prompt_front: Now, answer the following question based on the text below, only give me the answer and do not output any other words.

Question: What did the London Directory proclaim to contain?

Read the following text and answer briefly.

Context 1: A Brief History of Benjamin Franklin's Residences on Craven Street, London: 1757 - 1775 - Journal of the American Revolution
Benjamin Franklin House, 36 Craven St, London  (Photo by Elliott Brown | Wikimedia Commons)
If one looked into Benjamin Franklin’s time on Craven Street, they might initially believe he lived at 36 Craven Street the entirety of his two stays in London based on the plethora of articles on the internet that say so  If they dug a little deeper they might read that he lived at No  27 Craven Street, previously numbered 7, but now numbered 36; or that he lived exclusively at No  7 Craven Street; or that he lived in multiple residences on Craven Street; or that he moved out of No  36 to another house on Craven Street and then moved back into No  36 the last year of his residence  What is one to believe with all of the conflicting accounts? What does the historical record have to say about Franklin’s time on Craven Street?
Figure 1  Spur Alley 1685  “A map of the parish of St Martins in the Fields, taken from ye last survey, with additions (1685)”  (© The British Library Board, Shelfmark: Maps Crace Port  13 2, Item number: 2)
Before Craven Street existed there was Spur Alley, a narrow passageway sandwiched between the Hungerford Market to the north (now Charing Cross Station) and Scotland Yard and the Northumberland House and Garden to the south  It was flanked on both ends by major thoroughfares, the Strand on the west, connecting Westminster to London by road, and the River Thames on the east, not only connecting the two cities to each other and to Southwark on the south side of the Thames, but connecting the entire metropolis to the rest of the world  Being located in the City of Westminster, Spur Alley had escaped the devastation of the Great Fire of London in 1666 leaving its wooden structures, built in the early part of seventeenth century, intact, but also in dire need of restoration or demolition  “The ratebooks show that during the last thirty years or so of their existence the houses in Spur Alley were in a very bad condition  Few of them were rated at more than a few shillings and many of them were unoccupied ”[1] The landowner, William, 5th Baron Craven, desiring to increase the profitability of his assets, tore down the derelict structures on Spur Alley around 1730 and leased the newly established lots to builders  By 1735, twenty brick houses in the Georgian style had been built on the west side and sixteen on the east side of the way now called Craven Street [2]
Figure 2  Craven Street 1746  (John Rocque London, Westminster and Southwark, First Edition 1746, Motco Enterprises Limited, motco com)
Letters to Franklin during his residence with Mrs  Margaret Stevenson, his landlady on Craven Street, were addressed rather vaguely; “Craven Street/Strand”, “Mrs  Stevensons in Craven Street”, or “Benjamin Franklin Esqr ” are but a few examples  Letters from Franklin referenced “London,” or sometimes “Cravenstreet,” but never included a number  Despite the absence of numbered addresses in Franklin’s correspondence, there was a sense of one’s place in the neighborhood based on entries in the Westminster Rate Books (tax assessments)  The Rate Books did not list house numbers during Franklin’s time there, but they did list the residents of Craven Street in a particular order that became the default numbering system for the street  Number one was associated with the first resident listed under “Craven Street” in the Rate Books and was the northernmost house on the west side of the street  The numbers increased counter-clockwise down the west side and up the east side in accordance with the list of residents  In 1748, the first year of Margaret Stevenson’s (Stevens in the Rate Books for that year) residence on Craven Street, she is listed as the twenty-seventh resident, the second house north of Court Street (later Craven Court, now Craven Passage) on the east side of the street [3]
In 1766, Parliament passed the London Paving and Lighting Act (6 Geo  3 c  26), “An act for the better paving, cleansing, and enlightening, the city of London, and the liberties thereof; and for preventing obstructions and annoyances within the same; and for other purposes therein mentioned ”[4] One of the other purposes therein mentioned was the numbering of houses  With an aim to bring order to the chaotic numbering systems or lack thereof on London streets the Act provided that “… the said commissioners … may also cause every house, shop, or warehouse, in each of the said streets, lanes, squares, yards, courts, alleys, passages, and places, to be marked or numbered, in such manner as they shall judge most proper for distinguishing the same ”[5] This was quite an undertaking that took years to accomplish  It was a decade later before numbered addresses on Craven Street in the City of Westminster appeared in The London Directory (1776)  The London Directory and its competitors were published primarily by booksellers or printers to supplement their income and were highly profitable  To say they were competitive is an understatement  “Some of the most hotly disputed struggles over copyright in the century concerned guidebooks  Many were optimistically emblazoned with a royal license and a notice that the work had been entered at Stationers’ Hall  Various struggles between rival guides intensified as the potential for profits became clear ”[6] The London Directory boldly proclaimed to contain “An ALPHABETICAL LIST OF THE NAMES and PLACES of ABODE of the MERCHANTS and PRINCIPAL TRADERS of the Cities of LONDON and WESTMINSTER, the Borough of SOUTHWARK, and their Environs, with the Number affixed to each House ”[7] Kent’s Directory made a similar proclamation: “An Alphabetical LIST OF THE Names and Places of Abode OF THE DIRECTORS of COMPANIES, Persons in Public Business, MERCHANTS, and other eminent TRADERS in the Cities of London and Westminster, and Borough of Southwark WITH THE NUMBERS as they are affixed to their Houses agreeable to the late Acts of Parliament ”[8] Mrs  Stevenson wasn’t included in the directories because she didn’t meet the criteria of being a merchant or trader, not because she was a woman  Although it is rare to see women listed in the directories, some examples do exist [9] If Mrs  Stevenson had appeared in the directories in 1776 it would not have been on Craven Street as she had moved to Northumberland Court, a stone’s throw away, the previous year [10] A comparison of Craven Street residents whose names and addresses do appear in the directories with the same residents as they appear in the Westminster Rate Books determines if the numbering systems were congruent  For the most part they were  For example, Joseph Bond at No  30, William Rowles at No  31, Samuel Sneyd at No  32, and Jonathan Michie at No  35 in The London Directory coincide with their places of residence in the Westminster Rate Books; however, errors did occur  The 1776 edition of The London Directory lists Brown & Whiteford, wine merchants, at No  9 Craven Street while the Westminster Rate Books list them as the twenty-ninth residents  Obviously, it makes no sense to have Brown & Whiteford at No  9 in The London Directory and their next-door neighbor, Joseph Bond, at No  30  The same error appears in Baldwin’s The New Complete Guide for 1783  The New Complete Guide may have “borrowed” the error from The London Directory  It was not uncommon for the owner of one directory to copy entries from another to save both time and money  Beginning in 1778 and contrary to The London Directory, Kent’s Directory faithfully followed the numbering system of the Westminster Rate Books in all of its editions and listed Brown & Whiteford at No  29 as did Bailey’s Northern Directory in 1781  Perhaps realizing their error, The London Directory changed their listing of Brown & Whiteford from No  9 to No  29 in their 1783 edition and maintained that listing thereafter 
Sometime prior to 1792, the embankment on the Thames at the south end of Craven Street had been sufficiently extended allowing for the construction of ten new houses below the original houses: “ … four houses, Nos  21–24, were built on the west side, and six houses, Nos  25–30, on the east side of the way ”[11] In a note in the same report, the new numbering system is explained  “The houses in the street, which had previously been numbered consecutively down the west side and up the east side, were then renumbered on the same system to include the additional houses ”[12] Because the new houses (21-24) on the west side were built below the existing houses (1-20), houses 1-20 retained their original numbering 
Figure 4  Craven Street 1799  (Richard Horwood’s Map of London, Westminster and the Borough of Southwark 1799, Motco Enterprises Limited, motco com)
One would think that the numbers of the sixteen original houses on the east side, Nos  21 – 36, would simply increase by ten with the addition of the ten new houses, but such was not the case; they increased by nine  How could that be? The only possible explanation is that No  21 of the original houses was demolished to make way for the construction of the northernmost of the six new houses on the east side (No  30)  Evidence of No  21’s demolition appears in the lease granted to Charles Owen by William, 7th Baron Craven, in 1792, which describes No  22 as: “All that messuage in Craven Street late in the occupation of Francis Deschamps undertaker … being the Southernmost house in the Old Buildings on the East Side of the said Street numbered with the No  22 ”[13] The lease describes No  22 as being the southernmost house in the old buildings on the east side of Craven Street  Clearly the house previously at No  21 did not exist when the lease granted to Charles Owen was written in 1792 as it used to be the southernmost house  It is also worth noting that in 1790, The London Directory listed Jacob Life at No  21 (original numbering)  In 1791-2, it listed him at No  6  With No  21 vacated, it would allow for its demolition and the construction of the tenth new house  By utilizing lot No  21 for the new construction, only nine additional lots were needed to build the ten houses, hence, Margaret Stevenson’s former residence at 27 became 36 (27 + 9) in the renumbering and not 37 
For nearly a century and a half after Franklin departed London for America in March of 1775 the scales were tipped heavily in favor of his residence having been No  7 Craven Street  As early as 1807 in London; Being An Accurate History And Description Of The British Metropolis And Its Neighborhood, Volume 4, one would have read: “In Craven Street is a house, No  7, remarkable for having been the residence of Dr  Benjamin Franklin [14] In 1815, the identical phrase appeared in The Beauties of England and Wales [15] After 23 editions of not mentioning Franklin, his name finally appeared in the 24th edition of The Picture of London in 1826: “The house, No  7, Craven Street, in the Strand, was once the residence of Dr  Benjamin Franklin ”[16] In 1840, Jared Sparks referred to Franklin’s Craven Street residence appearing in London guide books in his voluminous The Works of Benjamin Franklin: “In the London Guide Books, ‘No  7, Craven Street,’ is still indicated as the house in which Dr  Franklin resided ”[17] In 1846, George Gulliver F R S , in his book, The Works of William Hewson, wrote: “She [Polly] had been upon terms of the warmest friendship with Dr  Franklin
Figure 5  No  7 Craven Street with Memorial Tablet  (Photo courtesy of British History Online, and the Survey of London)
