History of Nevada/Native American, Spanish and Mexican Alta California-Nevada (to 1848)

Spanish GovernanceEdit

Alta CaliforniaEdit

Alta California Territory

Nevada was originally part of a Spanish territory known as Alta California that came about as part of Spain’s colonization of North America. This territory included land north of modern San Diego, and was established initially as a way to prevent Russian, English, and French settlement and economic exploitation in the area. There was a worry among the Spanish that something as simple as foreign scouts could be the precursor to an attempt at taking over their territories. Even two American traders, Jean Chapuis and Louis Feuilli, who mistakenly arrived on the outskirts of New Mexico in 1752 were regarded with great caution by Spanish authorities. However, as the need for funding grew, the Spanish King Carlos I, gave control of the lands to the Franciscan College of San Fernando, after expelling the Jesuits, in an effort to claim the land inexpensively for Spain. The Franciscans established very successful religious missions throughout Alta California. From 1769-1823 there were a total of 21 missions. along the coast of Alta California and, as time progressed they developed into modern day metropolises. Their religious missions were immensely important to Spanish control in the area. From this point forward, the assimilation of Native populations was just as important as other, secular activities to the Spanish explorers and settlers.

Spanish exploration into modern Nevada occurred from the seventeenth century through to Mexican independence in 1821. However, throughout most Spanish rule over the lands of Alta California, there was very limited exploration and settlement in modern Nevada. One of the earliest documented attempts to explore the land that has become the state Nevada was by way of the Spanish Coronado expedition in 1540. Originating in Mexico, a party from the expedition attempted to move north-west through Arizona towards Nevada but was blocked by the Grand Canyon. Immense physical barriers such as the Grand Canyon and deserts strongly discouraged early exploration into the region that is now called Nevada and eastern California. A perceived lack of valuable resources and navigable water routes prevented many Spanish, and later Mexican, explorers from heading north-west of Arizona and into Nevada. Due to the aforementioned circumstances, much confusion persisted about the exact geographic makeup of the land to the north-west of New Mexico beyond the midpoint of the eighteenth century. In 1750, Vélez Cachupín, the Spanish Governor of New Mexico at the time, said that it was believed the Pacific Ocean was not far from New Mexico. The belief that the ocean was near enough to support New Mexico was a common idea until at least 1775. The land that has become Nevada was not widely recognised to even have existed until after this time.

Native Americans in Spanish Alta CaliforniaEdit

Before and after 1848, the Euro-American emigrants traveling to and through Nevada played a very important part in the complex equation of culture contact, subsistence resources, technology, and social organization. This would go on to shape the customs and society of the Native American groups such as the Northern Paiute, Western Shoshone, and Southern Paiute. Before 1827 the Sierra was occupied only by Native Americans, but by 1897 due to the expansion of American settlers, the economies and cultures of the indigenous population had been displaced, and the people themselves losing their traditional way of life. Agricultural practices from settlers in nearby cities caused detrimental ecological effects to Native American hunting grounds and constant travelling further west depleted the Nevada landscape. To feed themselves, many Native Americans were forced to work on settlement farms and in the process, were highly mistreated. The Law of Secularization, passed by the Mexican National Congress in 1833, was an attempt to gain control of the Alta California by the secularization of the Native Population so that they could be immersed into the colony’s society. The Mexican government's aspirations was successful and a significant portion of the Native population in Alta California were given job opportunities and chances to be immersed into the trap of a materialistic culture. The earliest recorded entrance to the Sierra Nevada, beyond its western foothills by Euro-Americans, came between 1827 and 1833. It was credited to the Spaniard by the name of Francisco Garces, who crossed the Colorado river and into the state of Nevada as a missionary from the colonial Viceroyalty of New Spain and was charged with the exploring the vast uncharted areas of the Great Basin. This emigration through the Sierra Nevada to California after the late 1820s portrayed the Sierra as, “a frightening barrier to overcome as quickly as possible in order to reach California”.

Mormon Civilizations in NevadaEdit

When Spanish and American exploration reached the western United States, the people of the Mormon civilizations in the Utah territory claimed the territorial rights of the entire Great Basin and the Colorado watershed. Although, they applied to become apart of the Union of the United States, they were denied access by congress in 1850. Part of the territory was then given to the territory of Utah. This did not stop the Mormons from creating there own society naming it the “State of Deseret”. With the increase in the population of Mormon immigrants in the area they decided that their society needed the rule of law. A Declaration of Rights of the Constitution was constructed and consisted of three main branches of government, including Legislative, Executive, and Judiciary. This democratic society even elected their own governor.

