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The Politics of Uncertainty: Lobbyists and Propaganda in Early Twentieth-Century America

Published online by Cambridge University Press:  01 April 2009

Christopher M. Loomis*
Affiliation:
University of Virginia

Abstract

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Articles
Copyright
Copyright © Donald Critchlow and Cambridge University Press 2009

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References

NOTES

1. U.S. Senate, Special Committee to Investigate Lobbying Activities, Investigation of Lobbying Activities, 74th Cong., 1st sess., 1936, 1683 (hereafter Investigation of Lobbying Activities, 1936).

2. On lobbying during the Gilded Age, see Thompson, Margaret S., The “Spider Web”: Congress and Lobbying in the Age of Grant (Ithaca, 1985).Google Scholar On the development of modern interest groups, see Balogh, Brian, “‘Mirrors of Desires’: Interest Groups, Elections, and the Targeted Style in Twentieth-Century America,” in The Democratic Experiment: New Directions in American Political Theory, ed. Jacobs, Meg, Novak, William J., and Zelizer, Julian (Princeton, 2003), 222–49Google Scholar; Tichenor, Daniel J. and Harris, Richard A., “Organized Interests and American Political Development,” Political Science Quarterly 117 (Winter 2002–3): 587612Google Scholar; Clemens, Elisabeth S., The People’s Lobby: Organizational Innovation and the Rise of Interest-Group Politics in the United States, 1890–1925 (Chicago, 1997)Google Scholar; Hansen, John M., Gaining Access: Congress and the Farm Lobby, 1919–1981 (Chicago, 1991)Google Scholar; Rodgers, Daniel T., Contested Truths: Keywords in American Politics Since Independence (New York, 1987), 176–211.Google Scholar

3. At the same time, historians have offered insight into how interest groups organize and sustain constituencies, problems that Bentley and Truman left largely unaddressed. Put another way, historiography on interest groups helps explain how we arrived at the system Truman described in 1951. This historiography also complements several decades of political science research addressing similar questions of group mobilization and maintenance. Drawing on rational choice theory (often referred to within the field as exchange theory), this scholarship frames the organization of interest groups as a collective action dilemma. In this regard, my article follows Robert Salisbury’s work in casting lobbyists like Arnold as the central figures in group formation, and it also dovetails with more recent studies showing how imperfect information—as well as irrational decision making—influence individual decisions to join such associations. Clemens, People’s Lobby; Balogh, “Mirrors of Desires”; Hansen, Gaining Access. On pluralism, see Bentley, , The Process of Government: A Study of Social Pressures (Chicago, 1908)Google Scholar; Truman, , The Governmental Process: Political Interests and Public Opinion (New York, 1951).Google Scholar On exchange theory, see Olson, Mancur, The Logic of Collective Action: Public Goods and the Theory of Groups (Cambridge, Mass., 1965)Google Scholar; Salisbury, Robert H., “An Exchange Theory of Interest Groups,” in Interest Group Politics in America, ed. Salisbury, Robert H. (New York, 1970), 32–67Google Scholar; and for an incisive review of this literature, see Baumgartner, Frank R. and Leech, Beth L., Basic Interests: The Importance of Groups in Politics and in Political Science (Princeton, 1998), 64–82.Google Scholar

4. Gary, Brett, The Nervous Liberals: Propaganda Anxieties from World War I to the Cold War (New York, 1999)Google Scholar; Sproule, J. Michael, Propaganda and Democracy: The American Experience of Media and Mass Persuasion (New York, 1997)Google Scholar; Schudson, Michael, The Good Citizen: A History of American Civic Life (New York, 1998), 192–202.Google Scholar Balogh notes interest groups use media and marketing strategies in “Mirrors of Desires,” 224.

5. U.S. Senate, Subcommittee of the Committee on the Judiciary, Lobby Investigation, 71st Cong., 2nd sess., 1929–30, 797 (hereafter Lobby Investigation, 1929–30).

