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Browsing: Legal Papers of John Adams, Volume 2


Docno: ADMS-05-02-02-0006-0001

Editorial Note

The majority of John Adams' cases in the Court of Vice Admiralty involved breaches of the British Acts of Trade. The Acts were a coherent body of legislation, enacted between 1660 and the Revolution, which regulated the flow of colonial trade, laid duties on some aspects of it, and established a system of enforcement. The basic regulatory provisions were: that vessels engaged in the plantation trade had to be English- or colonial-built, owned, or manned; that certain enumerated goods produced in the colonies could be shipped only to England or to another colony; and that most European goods could be shipped to the colonies only from English ports.1
This system was designed primarily to aid the English merchant and shipbuilder by creating monopolies in the colonial trade, but it did benefit colonial shipbuilders, and at least some colonial merchants, by assuring them of markets. The system also was an indirect producer of revenue for the Crown, since goods flowing through English ports were subject to duties to be paid there by the importer or exporter. The only duties levied in the colonies before 1764 had their primary effect as measures to support or encourage trade with England, rather than as direct revenue-producers. Thus, although the Plantation Duties Act of 1673, laying duties upon enumerated goods shipped from one colony to another, had the effect of equalizing the tax burden between English and colonial consumers of colonial goods, its principal aim was to make shipment of these goods to England more economical for the exporter than intercolonial shipment. Similarly, the heavy duties laid upon the importation of foreign colonial sugar products by the Sugar Act of 1733 were designed to put British West Indian sugar producers in a favorable position.2
Enforcement of these measures was in the hands of customs officials in the colonies who were responsible to the Commissioners of the Customs in England.3 The colonial officers administered a complicated documentary control system designed to insure compliance with both regulatory and { 99 } revenue provisions. The basis of the system was the requirement that vessels arriving from or bound for parts beyond the seas enter and clear with the customs officers at each port.4 This practice permitted a constant check on each vessel's compliance with the Acts, as evidenced by certain required documents. For example, the nationality of vessels and crews was controlled through the ship's register, a certified copy of the master's or owner's oath that the vessel was English built, owned, and manned.5 A vessel carrying enumerated goods had to give bond on clearing that they would be landed only in an English or colonial port; if a certificate of compliance were not returned within a certain time, the bond was forfeit.6 To ensure that European goods had been shipped in England, the master was required to submit a manifest, showing the nature, amount, and origin of his cargo before his vessel could enter and unload. The payment of duties was also controlled through the manifest and through certificates of the officers on entry and clearance that duties had been paid.7
To prevent violations, the customs officers had broad powers to search vessels, as well as premises ashore, for contraband, and to seize such goods.8 Violators were subject to a variety of penalties, ranging from small fines for failure to comply with administrative rules to forfeiture of vessel and goods for breach of the substantive requirements of the Acts. Although in England such offenses were within the jurisdiction of the Court of Exchequer, in the colonies many of them could be sued upon in the Courts of Vice Admiralty, which had been established in 1697 primarily for this purpose. The customs officers were allowed to bring suit for penalties and forfeitures, receiving a share of the proceeds upon condemnation. Jurisdiction of these actions was concurrent at common law, but in Massachusetts at least, the officers preferred to proceed in Admiralty, where recovery was not subject to the whim of a jury friendly to the offender.9
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There was some opposition to this system at its inception, but after about 1725 the furor generally died down. Historians have seen this reaction as an indication that the colonists had come to accept the benefits which they received in trade with England as compensation for some of the disadvantages which regulation imposed. This was undoubtedly a factor, but it is clear that colonial acceptance was made easier by the fact that after 1725 English policy seemed to be one of deliberately ignoring violations of the system. Revenue collections from the colonies were small, in part because of the regulatory purpose of the revenue measures, but to an even greater extent because of a widespread laxity of enforcement that was known to and condoned by Parliament. Presumably a similar laxity pervaded the enforcement of other provisions of the Acts.10
Adams came upon the scene just as this policy of laxness was being abandoned. New England's trade with the enemy during the Seven Years' War had reached such heights that the Crown made determined efforts to control it through strict enforcement of the Acts of Trade. There was an immediate reaction among the Boston merchants against the Admiralty court and the customs officials, which manifested itself in several ways, including opposition to the officers' application for writs of assistance (general search warrants). Adams attended the first of two arguments on the question, held before the Superior Court at Boston in February 1761. Although he was not of counsel, he produced a report which was widely circulated and of some importance in later political struggles. Boston's resistance to the application, although unsuccessful, marked the first step in an opposition to the Acts which was to culminate in the American Revolution.11