Humboldt River Route

The Humboldt River route was one of the first main passages for emigrants travelling from the Western United States, as well as northern emigrants, because it offered water over most of it's length. Located in Northern Nevada, nearly 200,000 people trailed through the Humboldt River area with horses, mules, and cattle, which were not typically seen in the Sierra at the time. As outlined through the exploration of emigrant diaries, the significant changes to the Sierra and its Natives from this migration were: (1) emigrants’ consistent depletion (following trappers) of resources – especially in land animals and fishing; (2) emigrants’ introduction of horses, mules, and cattle as new resource for Natives to use in transportation, food, companionship, trade, and even military purposes, as this created “horseback natives”; (3) emigrants’ introduction of new technology such as iron, guns, metal cookware, and clothing, whether actually traded or merely abandoned; (4) emigrants’ near elimination of Native people through the introduction of disease and outright genocide; and (5) emigrants learning Euro-American customs through prolonged contact with Shoshones and Paiutes along the Humboldt.

The Paiutes and Shoshones were nomadic peoples that occupied the Sierra Nevada, which was commonly referred to as the Great Basin at the time. The Paiutes and Shoshones lived and camped in small groups along the major river areas including the Humboldt River, Pyramid and Walker Lake, as well as the surrounding dry-lands. Travelling in small groups allowed the Natives to be very mobile, and to follow the ripening resources of the land. In a sense, they were one with the land as this how they derived the necessary resources to survive in the Nevada dessert. The first white men to set foot in the Humboldt County were the French Canadian, Iroquois and Hawaiian fur trappers of the Hudson’s Bay Company’s fifth Snake Country Expedition, led by Peter Skene Ogden. On November 9th, 1828, this group crossed from the Quinn River drainage to the Little Humboldt River in the Humboldt Basin by way of Paradise Hill Pass. The group then proceeded down the Little Humboldt to its connection with the Humboldt main stem, arriving later that evening. Ogden’s 1828-1829 Humboldt Basin travels are of great importance as he and his men produced the first true map of the Humboldt Basin, which was used extensively by future emigrants.

Peter Skene Ogden

After 1827, roughly around the same time that Ogden and his fellow trappers reached Humboldt, Jedidiah Strong Smith, an American fur trapper, began exploring the Eastern parts Nevada. Common to both expedition parties, and to expeditions that followed, many emigrants assumed that they were entering open country, eligible for conquest and exploitation. Once these emigrants discovered Native presence, they quickly discounted the legitimacy of their claims to the land and its resources. From these two new established transportation routes across Nevada came a significant loss of natural resources and access to favoured camping and community areas for Natives along these routes. Of this loss of resources, one of the most significant was seen through the complete decimation of the beaver population by 1829; an essential part of Native American life. This rapid depletion was due to competing fur trappers and companies each trying to undercut potential profit for one another by trapping every available animal in the region. Competition caused this significant reduction of the beaver population and took away a source of meat and clothing for Native populations. It also disrupted hydrologic patterns affecting fish populations as well as having an impact on the other game animals and edible plants in the area. With the loss of such crucial parts of the native ecosystem, Native Americans lives were altered in dealing with the subsequent environmental repercussions. Trappers and emigrants changed the landscape and did not respect the Native customs, causing the Native groups to respond with aggression and violence. In 1833, for example, a group of Paiutes were wrongly accused and killed by trappers who believed they had been stealing their beaver traps. For years to come after Jedidiah, there was a perpetual mistrust built up between Native Americans and white explorers due to many confrontations, sometimes violent, over resources. In fact, Jedidiah Strong Smith eventually died as a result of one of these confrontations. The mistrust was built up over time and continued into the second half of the 19th century as Native Americans we're extremely upset with the depletion of their sacred land. According to Ginny Bengston's environmental assessment Northern Paiute and Western Shoshone Land Use in Northern Nevada, this depletion was due to the growing influx of people caused by the California gold rush, silver mining in Nevada, and the establishment of the United States rail system. This lead to perpetual difficulties for later explorers, none of which would be comparable to the ecological difficulties the Native Americans of Nevada would now face within their own environment.