6. Although scholars have written extensively about what lobbyists do, their effectiveness remains largely unclear. This holds true for historical accounts, as well as more recent political science, which has yet to systematically measure and explain lobbyists’ influence on the policymaking process. In fact, exchange theory—the paradigm that has dominated political science research on interest groups since the late 1960s—has more or less avoided the question of influence altogether. In this article, I turn these questions about lobbyists’ power and influence into the object of analysis, showing how persistent questions about how lobbying worked changed conceptions of lobbyists, public opinion, and democratic citizenship during the early twentieth century. The point, then, is not to show the extent to which fears about propaganda were justified—or even how many lobbyists like Arnold there were—but rather to demonstrate how the struggle to resolve these uncertainties reshaped American political culture. Hansen, Gaining Access, 22–25; Baumgartner and Leech, Basic Interests, 36–38, 64–82, 120–46.

7. I have found mentions of Arnold as the Beaumont chamber’s secretary as early as 1906. He became the president of the Commercial Secretaries’ Association the following year. “Five Million Club,” Dallas Morning News, 26 October 1906, 10; “Convention of Secretaries,” Dallas Morning News, 30 July 1907, 4; Lobby Investigation, 1929–30, 630, 695.

8. “Looney Brings Suit to Dissolve Business Men’s Association,” Dallas Morning News, 28 June 1914, 1; “B. F. Looney Opens Campaign,” Dallas Morning News, 21 May 1916, 7; “Brewing Propaganda,” New Republic, 21 August 1915, 62–64. For a broader overview of the Texas prohibition battle, see Odegard, Peter H., Pressure Politics: The Story of the Anti-Saloon League (New York, 1928), 249–56.Google Scholar

9. In addition to the plate service, Arnold apparently used similar tactics with pamphlets and other publicity. “B. F. Looney Opens Campaign,” 7.

10. “Looney Brings Suit,” 1.

11. “B. F. Looney Opens Campaign,” 7; Ready, Milton L., “The Southern Tariff Association” (M.A. thesis, University of Houston, 1966), 20.Google Scholar

12. “Brewing Propaganda,” 62–64; U.S. Senate, Committee on the Judiciary, Brewing and Liquor Interests and German and Bolshevik Propaganda, vol. 2, 65th Cong., 3rd sess., 1918–19, 2525–26 (hereafter Brewing and Liquor Interests).

13. According to Arnold, various brewers contributed somewhere between $29,000 and $41,000 between 1914 and 1916 (some of these funds may have gone to the Farm Life Commission). Eight to ten railroads—including the Santa Fe, Southern Pacific, Union Pacific, and the Missouri, Kansas, and Texas—gave $40,000 to $50,000. Arnold put his own salary at $500 a month, although it is unclear if he was always able to draw the full amount. “Brewing Propaganda,” 62–64; Brewing and Liquor Interests, 2524–615.

14. Ibid.

15. Brewing and Liquor Interests, 2604.

16. “Brewing Propaganda,” 62.

17. Ibid., 64.

18. McCormick, Richard L., “The Discovery That Business Corrupts Politics,” American Historical Review 86, no. 3 (1981): 247–74Google Scholar; Thompson, “Spider Web”; Keller, Morton, Affairs of State: Public Life in Late Nineteenth-Century America (Cambridge, Mass., 1977), 244–46Google Scholar, and Keller, , The Life Insurance Enterprise, 1885–1910: A Study in the Limits of Corporate Power (Cambridge, Mass., 1963), 214–64.Google Scholar

19. U.S. House of Representatives, Select Committee of the House of Representatives appointed under H.Res. 198, Charges Against Members of the House and Lobbying Activities, H. Rpt. 63-113, 1913, 24. See also Brooks, Robert C., “The Nature of Political Corruption,” Political Science Quarterly 24, no. 1 (1909): 1–22.CrossRefGoogle Scholar

20. The House had passed a temporary rule in 1876 requiring lobbyists to register with the clerk, but proposals for a federal lobbying act never gained much traction during the early 1900s. Instead, the House’s 1913 report—which followed an investigation into the passage of the Underwood Tariff—served as a de facto ethics guide. Additionally, the Publicity Acts (Corrupt Practices Acts) of 1910 and 1911 did require the reporting of contributions and expenditures in House and Senate races, and the 1911 act also limited campaign spending. Pendleton Herring noted that Massachusetts passed the first lobbying law in 1890, and Richard McCormick later found that at least twelve more states passed such statutes during the first decade of the 1900s. On the 1876 rule, see Thompson, “Spider Web,” 46; on the publicity acts, see Pub. L. no. 61-274, 25 June 1910, 822–24; Pub. L. no. 62-32, 19 August 1911, 25–29; for failed federal lobbying bills from this period, see the Congressional Record. On state laws, see Herring, , Group Representation Before Congress (New York, 1929; 1967), 258–62Google Scholar; McCormick, “The Discovery That Business Corrupts Politics,” 266.

