'Neal, from whom she learned about acting. Furthermore, she was excited to land a supporting role in "Bart Got a Room", which aired mainly on film festivals in 2008 before having a limited release in 2009, because it allowed her to work with William H. Macy. She also played a witch disguised as a cheerleader in a 2008 episode of The CW series "Supernatural".


title: Ashley Benson

text: In 2009, Benson starred in ABC's short-lived supernatural comedy television series "Eastwick". The show was based on John Updike's novel, "The Witches of Eastwick", and the 1987 film adaption of the same name. The series only lasted 11 episodes before ABC cancelled the series due to low ratings but has since gained a cult following.


title: Ashley Benson

text: In December 2009, Benson was cast as Hanna Marin in the ABC Family mystery-thriller teen drama series "Pretty Little Liars", based on the novel series by Sara Shepard. Hanna is the "diva" and "It girl" of the group, having taken Alison DiLaurentis' place as the most popular girl at Rosewood High in Alison's absence. The series premiered to 2.47 million viewers with Benson's performance being praised by critics. She also received a number of awards and nominations. Benson reprised the role in the spin-off series "Ravenswood" in two episodes.


title: Ashley Benson

text: In 2010, Benson starred in the television film "Christmas Cupid" alongside Christina Milian and Chad Michael Murray, which also aired on ABC Family. In January 2012, Benson was cast in the film "Spring Breakers", after Emma Roberts dropped out due to creative reasons. The film centers on four college students who are arrested and bailed out by a drug and arms dealer, who sends them out to do some dirty work on spring break. The film co-starred Selena Gomez, Vanessa Hudgens, and James Franco. Filming took place in March and April 2012, and the film was released in March 2013.


title: Ashley Benson

text: In the January 21, 2013, episode of the CBS sitcom "How I Met Your Mother", Benson appeared as Carly Whittaker, Barney Stinson's half-sister who dated Ted Mosby. That same month, Benson became the face of eveningwear designer Faviana.


title: Ashley Benson

text: She starred in the 2015 independent horror thriller film "Ratter", playing Emma Taylor, a girl who is stalked through her technological devices. That same year, she also appeared in "Pixels" as Lady Lisa, a fictional game character brought to life. In 2016, Benson appeared in the biographical comedy-drama film "Elvis & Nixon" as Margaret.


title: Ashley Benson

text: In 2018, it was announced that Benson would star alongside Cara Delevingne and Elisabeth Moss in Alex Ross Perry's music drama film "Her Smell", and the film received generally positive reviews, with Benson becoming a contender for the Academy Award for Best Supporting Actress. For the film's soundtrack, Benson did all her own vocals.


title: Ashley Benson

text: In 2020, Benson was featured on "Creep" by G-Eazy, a cover version of the Radiohead song. She also appeared in the music videos previously for NLT's "That Girl", One Call's "Black Light", and Hot Chelle Rae's "Honestly".


title: Ashley Benson

text: From 2018 to 2020, Benson was in a high-profile relationship with English model Cara Delevingne, and has since been in an on-again, off-again relationship with rapper G-Eazy. She currently resides in Los Angeles.


title: Thomas Cromwell

text: Thomas Cromwell (; 1485 – 28 July 1540), briefly Earl of Essex, was an English lawyer and statesman who served as chief minister to King Henry VIII from 1534 to 1540, when he was beheaded on orders of the king, who later blamed false charges for the execution.


title: Thomas Cromwell

text: Cromwell was one of the most powerful proponents of the English Reformation, and the creator of true English governance. He helped to engineer an annulment of the king's marriage to Catherine of Aragon so that Henry could lawfully marry Anne Boleyn. Henry failed to obtain the approval of Pope Clement VII for the annulment in 1533, so Parliament endorsed the king's claim to be Supreme Head of the Church of England, giving him the authority to annul his own marriage. Cromwell subsequently charted an evangelical and reformist course for the Church of England from the unique posts of Vicegerent in Spirituals and Vicar-general (the two titles refer to the same position).