since she was eighteen years of age  That eminent philosopher resided with her mother, Mrs  Margaret Stevenson, at No  7, Craven Street, Strand, during the fifteen years of his abode in London ”[18] Guide books mentioning Franklin at No  7 continued to proliferate throughout the century: Handbook for London; Past and Present, Volume I (1849);”[19] Handbook for Modern London (1851);”[20] The Town; Its Memorable Characters and Events (1859);”[21] London and Its Environs (1879) [22] There was an anomaly when London In 1880 Illustrated With Bird’s-Eye Views of the Principal Streets, Sixth Edition (1880) placed Franklin at 27 Craven street [23] The anomaly lasted for six years until his place of residence was changed to No  7 in the revised edition, London  Illustrated by Eighteen Bird’s-Eye Views of the Principal Streets (1886) [24] London Past and Present; Its History, Associations, and Traditions, Volume 1 (1891), copied the 1849 Handbook for London almost word-for-word and included, “The house is on the right from the Strand ”[25] In October of 1867, The Society of Arts in London declared that: “In order to show how rich the metropolis is in the memory of important personages and events, which it would be desirable to mark by means of tablets on houses, the Council have caused an alphabetical list to be prepared, … ”[26] Franklin had been elected a corresponding member to the Society in 1756 and was a popular choice among Council members deciding who they were to memorialize [27] By January of 1870, a tablet honoring him was affixed to the house they believed to have been his residence while in London, No  7 Craven Street in the Strand on the west side of the street [28] A majority of historians writing about Franklin in the nineteenth and early twentieth century placed him at No  7: O  L  Holley, The Life of Benjamin Franklin (1848); E  M  Tomkinson, Benjamin Franklin (1885); John Torrey Morse, Benjamin Franklin (1891); Paul Elmer More, Benjamin Franklin (1900); John S  C  Abbot, Benjamin Franklin (1903); Sydney George Fisher, The True Benjamin Franklin (1903)  A notable exception is D  H  Montgomery’s His Life Written by Himself published in 1896  He has Franklin at No  27 Craven Street  It seems then that depending upon the source, Franklin was thought to have lived at either No  7 or No  27, but not both, the overwhelming majority favoring No  7  As late as 2011, Franklin is still mentioned as living at No  7 [29]
In 1913, No  7 was scheduled to be torn down  An article in the March 1914 edition of The Book News Monthly, describes the situation:
As is well known to informed American pilgrims, it has been possible for all admirers of the famous philosopher and statesman to pay their respects to his memory before that house, No  7 Craven Street, just off the Strand, which was his chief home during his two sojourns in the British capital, but even as these lines are being written the London newspapers are recording that that interesting shrine is soon to be pulled down to make room for a restaurant  It is some mitigation of this misfortune to remember that at the most the Craven Street house was nothing more than a reproduction of the one in which Franklin had his suite of four rooms, for the structure has been rebuilt since Franklin’s time  When, then, some one makes a piteous plea that at least the philosopher’s bedroom shall be preserved, the soothing answer is that the apartment in question is only a replica of that in which the illustrious American enjoyed his well-earned slumbers in 1757-62 and 1764-75  The restaurant-builder, however, with an eye doubtless to possible American patronage, has assured the world that every effort will be made to preserve as much as possible of the entire structure [30]
Concerned with the possible demolition of Franklin’s residence, the Royal Society of Arts (formerly the Society of Arts[31]) initiated an inquiry into the matter [32] The London County Council, having taken over the responsibility of placing memorial tablets on notable houses from the Royal Society, was charged with the investigation  It ultimately fell to Sir George Laurence Gomme, a clerk to the Council, to come up with a response  A few years earlier Sir George had discovered Margaret Stevenson residing at No  27 Craven Street in the Westminster Rate Books  He must have wondered why No  7 on the west side of Craven Street was being celebrated as Franklin’s residence when the evidence clearly showed otherwise 
Sir George and his staff examined the various London directories discussed earlier and came up with a novel explanation for the discrepancy  They concluded that there had been two numbering systems on Craven Street  An anonymous author echoes Sir George’s conclusion about the two numbering systems in an article in The Journal of the Royal Society of Arts:
…an inspection of the directories of that time proves that there were at least two systems of numbering in Craven Street before the erection of the additional houses  According to one of these the numbers started from the top (Strand end) on the west side of the street, and ran down to the bottom to No  20, then crossed over and went back to the Strand along the east side – 21 to 36  According to the other system, the east side of the street was numbered from the bottom upwards, starting at No 1  This was not apparently in general use, but there is evidence that this numbering was at all events occasionally used 
The evidence of these two systems of numbering, and for believing that Mrs  Stevenson’s house was first No  7 under the oldest system, next No  27 under the second system, and finally No  36 under the latest and existing system, is to be found in the various directories and the Westminster rate-books [33]
The “evidence” mentioned above consisted of The London Directory’s listing of Brown & Whiteford at No  9: “The rate-books for 1781 and 1786 show the house next but one to the north of Mrs  Stevenson’s house as in the occupation of Brown and ‘Whiteford,’ while the old directories mention the business of the firm as wine merchants, and give their address as 9, Craven Street – then a little later, down to 1791, as 29, Craven Street  Curiously enough, in the years 1778 to 1780, or 1781, Lowndes gives it as No  9, and Kent as 29 ”[34] Ignoring Kent’s Directory having Brown and Whiteford as 29 and The London Directory (Lowndes) having Brown and Whiteford “a little later” as 29, and knowing that Mrs  Stevenson lived two doors south of them, Sir George concluded that her house must have been numbered 7, even though there is no listing in any of the directories of her residence ever being No  7  He surmised that the No  7 on the west side of Craven Street with the memorial tablet thought to have been Franklin’s residence had simply been confused with number 7 (27) on the east side  Again from The Journal of the Royal Society of Arts:
Taking all the evidence together, there cannot be any doubt whatever that Mrs  Stevenson’s house, in which Franklin lodged, was the house two doors north from Craven Court, first numbered 7, afterwards 27, and finally 36, and consequently that the house in which Franklin lived was that now numbered 36, not the one now numbered 7, on which the tablet is placed [35]
A response to The Royal Society of Arts was issued: “… the London County Council … informed the Society that it had made a mistake and that No  36 Craven street was the building that deserved commemoration ”[36] The Society accepted the Council’s conclusion, and despite assurances of preservation by the restaurant builder, No  7 was torn down the following year 
Sir George’s assertion “that Mrs  Stevenson’s house, in which Franklin lodged, was the house two doors north from Craven Court” was correct, however, his assertion that it was “first numbered 7, afterwards 27”, was not  It was only by association with the errant entry of Brown & Whiteford at No  9 from 1776-1782 in The London Directory that Mrs  Stevenson’s address was conjured to be No  7  The problem with associating her address exclusively with that of Brown & Whiteford at No  9 during those years is that, as previously demonstrated, The London Directory also listed four other Craven Street residents, Bond, Rowles, Sneyd, and Michie, who’s addresses did conform to the numbering system in The Westminster Rate Books  If Brown & Whiteford at No  9 was indicative of a numbering system different from The Westminster Rate Books, Bond, Rowles, Sneyd, and Michie would have been listed as Nos  10, 11, 12, and 15, respectively  So on one hand Sir George was relying on the Westminster Rate Books to establish Mrs  Stevenson at No  27 and on the other hand he was dismissing the Westminster Rate Books to establish her at No  7  Instead of using the anomalous listing of Brown & Whiteford at No  9, he could have just as easily, and more logically, used the Bond et al  listings, or the post-1782 Brown & Whiteford listing in the London Directory at No  29 to establish Mrs  Stevenson at No  27  Even if there had been two numbering systems, his assertion that No  27 was first numbered 7 would still be false  The earliest numbering system was the Westminster Rate Books dating from the early 1730s when the houses were constructed  Brown & Whiteford at No  9 didn’t appear until 46 years later and then only for a brief period 
There is ample evidence in Franklin’s correspondence and in a memoir by Polly Hewson (Mrs  Stevenson’s daughter) that Benjamin and Mrs  Stevenson lived in not one, but two houses on Craven Street  On July 6, 1772, Polly wrote to Benjamin from her house at Broad Street North in London: “My Mother I must tell you went off last friday week, took our little Boy with her and left Mr  Hewson [Polly’s husband, William] the care of her House [27 Craven Street]  The first thing he did was pulling down a part of it in order to turn it to his own purpose, and advantage we hope  This Demolition cannot affect you, who at present are not even a Lodger [Benjamin was traveling at the time], your litterary apartment remains untouch’d, the Door is lock’d …”[37] In a memoir about her husband written after his death Polly writes: “He [William Hewson] began his Lectures Sept  30, 1772, in Craven-street, where he had built a Theatre adjoining a house which he intended for the future residence of his family ”[38] On October 7, 1772, Benjamin wrote to his son William: “I am very well  But we [Mrs  Stevenson and I] are moving to another House in the same street; and I go down tomorrow to Lord LeDespencer’s to [stay a] Week till things are settled ”[39] To his son-in-law, Richard Bache, on the same day he wrote: “We are moving to another House in the [street] leaving this to Mr  Hewson ”[40] Writing to a friend on October 30, 1772 he explained: “I should sooner have answered your Questions but that in the Confusion of my Papers, occasioned by removing to another House, I could not readily find the Memorandums …”[41] On November 4, 1772 Benjamin informed his wife Deborah of the move  “We are removed to a more convenient House in the same street, Mrs  Stevenson having accommodated her Son-in-Law with that we lived in  The Removing has been a troublesome Affair, but is now over ”[42]
An agreement had been struck between the parties  Margaret and Benjamin would move to another house on Craven Street and allow Polly and William to move into No  27, the large yard behind the house being spacious enough to accommodate the anatomy school William wished to build [43] Perhaps the idea was inspired by Margaret’s next-door neighbor at No  26, Dr  John Leake, a man-midwife and founder of the Westminster Lying-in Hospital, who had built a theater adjoining his residence in which he practiced anatomy and taught midwifery [44]
After Margaret and Benjamin vacated No  27, Polly, William, their son William Jr , and William’s younger sister, Dorothy Hewson, took up residence there [45] In the 1773 Westminster Rate Books for Craven Street, Mrs  Stevenson’s (Stephenson in the Rate Books) name has been crossed out and replaced with “William Hewson ”[46] Further proof that the Hewsons had indeed moved into 27 Craven Street has been confirmed by the discovery of human and animal remains buried in the basement of No  36 (formerly No  27 and now the Benjamin Franklin House), a by-product of the dissections that took place at William’s anatomy school [47]
