Zeitschriftenartikel zum Thema „1887-1965 Criticism and interpretation“

Juvenile delinquency in Jakarta Theft of Lighters in Student Boarding Areas 1965-1998. This study aims to determine the juvenile delinquency in Jakarta in the theft of matches in the 1965 student boarding area, besides that the authors also expect readers to understand juvenile delinquency in Jakarta. Research uses historical research methods. The method used is heuristics, criticism / verification, interpretation and historical writing. The results of the study understood the initial program of economic and education policy during the New Order government, could understand juvenile delinquency in the student settlement environment during the New Order government, outline match theft and its continued development until the end of the new order government.

Juvenile delinquency in Jakarta Theft of Lighters in Student Boarding Areas 1965-1998. This study aims to determine the juvenile delinquency in Jakarta in the theft of matches in the 1965 student boarding area, besides that the authors also expect readers to understand juvenile delinquency in Jakarta. Research uses historical research methods. The method used is heuristics, criticism / verification, interpretation and historical writing. The results of the study understood the initial program of economic and education policy during the New Order government, could understand juvenile delinquency in the student settlement environment during the New Order government, outline match theft and its continued development until the end of the new order government.

From the end of the nineteenth century until well into the 1980s, one spoke of the “political sciences” (in the plural), a concept that included all the disciplines that analyzed political phenomena. “Sociological interpretation” began in the 1960s as a model of social science meant to provide both criticism and direction regarding development policies. Rodolfo Stavenhagen’s 1965 “Seven Erroneous Theses about Latin America” is an example of the role played by the political sciences at the time. Given the development of contemporary political science, which seeks dependent and independent variables and mid-range theories and bases its claims on empirical information, the question arises what Latin American political science can (re) learn from the interpretive model employed 50 years ago. Desde finales del siglo XIX y todavía en los años ochenta del siglo XX se hablaba de “ciencias políticas” (en plural), concepto en el cual se incluían todas aquellas disciplinas que analizaban los fenómenos políticos. La “interpretación sociológica” se erigió en la década de los años sesenta como un modelo de ciencia social que formulaba críticas pero también orientaba políticas de desarrollo. “Siete tesis equivocadas sobre América Latina” (1965) de Rodolfo Stavenhagen es un ejemplo del ejercicio de las ciencias políticas de la época. A la luz del desarrollo de la ciencia política contemporánea, que busca variables dependientes e independientes y teorías de alcance medio y funda sus afirmaciones a partir de información empírica, se trata de responder a la pregunta qué puede (re)aprender la ciencia política latinoamericana del modelo interpretativo de hace cincuenta años.

Penelitian ini bertujuan untuk menjelaskan aksi mahasiswa indonesia dan kesatuan aksi pelajar indonesia dalam proses peralihan kepemimpinan nasional tahun 1965-1968. Perjuangan peranan aksi-aksi mahasiswa sebagai “pressure group” sangat besar. Metode yang digunakan dalam penelitian ini yaitu penelitian histori meliputi langkah-langkah sebagai berikut: (1). Heuristik (2). Kritik, (3). interpretasi (4). Historiografi. Hasil penelitian menunjukkan bahwa Supersemar dan gerakan aksi mahasiswa telah membawa kemenangan bagi Orde Baru melalui proses konstitusional terhadap penyelewengan ideologi, politik, ekonomi, sosial dan budaya.Kata Kunci : Aksi Mahasiswa, Peralihan KepemimpinanABSTRACTThis study aims to explain the actions of Indonesian students and the unity of Indonesian student action in the process of transitioning the national leadership in 1965-1968. In the struggle the role of student actions as a "pressure group" is very large. The method used in this research is historical research including the following steps: (1). Heuristics (2). Criticism, (3). interpretation (4). Historiography. The results showed that Supersemar and the student action movement had brought victory for the New Order through a constitutional process of ideological, political, economic, social and cultural distortion.Keywords: Student Action, Leadership Transition

Tujuan dari penelitian ini adalah untuk mengetahui latar belakang pembredelan surat kabar Pikiran Rakjat pada 1965 setelah munculnya peraturan bagi pers untuk berafiliasi dengan partai atau organisasi politik tertentu. Penelitian ini menggunakan metode penelitian sejarah kritis yang terdiri dari empat tahapan kerja: heuristik, kritik sumber, interpretasi, dan historiografi. Hasil penelitian ini menunjukkan bahwa pada awal tahun 1965, kegiatan pers surat kabar Pikiran Rakjat sempat diberhentikan oleh pemerintah disebabkan terlambatnya surat kabar ini untuk terlibat dalam aktivitas politik. Pada 24 Maret 1966 atas dorongan Pangdam Siliwangi para wartawan yang di wakili Sakti Alamsyah sepakat untuk melakukan kerjasama untuk menerbitkan surat kabar Angkatan Bersenjata Edisi Jawa Barat. Belum setahun surat kabar ini terbit, Kementeriaan Penerangan mencabut kembali peraturan tentang afialiasi dalam dunia politik. Kondisi ini menyebabkan pada 24 Maret 1967 surat kabar Angkatan Bersenjata Edisi Jawa Barat berubah nama menjadi Harian Umum Pikiran Rakjat dibawah pemimpin umum redaksi yaitu Sakti Alamsyah. The purpose of this study is to determine the background to the banning of the Pikiran Rakjat Newspaper in 1965. The ban came after the government issued a regulation of requiring the press to be affiliated with certain political parties or organizations. This study uses a critical historical research method consisting of four stages of work, namely heuristics, source criticism, interpretation, and historiography. The results of this study show evidence that in the beginning of 1965 the government banned the newspaper because it was considered too late to engage in political activity. At the instigation of Commander of Military Regional Command/Siliwangi, it was on 24 March 1966 that journalists represented by Sakti Alamsyah agreed to cooperate in publishing Angkatan Bersenjata Newspaper West Java edition. However, when it was not yet a year old, the Ministry of Information revoked the regulations on obligating the press to affiliate with the political world. It was on March 24, 1967 that Angkatan Bersenjata Newspaper West Java edition consequently changed its name to Harian Umum Pikiran Rakjat and was operated under the editor-in-chief Sakti Alamsyah.

