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“The Most Unjust Piece of Legislation”: Section 213 of the Economy Act of 1932 and Feminism During the New Deal

Published online by Cambridge University Press:  27 April 2009

John Thomas McGuire
John Thomas McGuire
Affiliation:
Tompkins Cortland Community College
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Extract

In February 1936, a former federal government worker named Gussie E. Howell penned a letter to Grace Brewer, director of the Governmental Workers' Council (gwc) of the National Woman's Party (nwp). Howell, who lived in Texas, had apparently heard from colleagues about a questionnaire sent out by the nwp about the effects of Section 213 of the Economy Act of 1932 (“Section 213”). Howell said that while she had not seen the questionnaire, she wanted to describe the effect of Section 213 on her life.

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Articles
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Journal of Policy History , Volume 20 , Issue 4 , October 2008 , pp. 516 - 541
Copyright
Copyright © The Pennsylvania State University, University Park, PA. 2008

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References

Notes

1. Gussie E. Howell to Grace Brewer, 3 February 1936, in Pardo, Thomas C., ed., The National Woman's Party Papers, 1918–1974Google Scholar (microfilm, 179 reels, Microfilming Corporation of America, 1977–78), reel 57. Hereaft er cited as Pardo, ed.

2. Isabel Fichter to Grace Brewer, 6 January 1936, in Pardo, ed., reel 57.

3. Section 213 of the Economy Act of 1932 and its repeal is discussed and analyzed in Rung, Margaret C., Servants of the State: Managing Diversity and Democracy in the Federal Workforce, 1933–1953 (Athens, Ga., 2002)Google Scholar; Cott, Nancy F., Public Vows: A History of Marriage and the Nation (Cambridge, 2000)Google Scholar; Rung, Margaret C., “Gender and Public Personnel Administration in the New Deal Civil Service,” American Review of Public Administration 27 (12 1997): 307–323Google Scholar; Ware, Susan, Beyond Suffrage: Women and the New Deal (Cambridge, 1981), esp. 117–118Google Scholar; and particularly Lois Scharf, To Work and to Wed: Female Employment, Feminism, and the Great Depression (Westport, Conn., 1980), 45–53Google Scholar. Storrs, Landon R. Y., Civilizing Capitalism: The National Consumers' League, Women's Activism, and Labor Standards in the New Deal Era (Chapel Hill, 2000), 90Google Scholar, contains a brief mention of the alliance to repeal Section 213, including an assessment that agrees with Scharf's conclusion that the alliance constituted a “united effort.” The description of Section 213's discrimination can be found in Winifred Mallon, “empty triumph for women revealed in repeal of section 213,” New York Times, 17 October 1937, sec. 6:6.

4. Mary Anderson, “Women in Government Service,” radio talk from Washington, D.C., during Business Women's Week, 8–14 March 1931, in Sealander, Judith, ed., Records of the Women's Bureau of the U.S. Department of Labor, 1918–1965, National Archives, Part I: Reports of the Director, Annual Summaries, Major Conferences, Speeches, and Articles (microfilm, 23 reels, University Press of America, 1986), reel 15.Google Scholar

5. Swartz quoted in Gladys Oaks, “Should Married Women Work?” Equal Rights 16 (24 January 1931), 405, in Pardo, ed., reel 155.

6. “Married Women in Government Jobs,” Equal Rights 16 (31 January 1931), 414; “California Women Fight Marriage Bill,” Equal Rights 17 (25 July 1931): 195; and “Still the Working Wives Problem,” Equal Rights 18 (6 February 1932): 6, all in Pardo, ed., reel 155.

7. Quoted in Oaks, “Should Married Women Work?” 405.

8. Leuchtenberg, William, Franklin Roosevelt and the New Deal (New York, 1963), 3–4, 13–16.Google Scholar

9. “Still the Working Wives Problem,” 6. Homer S. Cummings to Franklin D. Roosevelt, 24 June 1933, photostatic copy in Official File 252, Government Employees, April–July 1933 (Franklin D. Roosevelt Library, Hyde Park, New York).