title: Thomas Cromwell

text: During his rise to power, Cromwell made many enemies, including Anne Boleyn, with his fresh ideas and lack of nobility. He duly played a prominent role in her downfall. He later fell from power, after arranging the king's marriage to German princess Anne of Cleves. Cromwell had hoped that the marriage would breathe fresh life into the Reformation in England, but Henry found his new bride unattractive and the marriage was a disaster for Cromwell, ending in an annulment six months later. Cromwell was arraigned under a bill of attainder and executed for treason and heresy on Tower Hill on 28 July 1540. The king later expressed regret at the loss of his chief minister, and his reign never recovered from the incident.


title: Thomas Cromwell

text: Thomas Cromwell was born around 1485, in Putney, Surrey, the son of Walter Cromwell, a yeoman, fuller and cloth merchant, and owner of both a hostelry and a brewery. A popular tradition that he also carried on the trade of blacksmith may have arisen from his use of the alternative surname of "Smith", rather than actually practising the trade. As a successful tradesman, Walter was regularly called upon for jury service and was elected Constable of Putney in 1495. A well-informed but anonymous contemporary chronicler wrote that Walter was of Irish ancestry, but biographer James Gairdner has identified Cromwell family roots in Norwell, Nottinghamshire. Thomas's mother, generally named as Katherine Meverell, was from a recognised "gentry family" in Staffordshire. She lived in Putney in the house of a local attorney, John Welbeck, at the time of her marriage to Walter in 1474.


title: Thomas Cromwell

text: Cromwell had two sisters: the elder, Katherine, married Morgan ("ap William") Williams, a Welsh lawyer's son who came to Surrey as a follower of King Henry VII when he established himself in the nearby Richmond Palace; the younger, Elizabeth, married a farmer, William Wellyfed. Katherine's and Morgan's son, Richard, was employed in his uncle's service and by the autumn of 1529 had changed his name to Cromwell.


title: Thomas Cromwell

text: Little is known about Cromwell's early life. It is believed that he was born at the top of Putney Hill, on the edge of Putney Heath. In 1878, his birthplace was still of note:


title: Thomas Cromwell

text: The site of Cromwell's birthplace is still pointed out by tradition and is in some measure confirmed by the survey of Wimbledon Manor […] for it describes on that spot 'an ancient cottage called the smith's shop, lying west of the highway from Richmond to Wandsworth, being the sign of the Anchor'. The plot of ground here referred to is now covered by the Green Man public house.


title: Thomas Cromwell

text: Alternatively, from contemporary manorial records, local historian Jackson Blomfield identifies the birthplace as The Brew House, situated at the foot of Putney Hill on the west side, near to Upper Richmond Road.


title: Thomas Cromwell

text: Cromwell declared to Archbishop of Canterbury Thomas Cranmer that he had been a "ruffian ... in his young days". In his youth he left his family in Putney and crossed the Channel to the Continent. Accounts of his activities in France, Italy and the Low Countries are sketchy and contradictory. The tale that he first became a mercenary and marched with the French army to Italy, where in 1503 he fought in the Battle of Garigliano, originally stems from a short story by the contemporary Italian novelist Matteo Bandello (in which Cromwell is a page to a foot-soldier, carrying his pike and helmet, rather than a soldier himself).


title: Thomas Cromwell

text: This tale was later taken up as fact by many writers, notably John Foxe in his "Actes and Monuments" of 1563. Diarmaid MacCulloch accepts that the specifics in Bandello's narrative suggest that it is more than an invented account, but James Gairdner, while acknowledging that Cromwell's year of birth is uncertain, points out that he could have been as young as 13 on the day of the battle. While in Italy, he entered service in the household of the Florentine banker Francesco Frescobaldi, who rescued him off the Florentine streets, where he was starving after leaving the French mercenaries. Later, he visited leading mercantile centres in the Low Countries, living among the English merchants and developing a network of contacts while learning several languages. At some point he returned to Italy. The records of the English Hospital in Rome indicate that he stayed there in June 1514, while documents in the Vatican Archives suggest that he was an agent for the Archbishop of York, Cardinal Christopher Bainbridge, and handled English ecclesiastical issues before the Roman Rota.