So what house on Craven Street did Mrs  Stevenson and Benjamin move into after vacating No  27? An examination of the Westminster Rate Books for the years 1774 and 1775 reveal them living not at No  7 on the west side of Craven Street as one might expect from the overwhelming consensus of nineteenth century guidebooks and biographies, but surprisingly at No  1 [48] The controversy of No  7 being torn down was all for naught as it had never been Franklin’s residence  Sir George was correct on that point  Unfortunately, No  1 was torn down as well in the early part of the twentieth century  The first time No  1 is mentioned as Franklin’s second residence is in the Survey of London: Volume 18, St Martin-in-The-Fields II: the Strand published by the London County Council in 1937, ironically the same County Council that had declared No  36 as Franklin’s only residence twenty-four years earlier 
From 1748 until 1772 Margaret ‘Stephenson’ occupied this house [No  27 (36)], and it was there that Benjamin Franklin settled after his arrival in London in 1757 as Agent to the General Assembly of Pennsylvania … In October, 1772, Mrs  Stevenson and Franklin removed to No  1, Craven Street (now demolished), and No  36 was for the next two years occupied by William Hewson, surgeon, who had married Mary Stevenson [49]
In the spring of 1774, William Hewson died unexpectedly of septicemia two weeks after cutting himself while dissecting a cadaver  Polly was left to care for their two young sons and was pregnant with a daughter she would give birth to in August of the same year  Is it possible that Margaret and Benjamin moved back into No  27 to assist Polly after the death of her husband as suggested in The Americanization of Benjamin Franklin?[50]
If the Westminster Rate Books are to be believed, the answer is no  For the year 1774, the Rate Books list Margaret Stevenson at No  1 and William Hewson at No  27  For the year 1775, they list Margaret Stevenson at No  1 and Magnus Falkner (Falconer/Falconar) at No  27  Magnus was William’s assistant at the anatomy school and fiancé to William’s sister, Dorothy  On his death bed, William instructed Polly, “let Mr  Falconar be my successor ”[51] Magnus would immediately take over the running of the anatomy school and continue William’s unfinished research  Four months later, he and Dorothy would marry [52] Essentially only two things changed at 27 Craven Street after William’s death: Polly gave birth to her daughter, and Magnus replaced William as the lease holder, so even if Margaret and Benjamin had wished to move back into No  27, there would have been no room for them  It is also interesting to note that considering the multiple times Benjamin wrote of his move out of No  27 (and complained of it), he never once mentioned moving back into No  27 in any of his correspondence after Mr  Hewson’s death 
Figure 6  No  36 Craven Street  (Photo courtesy of David Ross, britainexpress com)
In sum, based on the Westminster Rate Books[53] and Franklin’s correspondence, Mrs  Stevenson is known to have resided at No  27 (36) Craven Street from 1748 to 1772  It follows that, aside from the two years Franklin spent in Philadelphia from 1762 to 1764, he resided there from 1757 to 1772  Franklin’s correspondence also reveals that in the autumn of 1772, he and Mrs  Stevenson moved to another house on Craven Street  The 1773 Westminster Rate Books show her name crossed off at No  27 and William Hewson’s inserted  The following year the Rate Books list her at No  1 Craven Street  Evidence for Mrs  Stevenson and Benjamin remaining at No  1 after William’s death appears in the Westminster Rate Books for 1775 which have Mrs  Stevenson still residing at No  1 and Magnus Falkner residing at No  27  Further evidence can be construed from the lack of any mention of a move back into No  27 in Franklin’s correspondence  Despite the many theories one could devise as to why Franklin was thought to have lived at No  7 Craven Street by so many guide books and Franklin biographers of the nineteenth century, one thing is certain; at some point after Franklin’s departure to America in March of 1775, and no later than 1807, someone mistakenly associated him with No  7 on the west side of Craven Street, and it soon became his de facto residence  Credit must go to D  H  Montgomery in 1896 and Sir George in 1913 for setting the record partially straight by placing Franklin at No  27(36)  In 1937, the London County Council gave us the first accurate account of Franklin’s residences on Craven Street in the Survey of London at No  27(36) and No  1  It has been shown conclusively that No  27 was never previously numbered 7  It was, however, renumbered 36 in 1792 after ten additional houses were built at the southern end of the street and remains No  36 to this day 
[1] “Craven Street and Hungerford Lane”, in Survey of London: Volume 18, St Martin-in-the-Fields II: the Strand, ed  G H Gater and E P Wheeler (London, 1937), 27-39, Early History of the Site 
http://www british-history ac uk/survey-london/vol18/pt2/pp27-39
[2] “England, Westminster Rate Books, 1634-1900,” from database with images, Craven Street – 1735, FamilySearch from database by FindMyPast and images digitized by FamilySearch; citing Westminster City Archives, London 
[3] Ibid , Craven Street – 1748 
[4] The Statutes at Large, From Magna Charta to the End of the Eleventh Parliament of Great Britain  Anno 1761 Continued, Vol  XXVII, ed  Danby Pickering, (Cambridge, John Archdeacon, 1767), 96 
[6] James Raven, Publishing Business in Eighteenth-Century England, (Woodbridge: The Boydell Press, 2014), 201 
[7] The London Directory For the Year 1776, Ninth Edition, (London: T  Lowndes, 1776), title page 
[8] Kent’s Directory For the Year 1778, Forty-Sixth Edition, (London: Richard and Henry Causton, 1778), title page 
[9] A listing in Kent’s Directory for the Year 1882 on p  28 reveals, “Brown Sarah, Leather-seller, 1, Westmoreland-buildings, Aldersgate-street”, and in Kent’s Directory for the Year 1883 on p  175, “Whiteland Mary, Wine & Brandy Mercht  Jermyn-str  St  James ”
[10] “The Papers of Benjamin Franklin,” Sponsored by The American Philosophical Society and Yale University, Digital Edition by The Packard Humanities Institute, 22:263a 
http://franklinpapers org/franklin
Mrs  Stevenson wrote to Benjamin Franklin a letter from her new home at 75 Northumberland Court on November 16, 1775: “In this Court I have a kind friend, Mr  Lechmoen he comes and seats with me and talks of you with a hiy regard and friendship ”
[11] Survey of London, Early History of the Site 
[12] Survey of London, Footnotes/n 10 
[13] Survey of London, Historical Notes/No  31 
[14] David Hughson, LL D , London; Being An Accurate History And Description Of The British Metropolis And Its Neighbourhood, To Thirty Miles Extent, From An Actual Perambulation, Vol  IV, (London: W  Stratford, 1807), 227 
[15] The Reverend Joseph Nightingale, The Beauties of England and Wales: Or, Original Delineations, Topographical, Historical, and Descriptive, of Each County, Vol  X, Part III, Vol  II (London: J  Harris; Longman and Co ; J  Walker; R  Baldwin; Sherwood and Co ; J  and J  Cundee; B  and R  Crosby and Co ; J Cuthell; J  and J  Richardson; Cadell and Davies; C  and J  Rivington; and G  Cowie and Co , 1815), 245 
[16] John Britton, F S A  & Co , ed , The Original Picture of London, Enlarged and Improved: Being A Correct Guide For The Stranger, As Well As For the Inhabitant, To The Metropolis Of The British Empire Together With A Description Of The Environs, The Twenty-Fourth Edition (London: Longman, Rees, Orme, Brown, and Green, 1826), 479 
[17] Jared Sparks, The Works of Benjamin Franklin, Vol  VII, (Philadelphia: Childs & Peterson, 1840), 151 
[18] George Gulliver, F R S , The Works of William Hewson, F  R  S , (London: Printed for the Sydenham Society, MDCCCXLVI), xx 
[19] Peter Cunningham, Handbook for London; Past and Present, Vol  I, (London: John Murray, 1849), 245 
[20] F  Saunders, Memories of the Great Metropolis: or, London, from the Tower to the Crystal Palace, (New York: G P  Putnam, MDCCCLII), 138 
[21] Leigh Hunt, The Town; Its Memorable Characters and Events, (London: Smith, Elder and Co , 1859), 185 
[22] K  Baedeker, London and Its Environs, Including Excursions To Brighton, The Isle of Wight, Etc : Handbook For Travelers, Second Edition, (London: Dulau and Co , 1879), 133 
[23] Herbert Fry, London In 1880 Illustrated With Bird’s-Eye Views of the Principal Streets, Sixth Edition, (New York: Scribner, Welford, & Co , 1880), 50 
[24] Herbert Fry, London  Illustrated By Eighteen Bird’s-Eye Views of the Principal Streets, (London: W  H  Allen and Co , 1886), 40 
[25] Henry B  Wheatley, F S A , London Past and Present; Its History, Associations, and Traditions, Vol  1, (London: John Murray, New York: Scribner & Welford, 1891), 473 
[26] The Journal of the Society of Arts, Vol  XV, No  778, (October 18, 1867): 717 
[27] D  G  C  Allen, “Dear and Serviceable to Each Other: Benjamin Franklin and the Royal Society of Arts,” American Philosophical Society, Vol  144, No  3, (September 2000): 248-249 
Franklin was a corresponding member in 1756 because he was still residing in Philadelphia  He became an active member the following year when he moved to London 
[28] The Journal of the Society of Arts, Vol  XVIII, No  894, (Jan  7, 1870): 137 
“Since the last announcement, the following tablets have been affixed on houses formerly occupied by – Benjamin Franklin, 7 Craven-street, Strand, W C ”
[29] Franklin in His Own Time, eds  Kevin J  Haytes and Isabelle Bour, (Iowa City, University of Iowa Press, 2011), xxxvii 
“Takes lodgings with Margaret Stevenson at No  7 Craven Street ” It is unknown if the editors are referring to No  7 on the west side of Craven Street or No  36 on the east side using Sir George’s explanation of No  36 being previously numbered 7 
[30] Henry C  Shelly, “American Shrines on English Soil, III  In the Footprints of Benjamin Franklin,” in The Book News Monthly, September, 1913 to August, 1914, (Philadelphia: John Wanamaker, 1914), 325 
[31] The Journal of the Royal Society of Arts, Vol  LVI, No  2,880, (Jan  31, 1908): 245 
http://babel hathitrust org/cgi/pt?id=mdp 39015058423073;view=1up;seq=251
“His Majesty the King, who is Patron of the Society, has granted permission to the Society to prefix to its title the term ‘Royal,’ and the Society will consequently be known in future as the ‘Royal Society of Arts ’”
[32] Nineteenth Annual Report, 1914, of the American Scenic and Historic Preservation Society, (Albany: J  B  Lyon Company, 1914), 293 
http://babel hathitrust org/cgi/pt?id=wu 89072985302;view=1up;seq=4;size=150
[33] The Journal of the Society of Arts, Vol  LXII, No  3,183, (Nov  21, 1913): 18 
http://babel hathitrust org/cgi/pt?id=mdp 39015058422968;view=1up;seq=26
[36] Allen, “Dear and Serviceable,” 263-264 
[37] Papers of Benjamin Franklin, 19:20 
[38] Thomas Joseph Pettigrew, F  L  S , Memoirs of the Life and Writings of the Late John Coakley Lettsom With a Selection From His Correspondence, Vol  I, (London: Nichols, Son, and Bentley, 1817), 144 of Correspondence 
[39] Papers of Benjamin Franklin, 19:321b 
[40] Ibid , 19:314 
[41] Ibid , 19:353a 
[43] Simon David John Chaplin, John Hunter and the ‘museum oeconomy’, 1750-1800, Department of History, King’s College London  Thesis submitted for the degree of Doctor of Philosophy of the University of London , 202 
“Following Falconar’s death [1778] the lease [27 Craven Street] was advertised, and the buildings were described as:
A genteel and commodious house, in good Repair, with Coach-house and Stabling for two Horses…consisting of two rooms and light closets on each floor, with outbuildings in the Yard, a Museum, a Compleat Theatre, and other conveniences  (Daily Advertiser, 27 August 1778)”
[44] Simon Chaplin, “Dissection and Display in Eighteenth-Century London,” in Anatomical Dissection in Enlightenment England and Beyond: Autopsy, Pathology and Display, ed  Dr  Piers Mitchell, (Burlington: Ashgate Publishing Company, 2012), 108 
“Given that a nearby building at 35 [ No  26 in Franklin’s time] was occupied by the man-midwife John Leake, who advertised lectures – including lessons in the art of making preparations – at his ‘theatre’ between 1764 and 1788, it is possible that some facilities were shared  In both cases, however, the buildings [Leake’s residence at No  26 and Hewson’s residence next door at 27] served a dual function as domestic accommodation and as sites for lecturing and dissection ”
