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 was Hugh H. Goodwin's rank in the United States Navy?

Read the following text and answer briefly.

Context 1: Hugh Hilton Goodwin (December 21, 1900 – February 25, 1980) was a decorated officer in the United States Navy with the rank of Vice Admiral  A veteran of both World Wars, he commanded escort carrier  during the Mariana Islands campaign  Goodwin then served consecutively as Chief of Staff, Carrier Strike Group 6 and as Air Officer, Philippine Sea Frontier and participated in the Philippines campaign in the later part of the War 

Following the War, he remained in the Navy and rose to the flag rank and held several important commands including Vice Commander, Military Air Transport Service, Commander, Carrier Division Two and Commander, Naval Air Forces, Continental Air Defense Command 

Early life and career

Hugh H  Goodwin was born on December 21, 1900, in Monroe, Louisiana and attended Monroe High School there (now Neville High School)  Following the United States' entry into World War I in April 1917, Goodwin left the school without receiving the diploma in order to see some combat and enlisted the United States Navy on May 7, 1917  He completed basic training and was assigned to the battleship   Goodwin participated in the training of armed guard crews and engine room personnel as the Atlantic Fleet prepared to go to war and in November 1917, he sailed with the rest of Battleship Division 9, bound for Britain to reinforce the Grand Fleet in the North Sea 

Although he did not complete the last year of high school, Goodwin was able to earn an appointment to the United States Naval Academy at Annapolis, Maryland in June 1918  While at the academy, he earned a nickname "Huge" and among his classmates were several future admirals and generals including: Hyman G  Rickover, Milton E  Miles, Robert E  Blick Jr , Herbert S  Duckworth, Clayton C  Jerome, James P  Riseley, James A  Stuart, Frank Peak Akers, Sherman Clark, Raymond P  Coffman, Delbert S  Cornwell, Frederick J  Eckhoff, Ralph B  DeWitt, John Higgins, Vernon Huber, Albert K  Morehouse, Harold F  Pullen, Michael J  Malanaphy, William S  Parsons, Harold R  Stevens, John P  Whitney, Lyman G  Miller and George J  O'Shea 

Goodwin graduated with Bachelor of Science degree on June 3, 1922, and was commissioned Ensign in the United States Navy  He was subsequently assigned to the battleship  and took part in the voyage to Rio de Janeiro, Brazil, before he was ordered to the Naval Torpedo Station at Newport, Rhode Island for submarine instruction in June 1923  Goodwin completed the training several weeks later and was attached to the submarine   He then continued his further training aboard submarine  and following his promotion to Lieutenant (junior grade) on June 3, 1925, he qualified as submariner 

He then served aboard submarine  off the coast of California, before he was ordered for the recruiting duty to San Francisco in September 1927  While in this capacity, Goodwin applied for naval aviation training which was ultimately approved and he was ordered to the Naval Air Station Pensacola, Florida in August 1928  Toward the end of the training, he was promoted to lieutenant on December 11, 1928, and upon the completion of the training in January 1929, he was designated Naval aviator 

Goodwin was subsequently attached to the Observation Squadron aboard the aircraft carrier  and participated in the Fleet exercises in the Caribbean  He was transferred to the Bureau of Aeronautics in Washington, D C  in August 1931 and served consecutively under the architect of naval aviation William A  Moffett and future Chief of Naval Operations Ernest J  King 

In June 1933, Goodwin was ordered to the Naval War College at Newport, Rhode Island, where he completed junior course in May of the following year  He subsequently joined the crew of aircraft carrier  and served under Captain Arthur B  Cook and took part in the Fleet exercises in the Caribbean and off the East Coast of the United States 

He was ordered back to the Naval Air Station Pensacola, Florida in June 1936 and was attached to the staff of the Base Commandant, then-Captain Charles A  Blakely  When Blakely was succeeded by William F  Halsey in June 1937, Goodwin remained in Halsey's staff and was promoted to Lieutenant Commander on December 1, 1937  He also completed correspondence course in International law at the Naval War College 

Goodwin was appointed Commanding officer of the Observation Squadron 1 in June 1938 and attached to the battleship  he took part in the patrolling of the Pacific and 
West Coast of the United States until September 1938, when he assumed command of the Observation Squadron 2 attached to the battleship  

When his old superior from Lexington, now Rear Admiral Arthur B  Cook, was appointed Commander Aircraft, Scouting Force in June 1939, he requested Goodwin as his Aide and Flag Secretary  He became Admiral Cook's protégé and after year and half of service in the Pacific, he continued as his Aide and Flag Secretary, when Cook was appointed Commander Aircraft, Atlantic Fleet in November 1940 

World War II

Following the United States' entry into World War II, Goodwin was promoted to the temporary rank of Commander on January 1, 1942, and assumed duty as advisor to the Argentine Navy  His promotion was made permanent two months later and he returned to the United States in early 1943 for duty as assistant director of Planning in the Bureau of Aeronautics under Rear admiral John S  McCain  While still in Argentina, Goodwin was promoted to the temporary rank of Captain on June 21, 1942 

