Indiana Law Journal
Fall, 1991
  CLARA SHORTRIDGE FOLTZ: CONSTITUTION-MAKER
  Barbara Allen Babcock *

  


1 J. AYERS, GOLD AND SUNSHINE vi (1922) (published posthumously). The rest of the quote is also apt: "Each life helps to make up the sum of all history, and there is none so obscure or isolated but that it would, if properly written, throw a ray of light upon some latent event of value to the historian." Id.

2 Sail'er Inn v. Kirby, 5 Cal. 3d 1, 485 P.2d 529, 95 Cal. Rptr. 329 (1971); CAL. CONST. art. XX, ' 18 (1879) (In 1970, the wording was changed without substantive effect to: "a person may not be disqualified because of sex, from entering or pursuing a lawful business, vocation or profession.").

3 B. CURRAN, THE LAWYER STATISTICAL REPORT: A STATISTICAL PROFILE OF THE U.S. LEGAL PROFESSION IN THE 1980s (1985), quoted in Different Voices, Different Choices? The Impact of More Women Lawyers and Judges on the Justice System, 74 JUDICATURE 138 (1990); see Different Mix at Law Schools, N.Y. Times, Apr. 5, 1991, at B12 (law teaching statistics).

4 Babcock, Reconstructing the Person: The Case of Clara Shortridge Foltz, in REVEALING LIVES 131-40 (1990) (description of method in writing a biography without the subject's papers).
    Modern sources on Foltz include: Schwartz, Brandt & Milrod, Clara Shortridge Foltz: Pioneer in the Law, 27 HASTINGS L.J. 545 (1976) (This is the only modern law review article about Foltz, and it started me on the biography.); 1 NOTABLE AMERICAN WOMEN 1610-1950, at 641 (E. James, J. James & P. Boyer eds. 1971); 1 THE NATIONAL CYCLOPEDIA OF AMERICAN BIOGRAPHY (1930); Elwood-Akers, Clara Shortridge Foltz: California's First Woman Lawyer, 28 PAC. HISTORIAN 23 (1984); Polos, San Diego's "Portia of the Pacific," J. SAN DIEGO HIST. 185 (Summer 1980).
    Foltz's Struggles and Triumphs of a Woman Lawyer [hereinafter Struggles] appeared monthly in her magazine, The New American Woman (1916-1918). She described the constitutional period and took credit for "proposing" the two sections in March 1917.

5 Struggles, supra note 4, Mar. 1917 (reference to education section).

6 According to Foltz:

To the women of California this constitution--now amended beyond recognition of its framers--was a light bearer. It furnished to her the first streak of dawn, by which her awearied feet have been guided into larger fields of opportunity.
Struggles, supra note 4, Mar. 1917.
    For Foltz, the passage of the clauses led directly to her appointment in 1880 as clerk of the Judiciary Committee of the Legislative Assembly--a lawyer's job never before held by a woman. In virtually every interview and biographical index over fifty years of public life, she claimed credit for the anti- discrimination sections of the California Constitution.

7 Id.

8 Letter from Karl Marx to Friedrich A. Sorge (Nov. 5, 1880), reprinted in K. MARX & F. ENGELS, LETTERS TO AMERICANS, 1848-1895: A SELECTION 126 (A. Trachtenberg ed., L. Mins trans. 1953).
    A list of the books and articles I found most useful for the history and interpretation of the events surrounding the Constitutional Convention follows, starting with the early works. 7 H. BANCROFT, HISTORY OF CALIFORNIA (1890) [hereinafter H. BANCROFT, HISTORY OF CALIFORNIA]; 2 H. BANCROFT, POPULAR TRIBUNALS (1887) [hereinafter H. BANCROFT, POPULAR TRIBUNALS]; 3 J. BRYCE, THE AMERICAN COMMONWEALTH 223 (1888) (chapter entitled "Kearneyism in California"); George, The Kearney Agitation in California, 17 POPULAR SCI. MONTHLY 433 (1880); 4 T. HITTELL, HISTORY OF CALIFORNIA (1897); Hittell, The Legislature of 1880, 1 BERKELEY Q. 234 (1880); Sargent, The California Constitutional Convention of 1878-9, 6 CALIF. L. REV. 1 (1917); G. TINKHAM, CALIFORNIA--MEN AND EVENTS (1915); W. BEAN, CALIFORNIA: AN INTERPRETIVE HISTORY (1968); W. BEAN & J. RAWLS, CALIFORNIA: AN INTERPRETIVE HISTORY (1973); W. BULLOUGH, THE BLIND BOSS AND HIS CITY (1979); J. CAUGHEY, CALIFORNIA (2d ed. 1953); I. CROSS, A HISTORY OF THE LABOR MOVEMENT IN CALIFORNIA (1935); P. Ethington, The Structures of Urban Political Life: Political Culture in San Francisco, 1850- 1880 (1988) (unpublished Ph.D. dissertation, Stanford University); Ethington, A Language of Politics in a Politics of Class: The Workingmen's Party of California and the Twilight of Republicanism (1990) (unpublished manuscript); F. Fahey, Denis Kearney, A Study in Demagoguery (1956) (unpublished Ph.D. dissertation, Stanford University); W. HUTCHINSON, CALIFORNIA (1980); Kauer, The Workingmen's Party of California, 13 PAC. HIST. REV. 278 (1944); Kazin, Prelude to Kearneyism: The "July Days" in San Francisco, 1877, 3 NEW LAB. REV. 5 (1980) [hereinafter Kazin, Kearneyism]; Kazin, The Great Exception Revisited: Organized Labor and Politics in San Francisco and Los Angeles, 1870-1940, 55 PAC. HIST. REV. 3 (1986); D. Moorhead, Sectionalism and the California Constitution of 1879 (1941) (unpublished Ph.D. dissertation, Stanford University) (a shorter work under the same title is published in 12 PAC. HIST. REV. 287 (1943)); A. ROLLE, CALIFORNIA: A HISTORY (3d ed. 1978); A. SAXTON, THE INDISPENSABLE ENEMY: LABOR AND THE ANTI-CHINESE MOVEMENT IN CALIFORNIA (1971); S. Sharp, Social Criticism in California During the Gilded Age (1979) (unpublished Ph.D. dissertation, University of California, San Diego); Shumsky, San Francisco's Workingmen Respond to the Modern City, 55 CAL. HIST. Q. 46 (1976); C. SWISHER, MOTIVATION AND POLITICAL TECHNIQUE IN THE CALIFORNIA CONSTITUTIONAL CONVENTION, 1878-79 (1930) (Swisher's slender book on the 1879 Constitution remains the basic work on the subject sixty years later. It is a masterly, thorough and reliable treatment of the issues it covers, which do not include the anti-discrimination sections or women's suffrage. One paragraph is devoted to the latter debate at page 96.).
    By the end of the seventies decade, both the number of Chinese in the state and the state's total population had doubled. Over half the state's population was centered within 100 miles of San Francisco. D. Moorhead, supra, at 360-61.

9 Gertrude Atherton coined the "terrible seventies" phrase in CALIFORNIA: AN INTIMATE HISTORY (1927).
    For biographical information and a detailed account of the passage of the Woman Lawyer's Bill and of the Hastings' suit, see Babcock, Clara Shortridge Foltz: "First Woman," 30 ARIZ. L. REV. 673, 686-95 (1988).

10 The Lady Lawyers, San Francisco Chron., Feb. 15, 1879, at 2 ("aged masculine attorney"); DEBATES AND PROCEEDINGS OF THE [CALIFORNIA] CONSTITUTIONAL CONVENTION 1395 (1879) [hereinafter DEBATES].

11 CAL. CONST. art. IX, ' 9 (1879); DEBATES, supra note 10, at 1476.

12 Foltz v. Hoge, 54 Cal. 28 (1879).

13 Struggles, supra note 4, Mar. 1917. The full passage reads: "There were many splendid women in California in those days--women who had thought deeply, and who were profoundly by nature and learning, the peers of most of the men who composed the convention."
    The biographer's approach fits well with the newer hermeneutical approach to history:

Just as social historians have turned increasingly to the project of reconstructing the past as it was lived, so intellectual historians have tried to reconstruct ideas as they were thought, by trying to uncover what thinkers believed themselves to be doing . . . . This hermeneutical approach to historical inquiry does not rule out the attempt to find larger patterns of change . . . [but] merely requires that such interpretations be seen in terms of the meanings available in the past. These meanings are then examined critically in light of later developments, rather than through some lens designed to broaden or deepen perspectives in order to fit events to a preconceived pattern.
Kloppenberg, The Virtues of Liberalism: Christianity, Republicanism, and Ethics in Early American Political Discourse, 74 J. AM. HIST. 9, 11 (1987).
    Other articles on historical method that I found particularly useful are: Basch, The Emerging Legal History of Women in the United States: Property, Divorce, and the Constitution, 12 SIGNS 97 (1986); Kerber, Separate Spheres, Female Worlds, Woman's Place: The Rhetoric of Women's History, 75 J. AM. HIST. 9 (1988).

14 Struggles, supra note 4, Mar. 1917. Foltz spoke of the monthly column as "brief and hastily recorded reminiscences" and hoped that sometime "an inquisitive biographer may write the history of the progress of the first woman admitted to practice law on the Pacific Coast. Modesty should hardly prevent me from suggesting that my name must necessarily 'go over the top.' In the language of Pope, 'Let wreaths of triumph my temples twine."' Id., Mar. 1918.
    In writing about Foltz, I have a sense of being on a rescue mission, which can pose peculiar problems for the feminist biographer. Bell Gale Chevigny wrote of the "feminist fallacy" that may result from too much projection of our own "actual, latent, or ideal experience onto the subject." She attributes the tendency to "the validating stress that feminist theory has laid on the personal, the confusions about the role of the personal in our theory, the urgency and the fervor associated with a movement to redress historical and current injustice." Chevigny, Daughters Writing: Toward a Theory of Women's Biography, in BETWEEN WOMEN 359 (1984).
    Kathleen Barry, in a postscript to her important biography of Susan B. Anthony, writes of the possibilities of women's biography, "which can challenge the very structure and categories of the history men have jealously guarded as their own." She emphasizes discovering the active subject and moving "from the phenomenology of daily life to the structure of history." K. BARRY, SUSAN B. ANTHONY: A BIOGRAPHY OF A SINGULAR FEMINIST 359, 360-61 (1988). In my search for Foltz as an actor in the constitutional period, I have followed Barry's injunction to show my subject in the process of "active social construction of herself in the world." Id. at 361.
    On women writing about women, see also Bell & Yalom, Introduction, in REVEALING LIVES, supra note 4, at 1.

15 Scheiber, Race, Radicalism, and Reform: Historical Perspective on the 1879 California Constitution, 17 HASTINGS CONST. L.Q. 35, 52-57 (1989) (lamenting the lack of interest in the California Constitution at the centennial); Friedman, State Constitutions in Historical Perspective, 496 ANNALS 33 (1988). Typical of the dismissive treatment of Kearney and the work of the Convention as well are H. Bancroft and T. Hittell, see supra note 8, the two leading historians of the period.

16 Fritz, More Than "Shreds and Patches": California's First Bill of Rights, 17 HASTINGS CONST. L.Q. 13, 14-15 (1989) (quoting Keller, The Politics of State Constitutional Revision, 1820-1930, in THE CONSTITUTIONAL CONVENTION AS AN AMENDING DEVICE 68 (1981)) ("There has been a remarkable dearth of scholarly writing on nineteenth century constitution-making. As one scholar recently observed, '[F]ew themes in the history of American government have been less adequately studied."'). For one of the few exceptions to the lack of scholarly writing on the subject, see G. BAKKEN, ROCKY MOUNTAIN CONSTITUTION MAKING, 1850-1912 (1987).
    Revision of the starkly negative historic appraisal of the WPC seems unlikely, although there is some recognition of its role as a precursor to the Knights of Labor and other movements in the 1880s to oppose industrial capitalism with a more "republican" order. P. Ethington, supra note 8 (chapter of dissertation entitled "Under Construction: The Workingmen's Party of California in the Twilight of Republicanism").

17 3 J. BRYCE, supra note 8, at 228 n.1 ("[P]eople were unwilling to talk about the Kearney agitation, feeling it seemed to me, rather ashamed of it, and annoyed that so much should have been made of it (more they declared than it deserved) in the Eastern States.").
    James Bryce, a distinguished statesman and scholar, travelled in 1870, 1881 and 1883 to the United States to gather material for a book on the political character and behavior of Americans. On the last two trips, he came to the Pacific Coast. Published in 1888, the book was an instant classic.
    Edmund Ions wrote that "Bryce was intrigued by the reports he had heard of [the Kearney] agitation. . . . Was Kearney another John Bright, or merely a rabble rouser? Bryce talked with local newspaper editors and journalists. Almost all of them were opposed to Kearneyism." E. IONS, JAMES BRYCE AND AMERICAN DEMOCRACY 1870-1922, at 116 (1970).
    In his concluding observations of the chapter on Kearneyism in California, Bryce advises readers that, "till corrected by my California friends," he had thought the Workingmen's "movement more serious than it really was." 3 J. BRYCE, supra note 8, at 246. Even with his reduced opinion of the movement's importance, however, Bryce printed the entire constitution as an appendix to the first edition of the book.

18 The George article appeared as The Kearney Agitation in California, 17 POPULAR SCI. MONTHLY 433 (1880). Bryce also mentioned Hittell, The Legislature of 1880, 1 BERKELEY Q. 234 (1880) as a source. He also talked to newspaper publishers and editors, E. IONS, supra note 17, and generally relied, he said, "on what I could pick up in conversation." 3 J. BRYCE, supra note 8, at 246.
    One of Bryce's conversational sources was Bernard Moses, a young but already distinguished historian and professor at the University of California. See 13 DICTIONARY OF AMERICAN BIOGRAPHY 274 (1935-36) (Bernard Moses entry). In one of the few unfavorable contemporary reviews, the author takes Bryce to task for the nature of his sources: "Mr. Bryce sees America through the rim of a champagne glass to the strains of soft music, and in the smiles of fair women. He sees what America should be, but what it is not . . . ." L. Bryce, Errors in Prof. Bryce's "Commonwealth," 148 N. AM. REV. 344, 354 (1889) (author not related to Prof. Bryce). More typical of the book's reception is E. Eggleston, A Full-Length Portrait of the United States, 38 CENTURY MAG. 789 (1889) (favorable comparison with De Tocqueville; no national portrait ever drawn with such "fidelity or felicity").
    Bryce devoted two chapters to American women, whom he admired. 3 J. BRYCE, supra note 8, at 289 (chapter entitled "Women's Suffrage"); 3 id. at 504 (chapter entitled "The Position of Women"). But in the latter, he reveals that he learned nothing of the true story of the women's sections by asserting that several state constitutions "expressly provide that they shall be equally admissible to all professions or employments." Id. at 506. In fact, no other state had anything like the anti-discrimination sections of the 1879 California Constitution.

    Among the Bryce papers is an exchange of letters with Denis Kearney himself about the accuracy of the account; and Bryce slightly modified his descriptions of both Kearney and the WPC in response to the correspondence. The letters are reproduced in Nunis, The Demagogue and the Demographer: Correspondence of Denis Kearney and Lord Bryce, 36 PAC. HIST. REV. 269 (1967), and described also in Posner, The Lord and the Drayman: James Bryce vs. Denis Kearney, 50 CAL. HIST. SOC'Y Q. 277 (1971).

