ࡱ> proq` >objbjqPqP ;::f^D844 2J,0FFFzp+dN/2222222$3h76x*21zz11*2FF4?21111LFF2112111F  ihY2N1F12U202161L6161$1111*2*21111211114 4 4 d4 4 4 T 30 UCLALR 455 (Cite as: 30 UCLA L. Rev. 455) UCLA Law Review February, 1983 *455 THE ORIGINS OF THE PRESS CLAUSE David A. Anderson [FNa] ARTICLES THE ORIGINS OF THE PRESS CLAUSE David A. Anderson [FNa] II. THE LEGISLATIVE HISTORY OF THE PRESS CLAUSE By legislative history, I mean the record of the drafting, amendment, debate, and passage of the press clause and its textual antecedents in official declarations, state constitutions, and proposals of state ratifying conventions. This Article is neither a history of the press in colonial and revolutionary America nor an intellectual history of freedom of expression, though it draws on both. Those histories have received considerable attention already. [FN46] My enterprise is not the history of freedom of the press, but the history of the language that became the press clause of the first amendment. *463 A. PreRevolutionary Declarations The history of the press clause begins a generation before the actual drafting of the first amendment. [FN47] In 1768, the Boston Gazette, the leading organ of radicalism in Massachusetts, accused the royal governor of misrepresenting the position of the Massachusetts House to the British secretary of state. [FN48] The Royal Council condemned the article as a seditious libel, and Governor Bernard asked the House to turn the matter over to a grand jury for prosecution. The House, dominated by the radical leader Sam Adams, refused to do so and instead adopted a resolution stating: "The Liberty of the Press is a great Bulwark of the Liberty of the People: It is, therefore, the incumbent Duty of those who are constituted the Guardians of the People's Rights to defend and maintain it." [FN49] As we shall see later, [FN50] this language appears to have been adapted from one of "Cato's Letters" that had been republished in the Gazette only a few months earlier. [FN51] A more elaborate declaration came in 1774, on the eve of the War for Independence. The Continental Congress, hoping to make allies of the settlers in Quebec, approved a declaration explaining to the northern neighbors the goals of the American endeavor: The last right we shall mention, regards the freedom of the press. The importance of this consists, besides the advancement of truth, science, morality, and arts in general, in its diffusion of liberal sentiments on the administration of Government, in its ready communication of thoughts between subjects, and its consequential promotion of union among them, whereby oppressive officers are shamed or intimidated, *464 into more honourable and just modes of conducting affairs. [FN52] Three things should be noted about the Quebec Address. First, its view of the purposes of freedom of the press was not limited to scrutiny of government, but also included broader intellectual and cultural objectives. Second, the declaration said nothing about freedom of speech. Although it reflects values we associate today with freedom of speech, or freedom of expression generally, it viewed the press as the means by which these values were to be vindicated. Third, the declaration must be read as an expression of American aspirations rather than accomplishments. The press freedom that the Continental Congress so ardently commended to the inhabitants of Quebec was poorly protected by law in America. The colonial press had no legal protection in 1774 other than the common law prohibition against prior restraintshardly a sufficient safeguard for the ambitious role outlined for the press in the Quebec Address. B. The State Constitutions The Massachusetts resolution and Quebec Address were not law, of course. The first legally effective press clauses appeared in the eleven state constitutions adopted during the War for Independence. [FN53] Of those, nine included provisions on freedom of the press, all phrased in general terms. [FN54] There were essentially four versions of these early press clauses. The first was the provision drafted by George Mason in 1776 for the Virginia Declaration of Rights. It read: "That the freedom of the Press is one of the greatest bulwarks of liberty, and can never be restrained but by despotick Governments." [FN55] This was copied almost verbatim in the North Carolina Declaration of Rights, later in 1776. [FN56] The second model was that of Maryland, which said simply: *465 "That the liberty of the press ought to be inviolably preserved." [FN57] This was adopted verbatim in the Delaware Declaration of Rights, [FN58] and with minor deviations in the constitutions of Georgia [FN59] and South Carolina. [FN60] The Massachusetts Constitutional Convention of 1780 produced its own version of the press clause. It read: "The liberty of the press is essential to the security of freedom in a state: it ought not, therefore, to be restrained in this Commonwealth." [FN61] New Hampshire copied this model in its Bill of Rights of 1783. [FN62] The only state whose press clause did not follow one of these models was Pennsylvania; [FN63] it had the only original state constitution that protected freedom of speech as well as press. The Pennsylvania provision read: "That the