This article examines the influence of waters environment on the existence of Martapura port in Banjarmasin, South Kalimantan. Martapura port is a port located on the banks of Martapura River, Banjarmasin. This port has been an essential trade center since the 17th century during the heyday of Banjar sultanate. The strategic port location along the riverbank that divides Banjarmasin makes Martapura port crowded and visited by sailors and traders from various islands and other regions in Indonesia, even from other countries. Through historical research methods consisting of heuristics, source criticism, interpretation, and historiography, this article reveals how the waters environment influenced the existence of Martapura port until finally the port had to be moved to a new location. The results emphasize that the narrowing Martapura river due to the development of economic centers and residential settlements in the form of floating houses on both sides of the river and also sedimentation in the estuary, caused disruption of the shipping lanes to the port and the silting of the turning basins. As a result, the waterway became narrow and large ships were no longer able to move into the port. Therefore, in 1961, the construction of a new port on the banks of Barito river began and since 1965 Martapura port has only been used for the activities of small wooden ships and sailboats.

The history of economic thought remembers António Horta Osório for Schumpeter's reference to him in the History of Economic Analysis, in the context of a general appraisal of available works using mathematical instruments and language. This, however, does not do him justice, as he should also be praised for his pioneering interpretation of Pareto's general equilibrium. According to Stigler (1965), the definitive substitution of the cardinal utility hypothesis for the ordinal utility perspective was achieved by Johnson (1913) and Slutsky (1915). Weber (2001) discusses how far Pareto used cardinality, elects Slutsky (1915) as a pioneer of demand theory and prefers to reserve to R. G. Allen (1932–34), L. R. Klein and H. Rubin (1947–48), Samuelson (1947–48), R. C. Geary (1950–51), and Richard Stone (1954) the role of establishing ordinal utility in studying the utility function. This paper shows that Osório (1911) considered the subject of ordinalism before Johnson and Slutsky addressed the issue, as he had rejected the possibility of measuring utility and clearly stated that general equilibrium is not affected if cardinality is replaced by the ordinal conception for utility, according to Pareto's last formulation. Upon reading his book it becomes clear that not only was he perfectly aware of Edgeworth's contribution on the utility indifference curves, but also of Pareto's attempts to preserve general equilibrium from Fisher's criticism against cardinalism. Historians of economic thought have forgotten one of the early twentieth-century neoclassical economists. In this way the History of Economics has neglected an interesting proof of the consolidation of the Paretian ideas on ordinality, an issue that was an exciting and uncharted territory at that moment.

AbstractRevisiting the origins of the Interstate Commerce Commission (ICC) created in 1887 and offering a fresh interpretation that the commission was conceived and operated as a highly court-like agency, this paper argues that its emergence triggered the judicialization of the U.S. administrative state. It has been argued that the blueprint of the ICC took after existing railroad commissions. Its proponents in Congress, however, redesigned it with judicial courts as a model after facing criticisms based on the common-law principle of the supremacy of law allowing adjudication only to judicial courts. In accordance with such an institutional scheme, both the president and judiciary promoted the commission's judicialization by appointing lawyers as its members and reviewing its decisions. By the early twentieth century, the ICC was a prototypical agency whose court-like features permeated the administrative state. This paper thus offers a corrective to the literature on the U.S. administrative state building that has come to trivialize the role of the rise of the ICC. It was, instead, a critical juncture in the emergence of the modern administrative state in which being “quasi-judicial” was the norm rather than the exception for an administrative agency.