19 Struggles, supra note 4, July 1918. H.H. Bancroft, the period's best known historian, literally reduced the women's role to a footnote, and one that would be largely incomprehensible except to one who already knew the story. The footnote is appended to a cite to the women's education section:

There was in 1879 both curiosity and interest felt in the applications of Mrs. Clara S. Folz [sic], who had studied law and been admitted to practise [sic] . . . but who was refused admission by the directors of the Hastings law college. . . . Congress had just passed an act authorizing women to practise law, and a woman had been admitted to the U.S. sup. court [sic]. Under these circumstances, and knowing that the new constitution declared for equal educational and business rights, the directors submitted.
7 H. BANCROFT, HISTORY OF CALIFORNIA, supra note 8, at 393 n.32 (citing newspaper stories before the Hastings appeal from the decision).
    George Tinkham has this line at the end of a chapter on the Convention: "[A]fter much labor, Clara Foltz and Mrs. Laura de Force Gordon succeeded in having introduced and passed a section that no person on account of sex should be disqualified from carrying on any lawful business, profession or vocation." G. TINKHAM, supra note 8, at 229; see also WOMEN OF THE WEST (Biwheim ed. 1928) (Foltz entry: Foltz the "author" of the employment section); Collver, The American Woman's Battle for the Ballot, San Francisco Call, July 4, 1901, at 5 (Foltz the author of the constitutional sections; "brave little body of 'fanatics' . . . aiming at the skies").
    Though a few standard texts now mention Clara Foltz and Laura Gordon as early women lawyers, they do not connect them or the other suffragists with the historic anti-discrimination sections. Compare W. BEAN, supra note 8 with W. BEAN & J. RAWLS, CALIFORNIA: AN INTERPRETIVE HISTORY 255 (5th ed. 1988) (The first does not mention Foltz and Gordon and has only two lines on woman suffrage; the recent edition has a page on suffrage and cites Foltz and Gordon as pioneer women lawyers.). No modern histories connect the anti-discrimination sections to Foltz and Gordon or the suffrage movement.
    Some defense for this neglect lies in the difficulty, perhaps impossibility, of proceeding from the constitutional text to the women's story. There was no official legislative history at all for the women's sections, much less mention of Foltz or Gordon on the record.
20 San Francisco Chron., Feb. 27, 1879, at 2; Struggles, supra note 4, Aug. 1916 (name was on every tongue).

21 New Northwest, June 15, 1877, at 2 (letter from Clara Foltz).

22 F. NORRIS, THE OCTOPUS 1058 (Library of Am. ed. 1901).

23 J. AYERS, supra note 1, at 281-83. The book was published posthumously without historical or editorial note about the time or circumstances in which it was written. But it is probably the memoir that Ayers retired to write a few years before his death. Los Angeles Times, Nov. 13, 1897, at 5 (obituary). A copy of the manuscript in Ayers' own handwriting is at the Huntington Library, San Merino, California.
    The first and famous Nob Hill foray occurred on October 29, 1877. A. SAXTON, supra note 8, at 118 (quoting contemporary sources); I. CROSS, supra note 8, at 99-100. J.J. Ayers may have been using some artistic license when he told the story of being at Stanford's house and hearing the roar of the Workingmen. The Marie Antoinnette vase seems almost too pat, given that one of the great fears the WPC roused was communism and Paris in 1871 was often cited. On the other hand, it is not at all unlikely that Ayers dined with Stanford at some point in his career.

24 For examples of Kearney's rhetoric, see 4 T. HITTELL, supra note 8, at 604, 608 (references to "hemp" and to Judge Lynch); and 2 H. BANCROFT, POPULAR TRIBUNALS, supra note 8, at 722. As to "shoddy aristocrats," "activists of the WPC used this term so much that they eventually conjured up a whole party of such beings, referred to simply as the 'shoddys', or the 'shoddyites."' P. Ethington, supra note 8, at 27. He also notes Kearney's preference for morally pejorative terms--citing the following: "monopoly robber," "blood sucker" and "miserable felonious bank smashers." Id.; see also infra note 42; Speeches of Dennis [sic] Kearney, Labor Champion (1878) (pamphlet; Special Collections, Stanford University Library) (samples of Kearney's speeches on his Eastern tour in 1878).

25 A. SAXTON, supra note 8 (Saxton's thesis is that race hatred provided the cement to hold together the labor movement throughout its early years in California.); G. BARTH, BITTER STRENGTH: A HISTORY OF THE CHINESE IN THE UNITED STATES 1850-1870 (1964); Scheiber, supra note 15, at 43 (The Chinese were railed against "with a savagery that transcended all limits of ordinary political discourse even in an age of harsh rhetoric.").

26 A. SAXTON, supra note 8, at 105-12. P. Ethington, supra note 8, at ch. 6 ("Workingmen's Gothic: The Meaning of the Workingmen's Party of California") details the use by the major parties of the issue of Chinese immigration and posits as one reason for Kearney's swift ascent the inability of the Democrats and Republicans to offer any answer for the racial fears they exacerbated.

27 A. SAXTON, supra note 8, at 259 passim; Struggles, supra note 4, Mar. 1917 (Foltz quoting Kearney). The near-universal race prejudice toward the Chinese is shocking to modern sensibilities, especially because the racists were people of widely variant background and education, many of whom were themselves subject to discrimination because they were immigrants. E. SANDMEYER, THE ANTI-CHINESE MOVEMENT IN CALIFORNIA 62-63 (1973) (originally published in 1939 in ILL. STUD. SOC. SCI.), is still the best source for the buildup of tension and prejudice that culminated in the depressed seventies. In 1862, Leland Stanford in his inaugural address as governor spoke of discouraging Chinese immigration "by every legitimate means. Asia, with her numberless millions sends to our shores the dregs of her population." Id. at 43-44. In 1876, at an "anti-coolie" meeting in San Francisco, attended by as many as 25,000, people from all ranks of life harangued against Chinese immigration, including the governor of the state. Id. at 58-59. In the fall of 1876, a special U.S. Senate investigating committee came to San Francisco and listened to Californians of all kinds, including even the clergy, who opposed Chinese immigration on essentially racist grounds. Report of the Joint Special Committee to Investigate Chinese Immigration, S. REP. No. 689, 44th Cong., 2d Sess. (1877). The racial stereotypes involved in the testimony is explored in Spoehr, Sambo and the Heathen Chinese: Californians' Racial Stereotypes in the Late 1870's, 42 PAC. HIST. REV. 185, 190-97 (1973). One of the few friends to the Chinese to appear in California was Indiana Senator Oliver P. Morton, who headed the Senate investigating committee but died before the report was written. One San Francisco periodical lamented Morton's "unsound, unwise and unworthy" approach, noting that had Morton lived, he would have "come to the same conclusion as that to which all the more intelligent classes of the Pacific coast have now arrived." Argonaut, Dec. 19, 1877, at 4.

28 George, The Chinese on the Pacific Coast, N.Y. Tribune, May 1, 1869. Saxton says of the letter that it "constituted a classic statement of the economic argument against Chinese immigration as it has been developed during the preceding five years by anticoolie clubs, trade unions, and the renascent Democratic party." A. SAXTON, supra note 8, at 100. Later George recognized that the Chinese were being used politically to divert attention from real and radical reforms. In fact, the recognition of this fact was part of the impetus for his Popular Science Monthly article on Kearneyism (see supra note 8). Id. at 155. But George never completely gave up his "ethnocentric exclusivism," the "dark side of his intellectual background." J. THOMAS, ALTERNATIVE AMERICA: HENRY GEORGE, EDWARD BELLAMY, HENRY DEMAREST LLOYD AND THE ADVERSARY TRADITION 62 (1983).

29 Struggles, supra note 4, Mar. 1917. J.J. Ayers, who was one of the founders of the San Francisco Call and who in the late seventies was publisher of the Los Angeles Express, issued blasts against the Chinese and the railroad monopolies with the same intensity. In a typical editorial in early 1878, Ayers heartily approves objections that go beyond the wage competition of the Chinese; they "belong to a non-assimilative race . . . who came not to escape oppression, but for the purpose of making money. Freedom of thought is nothing to a Chinaman. . . . He has absolutely no conception of our society . . . government . . . institutions . . . they are thus in every sense, aliens . . . ." Los Angeles Express, Jan. 4, 1878, at 2; see infra text accompanying notes 98-99, 159, 168, 176-77.

30 W. BEAN & J. RAWLS, supra note 8, at 164, has a good chapter and bibliography on "The Terrible Seventies." All standard histories cover the same ground as to causes and effects of the national and the Pacific Coast depression. In her account of the fearful times that produced the constitution, Foltz wrote: "If ever in the world's history there was a time when cause preceded effect, it was in California in 1879." Struggles, supra note 4, Mar. 1917.

31 Samuel Howe established his academy in 1844 in Mt. Pleasant, where it flourished until 1916. Pamphlets about the academy, its first printed catalog, which relates the school's history, and other materials are in the Archives, Iowa Wesleyan University. Howe himself was an ardent abolitionist, woman suffragist and death penalty opponent. HISTORY OF HENRY COUNTY (1879) (available at Iowa State Historical Library, Des Moines). Arabella Mansfield, the first woman admitted to the bar in the United States, also attended Howe's academy where "the liberal principles of . . . Samuel L. Howe, abolitionist and suffragist--probably influenced her later career." 2 NOTABLE AMERICAN WOMEN 1610-1950, supra note 4, at 492 (Arabella Mansfield entry).
    An article written by one of "Miss Clara's" former teachers, refers to the "eloquent adventist minister, Elias Shortridge." Mt. Pleasant Golden Age, reprinted in San Jose Daily Mercury, June 24, 1880, at 3.
    "She was regarded by her teachers as possessing an extraordinary mind, having at the early age of twelve years finished the first two books of Latin, and stood at the head of her class in philosophy, history and rhetoric." AN ILLUSTRATED HISTORY OF SOUTHERN CALIFORNIA (1890) (Clara Foltz entry).

32 Church records show Elias Shortridge as an itinerant preacher throughout Indiana in the 1850s, then moving to Mt. Pleasant in late 1859. By the fall of 1863, he is again on the circuit, this time in Illinois. In Mt. Pleasant he "insisted on preaching" the doctrine of soul-sleeping, and since "he was a preacher of much more than ordinary ability numbers were carried away by this strange doctrine." The Christian Record, Pioneers of a Great Cause (unpublished manuscript; available at Disciples of Christ Historical Society, Nashville, Tennessee). Soul-sleeping as preached by Elias Shortridge involved a belief that the spirit does not immediately join the Eternal at the moment of death. For a lucid account of the Disciples of Christ orthodoxy, see G. WILLS, REAGAN'S AMERICA (1987) (Reagan's mother belonged to the Disciples of Christ). Thomas Barnes wrote that Foltz was "the daughter of a 'Campbellite,' a Church of Christ, minister of that extraordinarily evangelical sect that had the odor of inordinate enthusiasm about it and was considered heterodox by all mainline Protestant churches, preaching as it did the imminent Second Coming of Christ and rejecting all credal formulas." T. BARNES, HASTINGS COLLEGE OF THE LAW: THE FIRST CENTURY 47 (1978).

33 I describe Clara Foltz's marriage and divorce in Babcock, supra note 4, at 131. At the Hastings court argument, one reporter described her attire at length, including that her "wrists were ornamented with fringes of black silk, partially concealing hands not lacking in bone and muscle." San Francisco Chron., Feb. 25, 1879, at 1. Usually Foltz claimed that she was a widow, but in one of her early press interviews she said that Jeremiah had remarried only weeks after their divorce. The marriage certificate of Jeremiah Foltz and Kate M. McKerron records the marriage on June 26, 1880, which was a full year later.

34 In lectures and interviews, Foltz often told of her early dreams of "oratory, fame, or political recognition." See, e.g., San Jose Times Mercury, Aug. 20, 1882, at 5 (reprinted from the San Francisco Post, Aug. 12, 1882, at 2). The story of her mother's "prophetic words" is one she also repeated, here taken from the first chapter of Struggles, supra note 4, Apr. 1916.

35 The writer claimed it "was genius only that could [overcoming all obstacles] rise in six short years to the position of a first rate lawyer in a metropolitan city." San Jose Times Mercury, Jan. 1, 1885, at 1.

36 Entries for both Clara Foltz and her brother Samuel Shortridge in O. SHUCK, HISTORY OF THE BENCH AND BAR OF CALIFORNIA (1901) contain references to the Shortridge oratorical ability: "Her family has always been noted for mental and physical vigor and uncompromising virtue. Her father acquired distinction as an orator." Id. at 828. The Shortridge oratorical genealogy is more pronounced in Samuel's entry where Eli Shortridge of Alabama is invoked and described as a great spellbinder of jurors. Id. at 1079. In one of her jury arguments, Foltz proclaimed: "I am descended from the heroic stock of Daniel Boone, and never shrunk from contest nor knew a fear. I inherit no drop of craven blood." Struggles, supra note 4, Jan. 1918.

37 Sacramento Record-Union, Feb. 25, 1879, at 1 (letter from an unnamed Oregon correspondent commenting on Foltz's ready advocacy of suffrage); see Babcock, supra note 9, at 675-85 (describing Foltz's relationship to the suffrage movement).

38 Babcock, supra note 9, at 680-86 (Clara Foltz in San Jose from 1875 to 1878). On woman suffrage in Sacramento, see infra text accompanying note 171.

39 In a New Field, New Northwest, Feb. 22, 1877, at 2. The "'lecture was a well written production, and was well delivered, frequently calling out protracted applause."' Id. (quoting the San Jose Mercury). Other titles were "Impartial Suffrage," "Impartial Citizenship," "Political Liberty," "Why Women Need the Ballot," "Women and Work" and "Equality of the Sexes."

40 The quote "hard as rocks" appeared in the San Jose Weekly Mercury, Oct. 18, 1877, at 1; the other quotes appeared in the San Jose Weekly Mercury, Mar. 15, 1877, at 3. She said of the suffragists like herself that they "considered it better to scatter broadcast one truth in the face of ridicule than . . . to bask in the sunshine of senseless smiles." Id.

41 In her belief that the ballot was a source of power and respect in itself, and that until women voted they would not be able to accomplish any other social goals, Foltz followed the line of the National Woman Suffrage Association, led by Elizabeth Cady Stanton and Susan B. Anthony. In regard to working women particularly, the suffragists believed that they would never be able to achieve equality in the workplace until they had the vote. Speaking in California at the beginning of the 1870s decade, Anthony addressed working women especially when she pointed to "the changed condition and standing of negroes, produced by the ballot and insisted that it was not because colored people were more respected now than then, as a class, but because they had the power of the ballot, and could not be disrespected." San Francisco Alta, July 13, 1871. Anthony went on to suggest that, when empowered by the ballot, women would "inaugerate [sic] strikes, as men do, and obtain from their employers better wages and easier times." Id. For an excellent treatment of the relationship of the suffragists and working women, see E. DUBOIS, FEMINISM AND SUFFRAGE: THE EMERGENCE OF AN INDEPENDENT WOMEN'S MOVEMENT IN AMERICA 1848- 1869 (1978). For Foltz's relation to the National Woman Suffrage Association, see Babcock, supra note 9, at 677-80.
    Two reports of Foltz's evolving suffrage speech containing these phrases appear in the San Jose Weekly Mercury, Mar. 15, 1877, at 3-4, and the New Northwest, Feb. 22, 1878, at 2. "Meet upon the level" was a favorite saying of Foltz's that she apparently first heard from an old woman who told her that she hoped to vote before she died. Letter from Clara Foltz to New Northwest (Sept. 17, 1875) (Foltz writing of her move from Oregon to California and of meeting "Auntie Brown").