21. Clemens, People’s Lobby.

22. In both periods, the vast majority of these groups were making their first appearance before Congress. Tichenor and Harris, “Organized Interests and American Political Development,” 598.

23. “Where Are Those Lobbyists?” Washington Post, 22 March 1912, 6.

24. The rise of professional journalism likely amplified the shock of these exposés. Whereas the predominately partisan press of the late nineteenth century provided an unabashedly slanted interpretation of the news, by the first decade of the twentieth century Arnold’s articles would have likely been published in independent newspapers and consumed by readers who expected their news to be presented objectively. Stannard Baker, Ray, “Railroads on Trial, V: How Railroads Make Public Opinion,” McClure’s, March 1906, 535Google Scholar; “Tainted News as Seen in the Making,” Bookman, December 1906, 396; Kittle, William, “The Making of Public Opinion,” Arena, July 1909, 433Google Scholar; McGerr, Michael, The Decline of Popular Politics: The American North, 1865–1928 (New York, 1986), 107–37.Google Scholar

25. Corporate interests also employed more ham-fisted tactics, such as undercutting hostile papers’ advertising revenue, or simply buying the publications outright. Baker, “Railroads on Trial”; Morse, Sherman, “An Awakening in Wall Street,” American Magazine, September 1906, 2Google Scholar; “Publicity Campaigning,” Independent, 29 July 1909, 224.

26. Baker, “Railroads on Trial.”

27. Tavenner, Congressional Record 50, pt. 3 (27 June 1913), 2247. On the post office, see Sproule, Propaganda and Democracy, 25.

28. Baker, “Railroads on Trial”; Kolko, Gabriel, Railroads and Regulation, 1877–1916 (Princeton, 1965), 103–5CrossRefGoogle Scholar, 131.

29. Sproule, Propaganda and Democracy, 9–16; Gary, Nervous Liberals, 18–23.

30. Herring personally counted 530, and found more than 300 in the phone book. Herring, Group Representation Before Congress, 19; Schattschneider, E. E., Politics, Pressures, and the Tariff: A Study of Free Private Enterprise in Pressure Politics, as Shown in the 1929–1930 Revision of the Tariff (New York, 1935), 38–39.Google Scholar

31. Odegard, Peter H., The American Public Mind (New York, 1930), 168.Google Scholar

32. Ibid., 241–42.

33. Hansen, Gaining Access, 11–12.

34. Herring, Group Representation Before Congress, 24, 245.

35. Ibid., 24, 41.

36. Ibid., 25–26.

37. Arnold also did some work for the National Council of State Legislatures (NCSL), although the Taxpayers’ League and the Tariff Association were the main focus of the inquiry.

38. Lawson, William, “Lobby ‘Sucker’ List Bared at Senate Inquiry,” Chicago Daily Tribune, 6 November 1929, 5.Google Scholar

39. U.S. Senate, Committee on the Judiciary, Lobbying and Lobbyists, pt. 4, S. Rpt. 71-43, 1929, 1 (hereafter Lobbying and Lobbyists, S. Rpt. 71-43).

40. Ibid., 4.

41. Herring, Group Representation Before Congress, 27–28.

42. This figure may also include the NCSL collections, but that figure appears to have been negligible. Lobby Investigation, 708–9; Lobbying and Lobbyists, S. Rpt. 71-43, 2.

43. The details of Arnold’s solicitations also raised eyebrows. After one of Arnold’s field workers canvassed Minneapolis and St. Paul during the summer of 1929, at least two organizations asked for more information on the Taxpayers’ League’s activities and finances. In both cases, Arnold’s men demurred. In response to an inquiry from the St. Paul Association of Commerce, one of Arnold’s field agents wrote to the chair of the state organization: “We have gotten all the money we can get out of St. Paul and I doubt the wisdom of submitting such information to prospective contributors.” While Arnold commented that his subordinate’s “phraseology might be unfortunate,” he defended the decision by saying that the league was no longer active in the city. Lobby Investigation, 711–25, 773–74, 786–87.