Purpose This paper aims to explore the reasons why descriptive phenomenology (DP) can provide an improved understanding of hospitality, tourism and event experiences. This is achieved through two objectives: first, by revealing the complexities and philosophical depths of DP; second, by providing a practical, stepped method that offers rigour and transparency. Design/methodology/approach This paper is based upon a study that explored the lived experience of the popular music festival-goer. It generally discusses the phenomenological philosophies of Husserl (1965 [1911]) and the descriptive phenomenological method in psychology of Giorgi (2009). It identifies not only some of the challenges and criticisms of DP but also the strengths of using a scientific approach to phenomenological research. Findings The philosophical strengths underlying DP afford a deeper understanding of the phenomenon being studied. The lived experience music festival study illustrates that the method of data collection and analysis highlights the intricacy of the philosophical debate and research findings. Although the bracketing, or epoché, method of DP has been criticised, the actual application is far more complex than trying to blank out prior knowledge. The aim is to ensure that it is the participants’ experiences that are used to identify the structure that is the phenomenon rather than the personal interpretation of the researcher. Originality/value It is recognised that researching the lifeworld affords a greater depth of understanding of experiences in people’s lives. One of the disappointments has been that one branch of phenomenological research, DP, has been underutilised and at times misunderstood in hospitality, tourism and event research. This paper aims to demonstrate and illustrate why and how DP should be considered in the future research of such experiences.

Since its creation in 1965, the constitutional right of privacy has been difficult to understand, even contradictory. This may be explained as the result of the incremental implementation of the sweeping language of Griswold v. Connecticut, with privacy coming into conflict with other rights such as the freedom of the press. In addition, the initial criticisms of Griswold’s synoptic privacy reasoning intensified when Roe v. Wade provoked potent political opposition. These influences combined with the changing membership on the Supreme Court to produce an evaporation of privacy language from recent decisions, most notably Webster v. Reproductive Health Services and Cruzan v. Director, Missouri Department of Health. Furthermore, the Court is transforming Roe's declaration of privacy as a “fundamental right” protected by “strict scrutiny” into a “liberty interest” protected by the relaxed standard of “rational-basis scrutiny.” Finally, Rehnquist and Scalia want to give a narrow historical interpretation to any “liberty interest,” thus limiting the application of privacy to other areas of constitutional law.

According to the traditional view of Empedocles' cosmic cycle, there are two creations of plants and animals, one under the dominion of increasing Strife and one under the dominion of increasing Love. At the point at which Strife holds complete sway the four elements are completely separated and all life is destroyed; at the point at which Love is completely dominant there is also a destruction of the biological world, this time because the elements are blended into a perfectly homogeneous mixture. This interpretation of the cosmic cycle, which has prevailed almost since it was developed by Friedrich Panzerbieter (1844) and seconded by authority of Eduard Zeller (1856) was challenged by Paul Tannery (1887) and then by H. von Arnim (1902). Long after these essentially programmatic critiques, three independent studies published in 1965 by Jean Bollack, Uvo Hölscher and Friedrich Solmsen mounted a vigorous challenge to the received view. However, in a detailed monograph devoted to Empedocles' cosmic cycle, Denis O'Brien (1969) brought to bear an impressive array of scholarly evidence and critical acumen in support of the traditional view (or rather a modified version of it). Several challenges to the traditional view have appeared since O'Brien's book, of which the most significant is that of A. A. Long, who, while criticizing attempts of some opponents of the traditional view, produced some novel and interesting arguments against it. Although the traditional view continues to enjoy the support of authorities such as Jonathan Barnes and M. R. Wright, there is a decided shift in favour of revisionary views. Nevertheless recent advocates of a revisionary interpretation do not provide detailed refutations of the traditional view; Long's arguments remain the strongest objections to the traditional view, and they have never been refuted. Will they stand up to scrutiny?

The grammarian Lindley Murray (1745–1826), according to Monaghan (1996), was the author of the best selling English grammar book of all times, calledEnglish Grammarand first published in 1795. Not surprisingly, therefore, his work was subjected to severe criticism by later grammarians as well as by authors of usage guides, who may have thought that Murray's success might negatively influence the sales figures of their own books. As the publication history of the grammar in Alston (1965) suggests, Murray was also the most popular grammarian of the late 18thand perhaps the entire 19thcentury, and this is most clearly reflected in the way in which a wide range of 19th- and even some 20th-century literary authors, from both sides of the Atlantic, mentioned Lindley Murray in their novels. Examples are Harriet Beecher Stowe (Uncle Tom's Cabin, 1852), George Eliot (Middlemarch, 1871–2), Charles Dickens, in several of his novels (Sketches by Boz, 1836;Nicholas Nickleby, 1838–9;The Old Curiosity Shop1840–1;Dombey & Son, 1846–8); Oscar Wilde (Miner and Minor Poets, 1887) and James Joyce (Ulysses, 1918) (Fens–de Zeeuw, 2011: 170–2). Another example is Edgar Allen Poe, who according to Hayes (2000) grew up with Murray's textbooks and used his writings as a kind of linguistic touchstone, especially in his reviews. Many more writers could be mentioned, and not only literary ones, for in a recent paper in which Crystal (2018) analysed the presence of linguistic elements in issues ofPunchpublished during the 19thcentury, he discovered that ‘[w]heneverPunchdebates grammar, it refers to Lindley Murray’. Murray, according to Crystal, ‘is the only grammarian to receive any mention throughout the period, and his name turns up in 19 articles’ (Crystal, 2018: 86). Murray had become synonymous with grammar prescription, and even in the early 20thcentury, he was still referred to as ‘the father of English Grammar’ (Johnson, 1904: 365).