42 Kearney's Manifesto was first published in the San Francisco Chronicle on October 16, 1877. This paper had the largest circulation in California, and was an early and central supporter of the WPC, though its relations with Denis Kearney himself later became complicated. I. CROSS, supra note 8, at 97-98; A. SAXTON, supra note 8, at 120; infra note 192.
    "If the ballot fails, we are ready to use the bullet," was a typical Kearney formulation. See, e.g., San Francisco Evening Bull., Dec. 12, 1877. At his trial in January 1878 for incendiarism, one charge was that Kearney had said that his followers would hold a Thanksgiving Day parade, "if they had to march 'up to their knees in blood,' but it was established in court that he had not said 'blood', but 'mud."' W. BEAN & J. RAWLS, supra note 8, at 180. Kearney's speeches were largely extemporaneous and newspaper accounts varied widely. As to his intent, one follower testified at Kearney's trial that the "little things" the WPC leader said "were only used as metaphors." San Francisco Chron., Feb. 17, 1878.

43 Starting in July 1877 there occurred "one of the bitterest explosions of class warfare in American history--the Great strike of 1877." Beginning in the East and moving across the country, led by the Workingmen's Party of the United States, the strike was directed at the railroads--"symbols and creators of the new industrial order. . . . Although in San Francisco the strike degenerated into anti-Chinese rioting, elsewhere it achieved . . . remarkable . . . solidarity . . . ." E. FONER, RECONSTRUCTION 583-84 (1988). In San Francisco, the WPUS meetings to support the strike were taken over by anti-coolie hooligans, calling forth a "citizen vigilante" response, and helping to lead to the demise of the WPUS. In a much-noted irony, Denis Kearney was among the vigilantes. I. CROSS, supra note 8, at 88-95; A. SAXTON, supra note 8, at 113- 16.
    For the history of the WPUS, see P. FONER, THE WORKINGMEN'S PARTY OF THE UNITED STATES (1984). The Labor Standard, the WPUS organ, attempted to quell anti-Chinese racism and rioting. Id. at 76-77 (the quote in the text is from the Labor Standard).

44 W. DAVIS, HISTORY OF POLITICAL CONVENTIONS IN CALIFORNIA, 1849-1892, at 366-67 (1893) (WPC platform and expulsion of WPUS); Kazin, Kearneyism, supra note 8, at 5.

45 Although woman suffrage was not included among the progressive reforms the WPC advocated, it required no great imaginative leap for Kearney's followers to see that when votes are the weapon of choice, the more on your side the better. More specifically, white women's votes might be needed as an offset should the Chinese someday be enfranchised. (There were many restrictions on the immigration of Chinese women and few came to the United States.) See infra text accompanying notes 141-42. Most WPC delegates voted for woman suffrage at the Convention. Then, both as a consolation award for the failure of suffrage and because of benefits to working women, virtually all WPC delegates backed the clauses on access to education and employment. (The socialist Workingmen's Party of the United States did not officially back woman suffrage either, though they somewhat vaguely declared themselves for the "perfect equality of the rights of both sexes.") P. FONER, supra note 43, at 35.
    San Jose Weekly Mercury, Dec. 13, 1877, at 3 (Elias Shortridge on platform). On February 19, 1878, at 3, the Chronicle reported a "huge assembly" of Workingmen in San Jose, where the speakers included Elias Shortridge, again on a platform with Kearney. "The utmost good order prevailed and the meeting adjourned, fully confident that the Workingmen will be victorious at the polls tomorrow." San Jose did, in fact, elect a Workingman to the state assembly. In March, the WPC elected the mayor and city attorney of Sacramento, and the mayor, police judge, district attorney and justice of the peace in Oakland. I. CROSS, supra note 8, at 113. Earlier in the year the WPC had put in office a state senator from Alameda County. Id. at 111. These successes coincided with a decrease in the intensity of attacks on the Chinese and concentration instead on the abuses of land and railroad monopolies. Id. at 112.
    On the composition of the WPC, Lord Bryce noted that the party could never have achieved electoral success without the support "from the better sort of working-men, clerks and small shopkeepers." 2 J. BRYCE, supra note 8, at 378; see P. Ethington, supra note 8, at 309-12 (chapter entitled "Workingmen's Gothic: The Meaning of the Workingmen's Party of California") (containing a sophisticated analysis of meaning and composition of the WPC, arguing that it was essentially a political--rather than a labor--movement, and reached considerably beyond workingmen as such to include many middle-class occupations, as well as blue-collar workers in skilled occupations).

46 Struggles, supra note 4, Mar. 1917. Foltz quotes Kearney's racist rhetoric without comment or any attempt to distance herself beyond putting the slurs in quotation marks. Yet she was a great reader and had very likely read Lord Bryce's dismissive description of "Kearneyism in California," when The American Commonwealth was published in 1888. Bryce, moreover, had relied explicitly on Henry George's condemnation of Kearney as a run-of-the-mine politician. George, supra note 8, at 447.

47 On why he urged the ballot rather than the more usual weapons of labor, Kearney wrote Bryce:

I am opposed to strikes in a Republic where the ballot of a millionare's [sic] gardener or coachman cancels that of their Master. A strike amid such conditions is a brutal way of settling a difficulty. Pitting an empty belly and no bank account against a belly full and Plethoric bank book brings it down to a question of "bellys" [sic]. I wanted to tell our people to strike at the "ballot box."
Nunis, supra note 18, at 278-79.

48 Other advantages of constitutional conventions over even the most reformatory legislatures were that "they constitute only one house . . . [and are unconstrained by the governor's veto power]." 3 J. BRYCE, supra note 8, at 237.

49 Chinese were not allowed to become naturalized citizens, so only if they were born in the United States could they hope to vote. Since there were many restrictions on the immigration of Chinese women and few came, there were not many American-born Chinese. But Californians knew that someday the Chinese might be, as blacks had been, freely made citizens and thus enfranchised by the plain words of the fifteenth amendment. California voted against ratifying the fifteenth amendment precisely because it might some day enfranchise races other than blacks. P. Ethington, supra note 8, at 295; E. FONER, supra note 43, at 447.
    E. DUBOIS, supra note 41, in her chapter on "The Fifteenth Amendment and the Emergence of Independent Suffragism," relates how the passage of the fifteenth amendment divided the women's movement from the abolitionists and radical Republicans, and set the women on an independent course. Stanton and Anthony actually opposed passage of the fifteenth amendment because it failed to recognize women. The enfranchisement of former slaves gave new fuel to the racist and elitist arguments used throughout the woman suffrage movement, comparing the ignorant and politically irresponsible men who could vote to the educated and refined women still denied. Id. at 178. In the same vein, Clara Foltz wrote to Abigail Duniway in 1875 about presenting a petition at the polling place signed by a number of the tax-paying ladies, but "not having yet been made citizens of the United States, their petition was rejected. . . . Tim Wong, a Chinese resident of the town of Monterey, cast a Celestial vote . . . on the same day. But then Tim was born and raised in the State . . . speaks Spanish and English fluently, and crowning virtue, is the masculine persuasion. This is the first case on record, and should be the last, while woman, clothed with wisdom and armed with justice, stands knocking at the doors . . . ." New Northwest, Sept. 17, 1875, at 2.

50 4 T. HITTELL, supra note 8, at 588-91 (1878 legislature exceedingly busy and passed many important acts). The legislature was bicameral: the Senate with 40 members elected to four-year terms, one-half chosen every two years; the Assembly with 80 members elected to two-year terms. There were a total of 82 Democrats, 35 Republicans and 3 Independents in the legislature. In January, the Workingmen's Party in their first electoral victory sent a man named John Bones to the Assembly to fill a vacancy caused by death. He failed to be responsive to his constituency and became an added reason for the WPC to decry the possibility of working through the established system. C. SWISHER, supra note 8, at 14.

51 The California Law, Woman's Journal, Apr. 18, 1874, at 128, col. 3. The passage of the bill making women eligible for school offices was an important lesson in method for Foltz. Sarah Knox-Goodrich and others had travelled to Sacramento, "remaining there for weeks urging the measure." Id. Lobbying-- personally entreating legislators--was still questionable behavior for a woman in 1878. So were efforts to persuade from the public platform and the ritual visit to the polls to attempt to cast a vote. The only really acceptable modes of political expression were gentle persuasiveness within the home and signing petitions. See infra notes 170-71 (experience of Sacramento women).
    If the women's lobby had succeeded at the legislature, or at the Convention, California would have been the first state by more than a decade to endorse woman suffrage. In 1879, four states allowed women to vote on school matters and the sparsely populated territories of Wyoming and Utah allowed women full suffrage. See infra note 218.

52 A Sketch of Clara Shortridge Foltz, 13 W. COAST MAGAZINE 42 (1912) ( "caboose of cattle train"); O. SHUCK, supra note 36, at 831 ("maternal solicitude"); Struggles, supra note 4, June 1917 ("even hunger").

53 PEN PORTRAITS, Autobiographies of State Officers, Legislators, Prominent Business and Professional Men of the Capital of the State of California, also of Newspaper Proprietors, Editors and Members of the Corps Repertorial 105 (R.R. Parkinson 1878); see Babcock, supra note 9, at 678.

54 Main sources on Laura DeForce Gordon are: Papers of Laura DeForce Gordon [hereinafter Gordon Papers] (Stein Collection) (available at Bancroft Library, University of California at Berkeley); Obituary, Woman's Tribune, May 26, 1907, at 2-3; 11 NOTABLE AMERICAN WOMEN 1610-1950, supra note 4, at 68-69 (Gordon entry).

55 3 HISTORY OF WOMAN SUFFRAGE 752 (1881) (Consists of six volumes covering the years 1848-1920. Volumes 1-3 were edited by E. Stanton, S. Anthony & M. Gage; volume 4 by S. Anthony & I. Harper; and volumes 5 and 6 by I. Harper.).

56 Letter from Laura Gordon to Laura (no last name) (Feb. 16, 1877), contained in Gordon Papers, supra note 54.

57 Sonnet, PUCK, Jan. 1878, at 8-9.

58 Struggles, supra note 4, Aug. 1916. In one of her most popular lectures, entitled simply "Lawyers," Foltz often made the point: "If you think of studying law and some old fossil should tell you that no one will marry you if you do, don't believe him. You will have plenty of offers and . . . you will be happier if you marry. . . . A knowledge of law will make women better wives and truer mothers."

59 Struggles, supra note 4, Aug. 1916.

60 Notable exceptions in California include: Ellen Sargent, the wife of Aaron Sargent, a U.S. Senator thought to be on the payroll of railroads but the first to introduce woman suffrage in Congress; Mrs. Jeanne Carr, wife of Professor Carr of the University of California; and Mrs. Knox-Goodrich, Foltz's friend in San Jose.

61 Struggles, supra note 4, Oct. 1916 ("lady lawyer").

As the dawn seems to falter at the boundaries of a dark sky, so I hesitate to lift from oblivion the memory of the hurts and wounds which women inflicted upon me as I struggled to overcome the opposition they manifested at every turn against women in the legal profession. . . . I soon found myself and mine ostracized and ignored by the so-called 'best people' with whom my father's family had always moved.
Id., June 1917.

62 On Gordon: "Short, stocky, always earnest, sometimes nervous, 'handsome' or 'comely,' with strong regular features, large eyes and dark hair done up on occasion in a mass of lustrous curls, Mrs. Gordon was a speaker 'Websterian in force and eloquence."' 2 NOTABLE AMERICAN WOMEN 1610-1950, supra note 4, at 69 (Gordon entry). For a description of Daniel Webster's speaking style, see R. FERGUSON, LAW & LETTERS IN AMERICAN CULTURE 207-40 (1984).
    On Foltz: Typical of early reviews are the following phrases: "speaks and acts . . . like the good true and pure woman that she is"; "attitude and whole bearing" show that she was "speaking from the heart"; "wearing always the jewel of true womanhood." San Jose Weekly Mercury, Mar. 15, 1877, at 3. "There was something in the attitude and whole bearing of the speaker that impressed the audience at once with the fact that she was speaking from the heart--that her whole being was imbued with the righteousness of her position on the question of the equality of sex." San Jose Weekly Mercury, Oct. 18, 1877, at 1. "The greatest charm of her discourse consists in the fact that she speaks and acts like a woman who is thoroughly in earnest about what she is saying, like the good, true and pure woman that she is; the dutiful daughter, the faithful wife, the loving mother, and woman-hearted friend of humanity." New Northwest, Dec. 28, 1877 (quoted from the Oakland Transcript).

63 Struggles, supra note 4, Dec. 1916. The legal club incident in San Jose was important to Foltz, who devoted more space to it in her column than to the Woman Lawyer's Bill or the California Constitution. The bitterness of the dispute, the crudeness of the debate's terms and her unproved abilities as a lawyer all seem to have rendered her particularly vulnerable. Decades later she was still telling the story. See e.g., O. SHUCK, supra note 36, at 831.
    One fellow law student argued that "women had no rights a white man was bound to expect." Another held that "women are smart in some things, but . . . it is the smartness of the educated dog or monkey, without the originality to conceive and execute for themselves . . . ." San Jose Weekly Mercury, Jan. 3, 1878, at 3; San Jose Weekly Mercury, Jan. 10, 1878, at 3; San Jose Weekly Mercury, Feb. 7, 1878, at 3; Babcock, supra note 9, at 701.

64 Woman's Journal, Apr. 20, 1878, at 124 (quoting letter from an unnamed California legislator); Struggles, supra note 4, Aug. 1916.

65 Struggles, supra note 4, Aug. 1916.

66 The Sacramento Record-Union, Jan. 11, 1878, was unusual in describing the bill as "permitting women and persons of color to practice law upon passing the requisite examination." Nothing else in the extensive newspaper accounts of the debates even hinted that the bill would apply to classes other than women. Babcock, supra note 9, at 686-95 (detailed coverage of the debate in the Assembly and Senate of the Woman Lawyer's Bill).
    There is some argument that Foltz's choice of language was purposeful. She knew very well that the usual phrase for expanding rights was to prohibit their denial "on account of sex," as in the proposed sixteenth amendment to the U.S. Constitution (woman suffrage). Note also that the women's sections of the California Constitution also used this formulation. Perhaps she thought that people of color should be able to practice law, or perhaps she wanted to preserve the argument that former slaves and women should be treated alike. As it was in 1878, both women and former slaves could be citizens, but only black men could vote. Some of the asymmetry, which was one of the women's main appeals, would be lost if women but not blacks could practice law.

