xt7wwp9t2q46_107 https://exploreuk.uky.edu/dips/xt7wwp9t2q46/data/mets.xml https://exploreuk.uky.edu/dips/xt7wwp9t2q46/data/59m61.dao.xml American Liberty League 37 linear feet archival material English University of Kentucky This digital resource may be freely searched and displayed. Permission must be received for subsequent distribution in print or electronically. Physical rights are retained by the owning repository. Copyright is retained in accordance with U. S. copyright laws. For information about permissions to reproduce or publish, contact the Special Collections Research Center. Jouett Shouse Collection (American Liberty League Pamphlets), No. 110 "The New AAA: A Measure Which Seeks to Circumvent the Recent Decision of the Supreme Court and Regardless of Constitutionality Permits Resumption of the Payment of Subsidies to Farmers," March 9, 1936 text No. 110 "The New AAA: A Measure Which Seeks to Circumvent the Recent Decision of the Supreme Court and Regardless of Constitutionality Permits Resumption of the Payment of Subsidies to Farmers," March 9, 1936 2013 https://exploreuk.uky.edu/dips/xt7wwp9t2q46/data/59m61/59m61_110/Am_Lib_Leag_110_001/Am_Lib_Leag_110_001.pdf section false xt7wwp9t2q46_107 xt7wwp9t2q46 AN INVITATION TO JOIN THE
. AMERICAN LIBERTY LEAGUE * *
We extend to every American citizen who believes in
the fundamental principles which gave birth to the
Constitution of the United States an invitation to be- “
come a member of the American Liberty League.
You may indicate your acceptance of this invitation
by Hlling in the necessary information as to your name A
and address on the enrollment blank below and mailing * * *
it to American Liberty League, National Press Building,
Washington, D. C.
There are no fees or dues. If you are willing and able
to give monetary help for the League’s support your
contribution will be appreciated, as our activities are
rt d t` 1 b th l t 'ft f S . .
Elggéefs an my y e V0 im my gl S 0 our A Measure Which Seeks to C1rcum»
ENROLLMENT BLANK vent the Recent Decision of the
Supreme Court and Regardless
D“t"`—————— of Constitutionality Permits
I favor the principles and purposes of the American R°SumPti°n of the Payment
Liberty League and request that I be enrolled as a of Subsidies to Farmers
regular b g
{ *contributing lmem G1"
Signature I
Name (Mr. Mrs. Miss) ; ’ €R lc
40
E Street We cf
gg Q " Y Lev
G I
2 E
Q" Town
County State
*As a contributing member I desire to give $ AMERICAN LIBERTY LEAGUE A
_ _ _ 2 National Headquarters
h : - :
to help support the act1v1t1es of t e League Cash here NATIONAL PRESS BUILDING
with Installments as follows:;________ WASHINGTON, D_ (]_
* *
(H0) Document No. 110
E March, I936
_ The New AAA
ir
The Soil Conservation and Domestic Allot-
ment Act, signed by the President on February
29, 1936, is chiefly a political device to insure
_ continuance of cash benefits to farmers beyond A
the date of the November elections. This _1ll-
considered law is of doubtful constitutmnality,
threatens new dislocations 1n agriculture, mgects
, further elements of uncertainty into the entire
economic structure and promises no perrnaxrfrgt
solution of the farm problem. The new ,
thus risen from the ashes of the old offers even
greater freedom of experiment than its prede-
‘ cessor to a group of theorists whgse ri-zlcord has
. been one of tragic blunder. Un er t e recon-
structed mechanism the AAA retains the power
of "coercion by economic pressure" which the
` A T Supreme Court held was inherent in the methods
HEN you have finished with this employed byauthorgty of the old llaw. 1 _
pamphlet please pass it on to some in r£lIl;fS;0;1?J$;1(i§WV;;tl respect to t G mw aw IS
fyicna cy qgqugintance who might be 1. Control of agricultural production, ruled ‘
_ _ _ _ unconst1tut1onal by the Supreme Court, is 1n-
intevestecl, calling his attention to the tended to be accomphshed. h
· 2. Despite the absence of contracts wit
membeyslup blank on page 24` farmers, the law is designed to facilitate their
· regimentation in a manner in conflict with basic
principles of the American form of government.