AbstractWhen Jürgen Moltmann's Theology of Hope first appeared in 1965, it was seen as ushering in a new era of theological thinking. Karl Barth, however, sharply criticised the work as too heavily dominated by a ‘principle of hope’ that he believed Moltmann had inherited from the Marxist philosopher Ernst Bloch. This interpretation has largely been taken as fact among interpreters of Moltmann's theology of hope. This has caused most interpreters to see his turn to panentheism and ecotheology in God in Creation (1983) as being less of a shift of emphasis than a total change of trajectory or even break. There is evidence, however, that a different source contributed to the overall orientation of Moltmann's theology – an orientation that has remained throughout his life. This other source is the life and thought of the radical Schwäbean Pietists, Johann Christoph Blumhardt (1805–80) and his son Christoph Blumhardt (1842–1919). In this article the authors flesh out the thesis that the Blumhardts are the prior, deeper and more long-lasting influence on Moltmann by focusing on three key theological motifs that permeate his theology: 1) Christianity as eschatology; 2) the ‘theology of the earth’; and 3) the ethics of hope. Furthermore, they argue that when the ‘hidden’ influence of the Blumhardts is acknowledged, Moltmann's later ‘shift’ can be understood as essentially in continuity, rather than discontinuity, with his earlier thought.

This research entitled “The Action of Sarwo Edhie Wibowo in Maintaining Stability of Indonesia National Security (1965-1989)”. The Main problem in this research is “How was Sarwo Edhie Wibowo’s Action in Maintaining Indonesian National Security (1965-1989)”. The Research methodology used in this research is historical method through many steps such as heuristic, source criticism, interpretation and historiography. The researcher used interdisciplinary approaches through sociology and politic study. Sarwo Edhie Wibowo’s position as Commander of The Command of The Army Regiment (RPKAD) was most attracted era. Based on the command of PANGKOSTRAD Major General Soeharto, Sarwo Edhie succeeded to overcome coup of 30th September Movement. Entering New Order era, Sarwo Edhie officiated as Pangdam II/Bukit Barisan and helped in PNI stopping operation in North Andalas and then became Pangdam XVII/Cendrawasih. As Pangdam XVII/Cendrawasih, Sarwo Edhie had a role in succeeding PEPERA execution. In the end of his career, Sarwo Edhie became Governor of AKABRI, ambassador in South Korea, Head of BP7, and last as member of DPR/MPR. Until the end, he was retired and passed away at 10th November 1989.

This research entitled “The Action of Sarwo Edhie Wibowo in Maintaining Stability of Indonesia National Security (1965-1989)”. The Main problem in this research is “How was Sarwo Edhie Wibowo’s Action in Maintaining Indonesian National Security (1965-1989)”. The Research methodology used in this research is historical method through many steps such as heuristic, source criticism, interpretation and historiography. The researcher used interdisciplinary approaches through sociology and politic study. Sarwo Edhie Wibowo’s position as Commander of The Command of The Army Regiment (RPKAD) was most attracted era. Based on the command of PANGKOSTRAD Major General Soeharto, Sarwo Edhie succeeded to overcome coup of 30th September Movement. Entering New Order era, Sarwo Edhie officiated as Pangdam II/Bukit Barisan and helped in PNI stopping operation in North Andalas and then became Pangdam XVII/Cendrawasih. As Pangdam XVII/Cendrawasih, Sarwo Edhie had a role in succeeding PEPERA execution. In the end of his career, Sarwo Edhie became Governor of AKABRI, ambassador in South Korea, Head of BP7, and last as member of DPR/MPR. Until the end, he was retired and passed away at 10th November 1989.

This article discusses the Quranic exegesis concerning social care that is used as a base-praxis for philanthropy and social gatherings in the colonial period. The object of this study is Tafsier Soerat Al-Ma’oen (1930) written by K.H. Abdulchalim. This Sundanese-language work is actually developed as the result of Abdulchalim’s reading on the Quranic exegesis of Juz ‘Amma was written by Muhammad Abduh. Abdulchalim tried to interpret this surah and made it as the basis of the his philanthropic activities through the establishment of social institutions rather than carrying out casitas activities which he considered momentary and consumtive. His social activities were based on the teachings of philanthropy contained in the al-Mā‘ūn surah, such as philanthropic orientation from individual to collective, attachment between praying and the fulfilment of weak people’ right, criticism of the Muslim backwardness, and colonial occupation over his homeland. This study confirms that the Abdulchalim’s interpretation cannot be separated from the social situation as a nation that was being colonized faced with Dutch colonial policy and competition with Chinese traders. His exegesis becomes another example from the influence of Islamic renewal thrived in Cairo toward Southeast Asian Muslim activists, especially in the pre-independence period.