67 Struggles, supra note 4, Aug. 1916.

68 Id.

69 3 HISTORY OF WOMAN SUFFRAGE, supra note 55, at 758; Babcock, supra note 9, at 694-95 (Foltz's account of her last-minute appeal to the governor).

70 The more usual route for women's entrance to the bar was initial denial by courts, followed by remedial legislation. This process meant that the legislative debate was often focused on the capacity of the one woman who had brought the case. Babcock, supra note 9, at 701-06 (discussing the best known cases at the time Foltz was seeking bar admission).

71 Woman Suffrage in California, New Northwest, July 5, 1878, at 2 (letter from Clara Foltz dated June 20, 1878).

72 C. MCWILLIAMS, AMBROSE BIERCE 136 (1967).

73 Letter from Clara Foltz to Laura Gordon (May 2, 1878) (no year is given in the letter but internal evidence shows it to be 1878) (available in Gordon Papers, supra note 54).

74 New Northwest, May 17, 1878, at 2.

75 Laura Gordon had run for office once before: that of State Senator from San Joaquin in 1871 near the beginning of the suffrage movement in California. "Her eligibility to the office was vehemently denied. . . . The pulpit, press and stump speakers alternated in ridiculing the idea of a woman being allowed to take a seat in the Senate, even if elected . . . ." 3 HISTORY OF WOMAN SUFFRAGE, supra note 55, at 756. This time, however, she did not face the problem because the enabling legislation for the election of Convention delegates did not include "the male-only requirement that prevailed for office holding in the legislature." Scheiber, supra note 15, at 45.

76 New Northwest, supra note 71.

77 Id. "[W]hen delegates to the constitutional convention were to be elected, Mrs. Gordon . . . became an independent candidate only a week or two before the election. With Mrs. Foltz she made a very brief though brilliant canvass, attracting larger and more enthusiastic audiences than any other speaker. Mrs. Gordon received several hundred votes for the office, and felt compensated for the time and money spent by the great interest awakened in the subject of woman suffrage." 3 HISTORY OF WOMAN SUFFRAGE, supra note 55, at 759.

78 Foltz wrote: "We consider the argument that 'men will not respect women when they engage in politics' forever refuted so far as San Joaquin county is concerned." New Northwest, supra note 71. The arguments about women campaigning apply equally to women in the courtroom pit arguing to a jury--especially to the all-male jury of the 19th century. Commenting on the male lawyer fear of competition, one newspaper wrote about Foltz's and Gordon's efforts to attend Hastings:

It is not mere eloquence, nor melodious utterance, nor logical force, nor imaginative capacity that bring great forensic successes. For want of a better term it is commonly said that lawyers who have won difficult jury cases are endowed with a mysterious attribute called personal magnetism. Now it is precisely this mysterious attribute, already well established as an adjunct to men's success at the bar that is objected to when women are in question. . . . [M]en are afraid of the competition. . . . In truth this kind of objection is too much of a piece with the staple arguments against woman suffrage, to the effect that women would be soiled and degraded by mixing in the filthy pool of politics.
Sacramento Record-Union, Feb. 26, 1879.

79 New Northwest, supra note 71.

80 A. BUCHANAN, DAVID S. TERRY OF CALIFORNIA 171 (1956); see also New Northwest, supra note 71 (Terry campaigning in Stockton the same night as Foltz describes the office seekers adjourning to hear the women). On Terry's friendship with Gordon and his role at the Convention, see infra text accompanying notes 121-24. "Judge David S. Terry of the Broderick duel, was the gallant knight of the Convention. He championed in his incomparable manner the resolution adopting [the anti-discrimination sections], (both of which were proposed [by Foltz]) . . . ." Struggles, supra note 4, Mar. 1917.

81 Justice Stephen Field, who earlier had served on the California Supreme Court with Terry, was the Justice whose bodyguard, David Neagle, shot Terry. See generally In re Neagle, 135 U.S. 1 (1890). For an account of the events that led to Terry's death, see C. SWISHER, STEPHEN J. FIELD, CRAFTSMAN OF THE LAW 74, 328-61 (1930); see infra text accompanying notes 205-06.
    Accounts of the life of Terry can be found in: A. BUCHANAN, supra note 80; O. SHUCK, supra note 36, at ch. 11; C. SWISHER, supra note 8, at 29; A. WAGSTAFF, THE LIFE OF DAVID S. TERRY (1892).

82 DEBATES, supra note 10, at 669 (Terry's introduction of section forbidding corporations to hire Chinese).
    Volney Howard, a Non-Partisan from Los Angeles, and Charles Ringgold, a Workingman from San Francisco, were two other Chivalry Democrats who played important parts in this story. See infra text accompanying notes 91, 143-44.

83 O. SHUCK, supra note 36, at 566-679.

Mr. Wilson enjoyed an enormous revenue from his regular practice. . . . He was attorney for a score of millionaires . . . . He also frequently appeared for the Central Pacific Railroad Company. . . . He was not strong in appealing to the feelings, the passions. . . . [He had a] capacity for investigation . . . . In court Mr. Wilson was of easy bearing, but not courtly. . . . He talked forcibly, but not finely. He was cool, clear, eminently practical, concise, cogent, logical.
Id. at 566. Wilson died in 1892 at the age of 69: "He was in his office at work on the day before and attended a meeting of the Bar Association in the evening." Id. at 569; see also T. BARNES, supra note 32, at 44-47; infra text accompanying note 84.

84 C. SWISHER, supra note 8, at 17, 33 (story of how Wilson prevented the Convention in 1876-77); DEBATES, supra note 10, at 56.

85 I. CROSS, supra note 8, at 110-20; I CROSS, FRANK RONEY, IRISH REBEL AND LABOR LEADER (1931); F. Fahey, supra note 8, at 194-201 (an excellent account of the split in the Workingmen's Party); A. SAXTON, supra note 8, at 39-45; R. Shaffer, Radicalism in California 1869-1929, at 18 (1962) (unpublished Ph.D. dissertation, University of California at Berkeley) (Roney was "the outstanding labor leader of California in the 19th century.").

86 By the Workingmen's Party official account, the reason Kearney decreed that officers and leaders should not run for delegate positions was his fear of men using the party to promote themselves, and not being accountable to the membership that elected them. J. STEDMAN & R. LEONARD, THE WORKINGMEN'S PARTY OF CALIFORNIA: AN EPITOME OF ITS RISE AND PROGRESS 78-86 (1878). A recent experience gave good reason for these fears. In a special election in 1878, the WPC had elected a state senator, J.W. Bones, in Alameda County who had turned on them once in office. I. CROSS, supra note 8, at 111, 113; A. SAXTON, supra note 8, at 121, 125.
    Saxton gives an elegant delineation of the schism between Kearney and Roney:

Here in abstract terms was the controversy of Rousseau and John Locke. Yet for the American West it held a very concrete meaning. . . . [L]arge segments of the western labor force were migratory, relatively unskilled, often unemployed. Suspicion of stabilized leadership would be immediate and extreme. Thus, the power struggle between Roney and Kearney became the opening round in a cycle of conflict which has characterized both radicalism and labor organization in the West. . . . [T]rade unionists and socialists have generally repeated Roney's script while the anarchists, the Wobblies, and nearly always the leaders of the unskilled and unemployed have repeated Kearney's.
Id. at 126. Other, less ideological formulations of the conflict include Kearney's desire to control the Convention delegates from the outside, and "possibly also . . . [Kearney's] shrewd realization . . . that he was not equipped for successful participation in a convention of this kind." C. SWISHER, supra note 8, at 31.
87 3 J. BRYCE, supra note 8, at 228 n.1 (Bryce acknowledged his debt to George's "brilliant" article); George, supra note 8, at 445; Nunis, supra note 18, at 283 (letter from Kearney to Bryce). Roney was even more critical of the Workingmen who were elected: "The worst brand of stand-pat, corporation ridden politician would have made a better showing than this primitive band of fake reformers." I. CROSS, supra note 8, at 313. Only Saxton, noting that "both George and Roney had reason for bitterness against the Workingmen's party and their judgment was perhaps unfair," seriously questions the general evaluation of the Workingmen delegates as incompetent. Rather, he suggests that they were ineffective and unmotivated toward radical change, perhaps inevitably so. A. SAXTON, supra note 8, at 130-32; see also Shumsky, San Francisco's Workingmen Respond to the Modern City, 55 CAL. HIST. Q. 46, 55 (1976) (implying that their inexperience made the delegates representative of the movement that elected them).
    Henry George ran as a Democrat for Convention delegate. He did seek the Workingmen's endorsement as well, but refused to take the oath they had devised in the wake of the party schism. George interpreted the oath as promising total subservience to the party; the Workingmen as only a guarantee of loyalty. H. GEORGE, JR., THE LIFE OF HENRY GEORGE 299-300 (1930). The oath included these promises: to "dissolve all affiliation with all other political parties"; to "work faithfully for the establishment and maintenance of good government through [the WPC]"; to "work and vote for the election to office of all persons of known honesty and integrity nominated by [the WPC]." J. STEDMAN & R. LEONARD, supra note 86, at 81.

88 WASP, Aug. 9, 1879, reprinted in The Workingmen's Party of California, 1877-1882, 55 CAL. HIST. Q. 58, 68 (1976) (collection of contemporary cartoons); 2 H. BANCROFT, POPULAR TRIBUNALS, supra note 8, at 742; Argonaut, Dec. 7, 1878, at 8 passim. References to the birthplaces of the Workingmen were common. See, e.g., Sacramento Record-Union, Sept. 28, 1878, at 4 ("raw immigrants or Americans who have been in our state only a year or two"); Alta, California, July 5, 1878 ("[t]rained bands of Hessians . . . alien adventurers").

89 D. WALDRON & T. VIVIAN, BIOGRAPHICAL SKETCHES OF THE DELEGATES TO THE CONVENTION TO FRAME A NEW CONSTITUTION FOR THE STATE OF CALIFORNIA 1878, at 60- 61; D. Moorhead, supra note 8, at 239-47 (including chart showing nativity of all delegates). Of the 28 foreign-born delegates, half had occupations that involved property, all were employed in gainful pursuits. None, according to Moorhead, was a "raw immigrant." All except for one German had been in the state for five years or more. The only two native-born Californians were also Workingmen. C. SWISHER, supra note 8, at 31. 4 T. HITTELL, supra note 8, at 625, lists Vacquerel as one of the leaders among the supporters of woman suffrage. See infra text accompanying notes 141-42, 205. George referred to Vacquerel as the one real radical among the Workingmen delegates, a "Parisian communist . . . but he exercised no influence." George, supra note 8, at 449.

90 Undoubtedly there were some Workingmen (and some other delegates as well), foreign and domestic, who simply did not have the wit or the experience to follow the proceedings, especially in their strategic dimensions. But the Workingmen held regular party caucuses and had active leadership to at least prevent anyone from being completely lost on the votes. C. SWISHER, supra note 8, at 32.
    "The adoption of this clause [the employment section], so valuable to women, was mainly accomplished by the skillful diplomacy of Hon. Charles S. Ringgold, delegate from San Francisco, who introduced it in the convention and worked faithfully for its adoption." 3 HISTORY OF WOMAN SUFFRAGE, supra note 55, at 760.

91 Ringgold was one of those elected as a result of Kearney's decree forbidding leaders from running. "The Delegate . . . considers his nomination due to making a successful effort, to prevent professional politicians from entering the Party. A representative man of the people, he will keep a strict watch on all important measures requiring his support, and endeavor to be honest and fair to all." D. WALDRON & T. VIVIAN, supra note 89, at 23; see also J. STEDMAN & R. LEONARD, supra note 86, at 80.

92 W. DAVIS, supra note 44, at 384-86; George, supra note 8, at 445-46. D. Moorhead, supra note 8, at 329, lists woman suffrage as a WPC demand. But though Workingmen were the major supporters of woman suffrage, I have not found any explicit reference to woman suffrage in any other party history. I. CROSS, supra note 8, at 115-16, compared the platform of the Roney faction to that of the Kearneyites, and found it "surprisingly radical. It declared that the increasing poverty of the workers resulted from monopoly of the soil; that hours of labor should be reduced as use of machinery increased; that wages should represent the product of labor; that acquisition of land should be limited; that taxation should be graded as to relieve the workers altogether; and that the principle of the referendum should be established."

93 San Francisco Chron., Jan. 24, 1878 (WPC leaders feared that if they lost the election the victors would impose property qualifications on suffrage greater than any could bear.). Josephine Wolcott wrote to Laura Gordon in July 1878 saying that the events of the last two years had made her abandon universal suffrage as a goal, and that she thought women would have a better chance for the vote if there were property, residence and educational qualifications. Letter from Josephine Wolcott to Laura Gordon (July 1878), contained in Gordon Papers, supra note 54.
    There were parties other than the WPC and the Non-Partisans in the field, but the election was mainly between these two forces. Eleven Republicans, ten Democrats and three Independents were elected under the old party labels. C. SWISHER, supra note 8, at 28. The Roney faction also fielded a ticket for the First District At-Large seats, but won none. See infra text accompanying notes 95-96.

94 C. SWISHER, supra note 8, at 24-28 (breaks down elected delegates by party and occupation); W. DAVIS, supra note 44, at 390-93 (list of delegates and their party, former political affiliation and occupation); D. Moorhead, supra note 8, at 240-43, 244-47 (list of delegates by nativity, date of arrival in California and occupations; list of delegates by city, party, former party, age and years in state); J. STEDMAN & R. LEONARD, supra note 86, at 88 (Workingmen delegates divided by San Francisco and "the interior" of California).

95 C. SWISHER, supra note 8, at 17, 27. Writing in 1930, Swisher interviewed a delegate to the Convention, Byron Waters, who had been elected as a young man. Waters was a conservative Non-Partisan lawyer, active in the Convention, and had been a member of the 1878 legislature as well. There he had been a major opponent of the Woman Lawyer's Bill. At the Convention, he voted against all suffrage measures. Babcock, supra note 9, at 689 n.82. He told Swisher that the at-large delegates were provided because "they would be conservative in their outlook, and would oppose the radical element." C. SWISHER, supra note 8, at 120 n.37.

96 Moorhead shows how close the votes were in the at-large races and points out that had the WPC won these seats they would have had "83 delegates to the Non-Partisans 46." D. Moorhead, supra note 8; see also W. DAVIS, supra note 44, at 390-92.
    In addition to the occupations listed in the text, there were many others, ranging from corporation president to tailor, that had a single delegate. C. SWISHER, supra note 8, at 24-28.

97 San Francisco Post, Nov. 11, 1878, at 2. The Post's Convention coverage was daily, and included more than a summary of the proceedings or even the detailed transcript of other journals. Under the name of "Vivat Respublica," the same writer described the off-floor lobbying, quarrels and alliances that helped make the Convention run. The paper was a Democratic organ and tended to be more anti-corporation and sympathetic to the aims of the WPC than most of the rest of the Northern California press.
    Farmers, for instance, were elected as Democrats, Republicans and Independents (Independents were a farmer's party), Non-Partisans and even a few Workingmen from the interior of California. Swisher and most other histories credit the farmers with the balance of power at the Convention. In particular, the Workingmen carried the day when they had the farmer's vote.