people have a right to freedom of speech, and of writing, and publishing their sentiments; therefore the freedom of the press ought not to be restrained." [FN64] This is the provision invariably referred to as "the press clause" of the Pennsylvania Constitution, and as we shall see, this language eventually played an important role in the evolution of the first amendment. [FN65] But the Pennsylvania Constitution of 1776 contained a second provision relating to the press. This second press clause has been little noticed because it was contained not in the Declaration of Rights, where the other press clause was located, but in the main body of the constitution, called the "Plan or Frame of Government for Commonwealth or State of Pennsylvania." This second press clause read as follows: "The printing presses shall be free to every person who undertakes to examine the proceedings of the legislature, or any part of government." [FN66] *466 It is impossible to know exactly what this provision meant. It may have been an exhortation to printers to open their columns to opposing viewpoints on government. We usually think of the colonial newspapers as being intensely partisan, and most of them were. But many of them also served as forums for public debate. The South Carolina Gazette, which Benjamin Franklin helped found, was a forum for religious and political controversy throughout the prerevolutionary period. [FN67] As late as 1775, James Rivington, a leading Tory publisher, affirmed that his New York Gazetteer was open to all parties and that he considered his press "in the light of a public office, to which every man has a right to haverecourse." [FN68] Merrill Jensen, an indefatigable reader of the newspapers of the period, wrote that "most newspaper publishers believed that it was a part of their public duty to print materials on all sides of a question, even when they were counter to a particular publisher's own views." [FN69] Moreover, impartiality and accessibility seem to have been universally acknowledged as ideals, however often they may have been ignored in practice. Even the most partisan papers invariably claimed impartiality, and when printers were attacked for publishing unpopular viewpoints, they often defended by appealing to the public's appreciation of the value of free and open discussion. Thus, even though the press did not come to view itself as primarily a neutral conduit of information until much later, the ideal of impartiality already was powerful enough to have inspired the second Pennsylvania press clause. [FN70] III. INTERPRETING THE LEGISLATIVE HISTORY The legislative history of the press clause is, of course, inconclusive, not only in the sense that history is always inconclusive, but also because the Framers simply did not articulate what they meant by "freedom of the press." [FN193] Until some further evidence *487 of their views turns up (which seems unlikely, in view of the vast amount of attention historians already have devoted to the Framers and their writings), attempts to divine the "original understanding" of the press clause must begin with this sketchy history of its framing. Nevertheless, some conclusions may be drawn. First, freedom of the press, whatever it meant, was a matter of widespread concern. Nine of the eleven original states that adopted revolutionary constitutions protected freedom of press. [FN194] It was included in the bill of rights proposed at the constitutional convention; after that proposal was rejected, it was the only right proposed independently. Of the seven bills of rights that were proposed in the ratifying conventions, five contained press clauses. [FN195] By the time the First Congress began preparing a bill of rights, there was little doubt that one of the rights would be freedom of the press. Every version of the Bill of Rights considered by the First Congress contained a press clause; there was never any suggestion that it should be deleted. [FN196] Freedom of the press occupied a secure place in the framers' catalogue of essential rights. Second, the press clause had its own origins, separate and distinct from the other first amendment rights. Freedom of the press was neither equated with nor viewed as a derivative of freedom of speech. Most of the state constitutions protected freedom of the press, but only one protected speech. As Levy showed, [FN197] freedom of speech, unlike freedom of the press, had little history as an independent concept when the first amendment was framed. "It developed as an offshoot of freedom of the press, on the one hand, and on the other, freedom of religionthe freedom to speak openly on religious matters." [FN198] The hypothesis that the press clause was merely "complementary to and a natural extension of Speech Clause liberty," [FN199] advanced by Chief Justice Burger, is not supported by the historical evidence. Epistemologically, at least, the press clause was primary and the speech clause secondary. *488 "Freedom of expression," the notion of an interrelated complex of protections for thought, belief, and expression, is a modern concept. To impose it retrospectively on the framers is anachronistic. Although they gradually recognized a relationship between the freedoms of