From these beginnings arose a large increase in overland migration from the Western United States between 1840 and 1848. This was due to the discovery of gold, which initiated a massive migration from around the world into the Sierra that would shape Nevada’s early phase of development. The chance discovery of gold in this period painted a new image of the Sierra as a vast treasure house of resources to exploit. This lead to significant developments in: mining, lumber, grazing, water use, transportation, scientific activity, recreation, hunting, and urbanization. These developments would have a substantial impact on reducing Native American presence in the next half century.

Western Shoshone Territory

The main native groups of the land that is now Nevada were the Western Shoshone, Panamint, Paiute, and Goshute. In Ginny Bengston's environmental assessment Northern Paiute and Western Shoshone Land Use in Northern Nevada, he states that Euro-Americans came into contact with Native Americans in Nevada 200 years after their first encounters with indigenous populations in Utah, Arizona, and New Mexico. There is a unique environment and experience that Native Americans in Nevada had compared to other Native American groups throughout the country. Spanish experiences with native peoples in Alta California were similar to the interactions of other European and Native groups. Spanish-Native interaction was often riddled with conflict, violence, and exploitation. Natives north of Mexico often attacked mining camps and disrupted lines of communication in an attempt to prevent Spanish takeover of their lands. Native peoples did not just resist through violence, but also by withholding key information on navigable routes, water holes, and food sources from Spanish explorers, as well as by means as simple as intentionally misdirecting them. It was not uncommon for native guides to completely disappear and leave Spanish explorers lost and wandering for days or even weeks. The Spanish settlers used native slaves, often women and children, on ranches, in mines, and in households. Women and children were considered easier to control and less likely to revolt than men. Despite this, the trade of rifles, metal tools, and other European goods was also widespread.

The introduction of horses to many native groups in the Nevada area, mainly through theft, also took place during the Spanish rule of Alta California. The Spanish consistently attempted to convert and assimilate natives throughout the area to European religion and ways of life. It was thought that future missions further into Alta California would prove easier, and allow for the establishment of strong government and administration if Native peoples were culturally assimilated into the European way of life.

Western Shoshone Natives

Mexican Independence and Alta CaliforniaEdit

Although the Mexican War for Independence started in 1810, Alta California was left largely out of the conflict until 1818. Hippolyte de Bouchard, who was aligned with those for Mexican independence, sailed to Monterey, the administrative capital of Alta California, and ordered the surrender of all royal property. When he was defied he destroyed much of the city before leaving. His actions destroyed any previous support for the rebel cause in Alta California. In 1821 the War ended Spanish control of Mexico and its territories to the north. However, it took until the spring of 1822 before news of the successful revolt reached Monterey. In April of that year an assembly voted to swear allegiance to the newly formed government in Mexico, ending Spanish rule, and Alta California officially became a territory of the newly formed, independent Mexico.

Native American Pre-Reservation CultureEdit

Plant UseEdit

Native American diets most commonly consisted of a variety of wild plants and fruit such as raspberries, chokeberries, currants, pine nuts, sunflower, sand grass, blazing star, screw bean, and wild mustard. The most commonly found food source were pine nuts, which were collected from the pinyon pine and roasted over a sagebrush fire by the Native Americans to be eaten. It was also common for nuts from the pinyon pine to be stored in buckskin bags for future use or to be ground into meal to be put into thick soups; pine nuts therefore were multi-purpose as they acted as thickening agent. It was common for Native American bands in Nevada to be named after the foods they most commonly ate, an example of this is the Waddakut band which is known for often collecting and eating wada seeds from their region. In addition to this, it was common for Native Americans of Nevada to harvest roots of different plants to be used for food. The most common examples of this were wild carrot, wild garlic, and trail potato. Often these roots would be cooked or boiled and added to a thick soup.

Animal UseEdit

Cutthroat Trout, a Nevada delicacy

Native Americans of Nevada would hunt a large majority of the local wildlife. This included moles, jack rabbits, antelope, chipmunks, mountain sheep, porcupine, coyotes, elk, mice, grizzly bears, gophers, turtles and many more. Insects such as ants, grasshoppers, and larvae were also eaten. While fish were a part of the Native American diet in Nevada, they were considered to be a delicacy. The cutthroat trout was another staple food of Native Americans of Nevada and sometimes could weigh up to 25 pounds. Fish could be eaten raw or could be dried, smoked, and roasted. The Native people used all parts of the animals they hunted and wasted nothing. They would use the bones of large animals to create tools and the bones of smaller animals may be used for pendants, jewellery and septum piercings. Organs were removed and washed out so that they could be used to store and carry items such as nuts or blood. Skin and fur was used for clothing as well as barter. This meant no part of the animal was going to waste and therefore had small ecological impacts.