98 C. SWISHER, supra note 8, at 48; D. WALDRON & T. VIVIAN, supra note 89, at 99 (Ayers entry). Ayers had earlier been one of the founders of the Call newspaper in San Francisco, and had moved to Los Angeles in 1872. Id.; see supra note 29 and accompanying text.

99 Ayers received 40,597 votes while his opponent received 37,279 votes. D. Moorhead, supra note 8, at 215.

100 Letter from Clara Foltz to Laura Gordon (July 1878), contained in Gordon Papers, supra note 54.

101 Letter from Laura Gordon to Sarah Knox (July 1878) (hastily scribbled on the back of a ballot that shows her and David Terry's candidacy for delegate); Letter from Sarah Knox to Laura Gordon (July 1878); Letter from A.H. Eddy to Laura Gordon (July 1878). These letters are contained in the Gordon Papers, supra note 54.

102 See Obituary, supra note 54, at 1, cols. 2-3; Struggles, supra note 4, June 1917.

103 Woman at the Bar, The First Female Lawyer of the Pacific Coast, San Francisco Chron., Jan. 30, 1879, at 3 [hereinafter Woman at the Bar].

104 San Jose Weekly Mercury, Oct. 3, 1878, at 1.

105 Joseph Hoge was a Democrat, elected as a Non-Partisan. Sixty-five years old at the time of the Convention, he was an accomplished parliamentarian and earned the respect of most of the men at the Convention--as the tribute to him, and gift of 100 great books bound in leather on the last day, shows. See DEBATES, supra note 10, at 1525. Ayers remembered him as "springy and elastic, . . . at home with the exuberance of the younger members [,] . . . [without] superior in parliamentary knowledge [and] . . . thought by some to be 'czarish,' and disposed to crush . . . those who had the temerity to question his rulings." J. AYERS, supra note 1, at 308. Hoge had immigrated from Illinois where he had twice served in Congress, and where he and Wilson had been partners. O. SHUCK, supra note 36, at 565-66. He was also the first President of the San Francisco Bar and a founding Director of Hastings College of the Law. T. BARNES, supra note 32, at 44-45. Barnes writes that though active at the Convention, both Hoge and Wilson were "intimately and continuously involved in Hastings' direction during its first academic year." Id. at 46. In the same passage that she proclaimed David Terry the "gallant knight of the Convention," Clara Foltz said of Hoge: "He was opposed to women in public life, opposed to women in any place except possibly in their homes-- just as though every woman had a home then any more than she has now!" Struggles, supra note 4, Mar. 1917.
    Hoge was elected by one vote. After the Workingmen failed to garner enough votes for their candidate, Henry Larkin, they threw their votes to W.J. Tinnen, a Non-Partisan, but not the corporation candidate: That was Hoge and he won 74- 73. C. SWISHER, supra note 8, at 37.

106 3 HISTORY OF WOMAN SUFFRAGE, supra note 55, at 752 ("Mrs. Judge Shafter" was at one of the earliest meetings to organize a suffrage society in California.). One "Oscar" Shafter was a justice on the California Supreme Court from 1864 to 1867 and could have been the "Judge" in question, although this would leave unexplained James Shafter's ardent support of woman suffrage, at odds with his establishment positions on virtually every other issue at the Convention. James Shafter had, moreover, been a judge and was called by this honorific though this was many years before. D. WALDRON & T. VIVIAN, supra note 89, at 111.

107 As a member of the Assembly, McComas had played a major part in the debates over the Woman Lawyer's Bill. Babcock, supra note 9, at 693. For examples of woman suffrage petitions and resolutions, see DEBATES, supra note 10, at 81 (McFarland); id. at 89 (Rolfe); id. at 96 (Evey); id. at 97 (Grace); id. at 104 (Van Voorhies); id. at 110 (Blackmer); id. at 152 (McComas proposing that suffrage be made co-extensive with citizenship); id. at 376 (Shafter). The second person to introduce a woman suffrage petition, with 100 signatures, was H.C. Rolfe, one of the leaders of the woman suffrage efforts. 4 T. HITTELL, supra note 8, at 625. Elected as a Republican, from southern California, Rolfe had no visible connections to any external reason that would make him a woman suffragist.

108 Woman's Suffrage in Mayfield, San Jose Weekly Mercury, Dec. 18, 1879, at 2. This speech was on the eve of the first legislature to convene under the new constitution and the petition addressed it praying "that women may be granted the full exercise of the ballot." See infra text accompanying note 202. Many of the original petitions presented at the Constitutional Convention are on file with the Secretary of State, California Archives, Sacramento.

109 DEBATES, supra note 10, at 104, 1442. Van Voorhies voted regularly, and on the critical February 13 suffrage vote was in the women's camp. See infra text accompanying notes 157-65.

110 San Jose Mercury, Nov. 6, 1878, at 2 (reprinting a letter from Hamlet Davis of Truckee, a Workingmen's delegate). Davis also complimented the women's "energy and skill" and described their task as "herculean." Stedman was a native-born San Franciscan and at the time of the Convention he was an accountant in partnership with R.A. Leonard. These two became the historians of the Workingmen's movement. See supra note 86. At 69, Davis was one of the oldest delegates, a merchant from the interior of the state, and Stedman one of the youngest, 27, from San Francisco. Both were elected as Workingmen.

111 The repartee between Sarah Knox and John Stedman, and the other efforts of the women to influence the delegates, were not the sort of lobbying that the Workingmen tried to abolish altogether in the Constitution. In ill-drafted provisions that almost passed, all personal solicitation of legislators would have been a crime, even when not involving "bribery, promise of reward, intimidation or other dishonest means." DEBATES, supra note 10, at 143 (proposed amendment introduced by O'Sullivan).
    It is clear from the debates that even those with the broadest definitions of lobbying would not have included the women's activities, which they all saw as akin to petitioning. As Henry Larkin (Workingman from El Dorado) made explicit, the lobbying they were trying to eliminate was that done by the railroads particularly and the corporate interests generally. See DEBATES, supra note 10, at 1283 (Larkin); see also id. at 1281-84. See generally CAL. CONST. art. IV, ' 35 (1879, repealed in 1966) (current version at CAL. CONST. art. IV, ' 15) (inter alia, declaring lobbying a felony and defining lobbying as "seek [ing] to influence the vote of a member of the Legislature by bribery, promise of reward, intimidation, or any other dishonest means"). The first case decided under the old section was Foltz v. Cogswell, 86 Cal. 542 (1890), holding that a lawyer seeking favorable treatment for a client is not lobbying within the meaning of the constitution. The underlying action was Foltz's suit against a former client for a fee. Id.

112 Letter from Clara Foltz to Laura Gordon (Nov. 20, 1878), contained in Gordon Papers, supra note 54. Mrs. E.O. Smith was a suffragist. D.W. Herrington had been one of the three practitioners appointed by the court to examine Foltz's qualifications for the bar. Babcock, supra note 9, at 697.

113 The Committee on Right of Suffrage included the following members: J. Eagon, Non-Partisan, Lawyer; J. McCallum, Non-Partisan, Lawyer; J. Garvey, Democrat, Sheriff; J. Glascock, Non-Partisan, Farmer; W. Sweasey, Workingmen's Party, Farmer; E. Evey, Workingmen's Party, Farmer; J. Walker, Democrat, Physician; F.O. Townsend, Democrat, Farmer; N. Wyatt, Workingmen's Party, Lawyer; C. Cross, Workingmen's Party, Lawyer; and J. Caples, Non-Partisan, Farmer.
    Typically, there were relatively few Workingmen on important committees like this one. Moreover, none of the Workingmen on this Committee were from the San Francisco delegation. See DEBATES, supra note 10, at 63; W. DAVIS, supra note 44, at 390-92 (listing delegates, their present and past party affiliation and their occupations); D. Moorhead, supra note 8 (breakdown of occupations and party affiliations). Every was from Los Angeles and at 65 was one of the older men in the Convention, and had been a member of the Illinois Constitutional Convention in 1848. Wyatt was from Monterey, a hard-working lawyer by his account. Cross, from Nevada City, was also a lawyer. The fourth Workingmen's representative on the Committee was Sweasey, a farmer from Humboldt County, and a strong woman suffragist. D. WALDRON & T. VIVIAN, supra note 89 (individual entries for Evey, Wyatt, Cross and Sweasey); Cornford, The California Workingmen's Party in Humboldt County, 66 CAL. HIST. Q. 131, 139 (1987) (containing an account of Sweasey's politics).

114 According to one newspaper account:

The most interesting meeting of the evening was that held by the Committee on Suffrage, in the Assembly Chamber, when a number of woman suffragists addressed the Committee. The Chamber was filled, more than half the audience being ladies. Mrs. Dr. Carr, Miss Kellogg and Laura DeForce Gordon spoke . . . . All contended that women did desire the ballot, and if the Committee did not believe it, . . . they [should] remove her disabilities and see how they would flock around the polls.
San Francisco Chron., Oct. 30, 1878, at 2; see also DEBATES, supra note 10, at 450 (reference made several days later to woman suffrage meetings being held in the Assembly hall as an unusual and striking occurrence); 3 HISTORY OF WOMAN SUFFRAGE, supra note 55, at 759 (Gordon's lobbying from outset of Convention).

115 WASP, Nov. 2, 1878 (group picture on cover). The Wasp was an illustrated weekly magazine, published from 1876 until 1941. Its heyday, when it had the best writers and cartoonists, was from 1876 to 1894. K. JOHNSON, THE STING OF THE WASP (1967). Most people to whom I showed the cartoon saw the women as grotesque and unwomanly. Some, myself included, think that although the women are lampooned, they appear decent and orderly, especially in a small inset where they vote while men watch. A line of men sneers as they watch the women vote, but again nothing untoward is happening. The misshapen appearance of some of the suffragists could result from actual people being caricatured.
    The text inside treats the cover issue lightly by listing California's troubles of the last year, concluding: "Yet we never thought for one moment that the simplest remedy in the world would be to do simple justice and allow our female friends to vote at elections--for the best looking man." WASP, Nov. 2, 1878, at 2.
    The Wasp continued to recognize women's issues as important to the Convention, while taking the general position that the whole Convention was misguided. See, e.g., WASP, Feb. 15, 1878 (A two-page center spread showing "the constitutional pump" being worked by a man whose clothes are an amalgam of interest groups (Non-Partisans, WPC, Temperance Party, Republicans, Clergy and women suffragists). The pump is spewing forth measures including one labelled "Women's rights" in which the hook-nosed spinster-type hits a man over the head with an umbrella. The 1849 Constitution, depicted as a handsome woman, is being deluged and says "Help, I'm going down.").

116 At first the Committee voted to submit the issue of woman suffrage to the people at the same time as the ratification vote on the new constitution, but as a separate proposition. It then moved to the legislative proviso, which the Chronicle disapproved of saying the issue would "become a standing vexation" in the legislature.
We are of the opinion that a very large majority of the women of this State do not crave the right of suffrage and would vote against it if they had votes. But the minority is active, while the majority is a passive force.
San Francisco Chron., Nov. 10, 1878, at 4.

117 DEBATES, supra note 10, at 408 (Caples' minority report on suffrage).

118 Id. at 1007, 1367 (January and February debates respectively). Caught off-guard when woman suffrage arose again in February, Caples rather incoherently repeated many of his earlier examples. See infra text accompanying note 162.

119 Id. at 1009-10. Steele was elected as a Republican and Caples as a Non- Partisan Democrat. Steele's speech in which he answers all the objections to suffrage is a fine piece of rhetoric.

120 San Francisco Chron., Nov. 16, 1878, at 3; DEBATES, supra note 10, at 408 (Caples' report). Uniquely among the delegates, Caples had used the Convention handbook for an angry description of his "war a l'outrance" against the Kearneyites. D. WALDRON & T. VIVIAN, supra note 89, at 63.

121 Letter from David Terry to Laura Gordon (Nov. 20, 1878) (emphasis Terry's), contained in Gordon Papers, supra note 54. Terry had laid the groundwork for the debate by establishing that Caples intended to use his minority report on the Convention floor, where Gordon would have no opportunity to respond.

122 Argonaut, Dec. 7, 1878 (the day the corporations clause was passed). The corporations debate opened on November 13; on November 20, the date of Terry's letter to Gordon, Ayers had upped the ante by introducing a clause that strengthened the proposed railroad commission.
    C. SWISHER, supra note 8, at ch. IV (chapter IV is entitled "Corralling Corporations"), explains the varying motivations and machinations in this central debate. He lists the leaders of the conservative group as including McFarland, Barnes, S.M. Wilson, Shafter, Edgerton and Belcher. Id. at 59.
    "In opinions and temper Terry was a good deal like the Workingmen delegates, and having about ten times as much brains as the smartest among them, he soon became their actual though not their acknowledged leader." Oakland Enquirer, reprinted in A. BUCHANAN, supra note 80, at 187. On the relations between Terry and the Workingmen, see A. BUCHANAN, supra note 80, at 187-90; A. WAGSTAFF, supra note 81, at 254-55; see infra text accompanying notes 80-82.

123 On Terry's motives for writing the letter, no matter of principle was involved because Terry never felt strongly one way or the other about suffrage. (He found many other subjects more important.) He may have thought this a good chance to undermine Caples, or to support a Workingmen's objective without being identified with it. But as noted in the text, his main motivation was undoubtedly his friendship with Gordon. Letter from David Terry to Laura Gordon (Mar. 3, 1877), contained in Gordon Papers, supra note 54 (Terry sent Gordon news of her husband: "I had a good deal of talk with him about which I will tell you sometime.").

124 Apparently, Gordon issued one challenge; the newspapers mentioned it in December. See e.g., San Francisco Post, Dec. 9, 1878 ("Caples will stand a poor chance."). Tinkham relates that Terry became the leader of the "most rabid Chinese haters, anti-monopolists and anti-railroad men." As to Terry's motives, Tinkham said the best guess was his "hatred for corporations and his desire again to sit upon the supreme bench. As a leader on the working man's measures he believed he could command their votes." G. TINKHAM, supra note 8, at 228. A Wasp cartoon at the end of the Convention shows Terry and others being served up "offices" by a woman whose apron is labelled "the new constitution" while the Workingmen pound on the door that Volney Howard leans against solidly. Workingmen's Party of California 1877-1882, supra note 88, at 71 (cartoon collection).

125 Letter from Clara Foltz to Laura Gordon (Nov. 20, 1878), contained in Gordon Papers, supra note 54.

126 Though the Foltz-Gordon team had been apart over the last few months, their accomplishments continued in tandem. On the day the papers covered Gordon before the Committee, Clara Foltz appeared for the first time in the district court (her initial trials were in the lower Justice Courts). As with Gordon's performance, the audience was full and the reviews were complimentary. The Chronicle, for example, said of Foltz in court that she was "calm . . . dignified . . . clear . . . not in the least out of place." San Francisco Chron., Oct. 31, 1878, at 4.