At the conclusion of the war in 1763 England was both financially strained and sharply aware of the extent of colonial evasion of the Acts of Trade. The American Act of 1764 was directed at both problems. For the first time duties were levied on colonial imports for the express purpose of raising a revenue. To prevent violation of this and other Acts, various holes in the enforcement system were plugged with requirements for ad• { 100 } { 100 } { 101 } ditional bonds and certificates and a closer check by the customs officers. Heavy pecuniary penalties against offenders were set in addition to the previous system of forfeitures, and it was made clear that all violations of the Acts could be sued upon in colonial Admiralty courts. In these suits the prosecuting officers were given certain procedural advantages. Finally a new superior court of Admiralty was created to hear cases from any province.12
Before the effect of these new measures could be felt, Parliament passed the Stamp Act of 1765, a provision for further revenue to be levied by a tax upon a variety of documents and printed matter. Colonial objections to the American Act were submerged in a sudden rush to defy the Stamp Act. In Boston, violence and the threat of violence prevented the distribution of the stamps. One result was that the courts, which required stamped paper for their documents, were closed. Adams appeared before the Governor and Council in December 1765 for the Town of Boston to pray that the courts be opened without stamps. Although his arguments took account of the political nature of the body which he was addressing, his notes show that he backed up rhetoric with authority, relying upon the kind of argument that had earlier been made against writs of assistance. The petition was denied on the ground that the question was a judicial one, but the Inferior Court soon opened in acquiescence to popular pressures. The Superior Court was formally opened, but did only token business until news of the Stamp Act's repeal was received in May 1766.13
Along with repeal, most of the duties of 1764 were reduced to acceptable levels.14 The enforcement provisions were not repealed, however. Calm temporarily prevailed until a change of governments in England brought Charles Townshend, long a proponent of colonial taxation, to the post of Chancellor of the Exchequer. The Townshend Acts of 1767 again laid duties upon American imports, to be used in part to pay colonial officials independently of the legislatures. The Acts renewed the drive for strict enforcement by authorizing the appointment of an American Board of Customs Commissioners to sit at Boston and exercise the powers formerly { 102 } held by the English Commissioners.15 At the same time the superior court created in 1764 was superseded by four new district courts of Admiralty, to sit at Halifax, Boston, Philadelphia, and Charleston, and exercise both original and appellate jurisdiction over surrounding provinces.16
Adams does not seem to have tried a revenue case in the Court of Admiralty before 1768. In that year, however, the activities of the Commissioners inevitably drew him into such matters. Their immediate application of the new enforcement policy increased the number of actions in Admiralty to the point where there was need for additional lawyers. Further, the Commissioners' policy aroused an immediate opposition among the merchants who seemed determined to spare no effort in resistance. Accordingly, Adams' first such case, Folger v. The Cornelia, No. 45, which was a direct confrontation between the Commissioners and those who had found the previous administration more agreeable, marked the beginning of a busy year and a half in the Court of Admiralty.17
The seizure of John Hancock's sloop Liberty in June 1768 provided the focus for the attack upon the Commissioners. Adams was deeply involved in this affair, both as counsel for Hancock in an action brought against him for penalties, and as a draftsman of political manifestos for the Town of Boston.18 At the same time there was a steady stream of less important revenue litigation in which Adams participated, perhaps because he was in court on Hancock's business.19 Although Adams was politically committed to opposition to the Acts of Trade, he was of counsel for Crown officers in two cases in the spring and summer of 1769. 20 As a lawyer, he had a right, if not a duty, to give his services to those who sought them. In view of the political situation, however, it is likely that he was under heavy pressure from the Crown to yield a more permanent allegiance. In his Autobiography, Adams wrote that sometime { 103 } during 1768 Jonathan Sewall had asked him to take over his position as advocate general in Admiralty. Adams reported that he had had no trouble in refusing this offer, since he wished to be under no obligation to those whose political principles he opposed. There is other evidence that some such episode took place. Perhaps Adams' legal activities for the Crown indicate that he gave Sewall's proposal more serious consideration than he was later willing to admit.21
The uproar over the Liberty led the Crown to send troops to Boston. The presence of soldiers and continued tension over the Commissioners' activities led at length to the Boston Massacre in March 1770 (Nos. 63, 64). In the aftermath of this episode the troops were withdrawn, and the Commissioners, who were accused of instigating both the Massacre and the earlier shooting of a small boy by their employee Ebenezer Richardson (No. 59), greatly moderated their tactics. The Boston merchants, feeling a revulsion against civil disobedience, in the fall abandoned the policy of nonimportation with which they had reacted to the Townshend Acts. Parliament had contributed to the atmosphere of conciliation in March by repealing all of the Townshend duties except the tax on tea.