[45] George Gulliver, F R S , The Works of William Hewson, F  R  S , (London: Printed for the Sydenham Society, MDCCCXLVI), xviii 
[46] Westminster Rate Books, Craven Street – 1773, courtesy of the City of Westminster Archives 
[47] S W  Hillson et al , “Benjamin Franklin, William Hewson, and the Craven Street Bones,” Archaeology International, Vol  2, (Nov  22, 1998): 14-16 
http://dx doi org/10 5334/ai 0206
[48] Westminster Rate Books, Craven Street – 1774, 1775, courtesy of the City of Westminster Archives 
[49] Survey of London, Historical Notes/No  36, Craven Street (not sourced) 
[50] Gordon S  Wood, The Americanization of Benjamin Franklin, (New York: The Penguin Press, 2004), 261 
[51] Pettigrew, Memoirs, 146 of Correspondence 
[52] http://founders archives gov/documents/Franklin/01-22-02-0178, note 7  “Falconar married Hewson’s sister five months after the Doctor’s death; most of the Craven Street circle attended the wedding, and BF gave away the bride: Polly to Barbara Hewson, Oct  4, 1774, APS” (American Philosophical Society); “England Marriages, 1538–1973 ,” database, FamilySearch (https://familysearch org/ark:/61903/1:1:V52W-TGS : accessed September 15, 2015), Magnus Falconar and Dorothy Hewson, September 12, 1774; citing Saint Martin In The Fields, Westminster, London, England, reference ; FHL microfilm 561156, 561157, 561158, 942 B4HA V  25, 942 B4HA V  66 
[53] I chose to rely on the Westminster Rate Books for the numbering system on Craven Street  The books were consistent throughout the eighteenth century in the ordering of residents on the street and were used as the basis for the 1792 re-numbering  For the most part, commercial directories aligned with them as well  If by chance a directory didn’t initially align, it would inevitably produce future editions that did 
Benjamin Franklin, Benjamin Franklin House, London
More from David Turnquist
If one looked into Benjamin Franklin’s time on Craven Street, they might   
I think it’s very ironic that on the street maps included in your excellent article, Craven Street is so close to Scotland Yard  Because following the back and forth juxtapositions of numbers 7, 27 and 36 Craven Street (throw in 75 Northumberland Court and 1 Craven Street, too) was a case that could confound Sherlock Holmes 
Excellent job of deciphering street renumbering material spanning sixty years, including that of a wrong house number (# 7) being erroneously identified and then perpetuated in subsequent street map printings  It’s gratifying at least to know that the present day #36 Craven Street is the correct house for Ben Franklin tourists to visit  Except for #1 Craven Street for the last three years Franklin was in London, but we won’t get into that 
Again, excellent article, David!
Context 3: South Dakota v  Wayfair, Inc  - Harvard Law Review
Fourth Circuit Invalidates Maryland Statute Regulating Price Gouging in the Sale of Generic Drugs 
South Dakota Supreme Court Holds Unconstitutional State Law Requiring Internet Retailers Without In-State Physical Presence to Remit Sales Tax 
Judicial junk, the Court has long thought, is easier to scrap when the erroneous precedent cannot be fixed by Congress, as in constitutional cases 1× 1  See Burnet v  Coronado Oil & Gas Co , 285 U S  393, 405–10 (1932) (Brandeis, J , dissenting); Lee Epstein, William M  Landes & Adam Liptak, The Decision to Depart (or Not) from Constitutional Precedent: An Empirical Study of the Roberts Court, 90 N Y U  L  Rev  1115, 1116 (2015) (“[Justice Brandeis’s] dissenting opinion       now has the status of black letter law ”)  On the flip side, whenever a bad precedent can be corrected by Congress, stare decisis applies with “special force ”2× 2  See Patterson v  McLean Credit Union, 491 U S  164, 172–73 (1989)  The Court, following Justice Brandeis, usually articulates the rule as distinguishing between “constitutional” and “statutory” precedents  See, e g , id  But the distinction is occasionally said to be between “constitutional” and “nonconstitutional cases ” See, e g , Glidden Co  v  Zdanok, 370 U S  530, 543 (1962) (plurality opinion)  Nomenclature aside, the Court has — until now — adhered to Justice Brandeis’s key insight that the important factor is whether or not the mistake may be legislatively corrected  Last Term, in South Dakota v  Wayfair, Inc ,3× 3  138 S  Ct  2080 (2018)  the Court tinkered with this thinking in overruling an outdated dormant commerce clause precedent  Dormant commerce clause decisions technically produce constitutional holdings, but Congress may override them at will 4× 4  See Prudential Ins  Co  v  Benjamin, 328 U S  408, 421–27 (1946)  Under the usual logic of stare decisis, it should take special force to dislodge such precedents  But Wayfair applied the weakened stare decisis of constitutional cases, asserting that the Court must “address a false constitutional premise         whether or not Congress can or will act ”5× 5  Wayfair, 138 S  Ct  at 2096–97 
Emerging from Wayfair is an odd and ominous development in stare decisis doctrine  Odd, because it turns on a formal classification instead of on Congress’s practical ability to fix the problem  Ominous, because the Court’s logic leads far past the dormant commerce clause  Wayfair grants only feeble stare decisis to precedents that set a “constitutional default rule,”6× 6  Id  at 2096 (“While       Congress has the authority to change the physical presence rule, Congress cannot change the constitutional default rule ”)  meaning constitutional decisions that allow for legislative adjustment or override  This new stare decisis analysis makes other precedents setting constitutional default rules more vulnerable — including, perhaps, mainstays of criminal procedure like Miranda v  Arizona7× 7  384 U S  436 (1966)  and Mapp v  Ohio 8× 8  367 U S  643 (1961) 
Since its 1967 decision in National Bellas Hess, Inc  v  Department of Revenue,9× 9  386 U S  753 (1967)  the Court has held that, under the “dormant” or “negative” implication of the Commerce Clause,10× 10  The dormant or negative commerce clause is a judicial derivation from the Commerce Clause “prohibiting States from discriminating against or imposing excessive burdens on interstate commerce without congressional approval,” which “strikes at one of the chief evils that led to the adoption of the Constitution, namely, state tariffs and other laws that burdened interstate commerce ” Comptroller of the Treasury of Md  v  Wynne, 135 S  Ct  1787, 1794 (2015)  states may not compel remote sellers with no physical presence in the state to collect and remit sales taxes 11× 11  See Bellas Hess, 386 U S  at 759–60  In Quill Corp  v  North Dakota,12× 12  504 U S  298 (1992)  the Court refused to overrule the “bright-line, physical-presence requirement” of Bellas Hess, leaning heavily on stare decisis 13× 13  Id  at 317–18  Three Justices joined a concurrence explaining that their decision rested solely “on the basis of stare decisis ” Id  at 320 (Scalia, J , concurring in part and concurring in the judgment)  So the physical presence test remained the law of the land while the internet conquered the earth  Justice Kennedy had joined the Quill majority and Justice Scalia’s concurring opinion emphasizing stare decisis, but by 2015 he had second thoughts  Writing separately in Direct Marketing Ass’n v  Brohl,14× 14  135 S  Ct  1124 (2015)  Justice Kennedy acknowledged that “[t]he Internet has caused far-reaching systemic and structural changes in the economy” and therefore “Quill now harms States to a degree far greater than could have been anticipated earlier ”15× 15  Id  at 1135 (Kennedy, J , concurring)  He concluded with the wish that “[t]he legal system should find an appropriate case for this Court to reexamine Quill and Bellas Hess ”16× 16  Id 
Seldom has a concurring opinion signed by a lone Justice prompted a state to officially declare an emergency  Yet in 2016, in response to Justice Kennedy’s overture, the South Dakota legislature passed a law, S B  106, “to provide for the collection of sales taxes from certain remote sellers       and to declare an emergency ”17× 17  2016 S D  Sess  Laws ch  70 pmbl  217 (codified at S D  Codified Laws § 10-64 (2017))  It required every remote seller to collect and remit sales tax if the seller’s business in South Dakota comprised either a “gross revenue” greater than $100,000 or at least 200 “separate transactions” within one calendar year 18× 18  Id  § 1  Significantly, the law did not apply retroactively 19× 19  Id  § 5  The “emergency” declaration was necessary to give the law immediate effect, for the purpose of “permitting the most expeditious possible review of the constitutionality of this law” by the U S  Supreme Court 20× 20  Id  § 8(8)  As Justice Alito put it, the “South Dakota law [was] obviously a test case ”21× 21  Transcript of Oral Argument at 27, Wayfair, 138 S  Ct  2080 (No  17-494), https://www supremecourt gov/oral_arguments/argument_transcripts/2017/17-494_7lho pdf [https://perma cc/8HYH-VU8N] 
Expeditiously, a group of remote sellers challenged the law  After being sued by South Dakota for refusing to register for the newly required sales tax license, Wayfair, Inc , Overstock com, Inc , and Newegg, Inc  moved for summary judgment in South Dakota circuit court on the grounds that S B  106 was unconstitutional under Quill and Bellas Hess — a point South Dakota conceded, indicating that it was seeking review by the U S  Supreme Court to overturn Quill 22× 22  State v  Wayfair Inc , 2017 SD 56, ¶¶ 9–11, 901 N W 2d 754, 759–60  Accordingly, the South Dakota circuit court granted the motion for summary judgment and South Dakota appealed to the state’s highest court 23× 23  Id  ¶ 12, 901 N W 2d at 760  The South Dakota Supreme Court unanimously affirmed, recognizing that South Dakota’s “arguments on the merits” may be “persuasive” but “Quill remains the controlling precedent ”24× 24  Id  ¶ 18, 901 N W 2d at 761  See generally Recent Case, State v  Wayfair Inc , 2017 SD 56, 901 N W 2d 754 (S D  2017), 131 Harv  L  Rev  2089 (2018) 
The U S  Supreme Court vacated and remanded 25× 25  Wayfair, 138 S  Ct  at 2100  Writing for the Court one last time, Justice Kennedy26× 26  Justices Thomas, Ginsburg, Alito, and Gorsuch joined Justice Kennedy’s opinion  pilloried Quill’s physical presence rule as “arbitrary, formalistic,” “anachronistic,” and “unfair and unjust” to both states and brick-and-mortar retailers 27× 27  Wayfair, 138 S  Ct  at 2092, 2095  After all, the rationale of Quill was that remote sellers lacked a sufficiently “substantial nexus” with the state to justify imposing a duty of tax collection 28× 28  Quill Corp  v  North Dakota, 504 U S  298, 311 (1992) (quoting Complete Auto Transit, Inc  v  Brady, 430 U S  274, 279 (1977))  This was wrong even in the mail-order catalog days of 1967 and 1992, but “the Internet revolution has made [Quill’s] earlier error all the more egregious and harmful ”29× 29  Wayfair, 138 S  Ct  at 2097; see also id  at 2092  The rule deprived the states of billions of dollars, since they could not force remote sellers to collect the tax and consumers hardly ever paid it on their own 30× 30  Id  at 2088 (“[C]onsumer compliance rates are notoriously low ”)  Quill “serve[d] as a judicially created tax shelter” for remote retailers who do a great deal of business online 31× 31  Id  at 2094 
Satisfied that Bellas Hess and Quill were wrongly decided, the Court then jumped the hurdle of stare decisis  The Quill Court had feared upsetting reliance interests 32× 32  Quill, 504 U S  at 317 (“Bellas Hess       has engendered substantial reliance and has become part of the basic framework of a sizable industry ”)  Wayfair shrugged off this concern, noting that “stare decisis accommodates only ‘legitimate reliance interest[s]’”; by contrast, reliance on the physical presence rule was largely due to consumers evading their use-tax obligations 33× 33  Wayfair, 138 S  Ct  at 2098 (alteration in original) (quoting United States v  Ross, 456 U S  798, 824 (1982))  Quill had also appealed to Congress’s ultimate authority over interstate commerce as a reason to abide by a precedent, even if wrongly decided 34× 34  See Quill, 504 U S  at 318–19; id  at 320 (Scalia, J , concurring in part and concurring in the judgment) (“Congress   