127 See DEBATES, supra note 10, at 832-33.

128 The symbolism of language was a general interest of Blackmer's. Earlier when the proposed Declaration of Rights came to the floor he argued that the first clause should read "all persons" (rather than "all men") are by nature free and independent. DEBATES, supra note 10, at 232 (emphasis added). Blackmer pointed out that "person" was used in other parts of the Declaration of Rights and denied that the change would have any connection with woman suffrage, but would simply be "expressing precisely what we mean." Id. Blackmer wanted to remove the "male" word from the suffrage clause as well and though he did not speak against the legislative empowerment proviso, he clearly had reservations about it. Aside from the delay it would cause for woman suffrage, the proviso also trespassed on Blackmer's turf. He was the chairman of the committee in charge of proposing new procedures for amending the constitution and naturally against some hybrid that stood apart from the normal amendatory process.
    The issue for Blackmer was how the proposed proviso fit with the ordinary amendment process. It would allow a future legislature to remove disabilities in suffrage on account of sex; could yet another legislature, acting alone, renew them? In other words, would the legislative action under the proviso have the force of an amendment to the constitution? Blackmer's Committee proposed a new method, which would allow proposals to go to the people if two-thirds of both legislative houses proposed the amendment. The 1849 Constitution required a majority vote of two separate legislatures in succeeding years for a constitutional amendment. CAL. CONST. of 1849, art. X, ' 1.
    As Chairman, Blackmer argued that his proposal made the constitution easier to amend and would reduce the reliance of reformers on reaching the legislature. DEBATES, supra note 10, at 1276. The pro-constitution forces argued during the ratification campaign that the new clause accomplished its goal and that women should support it because it would make suffrage ultimately easier to obtain. See Sargent, supra note 8, at 22; infra text accompanying note 194. In 1911, during California's Progressive era, the present system was instituted which allows a popular vote on any amendment proposed by petition from eight percent of the voters at the last election. See Note, California's Constitutional Amendomania, 1 STAN. L. REV. 279, 281-82 (1949).
    Blackmer may have had yet another reason for objecting to the legislative proviso. It had originally been sent to the Committee on Future Amendments and he had referred it to the Committee on Suffrage. Had he guessed they might incorporate the proviso into their proposed clause, Blackmer might well have maintained it in his committee where he had on his side William P. Grace, another leading proponent of woman suffrage. See DEBATES, supra note 10, at 173.

129 Only seven of the 52 Workingmen delegates were previously Republican; only one of these (the lawyer Barbour) was among the San Francisco Workingmen's delegation. D. Moorhead, supra note 8; W. DAVIS, supra note 44, at 390-92; 3 J. BRYCE, supra note 8, at 378 (Bryce was speaking of the San Francisco support for the Workingmen's Party, though his reference to the "better sort" of Workingmen applies even more strongly to the delegates from outside of San Francisco.).
    Blackmer had immigrated from Massachusetts to Chicago where he had sold musical instruments until the great fire wiped out his stock in 1871. He then moved to California in 1873 and taught music in San Diego, opened another store and spent several years as county superintendent of schools. For biographical sketches of Blackmer, see entries in ILLUSTRATED HISTORY OF SOUTHERN CALIFORNIA 271 (1890); ILLUSTRATED FRATERNAL DIRECTORY 218 (Smythe ed. 1889), reprinted in HISTORY OF SAN DIEGO 656 (1916) (pictured as Supreme Representative from California to the Supreme Lodge of the Knights of Pythias).

130 D. WALDRON & T. VIVIAN, supra note 89, at 121.

131 DEBATES, supra note 10, at 832. Though he lamented his lack of preparation, Blackmer's first speech for suffrage reads better than his later more detailed and mechanical effort. I have supplied quotation marks for "the low green tent" line from John Greenleaf Whittier's Snowbound.

132 DEBATES, supra note 10, at 883. William Peyton Grace was one of the stalwarts for suffrage among the Workingmen and was a member of the San Francisco delegation. He was a "carpenter and architectural draughtsman" by trade and said he had "never advocated any violent measures" and would not be found "among the ranks of the unreasonable here." D. WALDRON & T. VIVIAN, supra note 89, at 67.

133 DEBATES, supra note 10, at 880. C.O. Finney, a Workingman-farmer, presented the resolution charging that a "hostile" legislature "so framed the calling act as to render impossible the completion" of the work. After the 100 days passed, the delegates were paid in script, which was never ultimately redeemed. Johnson, California's Constitution of 1879: An Unpaid Debt, 49 CAL. HIST. SOC'Y Q. 135, 136-37 (1970).

134 T. BARNES, supra note 32, at 18 (Founder Hastings speaking at the University of California graduation, June 1878).

135 Struggles, supra note 4, June 1917 ("But once my success began to be heralded by the gallant knights of the free and generous press of San Francisco, doors swung open to me, plates were laid at every function . . . .").

136 San Francisco Chron., Jan. 30, 1879, at 3.

137 DEBATES, supra note 10, at 1012. Lindow's broken English made him a figure of ridicule at the Convention. He was probably the subject of one of the most snobbish footnotes in recorded history, when Lord Bryce noted that "[a]n eminent lawyer, leader of the California bar," was discussing the clause prohibiting any "law impairing the obligation of contracts." There was an objection, and the lawyer "recognized in the objector a little upholsterer who used to do jobs about his house [who said] that he disapproved altogether of contracts because he thought work should be done by hiring workmen for the day." 3 J. BRYCE, supra note 8, at 238 n.1.
    Despite his difficulties of expression, Lindow represented the attitudes of some Workingmen (but not a majority of WPC members at the Convention) about woman suffrage: that the proper aspirational model was one of a woman protected in the domestic sphere rather than forced out to work or to vote.

138 DEBATES, supra note 10, at 1011-12. Wickes was a schoolteacher, a Democrat elected by the Workingmen. Originally from Maryland, he had come to California in 1852 to mine for gold. He maintained that the girls in his class were the equal of the boys and named many famous women whose sphere was unlimited: "Who fixed the sphere of Rosa Bonheur to put the landscape upon the canvas?" Id. at 1011. Referring to the Senator from California, Aaron Sargent, Wickes said:
[M]any men have risen to prominence on account of the judgment and instruction of their wives. I know a distinguished United States Senator now whose wife assists him in the preparation of his best speeches, and he is proud of her. He is in favor of woman suffrage.
Id. at 1012.
    Ringgold relied primarily on the Declaration of Independence by associating himself with the previous speech of William Grace, another Workingman. "[T]he whole human family" was created equal, and the "consent of the governed" did not mean the "consent of one half of mankind only." Id. at 1011; see supra note 132 (note on Grace).

139 DEBATES, supra note 10, at 242 (when "great charter of our liberties" language was under consideration).

140 For the Workingmen Party platform and discussion of inclusion of "great charter" language, see W. DAVIS, supra note 44, at 396-401; DEBATES, supra note 10, at 242 (remarks of Workingmen Delegate Patrick Dowling); C. SWISHER, supra note 8, at 93; Scheiber, supra note 15, at 74-78. Entirely open about his motives in opposing the proposed section of the Rights clause, Ringgold asserted that "[t]he doctrine of State sovereignty might as well be announced here as anywhere else." DEBATES, supra note 10, at 242. Ringgold had not only been a Copperhead Democrat, but had been twice arrested because of what he termed "[a] too freely expressed belief in State rights." His biographical sketch says that he was arrested first as an accessory in the fitting out of the schooner J.M. Chapman and later as a secessionist and Confederate officer. Both charges were dropped as unsubstantiated, but only the second was designated as "fanciful." D. WALDRON & T. VIVIAN, supra note 89, at 22-23.
    The saga of the schooner J.M. Chapman was this: It was purchased in 1863 with a letter of marque signed by Jefferson Davis and fitted with a cargo concealing a large quantity of weapons. The alleged plan was that it would privateer in the Pacific and collect gold and silver for the Confederacy. The J.M. Chapman was captured as it embarked on its maiden privateering voyage, and the capture and subsequent trials created a sensation in the state. R. CLELAND, A HISTORY OF CALIFORNIA: THE AMERICAN PERIOD 357 (1922); 4 Z. ELDREDGE, HISTORY OF CALIFORNIA 214-15 (1915).

141 DEBATES, supra note 10, at 1010. Alphonse Vacquerel, the Parisian who sought true freedom of speech in America, see supra text accompanying note 89, also gave a distinctive class twist to the debate when he objected:

Now sir, it has been said that only low class women would vote. I want to know what is the meaning of such a word. Because a woman is poor is she low? I hope, gentlemen, that you do not think that poverty is a crime. When I hold for the right of suffrage for women, I hold it for all women, rich or poor, in whatever class of society they belong.
Id. After all other woman suffrage efforts had failed at the January debates, Vacquerel sought a last amendment that also failed: "[W]henever the Courts shall grant to Mongolians the right of citizenship, the Legislature shall remove all disabilities from exercising the elective franchise on account of sex." Id. at 1018.
    At one point Vacquerel fell out with the WPC Convention caucus, but he continued to take WPC positions on the Convention floor, as in the woman suffrage debates. F. Fahey, supra note 8, at 240.
142 DEBATES, supra note 10, at 1012.

143 J. AYERS, supra note 1, at 308-09 (Howard was always "eagerly poring over rare tomes, or storing his mind with fresh knowledge from books of modern science and literature. It may be well imagined that such a man commanded the respect and admiration of his colleagues."); see also, e.g., 4 T. HITTELL, supra note 8, at 621 (another contemporary description of Howard: "a lawyer of ability and a man of intelligence and experience").

144 Howard had been a Southern statesman in fact, serving in the Texas Constitutional Convention and as U.S. Congressman from that state. D. WALDRON & T. VIVIAN, supra note 89, at 153. San Francisco Post, Nov. 26, 1878, printed a long admiring story of Howard -- ending by complimenting him on "the manners of a lamb, the claws of a lion."

145 DEBATES, supra note 10, at 1012; Struggles, supra note 4, Mar. 1918.

146 Woman at the Bar, supra note 103. The "Chief Justice" reference could only be to Terry because the current holder of that office was on the Hastings Board and thus a defendant in the suit, and the only other former chief justice to whom they might have had access, W.W. Cope, was also on the Hastings Board. The first chief justice had been the Hastings founder himself, Serranus Clinton Hastings. In chronological order the others were Henry A. Lyons, Hugh C. Murray, David S. Terry, Stephen J. Field, Silas W. Sanderson, John Currey, Lorenzo Sawyer, Augustus L. Rhodes, Toyal T. Sprague and William T. Wallace. J. JOHNSON, HISTORY OF THE SUPREME COURT JUSTICES OF CALIFORNIA, 1850-1900 (1963).

147 Foltz also signed her petition in pro per even though she had been admitted in Judge Morrison's court (after he had refused to accept her certificate of admission from the San Jose sister court). She may have been thinking ahead to the possibility of an appeal, and hoping to avoid taking the California Supreme Court bar examination. Ultimately, however, both Foltz and Gordon underwent the California Supreme Court examination; upon being admitted, Foltz then argued the Hastings appeal. Babcock, supra note 9, at 714.

148 The women sued the Hastings Board on which sat J.P. Hoge (President of the Board as well as the Constitutional Convention), Delos Lake (a former California Supreme Court Justice), J.R. Sharpstein (a future California Supreme Court Justice), and three others of the bar elite: Thomas Bishop, Thomas I. Bergin and O.P. Evans. See Babcock, supra note 9, at 709 & n.188.
    Foltz's papers are part of the Transcript on Appeal, Foltz v. Hoge, 54 Cal. 28 (1879); Gordon's are on file in the California State Archives, Sacramento, California.
    Letter from Laura Gordon to her parents (Feb. 6, 1879) (Gordon added: "be sure and send me some handkerchiefs and a change of underclothes by Trella [Foltz's oldest daughter, 13].").

149 Letter from Laura Gordon to her parents (Feb. 12, 1879). Other relevant parts of the letter for this story are:
My Darling Ma and Pa:
    Little Trella [Foltz's oldest daughter, 13] came home last night and brought me your good letter . . . was so glad to hear from you and get my clothes, I never needed clean clothes so much. . . . You will see by the papers that my application for writ of mandamus has been denied by the Supreme Court, but Mrs. Foltz's application to the lower court was granted and the writ is returnable Friday a.m. I want to be there with her, tho it is not at all probable they will come to trial. They intend to make us all the trouble and delay possible but I really believe we shall win in the end.
    See Letter from Laura Gordon to her parents (Feb. 6, 1879) (Gordon asked for clean clothes, a further indication that she had been staying in the city with Foltz for some time.).

150 Letter from Laura Gordon to her parents (Feb. 12, 1879).

151 Letter from Charles Ringgold to Laura Gordon (Jan. 30, 1879), contained in Gordon Papers, supra note 54. Ringgold writes in a beautiful hand, the effect only slightly marred by punctuation, spelling and grammar lapses. He closes: "Dear Madam I hope your success professionally and otherwise will keep pace with your corageous [sic] and meritorious efforts. Thanks for your kind invitation = [sic] I shall be pleased to call."

152 3 HISTORY OF WOMAN SUFFRAGE, supra note 55, at 759-60 ("Remembering the hard struggle by which the right to practice law had been secured to women and the danger of leaving it to the caprice of future legislatures, Mrs. Gordon drafted a clause which protects women in all lawful vocations, and by persistent effort succeeded in getting it inserted in the new constitution."). The WPC and the Grangers at the Convention were similarly determined to protect their reforms from the "caprice of future legislatures." C. SWISHER, supra note 8, at 96. The Convention proceedings are filled with direct references by members of all parties to the need to put specific provisions into organic law. Particularly interesting for our purposes are words delivered to great applause by David Terry. Referring to a clause to make corporation officers personally responsible for corporate fraud he said:

[T]he Constitution is the place to put it, where it cannot be amended or repealed at any time by a hasty Legislature. . . . I propose to put it here as a safeguard to the people. I propose to put it here where it cannot be amended or repealed, and let it stand for all time . . . .
    DEBATES, supra note 10, at 404. This desire to limit the realm of future legislative action by increasingly specific provisions was not unusual in 19th century constitutions, J. HURST, THE GROWTH OF AMERICAN LAW: THE LAW MAKERS (1950), though the effort in California produced Henry George's famous epigram denoting the 1879 Constitution a combination of "constitution, code, stump- speech, and mandamus." George, supra note 8, at 445-46.
153 Struggles, supra note 4, Mar. 1917; see supra text accompanying notes 121-22. Terry's modus operandi was generally one of great secrecy. He made a few powerful speeches, authored the resolution that would hold corporation directors personally responsible for fraud, and served responsibly on the judiciary committee, but otherwise Terry worked behind the scenes. See, e.g., DEBATES, supra note 10, at 396, 403-04, 808-09. By the end of January, he was seldom even on the Convention floor, though his name was often spoken by his Workingmen lieutenants. A. BUCHANAN, supra note 80, at 170-90; A. WAGSTAFF, supra note 81, at 242-79.

154 Letter from Charles Ringgold to Laura Gordon (Jan. 30, 1879), contained in Gordon Papers, supra note 54. The note's formal phrasing and its closing lines, "Allow me to subscribe myself/Yours truly/C.S. Ringgold," indicate the lack of familiarity between them. See supra note 151. Generally, but for their both being Democrats, there seems little in their lives before January 1879 that would have brought them together.
    In his letter to Gordon, Ringgold also said of the Convention: "It is running on imported propositions with a tendency to destroy rather than build." This is a reference to clauses of which Ringgold complained earlier that were taken from some Southern states' reconstruction constitutions, acknowledging the supremacy of the U.S. Constitution. See supra note 140.