So far as is known, Adams had no Admiralty cases for nearly three years after the summer of 1769. Although he may have withdrawn from practice in the court in disgust at the political ramifications, there are other possible explanations. In 1769 his business in the common-law courts drastically increased to the level where it was to remain until the Revolution. At the same time the atmosphere of conciliation following the Massacre had greatly reduced the number of customs cases and diminished the political tension which had surrounded such matters. A balance of interests in favor of the economics of the profession probably accounts for Adams' abandonment of the Admiralty.22
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Whatever the reason, he does not seem to have appeared there again until February 1772, when he was retained in the first appeal brought before the Boston District Court of Admiralty since its creation in 1768. Robert Auchmuty, previously judge for the Province, had been appointed to the new court, but he had apparently continued to sit in his former capacity also, thus rendering appeals of doubtful value in Massachusetts. The decision in this case had been given by Auchmuty's deputy in New Hampshire, however. In his diary Adams noted that “as it is a new Thing the Judge has directed an Argument, and a Search of Books concerning the Nature of Appeals by the civil Law. I found Time to look into Calvins Lexicon Title Appellatio and Provocatio, and into Maranta, who has treated largely of Appeals. Borrowed Ayliff, but there is no Table and could find nothing about the Subject. Domat I could not find.” The appeal and another from the condemnation of a vessel belonging to John Langdon of New Hampshire, were decided in favor of the Crown, presumably in spite of the efforts of Adams, who was probably on the side of the claimants.23
Adams did undertake at least two revenue cases in 1772 and 1773. Although the burning of the revenue cutter Gaspee in Rhode Island and the special tribunal appointed to investigate the incident had awakened political responses in him and in many others, his later cases had no particular political relevance, except as further evidence to the colonists of the oppressiveness of the system.24 The tax on tea, left unrepealed in 1770, finally led to the events which terminated whatever uneasy truce remained and took political dispute beyond the confines of the courtroom. In 1773 Parliament had saved the East India Company from collapse by an Act allowing it a full drawback of English duties on tea shipped to the colonies, and permitting it to ship directly to colonial consignees, instead of dealing through English tea merchants. With these advantages, the Company could now compete with the smugglers who had been evading the duty regularly since 1770. An increase in the sales of legally imported tea meant an increase in duties. More revenues meant more funds to be applied under the Townshend Acts to pay the salaries of royal officials. This threat aroused Boston, and other colonial ports, to action.25
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The first of the tea ships, the Dartmouth, arrived in Boston harbor on 28 November, and, apparently at the request of the Committee of Correspondence, came up to the town on the 30th, taking a berth at Griffin's Wharf the next day. There she was soon joined by other vessels. The ships had apparently entered at the Custom House soon after arrival, but none of the tea was unloaded. The “Body,” the ad hoc mass meeting which purported to speak for Boston, demanded that the ships be sent home with cargo still intact, but the owners were unable to comply. The customs officers refused to issue clearances until the tea had been unloaded, and Governor Hutchinson would not allow the province naval officer to give the vessels a pass to leave the port without a clearance.