By the end of December 1943, Goodwin was ordered to Astoria, Oregon, where he assumed command of newly commissioned escort carrier USS Gambier Bay  He was responsible for the initial training of the crew and was known as a strict disciplinarian, but the crew appreciated the skills he taught them that prepared them for combat  Goodwin insisted that everyone aboard has to do every job right every time and made us fight our ship at her best 

During the first half of 1944, Gambier Bay was tasked with ferrying aircraft for repairs and qualified carrier pilots from San Diego to Pearl Harbor, Hawaii, before departed on May 1, 1944, to join Rear admiral Harold B  Sallada's Carrier Support Group 2, staging in the Marshalls for the invasion of the Marianas 

The air unit, VC-10 Squadron, under Goodwin's command gave close air support to the initial landings of Marines on Saipan on June 15, 1944, destroying enemy gun emplacements, troops, tanks, and trucks  On the 17th, her combat air patrol (CAP) shot down or turned back all but a handful of 47 enemy planes headed for her task group and her gunners shot down two of the three planes that did break through to attack her 

Goodwin's carrier continued in providing of close ground support operations at Tinian during the end of July 1944, then turned her attention to Guam, where she gave identical aid to invading troops until mid-August that year  For his service during the Mariana Islands campaign, Goodwin was decorated with Bronze Star Medal with Combat "V" 

He was succeeded by Captain Walter V  R  Vieweg on August 18, 1944, and appointed Chief of Staff, Carrier Division Six under Rear admiral Arthur W  Radford  The Gambier Bay was sunk in the Battle off Samar on October 25, 1944, during the Battle of Leyte Gulf after helping turn back a much larger attacking Japanese surface force 

Goodwin served with Carrier Division Six during the Bonin Islands raids, the naval operations at Palau and took part in the Battle of Leyte Gulf and operations supporting Leyte landings in late 1944  He was later appointed Air Officer of the Philippine Sea Frontier under Rear admiral James L  Kauffman and remained with that command until the end of hostilities  For his service in the later part of World War II, Goodwin was decorated with Legion of Merit with Combat "V"  He was also entitled to wear two Navy Presidential Unit Citations and Navy Unit Commendation 

Postwar service

Following the surrender of Japan, Goodwin assumed command of Light aircraft carrier  on August 24, 1945  The ship was tasked with air missions over Japan became mercy flights over Allied prisoner-of-war camps, dropping food and medicine until the men could be rescued  She was also present at Tokyo Bay for the Japanese surrender on September 2, 1945 

Goodwin returned with San Jacinto to the United States in mid-September 1945 and he was detached in January 1946  He subsequently served in the office of the Chief of Naval Operations until May that year, when he entered the instruction at National War College  Goodwin graduated in June 1947 and served on Secretary's committee for Research on Reorganization  Upon promotion to Rear admiral on April 1, 1949, Goodwin was appointed Chief of Staff and Aide to Commander-in-Chief, Atlantic Fleet under Admiral William H  P  Blandy 

Revolt of the Admirals

In April 1949, the budget's cuts and proposed reorganization of the United States Armed Forces by the Secretary of Defense Louis A  Johnson launched the wave of discontent between senior commanders in the United States Navy  Johnson proposed the merging of the Marine Corps into the Army, and reduce the Navy to a convoy-escort force 

Goodwin's superior officer, Admiral Blandy was call to testify before the House Committee on Armed Services and his harsh statements for the defense of the Navy, costed him his career  Goodwin shared his views and openly criticized Secretary Johnson for having power concentrated in a single civilian executive, who is an appointee of the Government and not an elected representative of the people  He also criticized aspects of defense unification which permitted the Joint Chiefs of Staff to vote on arms policies of individual services, and thus "rob" the branches of autonomy 

The outbreak of the Korean War in summer 1950 proved the proposal of Secretary Johnson as incorrect and he resigned in September that year  Also Secretary of the Navy, Francis P  Matthews resigned one month earlier 

Later service

Due to the Revolts of the admirals, Blandy was forced to retire in February 1950 and Goodwin was ordered to Newport, Rhode Island for temporary duty as Chief of Staff and Aide to the President of the Naval War College under Vice admiral Donald B  Beary in April 1950  Goodwin was detached from that assignment two months and appointed member of the General Board of the Navy  He was shortly thereafter appointed acting Navy Chief of Public Information, as the substitute for Rear Admiral Russell S  Berkey, who was relieved of illness, but returned to the General Board of the Navy in July that year  Goodwin served in that capacity until February 1951, when he relieved his Academy class, Rear admiral John P  Whitney as Vice Commander, Military Air Transport Service (MATS) 

While in this capacity, Goodwin served under Lieutenant general Laurence S  Kuter and was co-responsible for the logistical support of United Nations troops fighting in Korea  The MATS operated from the United States to Japan and Goodwin served in this capacity until August 1953, when he was appointed Commander Carrier Division Two  While in this assignment, he took part in the Operation Mariner, Joint Anglo-American exercise which encountered very heavy seas over a two-week period in fall 1953 