44. “W. L. Mellon Listed as Tax Lobby Donor,” New York Times, 6 November 1929, 22; “Hoover Target in Duty Battle,” 1.

45. Lobby Investigation, 709–10, 725, 750.

46. Lobbying and Lobbyists, S. Rpt. 71-43, 2. Arnold’s habits seem to have rubbed off on his accomplices. Ida Darden, one of his principal assistants, refused to tell the federal census taker her occupation in 1920, and kept her 1921 marriage to another Arnold employee secret. Her husband, a former newspaperman, apparently started calling himself a traveling salesman just before the 1929 hearings. Green, Elna C., “From Antisuffragism to Anti-Communism: The Conservative Career of Ida M. Darden,” Journal of Southern History 65, no. 2 (1999): 300.Google Scholar

47. Herring noted one estimate that three or four lobbyists made over $30,000, while another half dozen made between $30,000 and $20,000. Lobby Investigation, 735–40; Herring, Group Representation Before Congress, 54.

48. Arnold claimed that he had also loaned much of this amount back to the two associations, and the books did show that both the Southern Tariff Association and the American Taxpayers’ League were running deficits. Lobby Investigation, 735–40.

49. Ibid., 698.

50. Brown Tindall, George, The Emergence of the New South, 1913–1945: A History of the South, vol. 10 (Baton Rouge, 1967), 135.Google Scholar

51. “Five Million Club,” 10; “Texas Economic League Is Organized,” Dallas Morning News, 15 December 1915, 8.

52. According to Charles M. Dollar, Kirby handled the fundraising at this stage. Dollar, “The South and the Fordney-McCumber Tariff of 1922: A Study in Regional Politics,” Journal of Southern History 39, no. 1 (1973): 53–55.

53. Ibid., 48–51.

54. Caraway’s investigation probably did not help the Tariff Association’s efforts on the Hawley-Smoot Tariff. But as Schattschneider wrote in his account of the tariff, Arnold still retained enough influence by the late 1920s to secure a special interview for the STA from the Senate Finance Committee following the conclusion of public hearings on the bill. Tindall, The Emergence of the New South, 134–35; Dollar, “The South and the Fordney-McCumber Tariff of 1922,” 58–59; Schattschneider, Political Pressures and the Tariff, 210–11.

55. Arnold’s other work for the STA included putting similar pressure on Florida legislators and, in a move that angered Democrats on the committee, reporting to Republicans on an ostensibly secret conference on tariff rates between Democrats and insurgent Republicans. Lobby Investigation, 648–94, 796–802; Tax Lobby Had Plan to Get Albany’s Aid, New York Times, 7 November 1929, 4; “Try to Link Arnold to War Propaganda,” New York Times, 8 November 1929, 6.

56. The STA had also dabbled in electoral politics, although without any notable success. In setting up the council, Arnold had also met with Vice President Charles Curtis, who purportedly pledged to take up the matter with President Hoover. Lobbying and Lobbyists, S. Rpt. 71-43, 5–6.

57. Letter from R. B. Creager to James Arnold, August 1929, reprinted in Lobby Investigation, 599–602.

58. Lobbying and Lobbyists, S. Rpt. 71-43, 6.

59. Of the many bills proposed during the 1920s, only Caraway’s S. 1095—from the 1st session of the 70th Congress—made it out of committee. The lawmakers proposing these bills cut across both partisan and regional lines. By contrast, thirty-two states had passed lobbying laws by the end of the 1920s. These statutes most often required registration and financial disclosure, and prohibited contingent compensation—or fees based on the lobbyist’s success at influencing legislation. But a 1932 article in the Harvard Law Review noted that many state laws contained only “vague prohibitions and unsuitable penalties,” as well as weak or nonexistent enforcement mechanisms. As the article lamented, “Lobbyists conform to the requirements only insofar as is convenient, and the net result of most of this regulatory legislation consists of perfunctorily kept and seldom examined dockets in secretarial offices.” It seems possible that the lack of any sound models at the state level retarded the progress of similar legislation in Congress. Herring, Group Representation Before Congress, 258–62; Pollock, James K. Jr., “The Regulation of Lobbying,” American Political Science Review 21, no. 2 (1927): 335–41CrossRefGoogle Scholar; “Control of Lobbying,” Harvard Law Review 45, no. 7 (1932): 1241–48; “Seeking to Curb the Lobby,” New York Times, 21 March 1928, 6.