title: Thomas Cromwell

text: At one point during these years, Cromwell returned to England, where around 1515 he married Elizabeth Wyckes (d. 1529). She was the widow of Thomas Williams, a Yeoman of the Guard, and the daughter of a Putney shearman, Henry Wykes, who had served as a gentleman usher to King Henry VII.


title: Thomas Cromwell

text: Cromwell's wife died early in 1529 and his daughters, Anne and Grace, are believed to have died not long after their mother. Their death may have been due to sweating sickness. Provisions made for Anne and Grace in Cromwell's will, dated 12 July 1529, were crossed out at some later date. Gregory outlived his father by only 11 years, succumbing to sweating sickness in 1551.


title: Thomas Cromwell

text: Cromwell also had an illegitimate daughter, Jane (–1580), whose early life is a complete mystery. According to novelist Hilary Mantel, "Cromwell had an illegitimate daughter, and beyond the fact that she existed, we know very little about her. She comes briefly into the records, in an incredibly obscure way—she's in the archives of the county of Chester."


title: Thomas Cromwell

text: Jane was born to an unknown mother while Cromwell mourned the loss of his wife and daughters. Jane presumably was educated and resided in Cromwell's homes; In 1539 she was living with her half-brother Gregory and his wife Elizabeth at Leeds Castle. Cromwell's records show him paying Elizabeth for clothing and expenses for Jane. It is unknown what became of Jane's mother. Cromwell was known to be one of the few men at court without mistresses and tried to keep this indiscretion secret.


title: Thomas Cromwell

text: Jane married William Hough (–1585), of Leighton in Wirral, Cheshire, around 1550. William Hough was the son of Richard Hough (1508–1573/1574) who was Cromwell's agent in Chester from 1534 to 1540. Jane and her husband remained staunch Roman Catholics, who, together with their daughter, Alice, her husband, William Whitmore, and their children, all came to the attention of the authorities as recusants during the reign of Elizabeth I.


title: Thomas Cromwell

text: In 1517, and again in 1518, Cromwell led an embassy to Rome to obtain from Pope Leo X a papal bull for the reinstatement of Indulgences for the town of Boston, Lincolnshire.


title: Thomas Cromwell

text: By 1520, Cromwell was firmly established in London mercantile and legal circles. In 1523, he obtained a seat in the House of Commons as a Burgess, though the constituency he represented has not been identified with certainty. He prepared a daring speech against King Henry's declared intention of leading an invasion of France, although it was expressed tactfully in terms of concern for the king's safety while on campaign and fear of the costs such an overbold policy would entail; it was the latter point that embodied Cromwell's true concern. There is no record of when Cromwell actually delivered the speech in the chamber and some modern historians, including Michael Everett and Robert Woods, have suggested that the whole episode was no more than a ploy, sanctioned by Henry himself, to allow him to withdraw graciously from his rash threat of war.


title: Thomas Cromwell

text: After Parliament had been dissolved, Cromwell wrote a letter to a friend, jesting about the session's lack of productivity:I amongst other have indured a parlyament which contenwid by the space of xvii hole wekes wher we communyd of warre pease Stryffe contencyon debatte murmure grudge Riches poverte penurye trowth falshode Justyce equyte dicayte [deceit] opprescyon Magnanymyte actyvyte foce [force] attempraunce [moderation] Treason murder Felonye consyli... [conciliation] and also how a commune welth myght be ediffyed and a[lso] contenewid within our Realme. Howbeyt in conclusyon we have d[one] as our predecessors have been wont to doo that ys to say, as well we myght and lefte wher we begann.