10. Scharf, To Work and to Wed, 46, and Equal Rights 18 (13 August 1932), 219, in Pardo, ed., reel 155.

11. O'Leary Archer, Lynn M., “The Contentious Community: The Impact of Internecine Conflict on the National Woman's Party, 1920–1947” (Ph.D. diss., University of California at Los Angeles, 1988)Google Scholar; Cott, Nancy F., “Feminist Politics in the 1920s: The National Woman's Party,” Journal of American History 71 (06 1984), 43–68Google Scholar; and Becker, Susan D., The Origins of the Equal Rights Amendment: Feminism Between the Wars (Westport, Conn., 1981), 82Google Scholar. The information about the National Woman Party's leadership in the 1930s can be found on the letterhead of Addie Owen to Mary Anderson, 13 October 1935, in Pardo, ed., reel 55. Josephine Casey's successful lobbying campaign in Georgia, and the state legislature's rejection of a night-work bill for working women, is described in Storrs, Civilizing Capitalism, 76–86; for information about the nwp's conservative allies, see 81–82, 108; and McGuire, John Thomas, “A Catalyst for Reform: The Women's Joint Legislative Conference (wjlc) and Its Fight for Labor Legislation in New York State, 1918–1933” (Ph.D. diss., State University of New York at Binghamton, 2001), 87–195Google Scholar. For the party's financial troubles in the early 1930s, see, for example, letter from Jane Norman Smith to Anita L. Pollitzer, 30 August 1933, in Pardo, ed., reel 52.

12. Scharf, To Work and to Wed, 46–47, and Equal Rights 18 (13 August 1932), 219, in Pardo, ed., reel 155. For the debate in the U.S. Senate on Section 213, the adverse newspaper criticism, and President Hoover's condemnation of the Economy Act of 1932, see Equal Rights 18 (13 August 1932), 219–23, in Pardo, ed., reel 155. For the details surrounding the conference, see Scharf, To Work and to Wed, 47. The figure of 1,900 employees is based on the questionnaires sent out by the U.S. Department of Labor's Women's Bureau and the National Woman's Party's Government Workers' Council in June 1935, as discussed in the section accompanying endnote 34. The three-fourths figure comes from a preliminary study conducted by the U.S. Department of Labor's Women's Bureau in early 1935, as also discussed below.

13. See the cover of Equal Rights 19 (22 April 1933) and the account of the visit of the women's delegation with Lewis Douglas, as well as Mrs. Roosevelt's press conference statement on page 95 of same issue, in Pardo, ed., reel 155. Maud Younger to Marvin McIntyre, 15 April 1933, in Official File 252, Franklin D. Roosevelt Library.

14. Edna Coleman to Louis H. Howe, April (?) 1933, Edna Coleman to Franklin D. Roosevelt, 25 April 1933, and Louis H. Howe to Mrs. Edward [Edna] Coleman, 29 April 1933, all in Official File 252, Franklin D. Roosevelt Library.

15. Handwritten note from a Mare F. Simmel on White House stationery, apparently April 1933 (emphasis in original) and Marvin McIntyre to Franklin D. Roosevelt, 12 June 1933; Cummings to Roosevelt, 24 June 1933; Marvin McIntyre to Lewis Douglas, 15 June 1933, and Lewis Douglas to Marvin McIntyre, 27 June 1933, all in Official File 252, Franklin D. Roosevelt Library.

16. E. Claude Babcock to Harriet H. Sheppard, 8 July 1935, in Pardo, ed., reel 55.

17. For the State Department's budgetary cuts, see Gellman, Irwin F., Secret Affairs: FDR, Cordell Hull, and Sumner Welles (Baltimore, 1995; New York, 2002), 36–37Google Scholar. For Roosevelt's March 1933 message on government economy, see Burns, James MacGregor, Roosevelt: The Lion and the Fox (New York, 1956), 167Google Scholar. For the salary cuts and furloughs, see Joseph W. Stern to Franklin D. Roosevelt, 5 May 1933, in Official File 252, Franklin D. Roosevelt Library. For quotation, see Louis H. Howe to Mae Wilson Camp, 27 July 1933, in Official File 252, Franklin D. Roosevelt Library.