Goodwin was ordered to the Philippines in May 1954 and assumed duty as Commander, U S  Naval Forces in the Philippines with headquarters at Naval Station Sangley Point near Cavite  He held that command in the period of tensions between Taiwan and China and publicly declared shortly after his arrival, that any attack on Taiwan by the Chinese Communists on the mainland would result in US participation in the conflict  The naval fighter planes under his command also provided escort for passing commercial planes  Goodwin worked together with retired Admiral Raymond A  Spruance, then-Ambassador to the Philippines, and accompanied him during the visits to Singapore, Bangkok and Saigon in January 1955 

On December 18, 1955, Goodwin's classmate Rear admiral Albert K  Morehouse, then serving as Commander, Naval Air Forces, Continental Air Defense Command (CONAD), died of heart attack and Goodwin was ordered to CONAD headquarters in Colorado Springs, Colorado to assume Morehouse's position  While in this capacity, he was subordinated to Army General Earle E  Partridge and was responsible for the Naval and Marine Forces allocated to the command designated for the defense of the Continental United States 

Retirement

Goodwin retired on June 1, 1957, after 40 years of active service and was advanced to the rank of Vice admiral on the retired list for having been specially commended in combat  A week later, he was invited back to his Monroe High School (now Neville High School) and handed a diploma showing that he had been graduated with the class of 1918  He then settled in Monterey, California where he taught American history at Stevenson school and was a member of the Naval Order of the United States 

Vice admiral Hugh H  Goodwin died at his home on February 25, 1980, aged 79  He was survived by his wife, Eleanor with whom he had two children, a daughter Sidney and a son Hugh Jr , who graduated from the Naval Academy in June 1948, but died one year later, when the Hellcat fighter he was piloting collided with another over the Gulf of Mexico during training 

Decorations

Here is the ribbon bar of Vice admiral Hugh H  Goodwin:

References

1900 births
1980 deaths
People from Monroe, Louisiana
Military personnel from Louisiana
United States Naval Academy alumni
Naval War College alumni
United States Naval Aviators
United States Navy personnel of World War I
United States Navy World War II admirals
United States Navy vice admirals
United States submarine commanders
Recipients of the Legion of Merit
Context 2: A special tribute to Del Bigtree (pictured) and his team at ICAN for his stunning 88 page letter to the HHS regarding vaccine safety  As Del reported - in the latest edition of Highwire - the letter, in response to an earlier reply from the then acting Director National Vaccine Program Office, Melinda Wharton, took virtually a year to compile, and is a meticulous piece of research  Most sensationally they researched the HHS claim through US government archives that at least some pediatric vaccines had been trialed against genuine placebo, and came to a negative conclusion  Not only that, they established that none of the vaccines those vaccines had been trialed against had ever been trialed against genuine placebo either  At the end of the line the toxic products were only being compared with other toxic products, rather than against saline 
Leave aside the sceptics, for any believer in the vaccine program as a necessary intervention in public health, this should be a devastating finding  Fundamentally, the research into the safety of any of the products before marketing was simply not there  The manufacturers apparently had no faith that their proto-products could withstand this scrutiny, and for the rest they just did not care: under the alleged imperative of protecting the population it seems anything went  So even before all the sham monitoring procedures and reviews which Del and his team dismantle in forensic detail we are left with the proposition that none of the present products being given to US children – and frequently other children across most of the developed world – have any meaningful pre-marketing safety data all  If you are believer in the program you have been let down: if you wanted a program with any pretensions to safety - supposing such a thing to be possible - it looks like you would have to start from scratch  The manufacturers did this: the governments, the politicians and the regulators (internationally) let it happen 
This damning document is published simultaneously with a demand in the UK from the Royal Society for Public Health (which I had never heard of) to shut down comment about vaccines on the web  It echoes calls from Seth Berkley of GAVI, Heidi Larson of the Vaccine Confidence Project and the European Parliament  The pamphlet airily dismisses concerns that vaccines have side effects or that you could possibly have too many  It is pure public relations, and if the RSPH claims to be "independent" it also admits that the publication was paid for by Merck, a detail which was reported by British Medical Journal and the Guardian, but not true to form by the BBC  We have, in truth, been building to this moment for two decades: as the evidence piles up that every single aspect of the program lacks integrity or is simply rotten to the core all the perpetrators can do is call for the silencing of their critics, and maintain the products are safe because they say so 
Please help give the ICAN letter the widest possible distribution, particularly to politicians 
"The outcome of disease always depends both on the virulence of the pathogen and the health of the individual immune system "
Nope  This makes no sense  Lots of people who seemed vibrant will get a very severe case of the same illness that a vulnerable baby overcomes in a day 
And under the germ theory it doesn't matter how strong your immune system *was*  Once it's been overcome by the pathogen it is every bit as weak as anybody else's with that pathogen 
What you say makes no sense  There's no reason for me to reply to you again 
"Why do you think that within a few years (not many) of the introduction of the vaccines for them, pertussis, measles, mumps, rubella, tetanus, diphtheria, Hib disease, and chickenpox (and others) almost entirely disappeared?"
Why do you keep asking this question when I've already provided the answer hundreds of times? Why are you so desperate to believe the people who you already recognize are harming our children?
Why would Walter Reed be any more trustworthy than Paul Offit or Senator Pan? Why would Jenner or Pasteur?
And you went no way to explaining my arguments against germ theory  If we are attacked by billions of viruses every day then if even a tiny fraction of them are pathogenic then we couldn't possibly survive  And even if we could, we would already be immune rendering every vaccine pointless  Once we had survived our first few days on earth, then we could never get sick again 
If that's wrong then we must conclude that precisely 0% of germs are pathogenic 
Plus your comment about the immune system completely misunderstood my point  The immune system does not allow us to overcome our math problem  In fact, it makes it worse 
You did provide one solitary example of a patient with what are presumably yellow fever symptoms but you didn't say whether they had been given any toxic medical treatments 
And like I said before, the whole "incubation period" is more than a little suspicious  Clearly they never found what they thought they would and just rigged the results to tell them what they want to hear 
Like every other germ theorist/vaccine promoter in history 
Many kinds of bacteria are constantly evolving and changing, like flu viruses  Others are more stable over time, like the yellow fever virus  Those that change develop new ways of infiltrating the cells of the organism being attacked (from our point of view, from its unconscious point of view, it's just carrying out its need to replicate, which it can only do inside the cells of its host)  The changes which allow it to better infiltrate are more successful and result in more viruses with those traits 
Our immune system is designed to detect and destroy potentially dangerous invading pathogens  Many bacteria are usually harmless and absolutely necessary  The minority are dangerous, and most people's immune systems do a good job of analyzing them and killing them, often with no signs of disease  Others experience a clinical infection, and the immune system usually mounts a successful attack on them 
The outcome of disease always depends both on the virulence of the pathogen and the health of the individual immune system  Vaccines are usually effective in giving immunity to the targeted diseases  They also have many dangers which everyone should be aware of, and vaccines should be avoided whenever possible  But in the case of the most dangerous diseases, everyone should learn about them and think about what he wants to do to protect himself and his children from them, considering all the factors involved  And no one can have 100% certainty that he has made the right decision, but that's life  But if you live in the Congo and many people around you are currently dying of yellow fever, then that means that you yourself are at risk of being bitten by a loaded mosquito and getting, often dying, of yellow fever  The yellow fever vaccine is very effective at preventing yellow fever  From there, each person must make a choice 
At the end of this stage there is a remission of two or three days  About 80% of those with clinical disease recover at this point, with permanent immunity  The other 20% enter the toxic stage, with a return of the fever, black vomit (coffee-ground emesis), diarrhea, a slowing of the pulse (Faget's sign), jaundice, yellow eyes, yellow skin, and failure of the kidneys, liver, and heart  The patient gets a strange hiccup (like with Ebola, a related disease), falls into a coma, and dies  About half of those patients who enter the toxic stage dies, even now, even with the best of hospital care  The Faget's sign can also occur at the end of the first stage 
You asked specifically about the symptoms of the Americans on Dr  Reed's team who got yellow fever in Cuba in 1900  I'll give the passage from The American Plague (162-5), which describes the course of Jesse Lazear's illness  "In his logbook, Lazear wrote an unusual entry on September 13  In all cases before those, page after page of records, Lazear had used the soldier's name and simply the date he was bitten, with no other attention to the mosquito  A one-line entry with a name and a date  On that day, however, in his elegant hand, Lazear did not write the soldier's name, but instead wrote 'Guinea Pig No  1 ' He went on to write that this guinea pig had been bitten by a mosquito that developed from an egg laid by a mosquito that developed from an egg laid by a mosquito that fed on a number of yellow fever cases: Suarez, Hernández, De Long, Ferández  It was a precise, detailed history that proved beyond doubt that the mosquito was loaded with the virus when it bit a healthy soldier   (If he had entered his name, then his death would have been considered medical suicide by the insurance company, and his wife and two children would not have gotten any payment ) For the next few days, Lazear's life continued much as it had over the last few months in Cuba  He fed and cared for the mosquitoes in the lab    Then he began to lose his appetite  He skipped a few meals in the mess hall  He didn't mention it to anyone, nor did he ask to see one of the yellow fever doctors; instead, he worked hard in the lab trying to ignore the oncoming headache 
"On September 18, he complained of feeling 'out of sorts,' and stayed in his officer's quarters  His head pounded and L  decided to write a letter  
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       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



ground_truth: Vice Admiral.

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: Who compiled the 88-page letter to the HHS regarding vaccine safety?

Read the following text and answer briefly.