ground_truth: An alphabetical list of names and places of abode of the merchants and principal traders of the cities of London and Westminster, the Borough of Southwark, and their environs, with the number affixed to each house.

prompt_front: Now, answer the following question based on the text below, only give me the answer and do not output any other words.

Question: What molecule was the focus of the study?

Read the following text and answer briefly.

Context 2: \section{Introduction}

Spectral line surveys have revealed that high-mass star-forming
regions are rich reservoirs of molecules from simple diatomic species
to complex and larger molecules (e g ,
\citealt{schilke1997b,hatchell1998b,comito2005,bisschop2007}) 
However, there have been rarely studies undertaken to investigate the
chemical evolution during massive star formation from the earliest
evolutionary stages, i e , from High-Mass Starless Cores (HMSCs) and
High-Mass Cores with embedded low- to intermediate-mass protostars
destined to become massive stars, via High-Mass Protostellar Objects
(HMPOs) to the final stars that are able to produce Ultracompact H{\sc
  ii} regions (UCH{\sc ii}s, see \citealt{beuther2006b} for a recent
description of the evolutionary sequence)  The first two evolutionary
stages are found within so-called Infrared Dark Clouds (IRDCs)   While
for low-mass stars the chemical evolution from early molecular
freeze-out to more evolved protostellar cores is well studied (e g ,
\citealt{bergin1997,dutrey1997,pavlyuchenkov2006,joergensen2007}),
it is far from clear whether similar evolutionary patterns are present
during massive star formation 

To better understand the chemical evolution of high-mass star-forming
regions we initiated a program to investigate the chemical properties
from IRDCs to UCH{\sc ii}s from an observational and theoretical
perspective  We start with single-dish line surveys toward a large
sample obtaining their basic characteristics, and then perform
detailed studies of selected sources using interferometers on smaller
scales  These observations are accompanied by theoretical modeling of
the chemical processes   Long-term goals are the chemical
characterization of the evolutionary sequence in massive star
formation, the development of chemical clocks, and the identification
of molecules as astrophysical tools to study the physical processes
during different evolutionary stages  Here, we present an initial
study of the reactive radical ethynyl (C$_2$H) combining single-dish
and interferometer observations with chemical modeling   Although
C$_2$H was previously observed in low-mass cores and Photon Dominated
Regions (e g , \citealt{millar1984,jansen1995}), so far it was not
systematically investigated in the framework of high-mass star
formation 

\section{Observations}
\label{obs}

The 21 massive star-forming regions were observed with the Atacama
Pathfinder Experiment (APEX) in the 875\,$\mu$m window in fall 2006 
We observed 1\,GHz from 338 to 339\,GHz and 1\,GHz in the image
sideband from 349 to 350\,GHz   The spectral resolution was
0 1\,km\,s$^{-1}$, but we smoothed the data to
$\sim$0 9\,km\,s$^{-1}$  The average system temperatures were around
200\,K, each source had on-source integration times between 5 and 16
min  The data were converted to main-beam temperatures with forward
and beam efficiencies of 0 97 and 0 73, respectively
\citep{belloche2006}  The average $1\sigma$ rms was 0 4\,K   The main
spectral features of interest are the C$_2$H lines around 349 4\,GHz
with upper level excitation energies $E_u/k$ of 42\,K (line blends of
C$_2$H$(4_{5,5}-3_{4,4})$ \& C$_2$H$(4_{5,4}-3_{4,3})$ at
349 338\,GHz, and C$_2$H$(4_{4,4}-3_{3,3})$ \&
C$_2$H$(4_{4,3}-3_{3,2})$ at 349 399\,GHz)  The beam size was $\sim
18''$ 

The original Submillimeter Array (SMA) C$_2$H data toward the
HMPO\,18089-1732 were first presented in \citet{beuther2005c}  There
we used the compact and extended configurations resulting in good
images for all spectral lines except of C$_2$H  For this project, we
re-worked on these data only using the compact configuration  Because
the C$_2$H emission is distributed on larger scales (see
\S\ref{results}), we were now able to derive a C$_2$H image  The
integration range was from 32 to 35\,km\,s$^{-1}$, and the achieved
$1\sigma$ rms of the C$_2$H image was 450\,mJy\,beam$^{-1}$   For more
details on these observations see \citet{beuther2005c} 

\section{Results}
\label{results}

The sources were selected to cover all evolutionary stages from IRDCs
via HMPOs to UCH{\sc ii}s  We derived our target list from the samples
of \citet{klein2005,fontani2005,hill2005,beltran2006}   Table
\ref{sample} lists the observed sources, their coordinates, distances,
luminosities and a first order classification into the evolutionary
sub-groups IRDCs, HMPOs and UCH{\sc ii}s based on the previously
available data  Although this classification is only based on a
limited set of data, here we are just interested in general
evolutionary trends  Hence, the division into the three main classes
is sufficient 

Figure \ref{spectra} presents sample spectra toward one source of each
evolutionary group  While we see several CH$_3$OH lines as well as
SO$_2$ and H$_2$CS toward some of the HMPOs and UCH{\sc ii}s but not
toward the IRDCs, the surprising result of this comparison is the
presence of the C$_2$H lines around 349 4\,GHz toward all source types
from young IRDCs via the HMPOs to evolved UCH{\sc ii}s   Table
\ref{sample} lists the peak brightness temperatures, the integrated
intensities and the FWHM line-widths of the C$_2$H line blend at
349 399\,GHz  The separation of the two lines of 1 375\,MHz already
corresponds to a line-width of 1 2\,km\,s$^{-1}$  We have three C$_2$H
non-detections (2 IRDCs and 1 HMPO), however, with no clear trend with
respect to the distances or the luminosities (the latter comparison is
only possible for the HMPOs)  While IRDCs are on average colder than
more evolved sources, and have lower brightness temperatures, the
non-detections are more probable due to the relatively low sensitivity
of the short observations (\S\ref{obs})  Hence, the data indicate
that the C$_2$H lines are detected independent of the evolutionary
stage of the sources in contrast to the situation with other
molecules   When comparing the line-widths between the different
sub-groups, one finds only a marginal difference between the IRDCs and
the HMPOs (the average $\Delta v$ of the two groups are 2 8 and
3 1\,km\,s$^{-1}$)   However, the UCH{\sc ii}s exhibit significantly
broader line-widths with an average value of 5 5\,km\,s$^{-1}$ 

Intrigued by this finding, we wanted to understand the C$_2$H spatial
structure during the different evolutionary stages   Therefore, we
went back to a dataset obtained with the Submillimeter Array toward
the hypercompact H{\sc ii} region IRAS\,18089-1732 with a much higher
spatial resolution of $\sim 1''$ \citep{beuther2005c}   Albeit this
hypercompact H{\sc ii} region belongs to the class of HMPOs, it is
already in a relatively evolved stage and has formed a hot core with a
rich molecular spectrum   \citet{beuther2005c} showed the spectral
detection of the C$_2$H lines toward this source, but they did not
present any spatially resolved images  To recover large-scale
structure, we restricted the data to those from the compact SMA
configuration (\S\ref{obs})  With this refinement, we were able to
produce a spatially resolved C$_2$H map of the line blend at
349 338\,GHz with an angular resolution of $2 9''\times 1 4''$
(corresponding to an average linear resolution of 7700\,AU at the
given distance of 3 6\,kpc)  Figure \ref{18089} presents the
integrated C$_2$H emission with a contour overlay of the 860\,$\mu$m
continuum source outlining the position of the massive protostar  In
contrast to almost all other molecular lines that peak along with the
dust continuum \citep{beuther2005c}, the C$_2$H emission surrounds the
continuum peak in a shell-like fashion 