The Kirchhoff-diffraction integral is often used to describe the (scalar) wave field from a monochromatic point source in the presence of ‘opaque’ screens. Despite criticisms that can be made of its ‘derivation’, the Kirchhoff field is an exact solution of the wave equation, and exactly obeys definite, though unusual, boundary conditions (Kottler 1923, 1965). Here, the path-integral picture of wave fields is used to interpret the Kirchhoff-diffraction field in terms of all conceivable propagation paths, whether or not they pass through the opaque screens. Specifically, it is noted that the Kirchhoff field equals Ʃ(1 ─ m )ψ m , where the sum is over all integers m , and ψ m is the wave field due to all paths from the source to the field point for which the number of outward screen crossings minus the number of backwards screen crossings is m . Expressed more topologically, m is the total linking number of a path, when closed by any unobstructed path, with the screen edge lines. Other models of diffraction by screens are compared with Kirchhoff diffraction in the path interpretation.

IntroductionIt has been nearly half a century since the appearance of Susan Sontag’s landmark essay “The Imagination of Disaster.” The critic wrote of the public fascination with science fiction disaster films, claiming that, on the one hand “from a psychological point of view, the imagination of disaster does not greatly differ from one period in history to another [but, on the other hand] from a political and moral point of view, it does” (224). Even if Sontag is right about aspects of the imagination of disaster not changing, the types, frequency, and magnitude of disasters and their representation in media and popular culture suggest that dynamic conditions prevail on both counts. Disaster has become a significantly urban phenomenon, and highly publicised “worst case” scenarios such as Hurricane Katrina and the Haiti earthquake highlight multiple demographic, cultural, and environmental contexts for visualising cataclysm. The 1950s and 60s science fiction films that Sontag wrote about were filled with marauding aliens and freaks of disabused science. Since then, their visual and dramatic effects have been much enlarged by all kinds of disaster scenarios. Partly imagined, these scenarios have real-life counterparts with threats from terrorism and the war on terror, pan-epidemics, and global climate change. Sontag’s essay—like most, if not all of the films she mentions—overlooked the aftermath; that is, the rebuilding, following extra-terrestrial invasion. It ignored what was likely to happen when the monsters were gone. In contrast, the psychological as well as the practical, social, and economic aspects of reconstruction are integral to disaster discourse today. Writing about how architecture might creatively contribute to post-conflict (including war) and disaster recovery, for instance, Boano elaborates the psychological background for rebuilding, where the material destruction of dwellings and cities “carries a powerful symbolic erosion of security, social wellbeing and place attachment” (38); these are depicted as attributes of selfhood and identity that must be restored. Similarly, Hutchison and Bleiker (385) adopt a view evident in disaster studies, that disaster-struck communities experience “trauma” and require inspired responses that facilitate “healing and reconciliation” as well as material aid such as food, housing, and renewed infrastructure. This paper revisits Sontag’s “The Imagination of Disaster,” fifty years on in view of the changing face of disasters and their representation in film media, including more recent films. The paper then considers disaster recovery and outlines the difficult path that “creative industries” like architecture and urban planning must tread when promising a vision of rebuilding that provides for such intangible outcomes as “healing and reconciliation.” We find that hopes for the seemingly positive psychologically- and socially-recuperative outcomes accompanying the prospect of rebuilding risk a variety of generalisation akin to wish-fulfilment that Sontag finds in disaster films. The Psychology of Science Fiction and Disaster FilmsIn “The Imagination of Disaster,” written at or close to the height of the Cold War, Sontag ruminates on what America’s interest in, if not preoccupation with, science fiction films tell us about ourselves. Their popularity cannot be explained in terms of their entertainment value alone; or if it can, then why audiences found (and still find) such films entertaining is something that itself needs explanation.Depicted in media like photography and film, utopian and dystopian thought have at least one thing in common. Their visions of either perfected or socially alienated worlds are commonly prompted by criticism of the social/political status quo and point to its reform. For Sontag, science fiction films portrayed both people’s worst nightmares concerning disaster and catastrophe (e.g. the end of the world; chaos; enslavement; mutation), as well as their facile victories over the kinds of moral, political, and social dissolution the films imaginatively depicted. Sontag does not explicitly attribute such “happy endings” to wish-fulfilling phantasy and ego-protection. (“Phantasy” is to be distinguished from fantasy. It is a psychoanalytic term for states of mind, often symbolic in form, resulting from infantile wish-fulfilment, desires and instincts.) She does, however, describe the kinds of fears, existential concerns (like annihilation), and crises of meaning they are designed (purpose built) to allay. The fears are a product of the time—the down and dark side of technology (e.g. depersonalisation; ambivalence towards science, scientists, and technology) and changes wrought in our working and personal lives by urbanisation. In short, then as now, science fictions films were both expressions of deep and genuine worries and of the pressing need to inventively set them to rest.When Sontag claims that “the imagination of disaster does not greatly differ” (224) from one period to another, this is because, psychologically speaking, neither the precipitating concerns and fears (death, loss of