18. The term “social justice feminism” is derived from the introduction to Social Justice Feminists in the United States and Germany: A Dialogue in Documents, 1885–1933, ed. Sklar, Kathryn Kish, Schüler, Anja, and Strasser, Susan (Ithaca, 1998), 5–11Google Scholar. See also Felix Frankfurter, “Hours of Labor and Realism in Constitutional Law,” 29 Harvard Law Review (February 1916), 367 (emphases in original); Sklar, Kathryn Kish, “Two Political Cultures in the Progressive Era: The National Consumers' League and the American Association for Labor Legislation,” in U.S. History as Women's History: New Feminist Essays, ed. Kerber, Linda K., Kessler-Harris, Alice, and Sklar, Kathryn Kish (Chapel Hill, 1995), 51Google Scholar; and McGuire, John Thomas, “From the Courts to the State Legislatures: Social Justice Feminism, Labor Legislation, and the 1920s,” Labor History 45 (05 2004), 225–246.Google Scholar

19. For a discussion of the first and second stages of social justice feminism in the United States, see McGuire, “From the Courts to the State Legislatures,” 225–27.

20. “Extracts From Address Delivered by Miss Rose Schneiderman Before the Women's Industrial Conference … Jan. 20, 1926: The Right to Citizenship,” Box 71, Folder 1171, Mary van Kleeck Papers, Sophia Smith Collection, Smith College, Northampton, Massachusetts; and “Address at Testimonial Luncheon in [Frances Perkins's] Honor …,” typed copy in Box 44, Frances Perkins Papers (Rare Book and Manuscript Collection, Butler Library, Columbia University).

21. Alice Paul to Katherine Morey, 20 March 1921, in Pardo, ed., reel 7.

22. Molly Dewson to Felix Frankfurter, 27 November 1928, in The Felix Frankfurter Papers (microform, 165 reels, Library of Congress Photoduplication Service, 1983), reel 100, and Molly Dewson to Isador Lubin, 16 April 1957, 2, in Scott, Ann Firor, ed., Mary Williams (Molly) Dewson Papers, 1893–1962, Women's Studies Manuscript Collections, Arthur and Elizabeth Schlesinger Library for the History of Women, Series 2: Women in National Parties, Part A: Democrats (microform, 14 reels, University Press of America, 1992), reel 3Google Scholar. For Eleanor Roosevelt's creation of the partnership between the Women's Joint Legislative Conference and New York's Democratic Party in the 1920s, see McGuire, John Thomas, “Making the Democratic Party a Partner: Eleanor Roosevelt, the Women's Joint Legislative Conference, and the Women's Division of the New York State Democratic Party, 1921–1927,” Hudson Valley Regional Review 18 (09 2001): 29–48Google Scholar. For her support of Frances Perkins, see Eleanor Roosevelt to Franklin D. Roosevelt, 22 November 1928, quoted in Lash, Joseph A., Eleanor and Franklin (New York, 1971; 1995), 323Google Scholar. For Eleanor Roosevelt's inclusion of Dewson into national Democratic Party circles, see Cook, Blanche Wiesen, Eleanor Roosevelt, Volume II: 1933–1938 (New York, 1999), 67–69Google Scholar, and Ware, Beyond Suffrage, 43–67.

23. Molly Dewson to Arthur Altmeyer, 25 August 1935, quoted in Ware, Susan, Partner and I: Molly Dewson, Feminism, and New Deal Politics (New Haven, 1987), 233Google Scholar. Burnita Sheldon Matthews, telegram, 7 June 1936, in Pardo, ed., reel 58. For an excellent overall discussion of the Social Security Act, see Kessler-Harris, Alice, In Pursuit of Equity: Women, Men, and the Quest for Economic Citizenship in Twentieth-Century America (New York, 2001), 117–151.Google Scholar