press, speech, petition, assembly, and religion, the process was inductive, rather than deductive. The Framers began not with a general theory of intellectual freedom, but with specific solutions to concrete grievances. The first amendment must be viewed (historically, at least) as the sum of its parts, not as a divisible integer. Third, there is no evidence that the framers intended to protect freedom of the press qualifiedly. Whatever the concept meant to them, they sought to protect it fully. Not one of the state press clauses included the Blackstonian limitation, "being responsible for the abuse thereof," which appeared in a number of later state constitutions. [FN200] None of the proposals of the ratifying conventions contained any such limitation, nor did any of the versions in the First Congress. The only attempt to impose any limitationthe proposal in the Senate to protect the press only "in as ample a manner as hath at any time been secured by the common law" [FN201]was defeated. In the debates of the Constitutional Convention and the First Congress, no one expressed any fear of the power of the press or any apprehension of abuse of its power. No one suggested that it was necessary to balance the freedom of the press against other interests. The Framers either did not appreciate, or appreciated but did not fear, the consequences of a free press. [FN202] Fourth (and most important), freedom of the press was viewed not merely as a desirable civil liberty, but as a matter integral to the structure of the new government. The press clause was the product of revolutionary ferment. There were no guarantees of press freedom in colonial charters and little agitation to add them. The demand for legal protection of the press was contemporaneous with the demand for independence and selfgovernment. The rhetoric often came from the pens of Englishmen, such as John Wilkes, "Cato," and "Father of Candor," [FN203] but the realities *489 that made the rhetoric relevant were the confrontations of American printers like John Peter Zenger and Eleazer Oswald with royal governors and other local representatives of the crown. [FN204] The first press clauses were written in response to a resolution of the Second Continental Congress, calling upon the states to repudiate the authority of the crown and establish their own governments. [FN205] These press clauses were produced not merely as salutary additions to an existing order, but as part of the urgent process of establishing "such government as shall, in the opinion of the representatives of the people, best conduce to the happiness and safety of their constituents in particular, and America in general." [FN206] We must remember that "[i]n the beginning [the Revolution] simply consisted of a number of state revolts loosely directed by the Continental Congress." [FN207] The state constitutions were revolutionary manifestos, and the press clause that evolved from them must be read in that light. Consider, for example, the Pennsylvania Declaration of Rights. Its preamble stated that "just, permanent, and proper forms of government are derived from and founded on the authority of the people only." [FN208] Throughout that declaration (and those of the other states), "the people" was used in juxtaposition with "government." [FN209] Thus, when the Pennsylvanians declared "That the people have a right to freedom of speech, and of writing and publishing their sentiments," they meant the people visavis the government. They guaranteed freedom of speech not for its own sake, but for its value in maintaining the desired relation between the people and their government. The second press clause of the PennsylvaniaConstitution [FN210] made this unmistakable: the right to examine *490 government was expressly guaranteed, either to the printers or perhaps to anyone who wished to avail himself of the printing presses for that purpose. [FN211] Throughout the formative period, the focus of discussion was on the role of the press in relation to the government. The Quebec Address shows some awareness that the press also had a role in advancing "truth, science, morality, and arts in general," [FN212] but the primary thrust of that document, and the exclusive thrust of *491 all other official declarations, was that freedom of the press was a necessary concomitant of selfgovernment. Neither the Federalists nor the AntiFederalists doubted its importance in that role. The only real issue was whether the protection of that role required a specific limitation on the government's power over the press. The demand for such a limitation was based squarely on a recognition of the press' adversary relationship to government. As Centinel wrote at the height of the ratification controversy, " m en of aspiring and tyrannical disposition ... have ever been inimical to the press, and have considered the shackling of it as the first step towards the accomplishment of their hateful domination, and the entire suppression of all liberty of public discussion, as necessary to its support." [FN213] In other words, a press clause was necessary, not to induce the press to provide a check on governmental power, but because it was universally assumed that the press would indeed provide such a check and