title: Thomas Cromwell

text: For a short while early in 1523 Cromwell became an adviser to Thomas Grey, 2nd Marquess of Dorset, drafting a parliamentary bill to relieve his sponsor of taxation on some property in Cumberland. Although the bill was not introduced in the 1523 session of Parliament, this may indicate that that the unidentified seat for which Cromwell was returned in that year was Carlisle, Cumberland, to present the Marquess's bill. Early in 1524 he become a member of the household of Lord Chancellor Cardinal Wolsey, although initially he maintained his private legal practice; in that year he was elected a member of Gray's Inn, a lawyers' guild. Cromwell assisted in the dissolution of nearly thirty monasteries to raise funds for Wolsey to found The King's School, Ipswich (1528), and Cardinal College, in Oxford (1529). In 1529 Wolsey appointed Cromwell a member of his council, as one of his most senior and trusted advisers. By the end of October of that year, however, Wolsey had fallen from power. Cromwell had made enemies by aiding Wolsey to suppress the monasteries, but was determined not to fall with his master, as he told George Cavendish, then a Gentleman Usher and later Wolsey's biographer:I do entend (god wyllyng) this after none, whan my lord hathe dyned to ride to london and so to the Court, where I wyll other make or marre, or ere [before] I come agayn, I wyll put my self in the prese [press] to se what any man is Able to lay to my charge of ontrouthe or mysdemeanor.


title: Thomas Cromwell

text: Cavendish acknowledges that Cromwell's moves to mend the situation were by means of engaging himself in an energetic defence of Wolsey ("There could nothing be spoken against my lord…but he [Cromwell] would answer it incontinent[ly]"), rather than by distancing himself from his old master's actions, and this display of "authentic loyalty" only enhanced his reputation, not least in the mind of the King.


title: Thomas Cromwell

text: Cromwell successfully overcame the shadow cast over his career by Wolsey's downfall. By November 1529, he had secured a seat in Parliament as a member for Taunton and was reported to be in favour with the King. Early in this short session of Parliament (November to December 1529) Cromwell involved himself with legislation to restrict absentee clergy from collecting stipends from multiple parishes ("clerical farming") and to abolish the power of Rome to award dispensations for the practice.


title: Thomas Cromwell

text: At some point during the closing weeks of 1530, the King appointed him to the Privy Council. Cromwell held numerous offices during his career in the King's service, including:


title: Thomas Cromwell

text: From 1527, Henry VIII had sought to have his marriage to Queen Catherine of Aragon annulled, so that he could lawfully marry Anne Boleyn. At the centre of the campaign to secure the annulment was the emerging doctrine of royal supremacy over the church. By the autumn of 1531, Cromwell had taken control of the supervision of the king's legal and parliamentary affairs, working closely with Thomas Audley, and had joined the inner circle of the council. By the following spring, he had begun to exert influence over elections to the House of Commons.


title: Thomas Cromwell

text: The third session of what is now known as the Reformation Parliament had been scheduled for October 1531, but was postponed until 15 January 1532 because of Henry's indecision as to the best way to proceed towards his annulment. Cromwell favoured the assertion of royal supremacy over the recalcitrant Church, and he manipulated support in the House of Commons for the measure by resurrecting anti-clerical grievances expressed earlier, in the session of 1529. Once he achieved his goal of managing affairs in Parliament, he never relinquished it. On 18 March 1532, the Commons delivered a supplication to the king, denouncing clerical abuses and the power of the ecclesiastical courts, and describing Henry as "the only head, sovereign lord, protector and defender" of the Church. On 14 May 1532, Parliament was prorogued. Two days later, Sir Thomas More resigned as Lord Chancellor, realising that the battle to save the marriage was lost. More's resignation from the Council represented a triumph for Cromwell and the pro-Reformation faction at court.