3. The Secretary of Agriculture is delegated
even greater legislative power than under the
r old Agricultural Adjustment Act. ‘ n
· 4. Weaknesses of the previous ‘parity price
l formula are recognized and the arbitrary char-
i acter of statistical bases is made evident by a
‘ 3. shift of emphasis to agriripltural net income.b
. 5. A proposed redistri ution of income e-
1 tween agricultural and industrial classes will
lead to new inequities unless those in command
i prove to possess omniscience.
l 6. The law will perpetuate harmful effects of
the old AAA such as narrowed markets both at
home and abroad abnormal relationships be-
tween commodities, increased relief rolls, extra
burdens upon processing industries and excessive
- prices to consumers.
7. Dairy and livestock industries are menaced
by a contemplated diversion of large acreages
to feed crops. _
8. Like the old law, the new act, when stripped
‘ of those features which are either ineffective or
» 3
l
. , _l
lHlUI`lOUS, is merely a· Subsidy to agriculture ct appropriation of the funds raised, and the direction
the expense of the taxpayers. for their disbursement, are but parts of the plan.
9. The law will not encourage farmers to be They are but means to an unconstitutional end.
efficient, thrifty and self-reliant, nor will it pro- “F¥'0If1 the accepted doctrine that the United
mote cooperative effort, accomplish the greater States is e Sevemmeet of delegated powers, it fol-
abundance necessary for a higher standard of ;°Withtlt ttl?S§ ‘l°t Bxptesiy 8*`t*~¤t€d» °I` F°eS°¤¤blY
living, force development of new uses for farm ° B imple mm S“° as are °°“t°"°d» ***6
. ,\ reserved to the states or to the people. To fore-
products, or restore foreign markets, all essen- · .
_ 1 , 1 e. 1 e. f eh . le 1 Stall any suggesuon to the contrary the Tenth
l313§1lI1 3 3S mg S0 U 10U 0 G agmcu um Amendment was adopted. The same proposition,
pI'O em. otherwise stated, is that powers not granted are
, . ll prohibited. None to regulate agricultural produc-
The Court DECISIOH lion is given, and therefore legislation by Congress
_ h ‘ ‘ n
The Supreme Court on January 6, 1936, 1n Ort ct purpose IS f°rb1dd°u‘
the Hoosac Mllle C01‘D01‘3t10H Q3Se held the The Court in disposing of the fiction that no
regulation of agricultural production under the coercion Wee applied to lemnere Send,
Agricultural Adjustment Act to be unconstitu- ; H _ `
tional. The Court ruled that control of agri- { _ It the te-Xmg POWEY may not be used as the
culture in the manner proposed was outside the cgslmmcct t° "Pf°”"€ 3 ’€g“1att9“ cf matters cf
authority of the Federal Government under the ; li; engoleigilerzlthtgeigigtf t° Whcch $*9 CQDEYTS
clause of the Constitution authorizing the Con- I neeeene eeee be gm I r Ewa may *· as m t E
o . , p oyed to raise the money neces-
g1‘€SS; to l3Y 311Cl collect t3X€S, - ·"· to · · · ‘ sary to purchase a compliance which the Congress
provlde for the . . . general welfare, as Well — is powerless to command? The Government asserts
as under the commerce clause. that whatever might be said against the validity
Rccpcctmg thc ccmmcrcc clgucc thc Ccuyt of the plan, if compulsory, it is constitutionally
Said; 3 pound becauee the rlelnd is accomplished by volun-
. . . a . ‘
"The time clause or Artic-ic 1. Section 8. cf the l tprttZ°°cti;§it)¤. att; iZ;ulZE0Z°tt°1$tl ltisvlitl
Constitution) endows the Congress with power ‘to i voluntary The farmer ef course me ref e
regulate commerce . . . among the several states.’ g eomply but the nnlee el eneh refueel iyth t;
Despite a reference in its first section to a burden l benente: The em . . S B OSS 0
. ; . ount offered IS 1ntended to be
upon, and an obstruction of the normal currents l Sulhelent te exert nreeenre on him to e t th
of commerce, the act under review does not purport ? proposed reguletlen Th greg O . °
. . . . . e power to confer or with-
to regulate transactions in interstate or foreign l hold unlimited benenne ie the Ower to
commerce. Its stated purpose is the control of g destroy. If the eeteen erewen geete not gceme 0;
agricultural production, a purely local activity, in E th b fi h · · . 0 weep
_ _ _ e ene ts, e will receive less for his crops· those
an effort to ra1se the prices paid the farmer. Indeed, { l who receive payments will be able ee und ll h.