Hunting MethodsEdit

Hunting methods varied depending on the animals that were being hunted. Large animals such as bison were most commonly chased off cliffs where they would fall of and then be bludgeoned to death. However, spears and bow hunting became a more common practice with some Native American tribes over time. For smaller animals such as rabbits, bands would gather together and chase rabbits into stretched out nets to be captured. This activity, in particular, was often carried out by the women and children of the native bands rather than the men who usually hunted. A different leader would be selected for different tasks or goals, including fishing, hunting, and trapping.


The Native Americans of Nevada were semi-nomadic, meaning that they did not live in permanent homes but did remain in a particular area for months at a time. Depending on the season, the Native Americans of Nevada would live at different altitudes. In the summer the Natives resided at a lower altitude of 3,000-4,000 feet, whereas in the winter they would relocate to altitudes of 6,000-7,000 feet. This allowed them to use altitude as a method of choosing their preferred temperature. Native Americans kept their housing clean and used them as a place to store food. Generally, a family unit would stick together and live within the same house. In the daytime Native Americans were active searching for food or foraging supplies, but at night time they would sleep close together in their shelters to provide warmth. When a Native American passed away it was common to burn down their home as an act of ‘fumigation’.

The shelters they made were semi-permanent which fitted their semi-nomadic lifestyle and needs. Summer shelters were most commonly made from tule, a common grass-like plant, which was stuck around a simple wooden frame. In the wintertime, houses were covered in bark or animal hide to help protect from the cold winds and winter snow. A place for storage known as a ‘cache’ was dug into the ground. The cache held food and supplies such as nuts, organ sacks, or even fur blankets. This was helpful for maintaining a clean home environment like the Native Americans of Nevada preferred.

Sweat houses were shelters built approximately 4-5 feet high and 6-8 feet wide that contained hot rocks in the centre which water would be poured over to create steam. These houses were often used for ceremonial prayer by the Native Americans and were often considered a place for healing rather than a place to be lived in.


Native Americans of Nevada wore clothing often made from tule and shredded sagebrush bark. These clothes were not made to last long and frequently wore away. Native Americans of Nevada preferred a clean lifestyle but did not have the resources to clean their clothing so they were frequently left with dirty clothes. The clothing they wore often consisted of sandals, moccasins, and shredded fibre aprons. Blankets were made from fur and animal hide to help keep warm throughout the winter season.


Many ancient Native Americans of Nevada believed powers were granted to an individual through their dreams. Both powers for good and evil were gifted through dreams, however they were taught to resist the evil powers and instead wait for the powers of good to enlighten them. The powers granted to them in their dreams included the special songs needed for curing the sick, where to go to find tobacco and other resources and more. Through the powers given to them by their dreams an individual could gain the power and respect needed to become the shaman.

One of the most common Native American religious beliefs in Nevada was the Peyote Religion. The Peyote Religion adopted beliefs from Christianity while maintaining its own virtues. The core concepts of the religion are to take pride in their ancient heritage, to live a moral life, and to believe in the brotherhood of all peoples. The religion puts great focus on the use of the Peyote plant which is a cactus which induces psychedelic effects when consumed. The religion believes that consuming Peyote before meditation helps provide one with an impactful spiritual experience.