60. Herring, Group Representation Before Congress, 258. For other examples, see Sen. William S. Kenyon (Iowa), Congressional Record 60, pt. 2 (1 January 1921), 1243; Sen. William C. Bruce (Md.), Congressional Record 69, pt. 4 (1927), 3931–32; “Case of the Lobby,” Washington Post, 20 July 1929, 6; “When Lobbying Is Vicious,” New York Times, 16 October 1929, 27; “Lobbyists,” New York Times, 17 November 1929, E4; Lippmann, Walter, “The Senate Inquisition: I.,” Forum and Century 84, no. 3 (September 1930): 129Google Scholar; “Right Kind of Lobbying,” Washington Post, 13 October 1930, 6.

61. Odegard, Pressure Politics, 12, 75–76.

62. Ibid., 76.

63. Odegard, American Public Mind, 178.

64. Odegard, Pressure Politics, 96–97, 228–40.

65. Ibid., 228.

66. Ibid., 97.

67. In 1927, a group of congressmen charged that the American Legion’s lobbyist had acted without authorization from the veterans’ group in helping to defeat a poison-gas treaty harmful to chemical manufacturers. Later, during the Caraway hearings, the senators found that an agent for the American Farm Bureau Federation—acting without the approval of the AFBF board—had allied with the American Cyanamid Co. in its bid for private ownership of a lucrative fertilizer-processing facility at Muscle Shoals, Alabama. The company apparently financed propaganda bearing the imprint of the Farm Bureau, while the AFBF lobbyist provided letters of introduction to corporate-backed field agents looking to advocate corporate ownership to local farm organizations. “House Group Seeks to Remove Taylor as Agent of Legion,” Washington Post, 23 January 1927, 6; Lobbying and Lobbyists, pt. 8 S. Rpt. 71-43, 1–4.

68. Schattschneider, Politics, Pressures, and the Tariff, 225.

69. Schudson, Good Citizen, 9–10, 188–232.

70. Lippmann, Walter, The Phantom Public (New York, 1925), 13–14.Google Scholar

71. For further discussion of this debate, see Schudson, Good Citizen, 212–19.

72. Lobby Investigation, 723.

73. Ibid., 801.

74. Lobbying and Lobbyists, S. Rpt. 71-43, 4.

75. Lobby Investigation, 626. For a full list of contributors to the ATL., see ibid., 729–32.

76. “Editorial of the Day: Lobbyists Should Change Their Methods,” Chicago Daily Tribune, 2 March 1920, 8; reprinted from the Des Moines Capital.

77. “Back Stage in Washington: Propagandists and Presidents,” The Independent, 17 March 1928, 256.

78. His patron, Kirby, had ousted him from the Tariff Association following the public scolding by Caraway, and the STA. dissolved shortly thereafter. Kirby himself had gone bankrupt because of the Depression, although this did not dissuade him from continuing to agitate for conservative causes. Ready, “Southern Tariff Association,” 137. On the program of the Taxpayers’ League, see Investigation of Lobbying Activities, 1669–71. For a general overview of the Black Committee’s work, see Wolfskill, George, The Revolt of the Conservatives: A History of the American Liberty League, 1934–1940 (Boston, 1962), 227–45.Google Scholar

79. “Identify the Lobbyists,” Washington Post, 6 April 1935, 6.

80. By the time of the hearings, the league’s annual revenue had fallen to about $46,000. Investigation of Lobbying Activities, 1656–57, 1680–86.

81. Ibid., 1664–65.

82. Ibid., 1690; “Witness Calls Lobby Inquiry ‘Pole Cat’ Unit,” Washington Post, 20 March 1936, 13; “Witness Explodes at Lobby Inquiry,” New York Times, 20 March 1936, 5; “Lobby Witness Speaks Mind on Black Quizzing,” Chicago Daily Tribune, 20 March 1936, 9.