\section{Discussion and Conclusions}

To understand the observations, we conducted a simple chemical
modeling of massive star-forming regions  A 1D cloud model with a mass
of 1200\,M$_\sun$, an outer radius of 0 36\,pc and a power-law density
profile ($\rho\propto r^p$ with $p=-1 5$) is the initially assumed
configuration  Three cases are studied: (1) a cold isothermal cloud
with $T=10$\,K, (2) $T=50$\,K, and (3) a warm model with a temperature
profile $T\propto r^q$ with $q=-0 4$ and a temperature at the outer
radius of 44\,K  The cloud is illuminated by the interstellar UV
radiation field (IRSF, \citealt{draine1978}) and by cosmic ray
particles (CRP)  The ISRF attenuation by single-sized $0 1\mu$m
silicate grains at a given radius is calculated in a plane-parallel
geometry following \citet{vandishoeck1988}  The CRP ionization rate is
assumed to be $1 3\times 10^{-17}$~s$^{-1}$ \citep{spitzer1968}  The
gas-grain chemical model by \citet{vasyunin2008} with the desorption
energies and surface reactions from \citet{garrod2006} is used 
Gas-phase reaction rates are taken from RATE\,06 \citep{woodall2007},
initial abundances, were adopted from the ``low metal'' set of
\citet{lee1998} 

Figure \ref{model} presents the C$_2$H abundances for the three models
at two different time steps: (a) 100\,yr, and (b) in a more evolved
stage after $5\times10^4$\,yr  The C$_2$H abundance is high toward the
core center right from the beginning of the evolution, similar to
previous models (e g , \citealt{millar1985,herbst1986,turner1999}) 
During the evolution, the C$_2$H abundance stays approximately
constant at the outer core edges, whereas it decreases by more than
three orders of magnitude in the center, except for the cold $T=10$~K
model   The C$_2$H abundance profiles for all three models show
similar behavior 

The chemical evolution of ethynyl is determined by relative removal
rates of carbon and oxygen atoms or ions into molecules like CO, OH,
H$_2$O  Light ionized hydrocarbons CH$^+_{\rm n}$ (n=2  5) are quickly
formed by radiative association of C$^+$ with H$_2$ and hydrogen
addition reactions: C$^+$ $\rightarrow$ CH$_2^+$ $\rightarrow$
CH$_3^+$ $\rightarrow$ CH$_5^+$   The protonated methane reacts with
electrons, CO, C, OH, and more complex species at later stage and
forms methane   The CH$_4$ molecules undergo reactive collisions with
C$^+$, producing C$_2$H$_2^+$ and C$_2$H$_3^+$  An alternative way to
produce C$_2$H$_2^+$ is the dissociative recombination of CH$_5^+$
into CH$_3$ followed by reactions with C$^+$   Finally, C$_2$H$_2^+$
and C$_2$H$_3^+$ dissociatively recombine into CH, C$_2$H, and
C$_2$H$_2$  The major removal for C$_2$H is either the direct
neutral-neutral reaction with O that forms CO, or the same reaction
but with heavier carbon chain ions that are formed from C$_2$H by
subsequent insertion of carbon  At later times, depletion and
gas-phase reactions with more complex species may enter into this
cycle   At the cloud edge the interstellar UV radiation
instantaneously dissociates CO despite its self-shielding,
re-enriching the gas with elemental carbon 

The transformation of C$_2$H into CO and other species proceeds
efficiently in dense regions, in particular in the ``warm'' model
where endothermic reactions result in rich molecular complexity of the
gas (see Fig ~\ref{model})   In contrast, in the ``cold'' 10\,K model
gas-grain interactions and surface reactions become important   As a
result, a large fraction of oxygen is locked in water ice that is hard
to desorb ($E_{\rm des} \sim 5500$~K), while half of the elemental
carbon goes to volatile methane ice ($E_{\rm des} \sim 1300$~K)  Upon
CRP heating of dust grains, this leads to much higher gas-phase
abundance of C$_2$H in the cloud core for the cold model compared to
the warm model  The effect is not that strong for less dense regions
at larger radii from the center 

Since the C$_2$H emission is anti-correlated with the dust continuum
emission in the case of IRAS\,18089-1732 (Fig \,\ref{18089}), we do
not have the H$_2$ column densities to quantitatively compare the
abundance profiles of IRAS\,18089-1732 with our model  However, data
and model allow a qualitative comparison of the spatial structures 
Estimating an exact evolutionary time for IRAS\,18089-1732 is hardly
possible, but based on the strong molecular line emission, its high
central gas temperatures and the observed outflow-disk system
\citep{beuther2004a,beuther2004b,beuther2005c}, an approximate age of
$5\times10^4$\,yr appears reasonable   Although dynamical and chemical
times are not necessarily exactly the same, in high-mass star
formation they should not differ to much: Following the models by
\citet{mckee2003} or \citet{krumholz2006b}, the luminosity rises
strongly right from the onset of collapse which can be considered as a
starting point for the chemical evolution  At the same time disks and
outflows evolve, which should hence have similar time-scales   The
diameter of the shell-like C$_2$H structure in IRAS\,18089-1732 is
$\sim 5''$ (Fig \,\ref{18089}), or $\sim$9000\,AU in radius at the
given distance of 3 6\,kpc   This value is well matched by the modeled
region with decreased C$_2$H abundance (Fig \,\ref{model})   Although
in principle optical depths and/or excitation effects could mimic the
C$_2$H morphology, we consider this as unlikely because the other
observed molecules with many different transitions all peak toward the
central submm continuum emission in IRAS\,18089-1732
\citep{beuther2005c}  Since C$_2$H is the only exception in that rich
dataset, chemical effects appear the more plausible explanation 

The fact that we see C$_2$H at the earliest and the later evolutionary
stages can be explained by the reactive nature of C$_2$H: it is
produced quickly early on and gets replenished at the core edges by
the UV photodissociation of CO  The inner ``chemical'' hole observed
toward IRAS\,18089-1732 can be explained by C$_2$H being consumed in
the chemical network forming CO and more complex molecules like larger
carbon-hydrogen complexes and/or depletion 

The data show that C$_2$H is not suited to investigate the central gas
cores in more evolved sources, however, our analysis indicates that
C$_2$H may be a suitable tracer of the earliest stages of (massive)
star formation, like N$_2$H$^+$ or NH$_3$ (e g ,
\citealt{bergin2002,tafalla2004,beuther2005a,pillai2006})  While a
spatial analysis of the line emission will give insights into the
kinematics of the gas and also the evolutionary stage from chemical
models, multiple C$_2$H lines will even allow a temperature
characterization  With its lowest $J=1-0$ transitions around 87\,GHz,
C$_2$H has easily accessible spectral lines in several bands between
the 3\,mm and 850\,$\mu$m   Furthermore, even the 349\,GHz lines
presented here have still relatively low upper level excitation
energies ($E_u/k\sim42$\,K), hence allowing to study cold cores even
at sub-millimeter wavelengths   This prediction can further be proved
via high spectral and spatial resolution observations of different
C$_2$H lines toward young IRDCs 

\acknowledgments{H B  acknowledges financial support
  by the Emmy-Noether-Programm of the Deutsche Forschungsgemeinschaft
  (DFG, grant BE2578)  }