love, meaninglessness, etc.), nor the ways in which people’s minds endeavour to assuage them, substantively differ. What is different is the way they are depicted. This is unsurprisingly a function of the political, social, and moral situations and milieus that provide the context in which the imagination of disaster unfolds. In contemporary society, the extent to which the media informs and constructs the context in which the imagination operates is unprecedented.Sontag claims that there is little if any criticism of the real social and political conditions that bring about the fears the films depict (223). Instead, fantasy operates so as to displace and project the actual causes away from their all too human origins into outer space and onto aliens. In a sense, this is the core and raison d’etre for such films. By their very nature, science fiction films of the kind Sontag is discussing cannot concern themselves with genuine social or political criticism (even though the films are necessarily expressive of such criticism). Any serious questioning of the moral and political status quo—conditions that are responsible for the disasters befalling people—would hamper the operation of fantasy and its production of temporarily satisfying “solutions” to whatever catastrophe is being depicted.Sontag goes on to discuss various strategies science fiction employs to deal with such fears. For example, through positing a bifurcation between good and evil, and grossly oversimplifying the moral complexity of situations, it allows one to “give outlet to cruel or at least amoral feelings” (215) and to exercise feelings of superiority—moral and otherwise. Ambiguous feelings towards science and technology are repressed. Quick and psychologically satisfying fixes are sought for these by means of phantasy and the imaginative construction of invulnerable heroes. Much of what Sontag says can straightforwardly be applied to catastrophe in general. “Alongside the hopeful fantasy of moral simplification and international unity embodied in the science fiction films lurk the deepest anxieties about contemporary existence” (220). Sontag writes:In the films it is by means of images and sounds […] that one can participate in the fantasy of living through one’s own death and more, the death of cities, the destruction of humanity itself. Science fiction films are not about science. They are about disaster, which is one of the oldest subjects in art. In science fiction films disaster is rarely viewed intensively; it is always extensive. It is a matter of quality and ingenuity […] the science fiction film […] is concerned with the aesthetics of disaster […] and it is in the imagery of destruction that the core of a good science fiction film lies. (212–13)In science fiction films, disaster, though widespread, is viewed intensively as well as extensively. The disturbances constitutive of the disaster are moral and emotional as well as material. People are left without the mental or physical abilities they need to cope. Government is absent or useless. We find ourselves in what amounts to what Naomi Zack (“Philosophy and Disaster”; Ethics for Disaster) describes as a Hobbesian second state of nature—where government is inoperative and chaos (moral, social, political, personal) reigns. Science fiction’s way out is to imaginatively construct scenarios emotionally satisfying enough to temporarily assuage the distress (anomie or chaos) experienced in the film.There is, however, a tremendous difference in the way in which people who face catastrophic occurrences in their lives, as opposed to science fiction, address the problems. For one thing, they must be far closer to complex and quickly changing realities and uncertain truths than are the phantastic, temporarily gratifying, and morally unproblematic resolutions to the catastrophic scenarios that science fiction envisions. Genuine catastrophe, for example war, undermines and dismantles the structures—material structures to be sure but also those of justice, human kindness, and affectivity—that give us the wherewithal to function and that are shown to be inimical to catastrophe as such. Disaster dispenses with civilization while catastrophe displaces it.Special Effects and Changing StorylinesScience fiction and disaster film genres have been shaped by developments in visual simulation technologies providing opportunities for imaginatively mixing fact and fiction. Developments in filmmaking include computer or digital techniques for reproducing on the screen what can otherwise only be imagined as causal sequences of events and spectacles accompanying the wholesale destruction of buildings and cities—even entire planets. Indeed films are routinely promoted on the basis of how cinematographers and technicians have advanced the state of the art. The revival of 3-D movies with films such as Avatar (2009) and Prometheus (2012) is one of a number of developments augmenting the panoramas of 1950s classics featuring “melting tanks, flying bodies, crashing walls, awesome craters and fissures in the earth, plummeting spacecraft [and] colourful deadly rays” (Sontag 213). An emphasis on the scale of destruction and the wholesale obliteration of recognisable sites emblematic of “the city” (mega-structures like the industrial plant in Aliens (1986) and vast space ships like the “Death Star” in two Star Wars sequels) connect older films with new ones and impress the viewer with ever more extraordinary spectacle.Films that have been remade make for useful comparison. On the whole, these reinforce the continuation and predictability of some storylines (for instance, threats of extra-terrestrial invasion), but also the attenuation or disappearance of other narrative elements such as the monsters and anxieties released by mid-twentieth century atomic tests (Broderick). Remakes also highlight emerging themes requiring novel or updated critical frameworks. For example, environmental anxieties, largely absent in 1950s science fiction films (except for narratives involving colliding worlds or alien contacts) have appeared en masse in recent years, providing an updated view on the ethical issues posed by the fall of cities and communities (Taylor, “Urban”).In The Invasion