Context 2:  (he wrote to his mother, and referred to his one-year old son Houston and the baby his wife Mabel was about to have: they were staying with his mother in the US)    That night, L  started to feel chilled as the fever came on  He never went to sleep but worked at his desk all through the night, trying to get all the information about the mosquitoes organized  By morning, he showed all the signs of a severe attack of yellow fever  The camp doctors made the diagnosis, and L  agreed to go to the yellow fever ward    L  was carried by litter out of the two-room, white pine board house in which he had lived since he and Mabel first arrived in Cuba    (In the yellow fever ward, in a separate one-room building), Lena Warner (the immune nurse who had survived the yellow fever in 1878, when she was nine, and was found in her boarded-up house by a former slave who first thought she was dead, and carried her to safety) nursed J L , recording his vitals  (I put up a link to his case record and vital signs last week  The surgeon general required that this record be made for every yellow fever patient )    (On September 25,) Lena Warner braced L's arms with all of her weight, shouting for help  Still he bolted from the bed, darting around the small frame-wood room as wildly as a trapped insect beating against glass  Two soldiers ran into the ward, pinning L to his bed, tying restraints around his wrists and elbows    Warner sponged his body with iced whiskey and water  She recorded his temperature, which had held at 104 degrees for days, on the chart beside his bed    (Warner watched him sleep ) But the quiet did not last  L's body began to lurch, and black vomit rolled from his mouth; through the bar hanging above his hospital cot  He writhed in the bed, and his skin grew deep yellow  His 104 temperature slowly fell, leveling out 99 degrees, and JL died at 8:45 p m  at the age of thirty-four "
As is obvious, there are many problems with vaccines  But, that being said, most of them usually work for a period of time to prevent the targeted diseases  The basic science behind vaccines is correct  Why do you think that within a few years (not many) of the introduction of the vaccines for them, pertussis, measles, mumps, rubella, tetanus, diphtheria, Hib disease, and chickenpox (and others) almost entirely disappeared? In the case of the routine childhood diseases, this was a bad thing, but it is a true thing 
Vaccines usually don't cause any obvious reactions  While they usually prevent the diseases, and that's why people continue to get them  With the increasing vaccination schedule, more and more are severely and permanently damaged, and it is immoral to mandate any vaccine for anyone for this reason  But it would also be immoral to prohibit vaccines for those who want them enough to take the risk 
Your article said as though it had any probative value that 90% of those who get pertussis had been vaxxed  The old DPT vaccine was MUCH more effective at preventing pertussis, but it was so dangerous (again, not to most, but to many), that developed countries replaced it with the acellular version, DTaP  From the beginning about twenty years ago, it was clear that it was not very effective and that huge numbers of vaxxed people got pertussis anyway, including my daughter who got pertussis at eight month old after having gotten three DTaPs  The pertussis vaccine continues to be very dangerous, and I do not recommend that anyone get it  It used to be a killer disease, but evolved to become much milder, to the extent that the disease is very rarely dangerous (usually only to newborns under three months old), while the vaccine is very dangerous  And they're trying to see how they can go back to the old DPT  This does not show that vaccine science has collapsed, but rather that the vaccine they developed to replace the DPT turned out to be much less effective than they first thought, while continuing to be much more dangerous than they first thought 
Your article extrapolated from that that modern medical science in general has collapsed, but that, again, is going too far  A older woman in Mexico City who is like my mother to me had a pacemaker inserted about two months ago to aid her failing heart, and it has restored her to optimism and energy, when she was despondent, weak, and close to death  I took my daughter to the dentist yesterday, who said she has three wisdom teeth coming in and that she said that the lower right one was sore  So, although I am cautious about X-rays, I made an appointment for a panoramic X-ray in a month to assess the wisdom teeth, and, if it seems appropriate, I'll take her to an oral surgeon to have one or more extracted under IV sedation, in his office, if possible (the dentist thought that it would be)  And I am confident that there will be no serious problems, but this is thanks to technology and training in modern medicine that haven't been available for that long 
I think that everyone should inform himself on all medical procedures before agreeing to anything, but I also think that he should have access to any medical procedure which is reasonable (and opinions can differ as to that) 
One problem is that you have not said how you think people should protect themselves against tetanus, bacterial meningitis, and yellow fever in the relevant cases, for example  These are diseases which healthy, well-nourished people used to die from very readily 
If most people stopped vaxxing and the mortality from these diseases rose to something like pre-vaccine levels, do you think they should just accept dying from them?
I put that in a separate paragraph because it is the crucial issue 
balinaheuchter Air Traffic Control You Tube - Colin Campbell example of - How to "Fudge a Nudge" -"Deal" or "No Deal" "Not in a month of Sundays" "No exceptions/no compromise?" -make a trade off -do an exception- everyone get's a good deal /good outcome!
Hans, you are right that we are looking at one of the biggest crimes in all history  When I read the story of that poor girl who was so healthy and is now confined to a wheelchair after getting her third Gardasil shot I could not believe that Merck could produce such a toxic vaccine and give it out to girls like it was something they absolutely had to have only to be mislead and made into cripples  Merck should be prosecuted for the damage they have done to so many girls who got the Gardasil vaccine and were physically debilitated for life  There is a place for the people who perpetrated this crime on young girls and women and it is called hell  They have destroyed people's lives and gotten away with it  My heart goes out to those who have suffered this damage for no damn good reason except to help make huge profits for Merck!
Here is the reason that the germ theory is nonsense 
1) Everyday we are bombarded with billions of germs  Presumably at least some of them are of the kind that germ theorists believe are dangerous (otherwise we would have to conclude that none of them are dangerous)  So how do we survive?
2) Let's just say that we ignore 1 and imagine that, by way of magic, none of the billions of viruses we get bombarded with are pathogenic but all those that are are tucked away somewhere  Ok  But presumably they reside in sick people right? So where are there lots of sick people? Doctor offices and hospitals! So everybody must be dying the moment they enter these places right?
3) I love this one because I have never seen anybody else ever raise it  Under the germ theory there are no negative feedbacks  This makes a stable biological system by definition impossible  The immune system is *not* a negative feedback it is the opposite  It actually reinforces our math problem because the immune system will weaken as the number of pathogens increase 
There is no way of resolving this problem without a discontinuity  A Deus ex Machina as The Almighty Pill so beautifully put it  So the germ theory is quite literally, mathematically impossible 
There is as much chance of it being true as 2+2 = 5 
There are plenty of other massive problems with germ theory such as why did things like SARS and bird flu magically disappear? Why do we have the symptoms that we do? Is our body controlling the symptoms to help fight the germs and if so, why would suppressing the symptoms with antibiotics or Tamiflu be considered a good idea? If the virus is causing the symptoms then why would it cause these kinds of things?
Context 3: 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  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: Del Bigtree and his team at ICAN.