the Government does not attempt to uphold the ‘ The result may well be nnenelel mln Thirse tm'
Validity ci thc cct cc thc bccic cf the commerce p purpose and intent of the statute ie ppt o(l?si:1il:f;d
clause, which, for the purpose of the present case, l by the feet that it hee nee been erfeeel f 1
may be put aside as irrelevant " ¤ · · p y Success “ ·
· It is. pomted out that, because there still remained
The Court rejected the Government’s con- l ;eI;;n;(n1e§§ei;1;%H;Oth€ dtental eed benefit P%YlPe¤tS
tention that under the general welfare clause l pendenee ef e - m ue t° Surrender thm md°‘
. . c ction, the Congress has gone further
the CQI1gI‘€SS m3Y 3PPI`0PI`l3t€ 3Hd 3UthQI`1Z€ tht? l and, in the Bankhead Cotton Act used the taxing
spending of money for agriculture. While hold- » power in a more directly minatory fashion to
mg that the power to tax and spend is not lim- f compel submission. This progression only serves
ltcd by thc dlycct, grants cf lggislgtivg power, more fully toeexpose the coercive purpose of the
the right to do so for the general welfare is l S°‘°‘aH€d tax *mP°S°d by the Pifeeelit ect- It is
subject to restr1ct1ons, such as the reserved rights ‘ Iiilpatttlltnt ef Agmculttllre hee prop-
l ri e e pan as one to -
Of g°§‘;i_i°Seld_ z cooperating minority in line. This is igilfzrctiaorllollly
“ l ’ I economic pressure. The asserted power of choice
The act invades the reserved rights of the states. 1S 1U¤S01'y·”
It is a statutorylplan to regulate and control agri- _
cultural production, a matter beyond the powers Referrmg lfurtller to contracts with farmers,
delegated to the Federal Government. The tax, the the Court Said:
4. 5
tOiilgrigrzilggaltl;”·lII?O‘§:r$"€Sgohllgx;l;§t;rl;d°§rl§°§€‘%_Sll§@‘; t l others who have served on local committees in .
expenditure under contracts between the GOVem_ - connection with the administration of control
ment and individuals; that much of the total t progri-imS' . . _
expenditures is so made. But appropriations and , Whlle the Pl`OVl$lOllS of the Agrllfulllurrll A€l·
_ mental purposes cannot justify contracts which are Bsslllg taxes and the P8·Ylll€lli» of bcllellts OI1
not within Federal power. And contracts for the basic agricultural commodities are unquesticn-
reduction of acreage and the control of production ably invalid, there is doubt as to some of the
are outside the range of that power- An approve- cl other sections. As the AAA interprets the Court
ation to be expended by the United States uruler l decision it did not affect marketin a reements
contracts calling for violation of a state law clearly r and Orders which und th g dg t r
would offend the Constitution. Is a statute less l A e 24 ’19 cr . G amen men S, 0
objectionable which authorizes expenditure of Fed- ugus ¤ 35> are appllcablc only to mllk»
eral moneys to induce action in a field in which t frmtsr V€g€l’a‘bl€S¤ tqltaccor Soy beans and naval
the United gtetee has no power to intelvmeddle? 2 stores. Several decisions adverse to the consti-
_ The Congress cannot invade state jurisdiction to tutionality of the license system established in
cortxlpel individual action; no more can it purchase the original act for use with marketing agree-
Suc action-" r ments were rendered in the lower courts prior
Such hope as the sponsors of the new law have t§eth;et€t§rS€g§esfW;l;.E .2E;£ge€*l;tguStér 1935 t lr
that it will be held constitutional rests upon er Orders substituted Merkegtrnan a SYS Bien
an assertion by the Court that Uthele is an are in effect by which- roduction gf rilfiglilgclflelits
shrines dlllemllce bstwsss 3* statute Slatlllg the and vegetables in numlerous areas is controlllldds
conditions upon which moneys shall be expended “ On the reeemmeudetten Or the Pres-d t th'
urlrl one effective _0ulY uP0¤ ·uSSurrlPrl0ll of u Congress repealed on February 10 1936(mthreg
contractual obligation to submit to a regulation Compulsory laws edmuustered b tue AAA th
which otherwise could not be enforced." Despite Beukheed Cetteu Centre] Aet tge Ke T gl B