of the Bodysnatchers and its remakes (1956, 1978, 1993), for example, the organic and vegetal nature of the aliens draws the viewer’s attention to an environment formed by combative species, allowing for threats of infestation, growth and decay of the self and individuality—a longstanding theme. In the most recent version, The Invasion (2007), special effects and directorial spirit render the orifice-seeking tendrils of the pod creatures threateningly vigorous and disturbing (Lim). More sanctimonious than physically invasive, the aliens in the 1951 version of The Day the Earth Stood Still are fed up with humankind’s fixation with atomic self-destruction, and threaten global obliteration on the earth (Cox). In the 2008 remake, the suave alien ambassador, Keanu Reeves, targets the environmental negligence of humanity.Science, including science as fiction, enters into disaster narratives in a variety of ways. Some are less obvious but provocative nonetheless; for example, movies dramatising the arrival of aliens such as War of the Worlds (1953 and 2005) or Alien (1979). These more subtle approaches can be personally confronting even without the mutation of victims into vegetables or zombies. Special effects technologies have made it possible to illustrate the course of catastrophic floods and earthquakes in considerable scientific and visual detail and to represent the interaction of natural disasters, the built environment, and people, from the scale of buildings, homes, and domestic lives to entire cities and urban populations.For instance, the blockbuster film The Day After Tomorrow (2004) runs 118 minutes, but has an uncertain fictional time frame of either a few weeks or 72 hours (if the film’s title is to taken literally). The movie shows the world as we know it being mostly destroyed. Tokyo is shattered by hailstones and Los Angeles is twisted by cyclones the likes of which Dorothy would never have seen. New York disappears beneath a mountainous tsunami. All of these events result from global climate change, though whether this is due to human (in) action or other causes is uncertain. Like their predecessors, the new wave of disaster movies like The Day After Tomorrow makes for questionable “art” (Annan). Nevertheless, their reception opens a window onto broader political and moral contexts for present anxieties. Some critics have condemned The Day After Tomorrow for its scientific inaccuracies—questioning the scale or pace of climate change. Others acknowledge errors while commending efforts to raise environmental awareness (Monbiot). Coincident with the film and criticisms in both the scientific and political arena is a new class of environmental heretic—the climate change denier. This is a shadowy character commonly associated with the presidency of George W. Bush and the oil lobby that uses minor inconsistencies of science to claim that climate change does not exist. One thing underlying both twisting facts for the purposes of making science fiction films and ignoring evidence of climate change is an infantile orientation towards the unknown. In this regard, recent films do what science fiction disaster films have always done. While freely mixing truths and half-truths for the purpose of heightened dramatic effect, they fulfil psychological tasks such as orchestrating nightmare scenarios and all too easy victories on the screen. Uncertainty regarding the precise cause, scale, or duration of cataclysmic natural phenomena is mirrored by suspension of disbelief in the viability of some human responses to portrayals of urban disaster. Science fiction, in other words, invites us to accept as possible the flight of Americans and their values to Mexico (The Day After Tomorrow), the voyage into earth’s molten core (The Core 2003), or the disposal of lava in LA’s drainage system (Volcano 1997). Reinforcing Sontag’s point, here too there is a lack of criticism of the real social and political conditions that bring about the fears depicted in the films (223). Moreover, much like news coverage, images in recent natural disaster films (like their predecessors) typically finish at the point where survivors are obliged to pick up the pieces and start all over again—the latter is not regarded as newsworthy. Allowing for developments in science fiction films and the disaster genre, Sontag’s observation remains accurate. The films are primarily concerned “with the aesthetics of destruction, with the peculiar beauties to be found in wreaking havoc, in making a mess” (213) rather than rebuilding. The Imagination of Disaster RecoverySontag’s essay contributes to an important critical perspective on science fiction film. Variations on her “psychological point of view” have been explored. (The two discourses—psychology and cinema—have parallel and in some cases intertwined histories). Moreover, in the intervening years, psychological or psychoanalytical terms and narratives have themselves become even more a part of popular culture. They feature in recent disaster films and disaster recovery discourse in the “real” world.Today, with greater frequency than in the 1950s and 60s films arguably, representations of alien invasion or catastrophic global warming serve to background conflict resolutions of a more quotidian and personal nature. Hence, viewers are led to suspect that Tom Cruise will be more likely to survive the rapacious monsters in the latest The War of the Worlds if he can become less narcissistic and a better father. Similarly, Dennis Quaid’s character will be much better prepared to serve a newly glaciated America for having rescued his son (and marriage) from the watery deep-freezer that New York City becomes in The Day After Tomorrow. In these films the domestic and familial comprise a domain of inter-personal and communal relations from which victims and heroes appear. Currents of thought from the broad literature of disaster studies and Western media also call upon this domain. The imagination of disaster recovery has come to partly resemble a set of problems organised around the needs of traumatised communities. These serve as an object of urban governance, planning, and design conceived in different ways, but largely envisioned as an organic