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 4: 
The non-denoised results are labelled with M = 0, and the noiseless values with p = 0  where sgn(η g ) is the sign of the sampled coefficient of the gth channel  γ = 1 means that all signs are positive  Observables Ô p=0 for the noiseless circuit are then approximated by resampling the observables from the denoiser ensemble
where γ = N G g=1 γ g is the overall sampling overhead, with γ g the overhead of the gth gate  Clearly, a large γ implies a large variance of Ô p=0 for a given number of samples, with accurate estimation requiring the cancellation of large signed terms  The number of samples required to resolve this cancellation of signs is bounded by Hoeffding's inequality, which states that a sufficient number of samples to estimate Ô p=0 with error δ at probability 1 − ω is bounded by (2γ 2 /δ 2 ) ln(2/ω)  
Since γ scales exponentially in γ g , it is clear that a denoiser with large M and γ 1 will require many samples  We observed that decompositions with γ > 1 are crucial for an accurate denoiser  Restricting to γ = 1 leads to large infidelity and no improvement upon increasing the number of terms in or the depth M of the denoiser 
Simply put, probabilistic error cancellation of gate noise introduces a sign problem and it is crucial to find optimal parameterizations (1) which minimize γ to make the approach scalable  This issue arises in all high performance error mitigation schemes , because the inverse of a physical noise channel is unphysical and cannot be represented as a positive sum over CPTP maps 
This is clearly visible in the spectra of the denoiser, which lies outside the unit circle (cf  Fig  )  This makes the tunability of the number of gates in each denoiser sample a crucial ingredient, which allows control over the sign problem, because we can freely choose the η i in   For the parametrization (1) of denoiser channels, we try to find a set of parameters for error mitigation by minimizing the normalized Frobenius distance between the noiseless and denoised supercircuits
which bounds the distance of output density matrices and becomes zero for perfect denoising  We carry out the minimization of on a classical processor, using gradient descent with the differential programming algorithm from   Instead of explicitly calculating the accumulated global noise channel and subsequently inverting it, we approximate the noiseless supercircuit C with the denoised supercircuit D C, effectively yielding a circuit representation D of the inverse noise channel 
Results  -To benchmark the denoiser we apply it to the second-order Trotter circuits of the spin-1/2 Heisenberg chain with periodic boundary conditions (PBC) where is the Pauli algebra acting on the local Hilbert space of site i  A second-order Trotter circuit for evolution time t with depth M trot consists of M trot − 1 half brickwall layers with time step t/M trot and two layers with half time step  
We consider circuits that are affected by uniform depolarizing noise with probability p for simplicity, but our approach can be used for any non-Clifford noise  The two-qubit noise channel is which acts on neighboring qubits i and i + 1 and is applied to each Trotter and denoiser gate, and p = 0 01 unless stated otherwise 
We study circuits with depths M trot = 16, 32, 64 for evolution times t = 0 5, 1,    , 5, and denoisers D with depths M = 1, 2, 4, 6, 8  In the top panels of Fig  we show (4) for a chain of size L = 8 as a function of time t  Here it can be seen that even for M trot = 32 a denoiser with M = 1 already improves by roughly an order of magnitude at all considered t 
Depending on M trot and t, further increasing M lowers , with the biggest improvements occurring for high precision Trotter circuits with large depth M trot = 64 and short time t = 0 5, where the Trotter gates are closer to the identity than in the other cases  At the other extreme, for M trot = 16 the improvements are relatively small upon increasing M > 2  In all cases the denoiser works better at early times than at late times, again indicating that it is easier to denoise Trotter gates that are relatively close to the identity 
To probe the accuracy of the denoiser on quantities that do not enter the optimization, as a first test we consider the two-point correlator between spins at different times where we have chosen the infinite temperature initial state, and C(t) is the Trotter supercircuit for time t  In the bottom panels of Fig  we show C zz i=L/2,j=L/2 (t) for the supercircuits from the upper panels, now for a L = 14 chain 
Here we see that at M trot = 16 we can retrieve the noiseless values already with M = 1, but that increasing M trot makes this more difficult  At M trot = 64 we see larger deviations, and improvement upon increasing M is less stable, but nonetheless we are able to mitigate errors to a large extent  As a further test, we compute the out-of-time-ordered correlator (OTOC) ]
In Fig  we show the results for i = L/2, for a Trotter circuit with depth M trot = 32 and a denoiser with depth M = 2  Here we see that a denoiser with M M trot is able to recover the light-cone of correlations, which are otherwise buried by the noise  In the Supplementary Material we consider how the denoiser performs at different noise levels p, and how the denoised supercircuits perform under stacking 