83. Soule, George, “Liberty League Liberty, I: Liberty in Politics,” New Republic, 26 August 1936, 63–67.Google Scholar

84. William White, “Utility Telegrams,” Emporia Gazette, reprinted in the New York Times, 28 July 1935, E8.

85. “Lobbying Blunders,” Washington Post, 18 July 1935, 8; “Two Lobby Inquiries Bare Much Bungling,” New York Times, 4 August 1935, E11; Crawford, Kenneth G., The Pressure Boys: The Inside Story of Lobbying in America (New York, 1939), 55–57Google Scholar; Newman, Roger K., Hugo Black: A Biography (New York, 1994), 176–81.Google Scholar

86. Crawford, Pressure Boys, 5.

87. Smith’s Boy Rangers countered with their own publicity blitz, but their valiant effort was crushed by Taylor’s goons. The exertions of CBS reporter H. V. Kaltenborn (appearing as himself), reporting on Smith’s filibuster from just outside the Senate chamber, appear to have been similarly ineffective.

88. Mr. Smith Goes to Washington, directed by Frank Capra, starring James Stewart and Jean Arthur (Columbia Pictures, 1939; distributed on DVD by Columbia TriStar Home Video).

89. Other laws passed during the 1930s regulated lobbying by shipping interests and public utility holding companies before federal commissions. The Foreign Agents Registration Act (1938), the Voorhis Act (1940) and the Smith Act (1941) also clamped down on radical and foreign groups of various stripes. On Black, see Zeller, Belle, “American Government and Politics: The Federal Regulation of Lobbying Act,” American Political Science Review 42, no. 2 (1948): 239–40CrossRefGoogle Scholar; Crawford, Pressure Boys, 44. On foreign and subversive propaganda, see Gary, Nervous Liberals, 194–251.

90. Senator Robert M. La Follette (Wisc.), Congressional Record 92, pt. 5 (1946): 6367–68.

91. The statute, part of a larger congressional reform package, defined a lobbyist as anyone who raised money to influence legislation or, more generally, “Any person who shall engage himself for pay or for any consideration for the purpose of attempting to influence the passage or defeat of any legislation by the Congress of the United States.” It specifically exempted individual citizens appearing before Congress, public officials, parties, and the press. “Federal Regulation of Lobbying Act,” Pub. L. 79-601, 2 August 1946, Title III, 839–42.

92. Arnold eventually changed the name of the Taxpayers’ League to the Western Tax Council. It is unclear whether he did much work on behalf of either organization following the Black investigation. Ready, “Southern Tariff Association,” 137; “James Asbury Arnold,” Chicago Daily Tribune, 31 July 1948, 4.

93. Within just a few years of its passage, numerous political scientists had concluded that ambiguities in the Lobbying Act’s language made it difficult to enforce or even understand. Even when lobbyists did register, Key noted, legislators continued to have difficulty discerning the size and strength of opposing constituencies. Zeller, “American Government and Politics,” 243–50; Lane, Edgar, “Some Lessons from Past Congressional Investigations of Lobbying,” Public Opinion Quarterly 14, no. 1 (1950): 14–32Google Scholar; Galloway, George B., “The Operation of the Legislative Reorganization Act of 1946,” American Political Science Review 45, no. 1 (1951): 41–68Google Scholar; Key, , Politics, Parties, and Pressure Groups, 4th ed. (New York, 1958), 167–70.Google Scholar

94. Key, Politics, Parties, and Pressure Groups, 22; Truman, Governmental Process.

95. Purcell, Edward A., The Crisis of Democratic Theory: Scientific Naturalism and the Problem of Value (Lexington, Ky., 1973), 197–235.Google Scholar

96. Shenon, Philip, “On Opinion Page, Lobby’s Hand Is Often Unseen,” New York Times, 23 December 2005Google Scholar, A1; Anne E. Kornblut and Philip Shenon, “Columnist Resigns His Post, Admitting Lobbyist Paid Him,” New York Times, 17 December 2005, A14; James V. Grimaldi and Susan Schmidt, “Report Says Nonprofits Sold Influence to Abramoff,” Washington Post, 13 October 2006, A1.

97. For a more complete discussion of the transformation of modern-day voluntary associations, see Schudson, Good Citizen, 278–81, 294–314; Putnam, Robert D., Bowling Alone: The Collapse and Revival of American Community (New York, 2000)Google Scholar; Skocpol, Theda, Diminished Democracy: From Membership to Management in American Civic Life (Norman, Okla., 2003).Google Scholar

98. On our tendency to overstate the power of the media as a causal force, see Schudson, Michael, The Power of News (Cambridge, 1995), 16–25.Google Scholar