In this state of things the owners of the Dartmouth sought counsel from Adams and Sampson Salter Blowers. The owners probably wanted both arguments to use before the customs officials and Hutchinson, and advice on the potential liability of the Dartmouth and her cargo for seizure. The account of the vessel's master shows that Adams and Blowers were paid a total of £7 4s. for “advice,” but no indication of its nature has survived.26 Under the applicable statutes duties were due upon “importation” and goods could be seized if duties remained unpaid twenty days after entry. The principal questions were probably whether there had been an “importation” within the Act when bulk had not been broken, and if there had, whether the customs officers could nevertheless clear out vessel and cargo without payment of duties.27 Before these questions could be raised in any legal proceeding, events made them moot. On 16 December Hutchinson refused a last request for a pass and an immortal band of Indians proceeded to dump the tea into Boston Harbor, in what Adams described in his diary as “the most magnificent Movement of all.”28
In reaction to this act of defiance, Parliament passed the Boston Port Act and other coercive measures designed to punish the Town and its supporters by terminating its trade and abridging provincial self-govern• { 106 } ment.29 Adams does not seem to have had further cases in the Vice Admiralty Court, but he was at least present to report a case in which the Port Act was put to the test there in the summer of 1774 (No. 53). In the meantime the colonies had begun to move toward union, revolution, and independence. The First Continental Congress sat at Philadelphia in September 1774, with Adams among its members.30 Before independence was formally declared, the British sought to bring the colonies to heel by Act of Parliament, extending the Port Act to other colonial ports. Finally Britain laid a total embargo on colonial commerce in a statute that was not an Act of Trade, but a measure regulating the taking and distribution of prizes. Adams' only contact with this later legislation was in the somewhat different context of prize litigation during the Revolution.31
1. These provisions were first enacted in the statutes, 12 Car. 2, c. 18, §§1, 18 (1660), and 15 Car. 2, c. 7, §6 (1663). For a summary of later statutory modifications, see Harper, Navigation Laws 388–390, 395–404. For provisions applicable to colonial manufacturing, see Knollenberg, Origin of the American Revolution 169–171.
2. See the Plantation Duties Act, 25 Car. 2, c. 7, §§2, 4 (1673); the Sugar Act, 6 Geo. 2, c. 13 (1733). For discussion of these Acts and the legislative purpose, see Barrow, Colonial Customs 26–32, 283–286.
3. Provision for a colonial customs service was first made in the Plantation Duties Act, 25 Car. 2, c. 7, §3 (1673). Its existence was confirmed and the officers' powers strengthened by 7 & 8 Will. 3, c. 22 (1696).
4. See 15 Car. 2, c. 7, §8 (1663); 13 & 14 Car. 2, c. 11, §§2, 3 (1662), made applicable in the colonies by 7 & 8 Will. 3, c. 22, §6 (1696). For cases involving the requirement of entry, see No. 46 and No. 48.
5. See 7 & 8 Will. 3, c. 22, §§17–21; No. 51; No. 45, note 3 34 .
6. See 12 Car. 2, c. 18, §19 (1660); 7 & 8 Will. 3, c. 22, §13 (1696); Harper, Navigation Laws 161–165. For further discussion, see No. 45, note 3 34 .
7. See 15 Car. 2, c. 7, §8 (1663); 13 & 14 Car. 2, c. 11, §§2, 3 (1662), made applicable in the colonies by 7 & 8 Will. 3, c. 22, §6 (1696); Instructions by the Commissioners for Managing and Causing to be levyed and collected His Majesty's Customs, Subsidies, and other Duties in England, to who is Established Collector of His Majesty's Customs at [] in America ([London], ca. 1733). For a case on European goods, see No. 52.
8. 13 & 14 Car. 2, c. 11, §§4–11, 15–20, 32–34 (1662), made applicable in the colonies by 7 & 8 Will. 3, c. 22, §6 (1696). See No. 44, No. 45, No. 50.
9. As to the establishment of the Vice Admiralty Courts, see Barrow, Colonial Customs 124–127, 145–150; Wroth, “The Massachusetts Vice Admiralty Court,” in George A. Billias, ed., Law and Authority in Colonial America (Barre, Mass., in press). As to doubts about the scope of the jurisdiction before 1764, see Knollenberg, Origin of the American Revolution 266–268. The various penalties and forfeitures, and the mechanics of suit run through all the statutes and are discussed in most of the cases that follow. See especially No. 46. A search of the records of the Massachusetts Superior Court and the Suffolk County Inferior Court files has revealed no actions at law under the Acts of Trade after 1764. An incomplete search for the earlier period has produced only a few revenue suits, and these were matters in which the power of the Admiralty Court was being tested by writ of prohibition. See, for example, Robinson v. Patriarch, SCJ Rec. 1725–1730, fol. 59 (Suffolk, 1726) (Dismissed on exceptions); Robinson v. Patriarch, SCJ Rec. 1725–1729, fols. 97–99 (Essex, 1726) (Quashed because summons said “Suffolk SS” instead of “Essex SS”); Lambert v. Bardin, SCJ Rec. 1730–1733, fol. 202 (Suffolk, 1732) (Verdict for forfeiture. Vessel ordered sold, with seamen's wages also to be paid). As to distrust of the jury, see No. 46, note 61.