Context 3:    can change the rule of Bellas Hess by simply saying so ”)  But Wayfair denied that Congress’s ability to change the law was a proper consideration:
While it can be conceded that Congress has the authority to change the physical presence rule, Congress cannot change the constitutional default rule  It is inconsistent with the Court’s proper role to ask Congress to address a false constitutional premise of this Court’s own creation  Courts have acted as the front line of review in this limited sphere; and hence it is important that their principles be accurate and logical, whether or not Congress can or will act in response 35× 35  Wayfair, 138 S  Ct  at 2096–97 
Having dispensed with the physical presence rule, the Court remanded the case to the South Dakota courts to determine in the first instance “whether some other principle in the Court’s Commerce Clause doctrine might invalidate the Act ”36× 36  Id  at 2099  But the Court listed “several features [of South Dakota law] that appear[ed] designed to prevent discrimination against or undue burdens upon interstate commerce ” Id 
Justices Thomas and Gorsuch each filed concurring opinions  Justice Thomas wistfully likened himself to Justice White — who voted for Bellas Hess but against Quill a quarter-century later — and confessed that he “should have joined [Justice White’s dissenting] opinion ”37× 37  Id  at 2100 (Thomas, J , concurring)  Justice Thomas added that the “Court’s entire negative Commerce Clause jurisprudence” is wrong and should be abandoned 38× 38  Id  Justice Gorsuch also wrote separately to express skepticism of the Court’s dormant commerce clause jurisprudence, raising “questions for another day” of whether the doctrine “can be squared with the text of the Commerce Clause, justified by stare decisis, or defended as misbranded products of federalism or antidiscrimination imperatives flowing from Article IV’s Privileges and Immunities Clause ”39× 39  Id  at 2100–01 (Gorsuch, J , concurring) 
Chief Justice Roberts dissented 40× 40  Justices Breyer, Sotomayor, and Kagan joined the Chief Justice’s dissent  Surprisingly, the dissenting Justices “agree[d] that Bellas Hess was wrongly decided, for many of the reasons given by the Court ”41× 41  Wayfair, 138 S  Ct  at 2101 (Roberts, C J , dissenting)  The dispute between the majority and the dissent turned entirely on the principles and application of stare decisis  Chief Justice Roberts argued that whether or how to reverse Quill should be left to Congress, which “has the flexibility to address these questions in a wide variety of ways” and “can focus directly on current policy concerns rather than past legal mistakes ”42× 42  Id  at 2104  He also pointed to the “baffling” burdens of compliance with the idiosyncratic tax codes of “[o]ver 10,000 jurisdictions,” particularly for small businesses, and doubted that new “software” — the majority’s proposed solution to this mess43× 43  Id  at 2098 (majority opinion) (“Eventually, software that is available at a reasonable cost may make it easier for small businesses to cope with these problems ”)  — would soon solve the problem 44× 44  Id  at 2103–04 (Roberts, C J , dissenting)  In Bellas Hess, the Court reasoned that the dormant commerce clause protects interstate business from being “entangle[d]       in a virtual welter of complicated obligations to local jurisdictions ” Nat’l Bellas Hess, Inc  v  Dep’t of Revenue, 386 U S  753, 759–60 (1967)  The dissent replied that the Court “vastly underestimate[d] the skill of contemporary man and his machines ” Id  at 766 (Fortas, J , dissenting)  The dispute in Wayfair over whether software is up to the task effectively reprised the old debate from Bellas Hess, only this time couched as part of the stare decisis inquiry’s concern for reliance interests rather than as a matter of dormant commerce clause doctrine  While Wayfair acknowledged that “[c]omplex state tax systems could have the effect of discriminating against interstate commerce,” 138 S  Ct  at 2099, the Court remarked that “[t]he physical presence rule is a poor proxy” for an inquiry into any actual burdens imposed on interstate commerce, id  at 2093 
Chief Justice Roberts emphasized that a “heightened form of stare decisis”45× 45  Wayfair, 138 S  Ct  at 2102 (Roberts, C J , dissenting)  applies when “Congress       can, if it wishes, override this Court’s decisions with contrary legislation ”46× 46  Id  at 2101 (first citing Michigan v  Bay Mills Indian Cmty , 134 S  Ct  2024, 2036 (2014) (tribal sovereign immunity); then citing Kimble v  Marvel Entm’t, LLC, 135 S  Ct  2401, 2409 (2015) (statutory interpretation); and then citing Halliburton Co  v  Erica P  John Fund, Inc , 134 S  Ct  2398, 2411 (2014) (judicially created doctrine implementing a judicially created cause of action))  In Quill, the Chief Justice noted, the Court had taken to heart that “Congress may be better qualified” and “has the ultimate power to resolve” the question47× 47  Id  at 2102 (quoting Quill Corp  v  North Dakota, 504 U S  279, 318 (1992))  while Justice Scalia had “recogniz[ed] that stare decisis has ‘special force’ in the dormant Commerce Clause context due to Congress’s ‘final say over regulation of interstate commerce ’”48× 48  Id  (quoting Quill, 504 U S  at 320 (Scalia, J , concurring in part and concurring in the judgment))  Moreover, “[i]f stare decisis applied with special force in Quill, it should be an even greater impediment” afterward since Quill effectively “tossed [the ball] into Congress’s court ”49× 49  Id  (alteration in original) (quoting Kimble, 135 S  Ct  at 2409); cf  Bay Mills, 134 S  Ct  at 2039 n 12 (“When we inform Congress that it has primary responsibility over a sphere of law, and invite Congress to consider a specific issue within that sphere, we cannot deem irrelevant how Congress responds ”)  Because the Court invited Congress to act and then “suddenly chang[ed] the ground rules, the Court may have waylaid Congress’s consideration of the issue ”50× 50  Wayfair, 138 S  Ct  at 2102–03 (Roberts, C J , dissenting) 
In Wayfair, the Court applied the flimsier form of stare decisis to a precedent that could have been overruled by Congress  It did so in the context of a dormant commerce clause case, but Wayfair’s logic extends to all constitutional default rules — that is, constitutional decisions that Congress remains free to change  Not only does Wayfair deviate from the Court’s decades-old stare decisis analysis, it also imperils other precedents that set constitutional default rules 
The Court’s reasoning in Wayfair departs from its prior stare decisis analysis  In 1932, Justice Brandeis posited that stare decisis must bend “in cases involving the Federal Constitution, where correction through legislative action is practically impossible ”51× 51  Burnet v  Coronado Oil & Gas Co , 285 U S  393, 406–07 (1932) (Brandeis, J , dissenting)  The Court has long since adopted his argument,52× 52  See, e g , Smith v  Allwright, 321 U S  649, 665 (1944)  as well as its corollary — that stare decisis commands “special force in the area of statutory interpretation” where “Congress remains free to alter what [the Court has] done ”53× 53  Patterson v  McLean Credit Union, 491 U S  164, 172–73 (1989)  For normative evaluations of heightened stare decisis for statutory precedents, see generally Einer Elhauge, Statutory Default Rules: How to Interpret Unclear Legislation 211–23 (2008); and William N  Eskridge, Jr , Overruling Statutory Precedents, 76 Geo  L J  1361, 1364–1409 (1988)  Justice Brandeis’s logic demands that dormant commerce clause cases, where Congress is free to act, be granted the weightier stare decisis 54× 54  Scholars have noted the curious fact that Justice Brandeis included many dormant commerce clause cases as examples of overruled constitutional precedents  See, e g , Earl M  Maltz, Commentary, Some Thoughts on the Death of Stare Decisis in Constitutional Law, 1980 Wis  L  Rev  467, 468–469, 469 n 11  One explanation for this is that Justice Brandeis sought the authority of Chief Justice Taney’s dictum that the Court’s “opinion upon the construction of the Constitution is always open to discussion” — which referred to the dormant commerce clause  See Burnet, 285 U S  at 408 n 3 (Brandeis, J , dissenting) (quoting The Passenger Cases, 48 U S  (7 How ) 283, 470 (1849) (Taney, C J , dissenting))  In Chief Justice Taney’s time, it was thought that Congress could not override the Court’s dormant commerce clause decisions, see Cooley v  Bd  of Wardens, 53 U S  (12 How ) 299, 321 (1852), so the context of Chief Justice Taney’s dictum does not conflict with Justice Brandeis’s theory of stare decisis  The Court applied this reasoning in Quill, as Chief Justice Roberts underscored 55× 55  Wayfair, 138 S  Ct  at 2102 (Roberts, C J , dissenting) 
Yet the Wayfair majority refused to consider Congress’s authority to legislate as a relevant factor for stare decisis 56× 56  Even Justice Kennedy’s earlier opinion in Direct Marketing contemplated judicially overruling Quill, conspicuously neglecting a possible legislative solution  See supra p  278  The Court even insisted that to do so “is inconsistent with the Court’s proper role,” since Quill embodied “a false constitutional premise of th[e] Court’s own creation ”57× 57  Wayfair, 138 S  Ct  at 2096 (emphasis added)  This refusal breaks from the practical Brandeisian wisdom that has guided the Court’s treatment of precedent for the better part of a century  The point is not that stare decisis should have ultimately propped up Bellas Hess yet again, as Wayfair’s dissenting Justices maintained  After all, a realistic approach that is alert to each branch’s institutional capacities might have led to the conclusion that Congress was actually ill-equipped to overrule Quill  In this vein, the Court could have sensibly pointed out that Congress is unlikely to stick its neck out with a tax hike (or a look-alike) from which only the states would benefit 58× 58  For two practical arguments to this effect, see Brian Galle, Essay, Kill Quill, Keep the Dormant Commerce Clause: History’s Lessons on Congressional Control of State Taxation, 70 Stan  L  Rev  Online 158, 160–62 (2018), https://review law stanford edu/wp-content/uploads/sites/3/2018/03/70-Stan -L -Rev -Online-158-Galle pdf [https://perma cc/22YP-P4V5]; Edward A  Zelinsky, The Political Process Argument for Overruling Quill, 82 Brook  L  Rev  1177, 1191–92 (2017)  Indeed, South Dakota advanced such practical arguments in its brief 59× 59  See Petitioner’s Brief at 54, Wayfair, 138 S  Ct  2080 (No  17-494) (“Congress has little incentive to act here because it would be (or appear to be) authorizing new or greater tax collections from its constituents, while receiving none of the revenue in return ”)  More generally, the Court might have discussed the limits of the states’ influence in the federal system as a reason not to wait for congressional intervention, a topic it has debated on other occasions 60× 60  See Richard H  Pildes, Institutional Formalism and Realism in Constitutional and Public Law, 2013 Sup  Ct  Rev  1, 30–32; see also Galle, supra note 58, at 159 (“Congress is not a trustworthy guardian of state fiscal power, making continuing judicial involvement a more appealing prospect ”)  Or it could have argued that new facts on the ground — namely, the blast of e-commerce that hit like a comet after Quill — overpowered stare decisis of any force, special or plain 61× 61  Two recent studies of stare decisis highlighted the physical presence rule as exemplifying a precedent that may reasonably be overruled due to changed facts  See Bryan A  Garner et al , The Law of Judicial Precedent 364–65 (2016); Randy J  Kozel, Settled Versus Right: A Theory of Precedent 112–13 (2017)  It should be noted that the authors of The Law of Judicial Precedent classify the physical presence rule as a constitutional precedent for stare decisis purposes, thus anticipating the Court’s misstep in Wayfair  Garner et al , supra, at 354–65  Because even statutory precedents may sometimes be overruled,62× 62  See Patterson v  McLean Credit Union, 491 U S  164, 173–74 (1989) (discussing justifications for overruling statutory precedents)  Contra Lawrence C  Marshall, “Let Congress Do It”: The Case for an Absolute Rule of Statutory Stare Decisis, 88 Mich  L  Rev  177 (1989)  the Court could have killed Quill without first planting its constitutional kiss of death 63× 63  Cf  Thomas R  Lee, Stare Decisis in Historical Perspective: From the Founding Era to the Rehnquist Court, 52 Vand  L  Rev  647, 704 (1999) (“Justice Brandeis’       memorable prose has since become a mandatory part of the burial rite for any constitutional precedent ”) 
The Court resisted such arguments  Instead, Wayfair reasoned that Congress’s total ability to correct an erroneous decision counts for nothing when the Court gets the Constitution wrong  That such a theory sprouts from a case like Wayfair, which repudiated a “formalistic distinction,”64× 64  Wayfair, 138 S



ground_truth: The focus of the study was on the reactive radical ethynyl (C$_2$H).

prompt_front: Now, answer the following question based on the text below, only give me the answer and do not output any other words.

Question: What did Justice Kennedy argue about Quill in Direct Marketing Ass'n v. Brohl?

Read the following text and answer briefly.