24. Jane Norman Smith to Alice Paul, 16 April 1933, and Jane Norman Smith to Helen Hunt West, 24 August 1934, in Pardo, ed., reels 51 and 53, respectively. Jane Norman Smith to Alice Paul, 14 January 1935; Sue Brobst, honorary president of the Business Women's Council of California to Florence Bayard Hilles, 28 January 1935; and Jane Norman Smith to Anita L. Pollitzer, April(?) 1935, all in Pardo, ed., reel 55. The best biographical material on Sue Shelton White can be found in Louis, James P., “Sue Shelton White,” Notable American Women, 1607–1950, A Biographical Dictionary, Vol. III, ed. James, Edward T., James, Janet Wilson, and Boyer, Paul S. (Cambridge, Mass., 1971), 590–592Google Scholar. For White's conflict with Eleanor Roosevelt and Rose Schneiderman, see Eleanor Roosevelt to Nellie Tayloe Ross, 28 March 1930, and typewritten response of Sue Shelton White to Rose Schneiderman's charges, n.d., both in Scott, ed., Sue Shelton White Papers, reel 12. For the tensions between White and Dewson, see Molly Dewson, “An Aid to the End,” vol. 1, 163–64, copy in Mary Williams (Molly) Dewson Papers, Franklin D. Roosevelt Library. White's new position in the National Recovery Administration is described in Louis, “Sue Shelton White,” 592. For Dewson's desire to remove White from the Women's Division, see Molly Dewson to Franklin D. Roosevelt, 30 October 1933 (with attached description of White's qualifications), and Molly Dewson to Mae(?), 20 December 1933, both in President's Personal File 5689, Dewson, Mary W. (“Molly”), Presidential Personal Files 5684 (1942–44)–5722, Franklin D. Roosevelt Library. See also Sue Shelton White to Mary W. Dewson, 28 December 1933, in Dewson, M. W., 1933–35 File, Box 4, General Correspondence Files, Women's Division of the Democratic National Committee Papers, 1933–1944, Franklin D. Roosevelt Library.

25. Cott, Nancy F., The Grounding of Modern Feminism (New Haven, 1987), 261–262Google Scholar. Jane Norman Smith to Anne Carter(?), 14 July 1933, in Pardo, ed., reel 52.

26. For Rose Schneiderman's protest, see Louis H. Howe to Lewis Douglas, 12 July 1933, in Official File 252, Franklin D. Roosevelt Library. (The letter from Rose Schneiderman apparently has been lost.)

27. Phyllis Gale to Clara Hargreaves, 31 October 1933, in Pardo, ed., reel 54.

28. McGuire, “A Catalyst for Reform,” 220–21. See also Mary Anderson's papers, now on microfilm in the edition of the Papers of the Women's Trade Union League and Its Principal Leaders.

29. McGuire, “A Catalyst for Reform,” 220. Mary Anderson, “What the New Deal Will Do for Women,” in Sealander, ed., Records of U.S. Department of Labor's Women's Bureau, Microfilm Edition, Part I, reel 22. For the controversy within the New Deal about the National Recovery Administration's discriminatory minimum-wage codes, see other cites, as well as “Minutes of the Council of the National Woman's Party, September 9, 1933,” in Pardo, ed., reel 114. Mary Anderson, “Women Workers and the New Deal,” 9 January 1937, in Sealander, ed., Records of U.S. Department of Labor's Women's Bureau, Part I, reel 22. For an excellent overview of Anderson's creation of alliances from 1920 through 1933, see chapter 1 of Kathleen Laughlin, A., “Backstage Activism: The Policy Initiatives of the Women's Bureau of the U.S. Department of Labor in the Postwar Era, 1945–1970” (Ph.D. diss., Ohio State University, 1993).Google Scholar

30. “Section 213 Annual Report, January 1936,” 5, in Pardo, ed., reel 114.

31. Ibid., 1.

32. Tables 1 through 9 of the “Section 213 Preliminary Report, September 23, 1935,” in Pardo, ed., The National Woman's Party Papers, reel 114.

33. “Section 213 Report,” 22. The exact number of federal government employees fired under Section 213 from its implementation in 1932 through its repeal five years later cannot be known for sure, since government agencies did not have to notify the Civil Service Commission of the firings. The commission later estimated that “from 1600 through 1800” employees were fired. Mallon, “Empty Triumph.”

34. For the National Woman's Party's continuing opposition to women's labor legislation, see Lee Terrys Perlman to Rebekkah Greathouse, 13 October 1935, and Helen Robbins Bittermann to Florence Bayard Hilles, 14 October 1935, both in Pardo, ed., reel 55. “Minutes of the Council of the National Woman's Party, January 8, 1937,” in Pardo, ed., reel 114. Owen to Anderson, 13 October 1935, and Mary Anderson to Edwina Avery, 10 January 1936, in Pardo, ed., reel 57.