this qualification many Senators and Renresen- Control Act and the Potato bontmirictc
tatives expressed the belief during the debates frrst Wes eueeted eu April 21 1934. the eeeend
H1 Congress that the P3Ym0¤l#S of agricultural on June 28 1934* and the third was incor orated
benefits, even without contracts, will be held to l in the AKA errreudmeuts ef Au ust 24p 1935
be a regulation of agriculture in violation of the ¤ AH tthree used the tarxin ewera f I, ’ '
Constitution. In their view "coercion by eco- ; rdreuee with preduetteu gugte S Stzmg c(?[tcOm`
¤01T1l0 P1"0SSur€” W0ul€l be 0PPll0€l through rll0 l obvious from the decisioiil in theyAAA case tllizf
oiier or cash PaYm€¤rS regardless of rll0 0XlSr· 7 these would have been declared unconstitutio all
ence of contracts. Federal payments to agricul- f B b · · · l ·n- ’
t . . | y o taining their prompt repeal the adminis-
ure are not in this respect comparable to con- l t t" 7 1 · ·
. . _ _ ra ion vt as ab e to escape adverse decisions by
ditional grants for education which the Court the Supreme Ceurt eu three lewe in addition to
ifs? il; uglaggustrutlou of lll0S0 Wlll0h properly I thre lhalf dozen talready held to be invalid in
· w o e or 1n par .
l The new Soil Conservation and Domestic
Status of Old Laws Allotment Act is an amendment to an act of
l A ril 27 1935 whi `
a The Agricultural Adjustment Act, enacted on ofpAgrici11ture to caililyadiitl liilf;$iln1l§e iiglaléligilgé
May 12, 1933, amended in minor particulars on t respecting soil erosion and created a Soil Con-
several 0003810118 and eX’teHS1Vely revised on i servation Service under his direction Notwith-
August 24, 1935, was held to be void only as to standing the existence of this service the new
. certain sections. Under its authority the AAA E law provides that the Secretary of Agriculture
personnel, which at the time of the Court deci- l may assign such powers conferred upon him as
s1on totaled about 6,500, has been kept largely he deems appropriate to the AAA. For such
. intact and will be used_1n the administration of purposes the provisions of law applicable to the
the new Soil Conservation and Domestic Allot- appointment and compensation of erso
ment Act. Besides the 6500 re ularl on the 1 d b h p' PS em-
11 th AAA h _» S Y p oyer _y t e AAA shall apply. The significance
payro , e as paid many thousands of of this 1S that employees of the Soil Conserva-
tion Service are subject to Civil Service and i broadening its purposes to include five objec-
Classification laws while those of the AAA tives, as follows:
are not. 1. Preservation and improvement of soil fer-
, tility.
A PO1itica_lLaW € Smialciigcglntjgttcgrltdof the economic use and con-
Methods employed in the consideration of the l 3. Diminution of exploitation and wasteful
new Soil Conservation and lPomest1c %tloténent g an;1 l}_1§G1€Ht1Qcc ESG of fnational S01ld1‘€i0g11g>(<;>Sé
t'f t 't l’t` 1 t . e om- ‘ Z e pro ec 1on o r1vers_ an r _r
tttnleiéltosi ‘§3t1‘t¤ai§°%,ttt.§dtOOiS i $$23; til'i1€€T?g‘1`tt§a({Jt§`i§(;};l €;?,ttgt;.;S..gn%i $2;.;;
as quickly as possi e a aw w 1C wou con- L _ _
tinue agricultural benefits during the campaign. ‘· c0l11`SeS and 111 ald of flood 00Ht{`0l·
It was evident that the administration was i 5. Reestabhshment, at as rapid a rate as the
willing to take a chance on another adverse 1 Secretary of Agriculture determines to be prac-
Court decision, a year or more hence, if thg tictablti) Stud in tcge generlal public interetthtif thi
recipients of cash benefits could be kept Satlsie ( Y6 I0 6 W6611 6 PU1`6 861112; POW€1` 0 6 116
while issues were under discussion by the candi- V income per person on farms and that of _the
dates fm. the Presidency and (jongmsg 1 income per person not on farms that prevailed
Despite the repudiation of its policy by the during the llV€·Y€a1‘ period August, 1909-July,
Supreme Court the administration and its 1914, inclusive, as determined from statistics
leaders in Congress were unwilling to allow available in the Department of Agriculture, and
tl t ‘ th 'th th AAA program the maintenance of such ratio. _ .