James Knox Polk: American Politician and 11th President of The United States

The American Acquisition of Alta California-NevadaEdit

The Mexican-American WarEdit

In the late 18th century, Nevada was under Spanish rule but after the Mexican War of Independence in 1822, it became a Mexican territory. Nevada was situated in the territory of Alta California (Spanish for Upper California). This territory included the modern day states of California, Nevada, Utah, Arizona, and parts of Wyoming, Colorado and New Mexico. Tensions between Mexico and America began growing more hostile and by 1846 the two countries erupted into war against one another. At this time, American’s possessed a major expansionist sentiment know as 'Manifest Destiny' and a year prior to the war, James K. Polk had been elected as America’s 11th president. While campaigning for his presidency he pledged to annex Texas and California from the Mexican government. Before the end of Polk’s first year as President he had annexed Texas, resulting in Mexico declaring war on the United States

The three main reasons to bring Texas into the Union as a state were religion, race and republicanism. Americans got their vote for annexing a new slave state in the name of freedom by gaining northern support to vote democratic. It is know that on America's side there were around 27,000 soldiers and 59,000 volunteers, but there is no adequate information on the strength of the Mexican army. Both sides worked to expand their army's strengths while also recruiting male citizen-soldiers. In America these were called volunteer regiments while in Mexico they were National Guard units, which were mobilized for the emergency. There is little information of Indian peoples' experiences during the war except that the conditions of the lives of settlers and soldiers grew worse. These people also had less freedom and their interactions with settler society became heavily policed.

The Mexican American war has been looked at as one of the most unjust wars ever waged. Americans knew that the Mexicans were a weaker country, without a strong army and thus used this to their advantage. The objective of the war was to expand the border to the Pacific Ocean by taking almost half of Mexico's territory. The two countries clashed due to the fact that Americans considered the Rio Grand River the border, while Mexicans considered the Nueces River as the border which separated the two countries. However, if there were to be a single reason for the Mexican-American War it would be the annexation of Texas. Previous to the war, in 1836, Texas won its independence from Mexico. Mexico only threatened war when the Americans annexed Texas in December 1845. Though the relationship between America and Mexico was already tense when President Polk tried to negotiate the purchase of California and the lands between it to work towards Manifest Destiny. The negotiation was 30 million dollars in exchange for Mexico's northern territories and additionally obtaining the Rio Grand River as the border rather than the Nueces River. James K. Polk was attempting to make half of Mexico a part of the United States.

Illustrated painting of The Battle of Palo Alto

The war initially started when the American Army crossed the Nueces River to establish a fort on the Rio Grande. Thus resulting in Mexico declaring war on April 23rd 1846; and Congress declaring war on May 13th 1846. The first battle fought was the battle of Palo Alto after the American annexation of Texas, Mexican troops surrounded Texas with cannons. Thirty-two hundred Mexican troops were blocking the return of American General Taylor. This resulted in a battle where there were 400 wounded and 200 killed Mexicans, with only 44 wounded and 9 killed Americans. The Mexicans may have had a larger army, but they lacked resources and training which resulted in a decisive defeat. The war on the northern side was over, but the war on the south of the river was about to begin. Mexicans went through a lot of struggle yet still did not want to make a deal with the Americans in selling their land. Mexico was committed to fighting although its troops lacked training and funding. Once the battle began in 1846 both governments realized that their armies would not be sufficient. Antonio López de Santa Anna, whom was an army officer and statesman was at the center of Mexico's politics. He passed through America from Cuba and arrived in Mexico on September 12th 1846. As Mexico's only hope to defeat the Americans, he immediately declared war which resulted in the Battle of Buena Vista. Santa Annas was thrilled because finally, the Mexican troops were winning this battle, but suddenly the American Army received assistance from Mexican politicians. This lead Santa Anna's confidence into grief, the Mexican army on the verge of victory began to retreat. Americans used artillery to repulse the much larger Mexican Army in the battle. By the end of the battle more than 2000 people had died. Santa Anna returned to Mexico City as the battle of Buena Vista ended. The battle was the bloodiest of the Mexican-American war and resulting in the loss of more Mexican than American troops.