Context 3:  Ct  at 2092  is ironic  Wayfair’s stare decisis analysis resorts to the formalism of making constitutional a “magic” word65× 65  See Transcript of Oral Argument, supra note 21, at 12  rather than asking whether Congress can step in 
Moreover, the Court’s new thinking on stare decisis threatens other constitutional default rules  Wayfair now stands for the proposition that a “constitutional default rule” — a term the Court apparently lifted from South Dakota’s reply brief on the merits66× 66  Reply Brief at 22, Wayfair, 138 S  Ct  2080 (No  17-494) (“Congress is polarized, which makes it critical       to get the constitutional default rule right ”)  — gets only weakened stare decisis  To appreciate why this holding matters, it is worth exploring the concept and scope of constitutional default rules  Contract theory describes default rules as legal rules that the parties may “contract around ”67× 67  See, e g , Ian Ayres & Robert Gertner, Filling Gaps in Incomplete Contracts: An Economic Theory of Default Rules, 99 Yale L J  87, 87 (1989)  Although “constitutional default rule” could be read broadly to include a variety of actors and contracting mechanisms,68× 68  See John Ferejohn & Barry Friedman, Toward a Political Theory of Constitutional Default Rules, 33 Fla  St  U  L  Rev  825, 826 (2006) (“When we speak of default rules in constitutional law, we typically are talking about specifications of ways the government can act (or modify its behavior) to get around a constitutional prohibition ”)  the Court’s use of the term for purposes of stare decisis may be narrowly defined as judicial precedents of constitutional law that “are ultimately subject to congressional control ”69× 69  Gillian E  Metzger, Congress, Article IV, and Interstate Relations, 120 Harv  L  Rev  1468, 1525 (2007) (describing judicially enforceable “constitutional default rules imposing obligations on the states in the name of union [that] are ultimately subject to congressional control”)  The dormant commerce clause is a paradigmatic constitutional default rule because what the Court does today Congress may undo tomorrow  Justice Scalia declared this fact “[t]he clearest sign that the negative Commerce Clause is a judicial fraud,” for “[h]ow could congressional consent lift a constitutional prohibition?”70× 70  Comptroller of the Treasury of Md  v  Wynne, 135 S  Ct  1787, 1808 (2015) (Scalia, J , dissenting)  But that’s what a constitutional default rule is  The Court has allowed Congress to overturn its dormant commerce clause cases since 1891 71× 71  See In re Rahrer, 140 U S  545, 560–62 (1891) 
Dormant commerce clause cases are not the only constitutional default rules  Professor Laurence Tribe’s treatise identifies two others 72× 72  1 Laurence H  Tribe, American Constitutional Law § 6-35 (3d ed  2000)  And in a groundbreaking article, Professor Henry Monaghan revealed “a substructure of substantive, procedural, and remedial rules” forming “a constitutional common law subject to amendment, modification, or even reversal by Congress ”73× 73  Henry P  Monaghan, The Supreme Court, 1974 Term — Foreword: Constitutional Common Law, 89 Harv  L  Rev  1, 2–3 (1975); see also Susan R  Klein, Identifying and (Re)Formulating Prophylactic Rules, Safe Harbors, and Incidental Rights in Constitutional Criminal Procedure, 99 Mich  L  Rev  1030 (2001) (further developing Monaghan’s theory in criminal procedure context)  What follows is a list of six lines of cases beyond the dormant commerce clause that may be fairly described as constitutional default rules  The first two are drawn from Tribe’s treatise while the next four are found in Monaghan’s article:
(1) State Taxation of Federal Instrumentalities: States may not tax instrumentalities of the federal government74× 74  McCulloch v  Maryland, 17 U S  (4 Wheat ) 316, 436 (1819)  — unless Congress consents 75× 75  See, e g , Helvering v  Gerhardt, 304 U S  405, 411 n 1 (1938) (“Congress may curtail an immunity which might otherwise be implied or enlarge it beyond the point where, Congress being silent, the Court would set its limits ” (citations omitted))  One court has described such judicial decisions as setting a “constitutional default rule ” United States v  Delaware, 958 F 2d 555, 560 n 9 (3d Cir  1992) (“[W]e must decide the constitutional default rule for this type of tax, fully aware that Congress could decide at any time to reverse our decision statutorily ”)  (2) Article I, Section 10 Cases: Article I, Section 10 provides that certain prohibitions on the states may be waived by Congress 76× 76  See U S  Const  art  I, § 10, cls  2–3  The Court has taken note of this when considering whether to overrule, for instance, an Import-Export Clause precedent 77× 77  See Hooven & Allison Co  v  Evatt, 324 U S  652, 668 (1945) (“In view of the fact that the Constitution gives Congress authority to consent to state taxation of imports and hence to lay down its own test for determining when the immunity ends, we see no convincing practical reason for abandoning the test which has been applied for more than a century        ”), overruled on other grounds by Limbach v  Hooven & Allison Co , 466 U S  353 (1984)  In Michelin Tire Corp  v  Wages, 423 U S  276 (1976), the Court left open the question whether “Congress may authorize, under the Import-Export Clause, an exaction that it could not directly impose under the Tax Clause ” Id  at 301 n 13  Metzger, however, argues that the Import-Export Clause is free of other clauses’ limits on congressional power  See Metzger, supra note 69, at 1500 & n 120  (3) Bivens Cases: In Bivens v  Six Unknown Named Agents of Federal Bureau of Narcotics,78× 78  403 U S  388 (1971)  the Court held that a violation of the Fourth Amendment gives rise to a right to sue for damages 79× 79  Id  at 397  But the Court has also held that “[s]uch a cause of action may be defeated       when       Congress has provided an alternative remedy which it explicitly declared to be a substitute for recovery directly under the Constitution and viewed as equally effective ”80× 80  Carlson v  Green, 446 U S  14, 18–19 (1980)  (4) Miranda Cases: The Miranda Court famously “encourage[d]” Congress and the states to explore alternative “procedures which are at least as effective in apprising accused persons of their right of silence and in assuring a continuous opportunity to exercise it ”81× 81  Miranda v  Arizona, 384 U S  436, 467 (1966)  In Dickerson v  United States, 530 U S  428 (2000), the Court struck down a congressional attempt to effectively abolish Miranda, holding that “Miranda announced a constitutional rule that Congress may not supersede legislatively ” Id  at 444  But Dickerson also stood by Miranda’s “invitation for legislative action” to replace Miranda with an adequate substitute  Id  at 440; see also Michael C  Dorf & Barry Friedman, Shared Constitutional Interpretation, 2000 Sup  Ct  Rev  61 (discussing legislative alternatives to Miranda)  (5) The Police Lineup Case: In United States v  Wade,82× 82  388 U S  218 (1967)  the Court created an exclusionary rule for evidence obtained from a police lineup in violation of the Sixth Amendment right to counsel but acknowledged that it could be replaced by “[l]egislative or other regulations       which eliminate the risks of abuse ”83× 83  Id  at 239  (6) The Exclusionary Rule Cases: Mapp v  Ohio made the Fourth Amendment “exclusionary rule” binding on the states,84× 84  367 U S  643, 655 (1961)  yet Congress is thought to have the power to replace it 85× 85  See Bivens v  Six Unknown Named Agents of Fed  Bureau of Narcotics, 403 U S  388, 422–24 (1971) (Burger, C J , dissenting) (inviting Congress to replace the Fourth Amendment exclusionary rule); Harold J  Krent, How to Move Beyond the Exclusionary Rule: Structuring Judicial Response to Legislative Reform Efforts, 26 Pepp  L  Rev  855, 864–71 (1999) 
All of the above are arguably constitutional default rules set by the Court that remain, to one degree or another, open to congressional revision  The list could be longer or shorter, depending on which default rules the Court will view as constitutional86× 86  A shorter list could be produced by whittling away at the constitutional status of the cases identified by Monaghan  While the Court has held that Miranda is a constitutional decision, Dickerson, 530 U S  at 444, some of the other cases may be viewed as nonconstitutional  See, e g , Collins v  Virginia, 138 S  Ct  1663, 1675–80 (2018) (Thomas, J , concurring) (arguing that Mapp is “nonconstitutional,” id  at 1678 n 5); Richard H  Fallon, Jr  et al , Hart and Wechsler’s The Federal Courts and the Federal System 775–77 (7th ed  2015) (discussing whether Bivens is constitutionally required)  Conversely, a longer list might include any constitutional right that can be waived by a party  See, e g , Daniel A  Farber, Another View of the Quagmire: Unconstitutional Conditions and Contract Theory, 33 Fla  St  U  L  Rev  913, 918 (2006) (describing the Eleventh Amendment as “just a contractual default rule that the states are free to barter away”)  Such a list might also include various constitutionally inspired judicial presumptions  See, e g , Jack Goldsmith & John F  Manning, The President’s Completion Power, 115 Yale L J  2280, 2299 (2006) (describing the Chevron presumption of delegated interpretive power to administrative agencies as “a constitutionally inspired default rule”); Nicholas Quinn Rosenkranz, Federal Rules of Statutory Interpretation, 115 Harv  L  Rev  2085, 2097–98 (2002) (describing clear statement rules as “constitutional default rules” reversible by Congress)  Many other decisions could likely be characterized as constitutional default rules; the list above is only an initial stab  and on how it will answer open questions about congressional authority over certain constitutional provisions 87× 87  See, e g , Thomas v  Wash  Gas Light Co , 448 U S  261, 272 n 18 (1980) (plurality opinion) (leaving unresolved whether Congress may limit constitutional full faith and credit obligations); White v  Mass  Council of Constr  Emp’rs, Inc , 460 U S  204, 215 n 1 (1983) (Blackmun, J , concurring in part and dissenting in part) (leaving unresolved “whether Congress may authorize       what otherwise would be a violation” of the Privileges and Immunities Clause); 1 Tribe, supra note 72, § 6-35, at 1243–44 (arguing that Congress cannot override judicial constructions of the Privileges and Immunities Clause); Metzger, supra note 69, at 1486–89 (arguing the opposite)  But the takeaway is clear: weaker stare decisis for constitutional default rules  Pre-Wayfair, one would have thought that stare decisis applies with special force to such precedents, given congressional power to set them straight  Not anymore  Why? Because it is improper to “ask Congress to address a false constitutional premise of th[e] Court’s own creation ”88× 88  Wayfair, 138 S  Ct  at 2096  The Latin for Wayfair’s doctrine is not stare decisis, which should reflect a realistic, working relationship between the legislative and judicial branches  It is mea culpa 
In its zeal to update the Constitution for “the Cyber Age,”89× 89  Id  at 2097  the Court deleted Congress from stare decisis doctrine in constitutional cases  The Court had better options  It could have left Quill on Congress’s doorstep, as the dissent argued  Or it could have justified overruling Quill notwithstanding the special force of stare decisis  Instead, the Court reasoned that it doesn’t matter whether Congress is willing and able to do the job: a constitutional mess calls for a judicial clean-up crew  For constitutional default rules — a category of decisions embracing the dormant commerce clause and sweeping far beyond — Wayfair’s new theory of stare decisis makes the Court’s precedents less sticky and Congress less relevant 



ground_truth: Quill harmed states more than anticipated due to the Internet.