tcicbiiz Ihiiarg Sbliii; stifcliwiarm grganizations as The Secretary of Agriculture is authorized to
were favorable to the administration were con- make payments or grants of other aid to agri-
sulted, one critical group being denied admit- cultural producers, including tenants and share-
tance to a general conference called by the tbroppcersg ‘ tn a1;1I<3(t11;ié;Stt)r<;c;‘%Sit)<£· sgt cccilnasggggttgnllpg tl};
ta ce of the subject. The ouse ommi ee P V _ i _
ii1(irAgriculture heard the Secretary of Agricul- t of thc1r_ land, (3) a percentage of their normal
ture and the Administrator of the Agricultural 1 production of any one or more agricultural
Adjustment A°".N“f°“‘“".l"’· but is mars 2ai‘si.°itiS§s$;t2€;;S 2at;.?s:.1;$;r2;.z$£;;*;
members rejecte repeate reques s y mmori y _ _ _ _ _
members for permission to invite outside experts. Pmdllclilon of Such _°0mm0dl}°Y PY 66mm6dm6S
The testimony of the Secretary of Agricuétitre zgtglgggtfg (?%0gl;Sl;g0$,%Q§¤mPt10¤, 01‘ (4) any
and the AAA Administrator was not printe or .\ _ · _
public distribution as is customary. The Senate ». _ In lieu of the contracts under the old AAA _1t
Committee on Agriculture allowed spokesinen l 1S p1“OV1ded that any payment or grant of aid
for farm organizations supporting the admmis- i shall be condltloned upon the utilrzation of land
e tration program to appear in a public hearing ( in conformity with farming practices which the
but heard AAA oiiicials in executive session. Sgcattaryt finds tend tn 6H66tu6l?6 th6 PuYP°S6S
. Alternative plans offered in both houses re- 0 6 60 ·
ceived no consideration whatever. On the floors Payments to producers by the Federal Gov-
of the two houses administration forces rode ernment will cease after_ January 1, 1938, at
roughshod over amendments lacking the ap- which time, or earlier in the case of such
proval of the AAA. states as obtain approval of plans, the same
purposes are to be accomplished under a state-
aid program.
Terms Of the Law Expenditures under the act in any year shall
Under the new law the powers conferred upon not exceed $509 000 OQ0. While the AAA was
the Secretary of Agriculture by the original Soil created for an iiiooduito period until the Presi-
Erosion Act are supplemented by a declaration dent "pr0cla1ms that the national economic
3 9
emergency in relation to agriculture has been _ they must do in order to qualify for benefits.
ended/’ the I1€W law is of a permanent 0ha1`a0t01`· The existence or non-existence of contracts seems
It establishes definitely a policy of subsidizing immaterial. Cooperating farmers will be told
agriculture. wait plant, how to plant it and what to do
· wi e crops. If the new lan involves an
Control ef Productlon less regimentation than the ldld, it is difficult
While the purposes in the new law are stated J tc lmd€YSh9~hd Wh0Y€1¤ Such is the case.