35. Iola J. Comish to Harriet Sheppard, 26 March 1936, in Pardo, ed., reel 57.

36. Scharf, To Work and to Wed, 46, 50.

37. Doolittle, Jan P., “Organized Women Under Attack: The Women's Joint Congressional Committee and Its Legislative Campaigns for Mothers and Children, 1920–1930” (Ph.D. diss., State University of New York at Binghamton, 2000), 54–58, 117–81, 444–53Google Scholar. Elizabeth Christman, secretary-treasurer of the national wtul to Alice L. Edwards, 8 December 1932, Alice L. Edwards to Dr. Sophonisba P. Breckinridge, 9 May 1933, Lucy R. Mason, general secretary of the ncl, to Mary T. Bannerman, 20 November 1936, and reply from Mary T. Bannerman to Lucy R. Mason, 11 December 1936, all in Sullivan, Joseph D., ed., The Records of the Women's Joint Congressional Committee, 1920–1970 (microfilm, 7 reels, Library of Congress Manuscript Division, 1983), reel 2Google Scholar. Form for Women's Joint Congressional Committee members, dated 15 November 1933, and Marian I. Pankhurst, National Federation of Business and Professional Women's Clubs, to Mary T. Bannerman, 18 January 1937, both in Sullivan, ed., Records of Women's Joint Congressional Committee, 1920–1970, reel 2. See also “Annual Report of the Committee on Dismissal of Married Persons in the Civil Service, Women's Joint Congressional Committee,” 3 December 1934, in Box 158, Folder 17, in Selma Dorschardt Papers (Labor Archives, Detroit).

38. Scharf, To Work and to Wed, 50. Edna A. Patterson to Edwina Avery, 19 January 1936 (quotation), and from Harriet Sheppard to Elsie M. Valentine, 14 January 1936, both in Pardo, ed., reel 57.

39. Representative Howard W. Smith to E. E. Biehl, January 1936 (Smith was chairman of the House Rules Committee at the time); Government Workers' Council to Members, 14 January 1936; Harriet Sheppard to Representative W. B. Bankhead, 21 January 1936; Harriet Sheppard to Gelene McDonald Bowman, 3 March 1936; Priscilla Lawyer Randolph to Franklin D. Roosevelt, 6 March 1936; and Constance A. Sporborg, chairman, legislative department of General Federation of Women's Clubs, to Harriet Sheppard, 16 April 1936, all in Pardo, ed., reel 57. Betty Gram Swing, “Report of Congressional Committee, January 1 to April 17, [1936],” in Pardo, ed., reel 57. National Poll of Public Opinion (15 November 1936), copy in Series 2, Box 340, Government and Legal Status of Women Folder, National League of Women Voters' Papers (Library of Congress Manuscript Division, Washington, D.C.)

40. Essary, Helen, “Gay Luncheon at White House Follows Rain-Drenched Inauguration,” Democratic Digest 14 (02 1937): 17Google Scholar, in Periodicals Section, Franklin D. Roosevelt Library.

41. McGuire, John Thomas, “Two Feminist Visions: Social Justice Feminism and Equal Rights, 1899–1940,” Pennsylvania History: A Journal of Mid-Atlantic Studies 71 (Autumn 2004): 457–458, 462.Google Scholar

42. Molly Dewson to Franklin D. Roosevelt, probably February 1933, in Scott, ed., Mary Williams (Molly) Dewson Papers, reel 3; Frances Perkins to Raymond Moley, 16 February 1933, in Subject File, “Labor Department,” Felix Frankfurter Papers (Library of Congress, Manuscript Division, Washington, D.C.), and New York Times, 13 April 1933, 1. Quotation about Eleanor Roosevelt from copy of interview with Mrs. May Thompson Evans by Dr. Thomas E. Scapes, Oral History, 30 January 1978, for Franklin D. Roosevelt Library, in East Carolina Manuscript Collection, Sy Joyner Library, East Carolina University, Greenville, North Carolina, p. 69. See also McGuire, “A Catalyst for Reform,” 315–25, as well as McGuire, “Two Feminist Visions,” 463.

43. Molly Dewson to Eleanor Roosevelt, 29 October 1935 and 17 April 1937, in Ware, Susan and Chafe, William H., eds., The Papers of Eleanor Roosevelt, 1933–1945 (microfilm, 20 reels, University Press of America, 1986), reel 7.Google Scholar

44. A voluminous historiography exists on Franklin D. Roosevelt's plan to increase the U.S. Supreme Court's membership after the 1937 inauguration. See, for example, Cushman, Barry, Rethinking the New Deal Court: The Structure of a Constitutional Revolution (New York, 1998)Google Scholar, Irons, Peter H., The New Deal Lawyers (Princeton, 1982)Google Scholar, and Baker, Leonard, Back to Back: The Duel Between FDR and the Supreme Court (New York, 1967)Google Scholar.