10. For the view that the system of duties and regulation prior to 1764 was agreeable to the colonists and that only changes made in that year and after (notes 12, 15, below) caused opposition, see Harper, Navigation Laws 365–378; Dickerson, Navigation Acts 208. These and earlier studies of the problem are admirably summarized in Barrow, Colonial Customs 1–17, 512–524, where the conclusion is reached that the entire system from 1660 on was inimical to colonial interests, and that lax enforcement between 1725 and 1764 was the key to colonial acceptance. The debt of the editors to this work here and elsewhere should be evident.
11. See No. 44.
12. The American Act, 4 Geo. 3, c. 15 (1764). For a summary of its provisions, see Knollenberg, Origin of the American Revolution 150–152, 176–181; compare Barrow, Colonial Customs 376–390. See also No. 46, No. 47, No. 52. Earlier a wartime practice had been extended by a measure providing for the seizure at sea by naval vessels of offenders against the Acts of Trade. 3 Geo. 3, c. 22, §4 (1763). See No. 51, note 1. As to the new Admiralty court, see Ubbelohde, Vice-Admiralty Courts 44–54. The court was given power to hear appeals from the provincial Admiralty courts by the Stamp Act, 5 Geo. 3, c. 12, §58 (1765).
13. JA 's notes of his argument, now in the Adams Papers, are printed in 2 JA, Works 159 note. See also JA 's diary entry for 20 Dec. 1765, 1 JA, Diary and Autobiography 266–267. Compare Quincy's account of the argument, Quincy, Reports 200–214. For further discussion, see No. 44, note 48; No. 46, note 68. See also Edmund S. and Helen M. Morgan, The Stamp Act Crisis 139–143 (Chapel Hill, 1953).
14. 6 Geo. 3, c. 52 (1766). The Act did tighten enforcement regulations in other respects, and did not affect the duties on wines. See Barrow, Colonial Customs 443–444; No. 46, note 17; No. 47, note 1.
15. 7 Geo. 3, c. 41 (1767); id., c. 46. As to the Commissioners, see No. 45. The Acts also tightened the entry requirements and clarified the status of the writ of assistance. 7 Geo. 3, c. 46, §§9, 10. See No. 44, note 29.
16. 8 Geo. 3, c. 22 (1767). See Ubbelohde, Vice-Admiralty Courts 130–133. See also No. 46, notes 41–43.
17. In 1767 there had been 15 actions on the docket of the Vice Admiralty Court, of which one can be definitely identified as a revenue case and 2 are suits under the White Pine Acts (p. 247–253 below). The rest are presumably ordinary civil maritime actions. In 1768, out of 33 actions, 12 entries were in rem actions under the Acts of Trade, and 12 were in personam actions, the latter the Hancock and Malcom prosecutions (see No. 46, note 26). In 1769, out of 55 actions, 21 were under the White Pine Acts (see No. 54), 18 were in rem actions under the Acts of Trade and 10 were in personam prosecutions, including those arising out of Dowse v. 33 Hogsheads of Molasses, No. 47. See Vice Adm. Min. Bk. To the extent that the figures here and in notes 22, 24, below, differ from those in Wroth, “Massachusetts Vice Admiralty Court,” 6 Am. Jour. Legal Hist. 367, the latter are erroneous.
18. See No. 46.
19. See Nos. 47, 48, 49.
20. See Nos. 50, 54. At the same time JA was of counsel for the accused in Rex v. Corbet, No. 56, a trial before a Special Court of Admiralty for the killing of a naval officer at sea, which had political implications.
21. For the passage in the Autobiography, see 3 JA, Diary and Autobiography 287–289. Hutchinson's statement that JA was offered the position of justice of the peace is discussed in id. at 289 note. In his diary for 22 Sept. 1772, JA noted that in the service of his “Country” he had sacrificed “Time, Peace, Health, Money, and Preferment, both of which last have courted my Acceptance, and been inexorably refused, least I should be laid under a Temptation to forsake the Sentiments of the Friends of this Country.” 2 id. at 63. That Sewall was dissatisfied with his post as early as the summer of 1768 seems clear from the story of his dealings with Samuel Venner. In Nov. 1768 he learned that he had been appointed Judge of the new Admiralty court at Halifax, which would have given him valid ground to look for a successor. See No. 46, notes 20, 27, 41–43. He was actually in Halifax on business at the time of the trial in Butler v. The Union, No. 50. Samuel Fitch was finally appointed to the post in March 1770. See No. 51, note 2. For the later relations between JA and Sewall, see 2 JA, Diary and Autobiography 67–68, and 1 Adams Family Correspondence 135–137.