that government therefore would seek to suppress it. Nothing makes the structural role of press freedom clearer than the "bulwark of liberty" metaphor with which the ideal was expressed. The phrase, as well as many of the ideas that it represented, came from Cato's Letters. [FN214] Cato was a pseudonym for the English journalists John Trenchard and William Gordon. [FN215] Their essays have been described as "the most popular, quotable, esteemed source of political ideas in the colonial period." [FN216] Essay No. 15, entitled, "Of Freedom of Speech: That the same is inseparable from Publick Liberty," first employed the bulwark metaphor: "Freedom of Speech is the great Bulwark of Liberty ...." [FN217] Liberty, in eighteenth century America, meant political liberty; it was not a guarantee of personal autonomy or selffulfillment. [FN218] Cato touted freedom of speech, not for its own sake, but for its value in combating governmental oppression and tyranny. This sacred Privilege is so essential to free Government that the Security of Property; and the Freedom of Speech, always go *492 together; and in those wretched Countries where a Man cannot call his Tongue his own, he can scarce call any Thing else his own. Whoever would overthrow the Liberty of the Nation, must begin by subduing the Freedom of Speech; a Thing terrible to publick Traytors. [FN219] That Cato described speech, not press, as the bulwark of liberty apparently was not important to those who borrowed the metaphor. The early press clauses drew heavily on both the phrase and the idea. The 1768 Massachusetts resolution, passed a few months after Letter No. 15 had been republished in the Boston Gazette, borrowed both: [FN220] "The Liberty of the Press is a great Bulwark of the Liberty of the People: It is, therefore, the incumbent Duty of those who are constituted the Guardians of the People's Rights to defend and maintain it." [FN221] The idea, though not the phrase, appears in the Quebec Address which assured the Canadians that through freedom of the press, "oppressive officers are shamed or intimidated, into more honourable and just modes of conducting affairs," [FN222] and in the Massachusetts and New Hampshire bills of rights, which asserted that " t he Liberty of the press is essential to the security of freedom in a state." [FN223] The influential Virginia Declaration of Rights was pure Cato: "That the freedom of the Press is one of the greatest bulwarks of liberty, and can never be restrained but by despotick Governments." [FN224] The Virginians apparently liked the bulwark metaphor so much that they retained it in the press clause they proposed at their state's ratifying convention, even though the substance of that clause came from the Pennsylvania Declaration of Rights, which had not used the metaphor. [FN225] And, of course, when Madison proposed the Bill of Rights to the First Congress, freedom of the press was included "as one of the great bulwarks of liberty." [FN226] The revolutionary context from which the press clause sprang, the concerns of those who demanded it, and the language *493 in which its role was expressed, all suggest that Justice Stewart was right: the Framers viewed the press clause as a structural provision of the Constitution. [FN227] "The primary purpose of the constitutional guarantee of a free press was ... to create a fourth institution outside the Government as an additional check on the three official branches." [FN228] The legislative history of the press clause also supports Professor Blasi's assertion that "one of the most important values attributed to a free press by eighteenthcentury political thinkers was that of checking the inherent tendency of government officials to abuse the power entrusted to them." [FN229] Stewart's structural theory accurately describes the role envisioned for the press in the new governmental scheme, and Blasi's checking function theory explains the means by which the press was expected to exercise that role. The StewartBlasi view of the press clause seems so thoroughly supported by the legislative history that one may wonder why it has not been universally accepted. The answer lies, I think, in the puzzle of seditious libel [FN230] and in the hegemony of Leonard Levy's interpretation of first amendment history. [FN231] If the Framers expected the press to operate as an effective check on government, how could they have tolerated the law of seditious libel, which made criticism of government a crime? And if they really understood the value of a free press, how could they have behaved so repressively toward it when they held power? There is no denying that the Framers tolerated seditious libel. As Jefferson said in 1804, even the Republicans had no intention of abolishing state libel prosecutions. [FN232] Furthermore, the First Congress rejected Madison's attempt to protect press freedom against state action, [FN233] and the same generation that wrote the first amendment also wrote the Alien and Sedition Acts of 1798. [FN234] Nor is there any doubt that the Framers were capable of behaving *494 repressively. During the revolutionary period, they harassed and intimidated printers suspected of Tory sympathies, [FN235] and thereafter one faction of them used the Sedition Act in a blatant attempt to crush opposition through seditious libel prosecutions. [FN236] To a generation predisposed to view the Framers as politicians and to judge them by what they did rather than what they said, these facts have made it easy to accept Levy's view that freedom of the press meant nothing more to the Framers than freedom from prior restraint. An examination of Levy's interpretation is therefore necessary. 