155 L.A. Express, Jan. 8, 1879 (fears about turning off light and heat). The desire of most of the members for a constitution shows best in that all but a few (15 of 152) signed the final product. See infra note 190.

156 DEBATES, supra note 10, at 1525. Johnson was a Non-Partisan, formerly a Democrat, originally from Maryland. He had graduated in classics from Yale, taught "dead languages" at a military academy in Kentucky, studied law at Indiana University and ended up in Santa Rosa, California. D. WALDRON & T. VIVIAN, supra note 89, at 65.

157 The 90-day residency requirement in the district changed the previous condition of 30 days only. John Eagon, committee chair, said it was done to prevent "colonization of voters." "The corporations" would move a group of voters into a district for 30 days and then vote their paid lackeys into office. A Workingman argued that while this might happen in the country, it was not likely in the cities and would operate to disenfranchise working men who often moved about within the city following the availability of work.

158 San Francisco Post, Feb. 15, 1879; DEBATES, supra note 10, at 1364.

159 Finally, Ayers was an anti-Chinese zealot and may have thought it well to preserve the possibility of quickly enfranchising women if necessary. Although, while the Convention sat, both houses of Congress, had passed a bill restricting Chinese immigration, its outcome was still not certain in February, nor its impact if signed into law. All but two of the delegates had voted to send a memorial to Congress urging the passage of the bill. Only one man, Charles Stuart, spoke for the rights of Chinese immigrants. DEBATES, supra note 10, at 1238, 1385, 1403; 4 T. HITTELL, supra note 8, at 622-24 (discussing Stuart's courage). The passage of the anti-Chinese legislation may have cooled the interest of some delegates in granting women suffrage.

160 DEBATES, supra note 10, at 1365. The effort to cut off debate took the form of a motion calling for the previous question. This motion was not debatable and called for a vote on the underlying issue to which an amendment was offered. Throughout the Convention, there were objections voiced to the use of this device, though all factions employed it at one time or another. The leading proponents of woman suffrage "demanded the ayes and noes" on the question: these were Ayers, O'Sullivan, Steele, Wickes and Grace. Once debate was assured, Vacquerel in his opening remarks said: "[C]ertain gentlemen on this floor are in the habit of moving the previous question whenever the question before the Convention does not suit their views, although they will keep this body discussing for days when it is about their individuality or the interest of their little county . . . ." Id. The parliamentary device of moving the previous question was used finally to defeat woman suffrage. See infra text accompanying note 178.

161 DEBATES, supra note 10, at 1365-66.

162 Id. at 1367. O'Sullivan, a Workingman from the San Francisco delegation, not previously heard from on woman suffrage, also gave a stirring appeal to justice. Id. at 1366.

163 Id. at 1368 (ayes and noes demanded); San Francisco Post, Feb. 15, 1879 (remarks of commentator). The commentator noted that the women lost by only twelve votes. Another way to assess the closeness of the vote is to note that it may have come within ten votes of passage: Steele, one of the proponents, changed his vote to "no" in order to be eligible, according to parliamentary procedure, to move a reconsideration; Jacob Freud, a Workingman who personally favored woman suffrage but feared it would hurt the chances for ratification, did not vote. Ringgold tried to force him to take a stand under the Convention rules that required that those present vote. DEBATES, supra note 10, at 1368.

164 DEBATES, supra note 10, at 1370; San Francisco Post, Feb. 15, 1879.

165 DEBATES, supra note 10, at 1370; The Lady Lawyers, San Francisco Chron., Feb. 15, 1879, at 2. As the women had planned before, Laura Gordon sought to join the suit, which the judge allowed. The tone of the story about the continuance was a harbinger of the elaborate press coverage yet to come. Here is a sample:

Mrs. Foltz with yellow hair, crimped and plaited, and Mrs. Laura Deforce Gordon, with dark brown hair, in coke-upon-Lyttleton curls down her back, sat at the bar table, and the former evinced her knowledge of Court practice by answering "Ready." However, an aged masculine attorney asked the Court that the hearing of the motion go over till next Friday . . . .
Id.

166 DEBATES, supra note 10, at 1422 (later comment on Monday's proceedings: "this is but a faint outline of the scene"); id. at 1388-89 (Herrington's remarks and the response that Herrington had a grudge against the town because he had failed with the ladies there, on account of his ugliness).

167 Id. at 1389-90.

168 Id. at 1395. One of the sections that glided by, re-enacted from the 1849 Constitution, provided that the wife could keep her separate property. Id. at 1392. In the History of Woman Suffrage, Aaron Sargent, while deploring the 1879 Constitution generally and incorrectly ascribing the failure of suffrage to the abnormal times created by the "sand-lotters," described the liberality of the California Code on married women's property. 3 HISTORY OF WOMAN SUFFRAGE, supra note 55, at 760-61.

169 San Francisco Post, Feb. 18, 1879, at 2. Not only the Democratic and sometimes eccentric Post, but the staid Sacramento Record-Union thought the suffrage battle was not lost. It reported a series of meetings of the Sacramento women with a new respectful tone. "The promoters appear to think that it may yet be possible to induce the Convention to do justice to the suppressed sex in the new constitution . . . ." After noting the "absence of the too frequent rant and denunciation," the reporter said the meeting was "a dignified assemblage of citizens who earnestly and quietly expressed their intention of using all legitimate means to secure to themselves a voice in the government of the country." Sacramento Record-Union, Feb. 20, 1879, at 1.

170 Sacramento Record-Union, Feb. 19, 1879 (Mrs. Waterhouse hoped the next meeting would be in the Senate chamber and Mrs. Gordon and Mrs. Foltz asked to speak. Mrs. G.W. Towle said it would be "undignified" to go to the capitol in a body. "Now is the time for women to work within their homes."). As the week progressed, however, the women grew bolder about approaching delegates directly. See infra note 171.
    The Record-Union was one of the most ably edited in the state, was generally conservative and was thought to be a Southern Pacific organ. But early on, it took a position for woman suffrage as a matter of simple justice. See, e.g., Sacramento Record-Union, Dec. 28, 1879, at 2 (First the writer says the Convention "seems afraid" of woman suffrage. "It is getting late in the day to laugh down the issue . . . . It is also getting late for the . . . sentimental dodge, which consists in asking whether you are prepared to have the sanctuary of the domestic circle polluted and the sacred sphere of woman invaded, and her glory quenched in the filthy pool of politics, and so forth and so on.").
    Earlier the paper had supported the Woman Lawyer's Bill and was decidedly on the women's side in the Hastings suit. Babcock, supra note 9, at 689 n.83. When the Sacramento women lost, however, the Record-Union encouraged them to use their influence to defeat ratification. It is hard to believe, but possible, the editors were so machiavellian as to intend that the women lose, and then turn them to the anti-ratification effort. See infra text accompanying note 194.

171 DEBATES, supra note 10, at 1441 (debates of February 21, 1879). See generally Sacramento Record-Union, Feb. 21-23, 1879 (stories describing the canvass for signatures and the women's meeting). On February 21, a motion carried for the women to make "direct application" to the delegates who had voted against leaving equal suffrage optional with the legislature. Twenty-four ladies then arose and agreed personally to solicit delegates. The words of the petition modestly requested "such provision in the new Constitution as will tend to secure to the women of the land a voice in the government of the country, by affording them the opportunity to exercise the right of suffrage." DEBATES, supra note 10, at 1441.

172 DEBATES, supra note 10, at 1424.

173 For a detailed account of the arguments on both sides, see Babcock, supra note 9, at 708-12.

174 San Francisco Chron., Feb. 25, 1879; San Francisco Call, Feb. 25, 1879; Daily Alta, Feb. 25, 1879, at 1. The Sacramento Record-Union, Feb. 26, 1879, had a lengthy editorial on the argument, and compared the opposition to women being lawyers to the arguments against suffrage as well as chiding the establishment bar on their fear of competition. The writer added: "What counsel meant by saying that women were unfitted for the rough and tumble of legal disputes is somewhat obscure. We should have supposed that wherever the law is practiced after civilized methods and by educated men, the amenities of life would be preserved . . . ."

175 V. STADTMAN, THE UNIVERSITY OF CALIFORNIA, 1868-1968, at 81-83 (1970) (details the battle and its genesis); DEBATES, supra note 10, at 1476- 77.

176 DEBATES, supra note 10, at 1476. The connection between the Hastings suit and the education clause was clear to contemporaries. "The agitation of the question of the admission of women to the Law College, which began during the session of the convention, led that body to incorporate [the women's education section]." 3 HISTORY OF WOMAN SUFFRAGE, supra note 55, at 759.

177 DEBATES, supra note 10, at 1476. One index to the support of a measure at the Convention is the party of the delegates who demanded a record of the vote. On the women's education section, Workingmen, who had been the mainstays of the suffrage debate, were the ones who demanded the count of "ayes and noes": Walker, O'Sullivan, Grace, West and Herrington. Caples and another nemesis on woman suffrage, Byron Waters, were among the twenty who voted against the education amendment.
    "The sentence [women's education section] nevertheless pleased the delegates who wanted to do something for the ladies. It also made it possible for a disgruntled delegate to say: 'The section is not viewed with much favor. Its adoption was secured not on its merits, but by an alliance between its supporters and the advocates of women's suffrage."' V. STADTMAN, supra note 175, at 83.

178 This was the same Murphy who the year before had been a main opponent in the Assembly of the Woman Lawyer's Bill. Babcock, supra note 9, at 692 n.103. He had been elected to the Convention as a Non-Partisan, formerly a "staunch Democrat." D. WALDRON & T. VIVIAN, supra note 89, at 110. Only 32 years old, Murphy was a lawyer, had been thrice elected district attorney of his county, and had served in the Assembly three times. He was known as a "forcible speaker" and an accomplished parliamentarian, and described as: "Tall," "robust," "florid complexion," "intelligent and gentlemanly," "rather jovial" and "ambitious as Caesar." MOHAN, CLOUGH & COSGROVE, PEN PORTRAITS OF OUR REPRESENTATIVE MEN 69 (1880) [hereinafter PEN PORTRAITS].

179 San Francisco Post, Feb. 28, 1879. In the writer's opinion, the Workingmen "were quite right in entertaining those fears, for the anti-monopoly non-partisans have gone back upon the Workingmen whenever an opportunity is offered. I trust that the ladies will be content for the present. A thorough defeat is better than an empty compromise." Id.

180 Sacramento Record-Union, Feb. 28, 1879, at 2, reprinted in DEBATES, supra note 10, at 1494 (The editorial was reprinted in the Convention debates when Murphy rose to a point of personal privilege and sought ineffectually to refute it.). The paper had been quite bruising about the way that Murphy treated the women, but it was an ugly scene to cut off debate when the women were there and had gathered more than 1,000 signatures on petitions in less than a week.

[C]ommon courtesy would have demanded a respectful hearing . . . . This Murphy has distinguished himself by similar acts, during such part of the session as he has been present . . . . Apparently incapable of originating an idea himself; neither a speaker, a thinker, nor a worker; an absentee during about half the session, and doing nothing useful when present, he has learned just enough . . . to enable him to move the previous questions, and he has done this . . . when to do it was little short of an outrage.
Id.

181 Letter from Charles Ringgold to Laura Gordon (Feb. 28, 1879), contained in Gordon Papers, supra note 54. He closes their partnership with these words: "My dear Madam hoping you will live to enjoy many years of political equality and social happiness, consider your correspondent ever your humble servant." He enclosed a page of the Convention proceedings showing the ayes and noes on debate closure and on the final male suffrage article.

182 San Francisco Chron., Mar. 6, 1879, at 3. Judge Morrison's opinion was issued on March 5. Morrison does not have the exact wording of the clause, but says: "The new State Constitution which is to be submitted to the people for ratification, contains a clause that no person on account of sex shall be disqualified from entering any profession or occupation."

183 Struggles, supra note 4, Nov. 1916; New Northwest, Mar. 20, 1879, at 2.

184 Judge Hastings spoke to a reporter from the Chronicle on the day the opinion came down: "He had first concluded to admit [the women], and then by advice of the Directors, . . . had withdrawn permission . . . . It was his opinion that under the law . . . ladies could be admitted . . . and that an appeal would not be sustained. San Francisco Chron., Mar. 6, 1879, at 3.
    Robert Francis Morrison (1826-1887) was originally from Illinois, and had read law there, and attended several terms at Harvard Law School. He came to California around 1850, and had practiced alone and with Delos Lake and others until he was elected Judge of the Fourth District (San Francisco) in 1869. He was a Chivalry Democrat, having run on "the southern ticket" for the State Senate in 1859. At the elections held pursuant to the new constitution, Morrison was elected on the Democratic and Workingmen's Party ticket for Chief Justice of the California Supreme Court. In a final touch to the interconnections of this story, in 1886 David Terry instigated an investigation into the fitness of Morrison, who had suffered a stroke, and another Justice, also in ill health. Many leaders of the bar testified about their experience with Morrison, with only Terry and a few others maintaining his lack of fitness. 8 J. SENATE & ASSEMBLY app. (1887) (27th session); Robert Francis Morrison, 35 J. ST. B. CAL. 701 (1958); San Francisco Call, Mar. 4, 1887 (obituary of Morrison); San Francisco Post, Mar. 4, 1887 (obituary of Morrison).

185 Letter from Clara Foltz to Laura Gordon (May 6), contained in Gordon Papers, supra note 54 (no year is given on the letter but internal evidence suggests 1879); Struggles, supra note 4, May 1917 (Trella reference).

186 Foltz v. Foltz (1879) (unpublished case available in the Superior Court Archives, San Jose, California); Babcock, supra note 4, at 131-40 (Foltz's marriage and divorce examined).

187 San Francisco Examiner, May 5, 1879, at 1; San Francisco Call, May 4, 1879, at 1 (rally advertisement); San Francisco Examiner, May 3, 1879, at 1 (rally advertisement).

188 San Francisco Call, May 5, 1879, at 1 (6,000 persons at Platts Hall rally); Los Angeles Express, May 5, 1879, at 2 (25,000 persons at open-air meeting); W. BEAN & J. RAWLS, supra note 8, at 183 (electoral statistics).

189 The provision for sending a copy to every registered voter in the state was included in Article XXII, a housekeeping provision of the document itself. DEBATES, supra note 10, at 1520; J. AYERS, supra note 1, at 307. The pamphlet with the constitution printed in full also contained an address to the people from the delegates urging ratification. Most newspapers printed both the text of the constitution and the address to the people.

190 Only fifteen delegates voted no on the new constitution, with two noes paired with ayes and 16 absent. None of the Workingmen, and very few of the older conservative lawyers, were among the noes. DEBATES, supra note 10, at 1521; C. SWISHER, supra note 8, at 100-13. Ayers' paper, the Los Angeles Express, ran, virtually daily, long stories about pro-ratification rallies, as well as articles and letters in support of the new constitution. See, e.g., Los Angeles Express, Apr. 3, 1879, at 2 ("extraordinary" opposition due to article curbing corporations); Los Angeles Express, Apr. 19, 1879, at 2 (story of "an immense mass of people" assembled in Los Angeles "to hear Judge Terry expound the new Constitution"); Los Angeles Express, May 2, 1879, at 3 (rally of 2,000 persons at which Ayers spoke and ridiculed delegates who opposed the Constitution); Los Angeles Express, May 5, 1879, at 2 (very long account of rally at which J.P. West spoke; also tells of 25,000 persons at a San Francisco rally where Terry spoke).