somewhat differently than in the Agricultural "‘
Adjustment Act, the real objective is to control Delegation of POWe1‘
production just as it was in the earlier law. By
controlling production it is hoped to adjust Y., The new law takes rank with the Work-
prices. To such extent as methods of control Relief Act of 1935 in its broad delegation of
are unsuccessful agriculture will be subsidized. “ power. Merely by reading it one cannot obtain
Whether or not farmers sign contracts can an adequate conception of the exact form of the
make little difference in the effect of the plan. new farm program. The general purposes as
They could have elected not to sign contracts stated give a vague idea that something will be
under the old AAA. Nevertheless the Supreme done with respect to soil fertility, soil conserva-
Court held that they were subject to "coercion t10H, soil erosion and farm income. There gre
by economic pressure." Similarly, the farmers no details. The Secretary of Agriculture told
need not qualify for benefits under the new the House Committee on Agriculture informally
Schgmg but be just, as mugh Subjgct {,0 ll`, 1S proposed to CllV€I'l» to Olrl'l€I' USGS fI`OII1
"coercion by economic pressure" as before. 20,000,000 to 30,000,000 acres of land, now in
The Court’s finding that "the regulation is 00tt0H, Wheat, corn and tobacco. Exactly how
not in fact voluntary" appears applicable to the it 1S to be d011e Was not explained. There
4 new plan. As stated by the Court "the amount 1S 110 mention of specific farm commodities in
offered is intended to be sufficient to exert pres- the law. The field is wide open as to which
sure on him to agree to the proposed regulation," 0r010S may be the subject of experimentation,
and one who does not receive the benefits is at The Secretary of Agriculture beeemee the Czar
a competitive disadvantage with his neighbor of Agriculture. His only limitations are the
and "the result may well be financial ruin." sum of $500,000,000 per year and a stipulation
It is ridiculous to insist as have sponsors of that he shall pay out the money to farmers
the law that there will be no regimentation of without requiring them to sign contracts in
farmers. I f they are to qualify for payments, adVah0€·
they must follow the program of the AAA, s Specific terms of the new law are in marked
whether it be for new treatment of land, for contrast with the more precise language of the
diversion of land from one crop to another, or Agricultural Adjustment Act. Under the pre- j
for a curtailment of production. q visions of the latter act, which were invalidated 1
The domestic allotment clause authorizes pay- by the Supreme Court, the Secretary of Agricul- .
ments to farmers for "a percentage of their ture was authorized to provide by agreements `
normal production of any one or more agricul— w1th_producers an adjustment of acreage or pro-
tural commodities designated by the Secretary duction and to make payments in compensation
which equals that percentage of the normal therefor. The payments were to be such as
‘ national production of such commodity or com- would yield to the producers approximately
V modities required for domestic consumption." llparlty priceS” as defined in the law. The agree-
Presumably such payments will not be made ments might- relate only to certain specified
unless farmers comply with certain conditions. ‘_‘baS10” agricultural commodities, originally seven
If there is a stipulation that any excess produc- in number and expanded to fifteen.
tion above the amount allotted for domestic While the Secretary of Agriculture had con-
consumption shall not be marketed, the type of siderable discretion under the old law, any in-
` restriction will be almost identical with that fringement upon the constitutional theory of
which has heretofore been applied to wheat, separation of powers was mild compared with
cotton, corn, hogs and other commodities. the broad powers delegated by the Congress
The farmers will know in advance just what _ under the new law.
10 11
If the administration now fails to solve the lower prices without any reduction in aggregate
agricultural problem, it will not be because of net income. Nevertheless, under the parity price
lack of authority. The Congress has abdicated formula it was sought to give the farmer a price
with respect to agriculture. The Secretary of per bushel or pound which would be equal in
Agriculture can do practically anything he purchasing power in industrial commodities to
pleases in the manipulation of economic ele- a bushel or pound in the pre-war base period
ments. Here we have "economic planning" in _, without taking into account any increase in the
full flower. quaatity pgoduced per acre, farm or farm
· · wor er. e parity price has a tendency to
P°11tY Prices spiral upward as allowance is made for advanc-
In s sfstsmsnt issnsd at ths tims gf signing , ing prices of industrial commodities, attributable
the new law the President emphasized that its 111 Pa1t to 11101‘eaSeS 111 prices of 1aW materials
goal is "parity, not of farm prices, but of farm 110111 the 1a1`111-
innnms_’* A farm price parity formula was in- _ Under the formula in the new law the purpose
cluded in the Agricultural Adjustment Act and 15 to reestablish and maintain "the ratio between
presumably was not affected by the Court deci- the P¤1el1aS111g power of the Het income per
sion except insofar as it has become impractical Pe1‘S011 011 farms and that of the income pe·r
to use it by reason of the elimination of control Pe1"S011 110t 011 farms that prevailed during the
programs affecting "basic" agricultural commod- l1Ve·Yea1_Pe110d Auguet, 1909-July, 1914.”
itiss The shift tn s formula, affsnting nsf, According to computations of the Department
income is a recognition of weaknesses of the of Agriculture the purchasing power of the per
parity price system and also illustrates the arbi- eeblte 1211111 11100111e, 111el11€l111g benefits, 111 1935
trary character of the statistical bases upon le 1QeP1`eSe11te