4. Madison's Views The most important dissenter was Madison himself. In the Virginia Report, [FN415] written in 179980 as the Republicans' protest to the Sedition Act, Madison said the Blackstonian view of freedom of the press "can never be admitted to be the American idea of it." [FN416] He called the distinction between prior restraint and subsequent punishment "a mockery." [FN417] Although he was not prepared to define precisely "the proper boundary between liberty and licentiousness of the press," [FN418] he was certain that representative governments "require a greater freedom of animadversion than might be tolerated by the genius of such a government as that *530 of Great Britain." [FN419] And he was equally certain that whatever the limits of freedom of the press, the Sedition Act transgressed them, because it "repressed that information and communication among the people, which is indispensable to the just exercise of their electoral rights." [FN420] Levy acknowledges that this view is inconsistent with his thesis. [FN421] But he concludes that "Madison's exposition of 1800 was not a reliable statement of the understanding prevalent at the time of the framing and ratification of the First Amendment." [FN422] As evidence, Levy relies primarily on the fact that Madison "remained silent in the Virginia ratifying convention of 1788 when George Nicholas, one of his closest supporters, defined freedom of the press as the absence of a licensing act." [FN423] . . . . *532 But as Professor Blasi has pointed out, [FN433] Madison had outlined the theory of liberty upon which the Virginia Report was based ten years earlier when he presented his proposed amendments to the First Congress. In the Virginia Report, Madison explained that the British view of freedom of the press could not be the American view because of the "essential difference" between their respective forms of government. [FN434] In the British system, he explained, the danger of encroachments on individual rights is understood to be confined to the executive; the legislature is trusted not only to eschew such encroachments itself, but also to protect its constituents from the executive. [FN435] In the United States, on the other hand, [t]he legislature, no less than the executive, is under limitations of power .... This security of the freedom of the press requires, that it should be exempt, not only from previous restraint by the executive, as in Great Britain, but from legislative restraint also; and this exemption, to be effectual, must be an exemption not only from the previous inspection of licensers, but from the subsequent penalty of laws. [FN436] Madison had drawn the same distinction between the British and American systems in 1789 when he introduced the Bill of Rights. The Magna Carta, he said, does not protect the "great rights, the trial by jury, freedom of the press, or liberty of conscience"; [FN437] it goes "no farther than to raise a barrier against the power of Crown; the power of the Legislature is left altogether indefinite." [FN438] But in the United States, the people "have thought it necessary to raise barriers against power in all forms and departments of Governments." [FN439] In addition, Madison's 1789 speech contains hints of a rather sophisticated understanding of the dangers of majoritarianism. [I]n a Government modified like this of the United States, the great danger lies rather in the abuse of the community than in the legislative body.... [It] is not found in either the executive or legislative departments of Government, but in the body of the people, operating by the majority against the minority. [FN440] Although he made no claim that his amendments would provide a legally effective barrier against the power of the community, he suggested that they would at least engender some degree of public opinion in favor of protecting individual rights against *533 the majority. [FN441] The argument referred to individual rights generally, but it necessarily applied with special force to freedom of expression since that freedom is especially susceptible to nongovernmental restraint. Although these ideas do not constitute a fullfledged "libertarian theory," their articulation in 1789 suggests that the libertarian theories of the Virginia Report cannot be dismissed as a rationalization created from whole cloth in 1799. Madison's ideas, together with contemporary criticism of seditious libel (Cato's immensely popular essays on freedom of expression and libel in particular) and the expansive generalities of the Quebec Address, demonstrate that Blackstone's crabbed view of press freedom was not the only source from which the Framers could have drawn.     Page PAGE 1 Copr. ( West 2003 No Claim to Orig. U.S. Govt. 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