The Mexican-American War in CaliforniaEdit

Following the annexation of Texas, America’s conviction to see Manifest Destiny as a reality, led them to look towards the annexation of Alta California. There was word that France and Britain were interested in the territory and Polk would not allow Alta California to fall under British or French rule. The US government first proposed the peaceful purchase of the Mexican territory or to annex the country through mutual agreement with its people, but neither of these propositions was going to be the case. In 1846, Alta California began experiencing some demographic changes. Alta California was mostly populated by Californios, people of mixed Mexican and Indian decent, and a newly settled Americans. Due to the lack of the Mexican government’s involvement in this territory they began experience a large sentiment of independence and self-governance. This would lead to the Bear Flag Revolt. The new American settlers felt that they would be removed from Alta California by the Mexican government due to the war between the two countries and decided to act first. Thirty-four American settlers joined together and stormed the northern military district of Mexican Alta California, but to their surprise, the Mexican leaders offered up their surrender peacefully and the settlers declared Alta California an independent republic flying under the Bear Flag. Polk had caught wind of this new change in the balance of power and assumed Alta California was ripe for the taking. He instructed General Kearny and 300 of his soldiers to march into Alta California and claim the Northwestern Mexican territory for the United States. Polk and Kearny assumed that with the successful Bear Revolt and the American Navy having taken over many important positions in the territory that it would be an easy undertaking.General Kearny decided to leave 200 of his men to defend New Mexico, and took the remaining 100 to march on Alta California. This would prove to be an almost fetal mistake for Kearny and his men as they would soon learn that they would experience overwhelming resistance. The American force was almost immediately attacked by a force of Mexican cavalry who drastically out-numbered them. Kearny’s force, who was exhausted from their long journey across the territory, experienced severe losses and Kearny himself was almost killed. General Kearny decided they would not advance any further until they received reinforcements. His forces were soon joined by a company of sailors and marines that had already been occupying the territory earlier. They continued towards San Diego with little resistance. Kearny issued a proclamation establishing a new government in Alta California and established Monterey as its capital. There were some political disputes about who claimed dominance in Alta California but Kearny had won and also received a promotion to major-general.

Mexico's Territory Before The Mexican-American War

The Treaty of GuadalupeEdit

Treaty of Guafalupe Hidalgo

Later in 1847 President Polk decided to attack Mexico City, hoping the threat of losing their capital would force Mexico to sell their northern lands to the United States. At this point Mexicans were forced to surrender and the war came to an end when General Scott took Mexico City. Polk sent his peace negotiator, Nicolas P. Trist, to Mexico and secure a peace treaty. The Mexicans, knowing the war had been lost, reluctantly signed the Treaty of Guadalupe, which was signed on February 2nd, 1848. The Mexican-American War officially ended with an American victory. Unfortunately for the Mexicans, only nine days after the signing of the treaty, the Americans discovered gold in California.

The Mexican-American war lasted roughly two years, starting in May 1846 due to the American annexation of Texas and ending with the Treaty of Guadalupe Hidalgo. The Treaty saw the United States gain 535,000 square miles (1,385,600 square kilometres) of territory.The Americans would gain control of over half of Mexico’s territory, territory that was to become the states of New Mexico, Arizona, California, Nevada, Utah, and parts of Wyoming and Colorado. The United States also decreased their offer from $30 million to $15 million for the Mexican land. During this period the Americans controlled all of Mexico, to a degree. In Washington, some congressmen were pushing for the entire country to be annexed to the United States, but Polk himself did not consider this reasonable. Mexicans living in the lands handed over to the Americans were now eligible for U.S. citizenship. In the end, the United States came away with a major geographic and political victory while the still young Mexico suffered greatly. At the end of the war, Mexico was a broken nation. No political figure wanted to take the blame for giving half of their country's land away to the United States. It had lost over 12 000 men in the battle and more than half of its territory to the Americans. The Mexican-American war is to this day is one of the most scrutinized and criticized wars that the American government has ever taken part in, many people believe that the Americans bullied Mexico into giving up its land.

Research NoteEdit

It is important to keep in mind that there is a serious lack of research and resources with historical information about Nevada at this time in history. The history of Nevada, and its people that became Nevada, is just not very well documented because most historians focus on California and Mexico where there is more information and major events. This is a very serious historical problem and people need to critical of this when researching the topic of Nevada before 1848. As stated previously, Native Americans in Nevada were relatively untouched for 200 years after the first interactions in neighbouring Utah, California, and New Mexico. Nevada tends to be overlooked prior to 1848 and thus some research and resources must be critically analyzed as the Native populations didn't have much of a chance to document history themselves. All accounts must be looked at through both the lens of the Native population as well as the explorer to gain a better understanding on how Nevada functioned prior to 1848.


Carlson, Helen. "Nevada." Western Folklore 14, no. 1 (1955): 44-49. doi:10.2307/1495952.

Keedy, Edwin R. "The Constitutions of the State of Franklin, the Indian Stream Republic and the State of Deseret." University of Pennsylvania Law Review 101, no. 4 (1953): 526-27. doi:10.2307/3309935.