title: Thomas Cromwell

text: The king's gratitude to Cromwell was expressed in a grant of the lordship of the manor of Romney in the Welsh Marches (recently confiscated from the family of the executed Edward Stafford, 3rd Duke of Buckingham) and appointment to three relatively minor offices: Master of the Jewels on 14 April 1532, Clerk of the Hanaper on 16 July, and Chancellor of the Exchequer on 12 April 1533. None of these offices afforded much income, but the appointments were an indication of royal favour, and gave Cromwell a position in three major institutions of government: the royal household, the Chancery, and the Exchequer.


title: Thomas Cromwell

text: Henry and Anne married on 25 January 1533, after a secret marriage on 14 November 1532 that may have taken place in Calais.


title: Thomas Cromwell

text: On 26 January 1533 Audley was appointed Lord Chancellor and his replacement as Speaker of the House of Commons was Cromwell's old friend (and former lawyer to Cardinal Wolsey) Humphrey Wingfield. Cromwell further increased his control over parliament through his management of by-elections: since the previous summer, assisted by Thomas Wriothesley, then Clerk of the Signet, he had prepared a list of suitably amenable "burgesses, knights and citizens" for the vacant parliamentary seats.


title: Thomas Cromwell

text: The parliamentary session began on 4 February, and Cromwell introduced a new bill restricting the right to make appeals to Rome, reasserting the long-standing historical fiction that England was an "empire" and thus not subject to external jurisdiction. On 30 March, Cranmer was consecrated Archbishop of Canterbury, and Convocation immediately declared the king's marriage to Catherine unlawful. In the first week of April 1533, Parliament passed Cromwell's bill into law, as the Act in Restraint of Appeals, ensuring that any adjudication concerning the king's marriage could not be challenged in Rome. On 11 April, Archbishop Cranmer sent the King formal notice that the validity of his marriage to Catherine was to be the subject of an ecclesiastical court hearing. The trial began on 10 May 1533 at Dunstable Priory (near to where Catherine was staying at Ampthill Castle) and on 23 May the Archbishop pronounced the court's verdict, declaring the marriage "null and invalid…contrary to the law of God". Five days later he pronounced the King's marriage to Anne to be lawful, and on 1 June, she was crowned queen.


title: Thomas Cromwell

text: In December, the King authorised Cromwell to discredit the papacy and the Pope was attacked throughout the nation in sermons and pamphlets. In 1534 a new Parliament was summoned, again under Cromwell's supervision, to enact the legislation necessary to make a formal break of England's remaining ties with Rome. Archbishop Cranmer's verdict took statutory form as the Act of Succession, the Dispensations Act reiterated royal supremacy and the Act for the Submission of the Clergy incorporated into law the clergy's surrender in 1532. On 30 March 1534, Audley gave royal assent to the legislation in the presence of the King.


title: Thomas Cromwell

text: In April 1534, Henry confirmed Cromwell as his principal secretary and chief minister, a position which he had held for some time in all but name. Cromwell immediately took steps to enforce the legislation just passed by Parliament. Before the members of both houses returned home on 30 March, they were required to swear an oath accepting the Act of Succession, and all the King's subjects were now required to swear to the legitimacy of the marriage and, by implication, to accept the King's new powers and the break from Rome. On 13 April, the London clergy accepted the oath. On the same day, the commissioners offered it to Sir Thomas More and John Fisher, Bishop of Rochester, both of whom refused it. More was taken into custody on the same day and was moved to the Tower of London on 17 April. Fisher joined him there four days later. On 7 May Cromwell led a deputation from the commissioners to Fisher and More, to persuade them to accept the Act and save themselves. This failed and, within a month, both prisoners were executed.