There we also calculate domain wall magnetization dynamics, and show the distribution of the optimized denoiser parameters and the sampling overhead associated to the denoiser as a whole  In Fig  we show the eigenvalues of the noisy supercircuits for a noisy second-order Trotter supercircuit with M trot = 16 at t = 1 (left), the corresponding optimized denoiser with M = 4 (center), and the denoised supercircuit (right) 
The eigenvalues λ of a unitary supercircuit lie on the unit circle, and in the presence of dissipation they are pushed to the center  We see that the spectrum of the denoiser lies outside the unit circle, making it an unphysical channel which cures the effect of the noise on the circuit, such that the spectrum of the denoised circuit is pushed back to the unit circle 
The noiseless eigenvalues are shown as blue bars, making it clear that the denoiser is able to recover the noiseless eigenvalues from the noisy circuit  In the Supplementary Material we show the spectra for a p = 0 036 denoiser, where we observe a clustering of eigenvalues reminiscent of Refs    There we also investigate the channel entropy of the various supercircuits  
Conclusion  -We have introduced a probabilistic error cancellation scheme, where a classically determined denoiser mitigates the accumulated noise of a (generally non-Clifford) local noise channel  The required number of mitigation gates, i e  the dimensionality of the corresponding quasiprobability distribution, is tunable and the parameterization of the corresponding channels provides control over the sign problem that is inherent to probabilistic error cancellation 
We have shown that a denoiser with one layer can already significantly mitigate errors for second-order Trotter circuits with up to 64 layers  This effectiveness of low-depth compressed circuits for denoising, in contrast with the noiseless time evolution operator compression from , can be understood from the non-unitarity of the denoiser channels 
In particu-lar, measurements can have non-local effects, since the measurement of a single qubit can reduce some highly entangled state (e g  a GHZ state) to a product state, whereas in unitary circuits the spreading of correlations forms a light-cone  To optimize a denoiser with convenience at L > 8, the optimization can be formulated in terms of matrix product operators or channels , which is convenient because the circuit calculations leading to the normalized distance and its gradient are easily formulated in terms of tensor contractions and singular value decompositions  
This provides one route to a practical denoiser, which is relevant because the targeted noiseless circuit and the accompanying noisy variant in (4) need to be simulated classically, confining the optimization procedure to limited system sizes with an exact treatment or limited entanglement with tensor networks 
Nonetheless, we can use e g  matrix product operators to calculate (4) for some relatively small t, such that the noiseless and denoised supercircuits in (4) have relatively small entanglement, and then stack the final denoised supercircuit on a quantum processor to generate classically intractable states 
Analogously, we can optimize the channels exactly at some classically tractable size and then execute them on a quantum processor with larger size  Both approaches are limited by the light-cone of many-body correlations, as visualized in Fig  , because finite-size effects appear when the light-cone width becomes comparable with system size 
1  The normalized distance (left) and z spin correlator C zz i=L/2,j=L/2 (right), for a second-order Trotter supercircuit of depth Mtrot = 16 for time t = 1, affected by various twoqubit depolarizing errors p  We compare the values obtained with and without a denoiser, i e  M > 0 and M = 0, to the noiseless values (p = 0) 
The denoiser is affected by the same noise as the Trotter circuit  We consider denoisers with depths M = 1, 2, 4, 6, 8, and we use a L = 8 Heisenberg chain with PBC for the normalized distance, while for the correlator we use L = 14  * david luitz@uni-bonn de to observe that even for larger noise strength p, the local observable C zz improves significantly even with denoisers of depth M = 1 
For large noise strengths, we generally see that the optimization of the denoiser becomes difficult, leading to nonmonotonic behavior as a function of p, presumably because we do not find the global optimum of the denoiser  It is interesting to analyze the spectra of the supercircuits considered in this work 
As mentioned in the main text, the spectrum of the ideal, unitary supercircuit C lies on the unit circle  The comparison to this case is therefore instructive  In the main text, we showed an example of the spectra in Fig  for moderate noise strength  Here, we show additional data for stronger noise p = 0 036 in Fig  for a denoiser with M = 4 layers, optimized to mitigate errors for a second-order Trotter supercircuit with M trot = 16 layers at time t = 1 
The eigenvalues λ of the noisy supercircuit C are clustered close to zero, far away from the unit circle (except for λ = 1), showing that the circuit is strongly affected by the noise  To mitigate the impact of the noise, the denoiser consequently has to renormalize the spectrum strongly  If it accurately represents the inverse of the global noise channel, its spectrum has to lie far outside the unit circle, which is the case 