45. McGuire, “Two Feminist Visions,” 463–64.

46. Ibid., 464.

47. For the Republican Party's acceptance of Section 213 repeal in its 1936 party platform, see Doris Stevens to Florence Bayard Hilles, 30 September 1936, and Emma Guffey Miller to James A. Farley, 23 April 1937, in Pardo, ed., reels 58 and 59, respectively. For the Democratic Party's refusal to consider the same issue, and the rejection of the proposal to include women on the party's platform committee at the 1936 national convention, see memorandum of 26 May 1936, as well as letters from Molly Dewson to Dorothy Smith McAllister, 14 and 27 May 1936, in Dorothy Smith McAllister Papers, 1932–1948 (microfilm, 2 reels, Bentley Library, University of Michigan, Ann Arbor, n.d.), reel 1. McAllister (1899–1983), a confidant and protégé, became director of the Women's Division of the dnc in April 1937. For Emma Guffey Miller's background, see Swain, Martha H., “Emma Guffey Miller,” in American National Biography, ed. Garraty, John A. and Carnes, Mark C. (New York, 1999), 15:481–82Google Scholar, and Mulder, Keith, “Emma Guffey Miller,” in Notable American Women: The Modern Period: A Biographical Dictionary, ed. Siderman, Barbara and Green, Carol Hurd (Cambridge, Mass., 1980), 476–477.Google Scholar

48. For Emma Guffey's lobbying on behalf of repeal of Section 213, see Radio Talk, Emma Guffey Miller, Washington, D.C., 14 March 1936, in Pardo, ed., reel 57. For her challenge to James A. Farley and Molly Dewson, see letter of 23 April 1937. For Dewson's letter to Emma Guffey Miller, see Molly Dewson to Franklin D. Roosevelt, 22 March 1937, with a copy of her letter to Guffey, in Box 130, President's Secretary's File, Franklin D. Roosevelt Library. The regional conference is described in detail in Kathleen McLaughlin, “Woman Democrats Praise Court Bill,” New York Times, 16 June 1937, 15, and McLaughlin, “Democrats Hailed for Aid to Women,” New York Times, 17 June 1937, 8. For the subsequent decline of the Women's Division, see McGuire, “Two Feminist Visions,” 467–68.

49. Representative Fred L. Crawford to Jennie McKibbin, 6 March 1937; Representative William M. Colmer to Emma Guffey Miller, 10 March 1937; and Lois Babcock to Molly Dewson, 27 April 1937, all in Pardo, ed., reel 59; Scharf, To Work and to Wed, 50, and “Summary of National Woman Party's Activities,” in The National Woman's Party Papers, 1913–1974: A Guide to the Microfilm Edition, ed. Pardo, Thomas C. (Sanford, N.C., 1979), 85.Google Scholar

50. Emma Guffey Miller to James A. Farley, 23 April 1937, and Lois Babcock to Molly Dewson, 27 April 1937, in Pardo, ed., reel 59. The anonymous source is in Mallon, “Empty Triumph.” For Eleanor Roosevelt's statement and the quotation, see “Section 213 Repealed!” Democratic Digest 14 (August 1937): 36, in Periodicals Section, Franklin D. Roosevelt Library.

51. Mallon, “Empty Triumph.” Gladys Avery to Laura Beaty, November 4, 1937, in Pardo, ed., reel 60, and “Minutes of the Council of the National Woman's Party, November 4, 1937,” 2, in Pardo, ed., reel 115.

52. Cott, The Grounding of Modern Feminism, 209–10.

53. Patterson, James T., Congressional Conservatism and the New Deal (Lexington, Ky., 1967), 160–162Google Scholar. Kennedy, David M., Freedom from Fear: The American People in Depression and War, 1929–1945 (New York, 1999), 345, 349, 783–84Google Scholar. For an overview of the postwar era in the United States, see Patterson, James T., Great Expectations: The United States, 1945–1974 (New York, 1996)Google Scholar; Becker, Origins of the Equal Rights Amendment, 83–86; Swain, “Emma Guffey Miller,” 482; and Mulder, “Emma Guffey Miller,” 477. For a discussion on how reform movements after World War II turned from rights based on class to rights based on groups, see Foner, Eric, The Story of American Freedom (New York, 1998), 285–305.Google Scholar