title: Thomas Cromwell

text: On 18 April, an order was issued that all citizens of London were to swear their acceptance of the Oath of Succession. Similar orders were issued throughout the country. When Parliament reconvened in November, Cromwell brought in the most significant revision of the treason laws since 1352, making it treasonous to speak rebellious words against the Royal Family, to deny their titles, or to call the King a heretic, tyrant, infidel, or usurper. The Act of Supremacy also clarified the King's position as head of the church and the Act for Payment of First Fruits and Tenths substantially increased clerical taxes. Cromwell also strengthened his own control over the Church.


title: Thomas Cromwell

text: During November 1534, another provision of the Act of Succession was in preparation: the appointment of three "vicegerentes" to supervise all ecclesiastical institutions. When the measure was put into effect on 21 January 1535, however, only one name remained: that of Cromwell. The King appointed him Royal Vicegerent and Vicar-General, and issued a warrant to authorise a visitation of all the country's churches, monasteries and clergy. Neville Williams explains that as Vicegerent in spiritual affairs Cromwell held sway over church doctrine and religious policy, while from the Vicar General title he drew his authority over monasteries and other church institutions. By September 1535 Cromwell had appointed his own officials for church administration, with authority over the archbishops of Canterbury and York, to oversee all church affairs. He never declared that this visitation was ever complete, so he retained its extensive powers in his own hands. In this capacity, Cromwell conducted a census in 1535 to enable the government to evaluate and tax church property more effectively.


title: Thomas Cromwell

text: A lasting achievement of Cromwell's vicegerency was his direction of Autumn 1538 that every parish in the country should securely maintain a record of all christenings, marriages and burials. Although intended as a means to flush out Anabaptists (dissenting religious refugees from the Low Countries and elsewhere who did not practise infant baptism) the measure proved to be of great benefit to the posterity of English historians.


title: Thomas Cromwell

text: The final session of the Reformation Parliament began on 4 February 1536. By 18 March, an Act for the Suppression of the Lesser Monasteries, those with a gross income of less than £200 per annum, had passed both houses. This caused a clash with Anne Boleyn, formerly one of Cromwell's strongest allies, who wanted the proceeds of the dissolution used for educational and charitable purposes, not paid into the King's coffers.


title: Thomas Cromwell

text: Anne instructed her chaplains to preach against the Vicegerent, and in a blistering sermon on Passion Sunday, 2 April 1536, her almoner, John Skip, denounced Cromwell and his fellow Privy Councillors before the entire court. Skip's diatribe was intended to persuade courtiers and Privy Councillors to change the advice they had been giving the King and to reject the temptation of personal gain. Skip was called before the council and accused of malice, slander, presumption, lack of charity, sedition, treason, disobedience to the gospel, attacking "the great posts, pillars and columns sustaining and holding up the commonwealth" and inviting anarchy.


title: Thomas Cromwell

text: Anne, who had many enemies at court, had never been popular with the people and had so far failed to produce a male heir. The King was growing impatient, having become enamoured of the young Jane Seymour and being encouraged by Anne's enemies, particularly Sir Nicholas Carew and the Seymours. In circumstances that have divided historians, Anne was accused of adultery with Mark Smeaton, a musician of the royal household; Sir Henry Norris, the King's groom of the stool and one of his closest friends; Sir Francis Weston; Sir William Brereton; and her brother, George Boleyn, 2nd Viscount Rochford. The Imperial Ambassador, Eustace Chapuys, wrote to Charles V that: he himself [Cromwell] has been authorised and commissioned by the king to prosecute and bring to an end the mistress's trial, to do which he had taken considerable trouble... He set himself to devise and conspire the said affair. Regardless of the role Cromwell played in Anne Boleyn's fall, and his confessed animosity to her, Chapuys's letter states that Cromwell claimed that he was acting with the King's authority. Most historians, however, are convinced that her fall and execution were engineered by Cromwell.


title: Thomas Cromwell

text: The Queen and her brother stood trial on Monday 15 May, while the four others accused with them were condemned on the Friday beforehand. The men were executed on 17 May 1536 and, on the same day, Cranmer declared Henry's marriage to Anne invalid, a ruling that illegitimised their daughter, Princess Elizabeth. Two days later, Anne herself was executed. On 30 May, the King married Jane Seymour. On 8 June, a new Parliament passed the second Act of Succession, securing the rights of Queen Jane's heirs to the throne.