Interestingly, we observe a clustering of eigenvalues which is reminiscent to the spectra found in   By comparison to these works, we suspect that this is due to the local nature of the denoiser, and warrants further investigation  The right panel of Fig  shows the result of the denoiser, pushing the eigenvalues back to the unit circle, nearly with the exact same distribution along the circle as the noiseless eigenvalues (blue bars) 
Due to the strong noise, this is not achieved perfectly, and it is clear that this cannot work in principle if the global noise channel has a zero eigenvalue  The complexity of an operator can be quantified by its operator entanglement entropy   Here we calculate the half-chain channel entanglement entropy S of the noiseless C, noisy C, denoiser D, and denoised D C supercircuits 
We define S as the entanglement entropy of the state that is related to a supercircuit C via the Choi-Jamio lkowski isomorphism, i e  ψ C = χ C /N , where the process matrix χ ab,cd C = C ac,bd is simply a reshaped supercircuit and N ensures normalization  Then we have S = −Tr [ψ C ln ψ C ]  This entropy measure is a particular instance of the "exchange entropy", which characterizes the information exchange between a quantum system and its environment  
In Fig  we plot the various S for a second-order Trotter circuit with M trot = 16 at t = 2, for a denoiser with M = 4, both affected by two-qubit depolarizing noise with p ∈ [10 −3 , 10 −1 ]  The Trotter circuit is for a Heisenberg model with L = 6 and PBC  We see that at large p, the noise destroys entanglement in the noisy supercircuit, and that the denoiser S increases to correct for this, such that the denoised supercircuit recovers the noiseless S 
Here we investigate how denoised supercircuits perform upon repeated application  We optimize the denoiser for a Trotter supercircuit for a fixed evolution time t  Then, to reach later times, we stack the denoised supercircuit n times to approximate the evolution up to time nt: In Fig  we stack a denoised t = 1 supercircuit up to n = 20 times and calculate the correlation function, defined in the main text, for the middle site 
We consider Trotter depths M trot = 8, 16, 32, 64 and denoiser depths M = 1, 2, 4, 6, 8, for a L = 14 Heisenberg chain with p = 0 01 depolarizing two-qubit noise  The noisy results correspond to M = 0 and the noiseless results to p = 0  In Fig  we calculate the OTOC, defined in the main text, with stacked time evolution for a denoised t = 2 supercircuit with M trot = 32 and M = 2, stacked up to ten times 
We see that the stacked supercircuit performs very well, and the additional precision obtained by using deep denoisers (M = 8) pays off for long evolution times, where we see convergence to the exact result (black dashed lines in Fig  ) as a function of M   FIG    The two-point z-spin correlator C zz i=L/2,j=L/2 (t) of a spin on the middle site at times 0 and t, for the infinite temperature initial state, for denoised second-order Trotter supercircuits that are optimized at evolution time t = 1 and then stacked up to twenty times 
We use Trotter depths Mtrot = 8, 16, 32, 64 and denoiser depths M = 1, 2, 4, 6, 8  The calculations were performed for a periodic Heisenberg model with L = 14 and PBC, affected by two-qubit depolarizing noise with strength p = 0 01, which also affects the denoiser  The non-denoised results are labelled with M = 0, and the noiseless results with p = 0 
The panels are arranged as Mtrot = 8, 16, 32, 64 for top left, top right, bottom left, bottom right, respectively  The costliest and most noise-susceptible operation is the two-qubit ZZ rotation with angle α, which is the foundation of the unitary piece in our channel parameterization, defined in the main text 
For completeness, we here present the α angles of the optimized denoisers  The results are shown in Fig  , which contains histograms for the channel count N G versus α  The histograms are stacked, with the lightest color corresponding to the angles of the denoiser at t = 0 5 and the darkest at t = 5  The top four panels are for a denoiser with M = 2 and the bottom four with M = 8 
We consider M trot = 8, 16, 32, 64  We see that in both cases the distribution widens upon increasing M trot , indicating that the unitary channels start deviating more from the identity  Moreover, while the M = 2 denoisers in all cases except M trot = 64 have ZZ contributions close to the identity, this is clearly not the case for M = 8 
For simplicity, we did not focus on obtaining denoisers with the smallest sampling overhead γ, which is required to minimize the sign problem and hence ease the sampling of mitigated quantities  Instead, we let the optimization freely choose the η i in the denoiser parameterization, as defined in the main text 
In Fig  we show the sampling overhead of the denoisers from Fig  of the main text  We see that for M = 1 and M = 2 the sampling overhead is relatively small and uniform across the different t, whereas for M > 2 the optimization sometimes yields a denoiser with large γ and other times with small γ  This could be related to the difference in α distributions from Fig   
The large fluctuations of γ appears to stem from the difficulty in finding optimal deep denoisers, and our optimization procedure likely only finds a local minimum in these cases  Here C(t) is the Trotter supercircuit for time t  In Fig  we show Z dw for the circuits from Fig 



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