22. In 1770 there were 13 actions in the Vice Admiralty Court, of which 5 were for breaches of the Acts of Trade and 2 were under the White Pine Acts. In 1771 out of 17 actions, 15 were for breaches of the Acts of Trade. See Vice Adm. Min. Bk. For the end of nonimportation, see Miller, Origins of the American Revolution 309–311. The Townshend Acts repeal was 10 Geo. 3, c. 17 (1770). As to JA 's 1769 practice, see vol. 3:335–337 below. He had moved to Braintree in April 1771 after his exhausting defense of the Massacre defendants (Nos. 63, 64). See 2 JA, Diary and Autobiography 6–7. Health is usually given as the reason for his departure. See id. at 7 note; 3 id. at 296. Compare 2 id. at 65–66. There is also reason to think, however, that he had had his fill of politics. Id. at 63.
23. See 2 JA, Diary and Autobiography 56. As to these cases, see Ubbelohde, Vice-Admiralty Courts 157. See Cutt v. Meservey, Vice Adm. Min. Bk., 23 Jan. 1772; Baker v. Meservey, id., 9 March 1772.
24. For Adams' cases, see Nos. 51, 52. As to the Gaspee, and the reaction to the incident, see No. 46, note 22; Miller, Origins of the American Revolution 325–329. For JA 's reactions see 2 JA, Diary and Autobiography 73, 75–76. Although the records of the Vice Admiralty court are incomplete, there is some evidence that the Commissioners increased their activities in 1772. The existing docket of the court, through March 1772, shows 16 actions, of which at least 10 were customs cases. Vice Adm. Min. Bk. See also, Receipts from Seizures of Ships, 1772–1773, MBAt:Price Papers, which contains receipts of 19 forfeitures and one composition between May 1772 and Sept. 1773. A check of the Boston newspapers reveals at least 10 seizures between Sept. 1773 and Feb. 1776.
25. The Tea Act was 13 Geo. 3, c. 44 (1773). See generally Benjamin W. Labaree, The Boston Tea Party 58–109 (N.Y., 1964). See also Dickerson, “Use Made of the Revenue from the Tax on Tea,” 31 NEQ 232 (1958).
26. See account of James Hall, in Francis S. Drake, ed., Tea Leaves 352 (Boston, 1884). See generally, Labaree, Boston Tea Party 118–137. For Hutchinson's account, see 3 Hutchinson, Massachusetts Bay, ed. Mayo, 307–312.
27. The basic provision was the Sugar Act, 6 Geo. 2, c. 13, §§2, 3 (1733), incorporated by the Townshend Act, 7 Geo. 3, c. 46, §4 (1767). The High Court of Admiralty had held that under the Act prohibiting European goods “importation” occurred upon arrival. See No. 52, note 5. The Privy Council, however, had held in another case that “importation” did not occur until bulk had been broken. Smith, Appeals to the Privy Council 496. The practice was thus presumably not fixed in the colonies and varied from port to port. That the officers did not consider that they had power in the ordinary course to clear out a vessel in such circumstances appears in an episode in 1774 at Salem, where tea was permitted to be sent on to Halifax only after bond for the duties had been given. Salem Custom Officers to Commissioners, 5 Dec. 1774, Salem Custom House Letter Book Outwards, 1772–1775, Office of the U.S. Collector of Customs, Boston, Mass. For a full discussion of this phase of the question, see Labaree, Boston Tea Party 126–127.
28. For JA 's comment, see 2 JA, Diary and Autobiography 85. See generally Labaree, Boston Tea Party 137–145.
29. The Port Act was 14 Geo. 3, c. 19. As to the rest of the legislation, see Miller, Origins of the American Revolution 355–376. See also Labaree, Boston Tea Party 178–203.
30. See 2 JA, Diary and Autobiography 97–160. Compare No. 53, note 5.
31. As to these Acts and JA 's concern with them, see No. 58, notes 14, 23 173 .
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