title: Thomas Cromwell

text: Cromwell's position was now stronger than ever. He succeeded Anne Boleyn's father, Thomas Boleyn, 1st Earl of Wiltshire, as Lord Privy Seal on 2 July 1536, resigning the office of Master of the Rolls, which he had held since 8 October 1534. On 8 July 1536, he was raised to the peerage as Baron Cromwell of Wimbledon.


title: Thomas Cromwell

text: Cromwell orchestrated the Dissolution of the Monasteries and visitations to the universities and colleges in 1535, which had strong links to the church. This resulted in the dispersal and destruction of many books deemed "popish" and "superstitious". This has been described as "easily the greatest single disaster in English literary history". Oxford University was left without a library collection until Sir Thomas Bodley's donation in 1602.


title: Thomas Cromwell

text: In July 1536, the first attempt was made to clarify religious doctrine after the break with Rome. Bishop Edward Foxe tabled proposals in Convocation, with strong backing from Cromwell and Cranmer, which the King later endorsed as the Ten Articles and which were printed in August 1536. Cromwell circulated injunctions for their enforcement that went beyond the Articles themselves, provoking opposition in September and October in Lincolnshire and then throughout the six northern counties. These widespread popular and clerical uprisings, collectively known as the Pilgrimage of Grace, found support among the gentry and even the nobility.


title: Thomas Cromwell

text: The rebels' grievances were wide-ranging, but the most significant was the suppression of the monasteries, blamed on the King's "evil counsellors", principally Cromwell and Cranmer. One of the leaders of the rebellion was Thomas Darcy, 1st Baron Darcy of Darcy, who gave Cromwell the prophetic warning during his interrogation in the Tower: "[…] men who have been in cases like with their prince as ye be now have come at the last to the same end that ye would now bring me unto.". The suppression of the risings spurred further Reformation measures. In February 1537, Cromwell convened a vicegerential synod of bishops and academics. The synod was co-ordinated by Cranmer and Foxe, and they prepared a draft document by July: "The Institution of a Christian Man", more commonly known as the Bishops' Book. By October, it was in circulation, although the King had not yet given it his full assent. However, Cromwell's success in Church politics was offset by the fact that his political influence had been weakened by the emergence of a Privy Council, a body of nobles and office-holders that first came together to suppress the Pilgrimage of Grace. The King confirmed his support of Cromwell by appointing him to the Order of the Garter on 5 August 1537, but Cromwell was nonetheless forced to accept the existence of an executive body dominated by his conservative opponents.


title: Thomas Cromwell

text: In January 1538, Cromwell pursued an extensive campaign against what the opponents of the old religion termed "idolatry": statues, rood screens, and images were attacked, culminating in September with the dismantling of the shrine of St. Thomas Becket at Canterbury. Early in September, Cromwell also completed a new set of vicegerential injunctions declaring open war on "pilgrimages, feigned relics or images, or any such superstitions" and commanding that "one book of the whole Bible in English" be set up in every church. Moreover, following the "voluntary" surrender of the remaining smaller monasteries during the previous year, the larger monasteries were now also "invited" to surrender throughout 1538, a process legitimised in the 1539 session of Parliament and completed in the following year.


title: Thomas Cromwell

text: The King was becoming increasingly unhappy about the extent of religious changes, and the conservative faction was gaining strength at court. Cromwell took the initiative against his enemies. He imprisoned the Marquess of Exeter, Sir Edward Neville, and Sir Nicholas Carew on charges of treason in November 1538 (the "Exeter Conspiracy"), using evidence acquired from Sir Geoffrey Pole under interrogation in the Tower. Sir Geoffrey, "broken in spirit", was pardoned but the others were executed.