191 Los Angeles Express, Apr. 7, 1879, at 2. Ayers maintained a continuous attack on the methods of the "monopolists." See, e.g., Los Angeles Express, Mar. 25, 1879; Los Angeles Express, Apr. 3, 1879, at 2 ("Men are attacked in their business and threatened in their credit if they dare show manhood and independence and even clerks and employees are bulldozed into seeming acquiescence."); George, supra note 8, at 446.

192 Hall, The San Francisco Chronicle: Its Fight for the 1879 Constitution, 46 JOURNALISM Q. 505 (1969); see San Francisco Chron., Apr. 13, 1879 (Terry's speech); San Francisco Chron., May 6, 1879 (Terry's speech rendered in other languages); C. SWISHER, supra note 8, at 18-19, 104-05. The Chronicle had been an early supporter of Kearney's. Contemporaries believed the swift rise of the WPC was due to the paper's coverage and support. George, supra note 8, at 439-40; 3 J. BRYCE, supra note 8, at 232; F. Fahey, supra note 8, at 94-111 (details Kearney's relationship with the Chronicle which was largely one of successful mutual manipulation).

193 San Francisco Post, Mar. 10, 1879, at 3. A few days earlier, the Chronicle had reported on "a movement . . . at Sacramento for holding a mass meeting of women to protest against the adoption of the new constitution." San Francisco Chron., Mar. 8, 1879, at 3.

194 Los Angeles Express, Mar. 24, 1879, at 2 (article quotes verbatim from the Sacramento Record-Union). Whether the Express or the Record-Union was right on the ease of constitutional amendment is difficult to say. The new constitution would allow proposed amendments to go to the people if two-thirds of both legislative houses proposed them. The 1849 Constitution required a majority vote of two separate legislatures in succeeding years for a constitutional amendment. CAL. CONST. of 1849, art. X, ' 1. Arguments could be made that either is a harder (or easier) process. The pro-constitution forces argued during the ratification campaign that the new clause was intended to make amendment easier, and therefore would make woman suffrage easier to accomplish. Sargent, supra note 8, at 22. In 1911, during California's Progressive era, the present system was instituted which allows a popular vote on any amendment proposed by petition from eight percent of the voters at the last election. See Note, supra note 128.

195 San Francisco Chron., Apr. 15, 1879, at 2. Under the headline, "A Constitution that Enlarges Their Privileges," the article assures women that "though not to the extent desired by the advance guard of the women's rights class," the new constitution gives women many advantages over the old. It concludes with a plea for all women to use their influence on behalf of their working sisters who are being driven out by the "dirty coolie slave, owned and hired out by a Chinese master, under secret, illegal, but unprovable contract." Id.

196 In one of her court appearances, "several of our most prominent attorneys . . . warmly congratulated her upon the success of her late war against the old fogeyism and narrow-mindedness of the Trustees of the Hastings Law School." San Jose Mercury, Mar. 8, 1879, at 3; see also THE BAY OF SAN FRANCISCO 670 (1892).

197 Quoted in New Northwest, Aug. 1, 1879, at 2.

198 Letter from San Jose, New Northwest, Sept. 4, 1879 (At this time Foltz had been admitted to the bar almost exactly one year.); San Francisco Call, Sept. 18, 1879; 3 HISTORY OF WOMAN SUFFRAGE, supra note 55, at 760 (Foltz & Gordon chief officers of Woman Suffrage Association).

199 E. SANDMEYER, supra note 27, at 62-63; 5 J. SENATE & ASSEMBLY app. (1880) (Documents 19 & 20). Sandmeyer says that friends of the Chinese claimed the vote was not a fair test because only "Against Chinese Immigration" actually appeared on the ballot. To vote "For," the elector had to scratch out one word and pen in the other. E. SANDMEYER, supra note 27, at 62-63.

200 They elected as well Robert Morrison, the judge in the Hastings case, to be the new chief of the California Supreme Court. See supra note 184.

201 San Jose Weekly Mercury, Sept. 11, 1879, at 2 ("It is a strange inconsistency that she should be permitted to hold an elective office and not be allowed [to be] an elector. . . . Mrs. Foltz is just the one to undertake advocacy of this kind . . . ."); New Northwest, Oct. 9, 1879, at 2 (Foltz is preparing a bill for the next legislature.).

202 Woman's Journal, Dec. 6, 1879, at 388 (reprinting petition addressed to the "Honorable Senate and Assembly of the State of California").

203 Woman as Constitutional Lawyer Next Step: Mrs. Clara Shortridge Foltz Hopes for Future, San Francisco Chron., Aug. 9, 1922.

204 During the Convention, Congress had enacted a bill which abrogated the Burlingame treaty giving the Chinese a right to free immigration. See supra note 159. President Hayes vetoed this measure, but in 1882, after some backing and filling, Congress again enacted a Chinese exclusion act, which was extended for many years. For the politics of the Chinese exclusion act, see A. SAXTON, supra note 8, at 178; and W. BEAN & J. RAWLS, supra note 8, at 184 ("it became clear that [California's] electoral votes, along with those of Washington and Oregon, could swing the presidency to the party that made the strongest promises to exclude the Chinese").
    Denis Kearney wrote to James Bryce of the decline of the Workingmen's Party: "I stopped agitating after having shown the People their immense power and how it could be used. The Chinese question was also in a far way of being solved." Nunis, supra note 18, at 284 (quoting J. BRYCE, THE AMERICAN COMMONWEALTH 388 (rev. ed.; New York, 1889)). "[The movement] stopped when I stopped, that was after accomplishing what we desired." Id. at 286.

205 Argonaut, Mar. 1, 1879, at 1.

206 When they married, Terry was 62 and Althea Hill almost 30 years younger. See supra note 81 (sources cited therein).

207 See supra text accompanying note 23 and sources cited supra note 98 (Ayers); supra note 83 and accompanying text (Wilson); supra text accompanying note 38 (Knox-Goodrich).

208 4 T. HITTELL, supra note 8, at 678; San Francisco Examiner, Mar. 20, 1880, at 1; Sarah Knox-Goodrich, Annual Meeting, American Women Suffrage Association: California Report, Dec. 25, 1880, at 410, col. 5.

209 As the legislature elected to implement (or dismantle, depending on one's politics) the new constitution, the 1880 session is of great historical interest. Only extreme self-restraint has kept the account to a few paragraphs. As with the rest of the story, newspapers are the major source. The San Francisco papers, the Alta, Call, Chronicle and Examiner covered the woman suffrage debates fully. Another very helpful source on the participants is PEN PORTRAITS, supra note 178.
    Foltz's remark about the black book of opponents, maintained "in case they ever come up for office again," was reported in the San Francisco Chronicle, Sept. 9, 1880, at 1 (reporting the annual meeting of the State Equal Suffrage Association).
    A couple of the warmest advocates of the Woman Lawyer's Bill in 1878, William B. May and Grove L. Johnson, were re-elected to this legislature and logically extended their arguments to suffrage. See Babcock, supra note 9, at 689-94 (Johnson was re-elected to the Assembly in 1878 and to the Senate in 1880). May "cited the success of women in the medical profession as one reason for his support of the Bill." Id. at 692 n.99 (citation omitted).
    The newspapers treated Assembly passage as the key to success, and assumed the Senate would follow its course. See, e.g., San Francisco Alta, Mar. 16, 1880, at 1.

210 Sketchbook of the 1880 California Legislature (available Bancroft Library, University of California at Berkeley). As another indication of Foltz's strong presence, the account of a speech by one opponent is followed by the observation: "The frowning gaze of Miss Gordon, and the dignified but cold, sarcastic glance of Mrs. Foltz will haunt him to his grave . . . ." San Francisco Examiner, Mar. 20, 1880, at 2.
    Foltz submitted the same brief (with only minor editorial changes) to the legislature of 1883 (available at Huntington Library, San Merino, California (Pamphlets, v. 126, 1880 brief), California State Library, Sacramento, California (1883 brief)). The brief argues basically that the new constitution specifically lists those categories of persons who may not be voters (e.g., Chinese persons, insane and incompetent persons) thus leaving other classes of potential voters to legislative discretion. This is the same argument that won the right for women to practice law in Indiana. In re Leach, 134 Ind. 665, 670 (1893).
    As the Chronicle pointed out, it was difficult to argue that woman suffrage, even limited to school matters, could be accomplished by the legislature alone, especially given the repetition three times in Article II (suffrage) of the word "male." San Francisco Chron., Jan. 20, 1880, at 2.
    Another argument advanced (but not by Foltz in her brief at least) for suffrage was based on Section 21 of Article I (the Bill of Rights). It forbids the granting of privileges or immunities to any citizen or class of citizens, except on the same terms as all other citizens. San Francisco Alta, Mar. 20, 1880, at 1 (account of the debate of March 19 in which several proponents of woman suffrage made this argument); see also 3 HISTORY OF WOMAN SUFFRAGE, supra note 55, at 759 ("a section in the bill of rights, together with other provisions in the new constitution, renders it quite probable that the legislature has the right to enfranchise women").
    Finally, some woman suffrage supporters tried to enlist section 18 of the Miscellaneous Subjects article to argue that the right to vote for office- holders followed from the right to hold office guaranteed against discrimination on account of sex. San Francisco Chron., Mar. 7, 1880 (reporting Equal Rights Party meeting).

211 The three evenings that woman suffrage was debated were March 11, 19 and 24 in 1880. The newspapers carried detailed stories of the debates on the following day. The women spoke on the first night. Of Madge Morris, who will appear again in Foltz's story, 3 HISTORY OF WOMAN SUFFRAGE, supra note 55, in 1881, it was said that she had made "a place for herself in light literature."

212 M. MORRIS, THE LURE OF THE DESERT AND OTHER POEMS 90 (1917) (poem entitled "To Clara Shortridge Foltz"). (From internal evidence in other stanzas about the age of her children, as well as the poem's quotation as early as 1883, it seems clearly to refer to the 1880 legislature.).

213 Sonnet, supra note 57.

214 E. DUBOIS, supra note 41, at 46-47, eloquently summarizes the larger messages of the women suffragists:

[W]oman suffrage constituted a serious challenge to the masculine monopoly of the public sphere. . . . [T]he prospect of enfranchisement was uniquely able to touch all women, offering them a public role and a relation to the community unmediated by husband or children. . . . [T]he suffrage demand . . . carried its implications into the family as well . . . and raised the specter of sexual equality there.
215 Zilfa Estcourt, Ladies of the Law, San Francisco Chron., July 2, 1939, at 5 (The writer described the women lawyers attending an American Bar Association meeting and recalled an interview with Foltz in 1933, a year before her death.)

216 See J. HURST, supra note 152 (After 1830, state constitutions filled with increasing amounts of specific legislation. Often these enactments were the products of interest-group conflicts.); Dodd, The Function of a State Constitution, 30 POL. SCI. Q. 201 (1915); M. Kellor, The Politics of State Constitutional Revision, 1820-1930, in THE CONSTITUTIONAL CONVENTION AS AN AMENDING DEVICE 67, 75-77 (K. Hall, H. Hyman, L. Sigal eds. 1981); Crain & Tollison, Constitutional Change in an Interest-Group Perspective, 8 J. LEGAL STUD. 165 (1979); Scheiber, Book Review, 23 STAN. L. REV. 1029 (1971) (Model of policy development portrays coalitional groups "organizing on the basis of collective self-interest, variously defined as regional or local, functional, ideological, or narrowly political.").
    Documents formed under these group pressures tended less toward broad pronouncements and more toward specific, virtually legislative, responses--the women's anti-discrimination sections are a good example.

217 A Test Case, San Francisco Call, Feb. 19, 1880, at 1. The court recognized the question in Brewer's case as novel and convened all the trial court judges to hear it, noting that the women's employment section "exists in no other Constitution but that of California." Alexander Campbell, a delegate to the Convention, was called to explain the section's intent. He said it was to "place women on a perfect equality with men in all avocations in life." Campbell also noted that if dance houses and dives were unlawful, they should be prohibited to both men and women. If not, both sexes should be able to work there. Then the court turned to Laura Gordon, "a member of the bar who was present and the lady made an address that was applauded." She said the purpose of the new section was to guarantee women all rights possessed by men. The court held the dive ordinance unconstitutional. A year later, the California Supreme Court mirrored this opinion in the case of a barmaid. In re Mary McGuire, 57 Cal. 604 (1881).

218 DEBATES, supra note 10, at 1012 (Non-Partisan Filcher, a newspaperman from Placer County, quoting an extract from the Indianapolis Journal of the views of S.H. Winsor). He added that "this same lady and a school teacher . . . in their buggies [drove] colored men and women, and even known harlots to and from the polls." Id. The Wyoming experience was contested in the papers with suffragists offering evidence of great regularity and beneficial effect when women voted. See, e.g., How Women Vote, San Francisco Chron., Dec. 28, 1878, at 4 (Mrs. Matilda Hindman claims woman suffrage a success in Wyoming: "men do not spit on the sidewalk along which woman voters pass . . . mothers trundle their baby carriages up to the polling places."). Steele (a proponent of woman suffrage) took up Hindman's testimony about Wyoming, DEBATES, supra note 10, at 1015-16, as Blackmer also did earlier. Id. at 1005.
    When she first started lecturing on suffrage, Clara Foltz had written to the Chief Justice of the Wyoming Territory to inquire how it worked. He replied that the "experiment had been too brief" to say whether "we have elevated society to a higher plane," but added:

Our best and most prominent ladies go to the polls, and carry with them the elevating atmosphere and influence which surrounds them everywhere . . . . [Woman suffrage] is slowly lifting us to a better and purer condition of public morality. The great wrong and injustice of class legislation, of disfranchising one-half and clearly the best half of all the citizens, is no longer working out upon us its inevitable evils.
San Jose Weekly Mercury, Apr. 5, 1877, at 2. Eli Blackmer, in arguing for woman suffrage, also quoted from Chief Justice Kingman in an 1872 letter. DEBATES, supra note 10, at 1005.

219 3 HISTORY OF WOMAN SUFFRAGE, supra note 55 (epigram of E. DUBOIS, supra note 41). (Stanton quote). Thomas McFarland, one of the main suffrage proponents at the Convention, said of Elizabeth Cady Stanton's lobbying:

Is there any right, or justice, or decency, in a law which gives the elective franchise to the most ignorant, debased, and brutal man in the land, whether born here or abroad, and denies it to Mrs. Stanton, a cultivated and intellectual woman, descended from revolutionary forefathers, and able to go before a committee of the United States Senate and make an argument on constitutional law that would have done credit to any gentleman on this floor or in this nation?
DEBATES, supra note 10, at 1004; Sacramento Record-Union, Feb. 26, 1879, at 2.

 


Copyright 1991 by the Trustees of Indiana University; Barbara Allen Babcock


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