unity that connects urban populations, their pasts, and settings in a meaningful, psychologically significant manner (Furedi; Hutchison and Bleiker; Boano). Terms like “place” or concepts like Boano’s “place-attachment" (38) feature in this discourse to describe this unity and its subjective dimensions. Consider one example. In August 2006, one year after Katrina, the highly respected Journal of Architectural Education dedicated a special issue to New Orleans and its reconstruction. Opening comments by editorialist Barbara Allen include claims presupposing enduring links between the New Orleans community conceived as an organic whole, its architectural heritage imagined as a mnemonic vehicle, and the city’s unique setting. Though largely unsupported (and arguably unsupportable) the following proposition would find agreement across a number of disaster studies and resonates in commonplace reasoning:The culture of New Orleans is unique. It is a mix of ancient heritage with layers and adaptations added by successive generations, resulting in a singularly beautiful cultural mosaic of elements. Hurricane Katrina destroyed buildings—though not in the city’s historic core—and displaced hundreds of thousands of people, but it cannot wipe out the memories and spirit of the citizens. (4) What is intriguing about the claim is an underlying intellectual project that subsumes psychological and sociological domains of reasoning within a distinctive experience of community, place, and memory. In other words, the common belief that memory is an intrinsic part of the human condition of shock and loss gives form to a theory of how urban communities experience disaster and how they might re-build—and justify rebuilding—themselves. This is problematic and invites anachronistic thinking. While communities are believed to be formed partly by memories of a place, “memory” is neither a collective faculty nor is it geographically bounded. Whose memories are included and which ones are not? Are these truly memories of one place or do they also draw on other real or imagined places? Moreover—and this is where additional circumspection is inspired by our reading of Sontag’s essay—does Allen’s editorial contribute to an aestheticised image of place, rather than criticism of the social and political conditions required for reconstruction to proceed with justice, compassionately and affectively? Allowing for civil liberties to enter the picture, Allen adds “it is necessary to enable every citizen to come back to this exceptional city if they so desire” (4). However, given that memories of places and desires for their recovery are not univocal, and often contain competing visions of what was and should be, it is not surprising they should result in competing expectations for reconstruction efforts. This has clearly proven the case for New Orleans (Vederber; Taylor, “Typologies”)ConclusionThe comparison of films invites an extension of Sontag’s analysis of the imagination of disaster to include the psychology, politics, and morality of rebuilding. Can a “psychological point of view” help us to understand not only the motives behind capturing so many scenes of destruction on screen and television, but also something of the creative impulses driving reconstruction? This invites a second question. How do some impulses, particularly those caricatured as the essence of an “enterprise culture” (Heap and Ross) associated with America’s “can-do” or others valorised as positive outcomes of catastrophe in The Upside of Down (Homer-Dixon), highlight or possibly obscure criticism of the conditions which made cities like New Orleans vulnerable in the first place? The broad outline of an answer to the second question begins to appear only when consideration of the ethics of disaster and rebuilding are taken on board. If “the upside” of “the down” wrought by Hurricane Katrina, for example, is rebuilding of any kind, at any price, and for any person, then the equation works (i.e., there is a silver lining for every cloud). If, however, the range of positives is broadened to include issues of social justice, then the figures require more complex arithmetic.ReferencesAllen, Barbara. “New Orleans and Katrina: One Year Later.” Journal of Architectural Education 60.1 (2006): 4.Annan, David. Catastrophe: The End of the Cinema? London: Lorrimer, 1975.Boano, Camillo. “‘Violent Space’: Production and Reproduction of Security and Vulnerabilities.” The Journal of Architecture 16 (2011): 37–55.Broderick, Mick, ed. Hibakusha Cinema: Hiroshima, Nagasaki and the Nuclear Image in Japanese Film. London: Kegan Paul, 1996.Cox, David. “Get This, Aliens: We Just Don’t Care!” The Guardian 15 Dec. 2008 ‹http://www.guardian.co.uk/film/filmblog/2008/dec/15/the-day-the-earth-stood-still›. Furedi, Frank. “The Changing Meaning of Disaster.” Area 39.4 (2007): 482–89.Heap, Shaun H., and Angus Ross, eds. Understanding the Enterprise Culture: Themes in the Work of Mary Douglas. Edinburgh: Edinburgh University Press, 1992. Homer-Dixon, Thomas. The Upside of Down: Catastrophe, Creativity and the Renewal of Civilization. Washington, DC: Island Press, 2006.Hutchison, Emma, and Roland Bleiker. “Emotional Reconciliation: Reconstituting Identity and Community after Trauma.” European Journal of Social Theory 11 (2008): 385–403.Lim, Dennis. “Same Old Aliens, But New Neuroses.” New York Times 12 Aug. 2007: A17.Monbiot, George. “A Hard Rain's A-gonna Fall.” The Guardian 14 May 2004.Sontag, Susan. “The Imagination of Disaster” (1965). Against Interpretation and Other Essays. New York: Dell, 1979. 209–25.Taylor, William M. “Typologies of Katrina: Mnemotechnics in Post-Disaster New Orleans.” Interstices 13 (2012): 71–84.———. “Urban Disasters: Visualising the Fall of Cities and the Forming of Human Values.” Journal of Architecture 11.5 (2006): 603–12.Verderber, Stephen. “Five Years After – Three New Orleans Neighborhoods.” Journal of Architectural Education 64.1 (2010): 107–20.Zack, Naomi. Ethics for Disaster. New York: Rowman and Littlefield, 2009.———. “Philosophy and Disaster.” Homeland Security Affairs 2, article 5 (April 2006): ‹http://www.hsaj.org/?article=2.1.5›.FilmographyAlien. Dir. Ridley Scott. Brandywine Productions, 1979.Aliens. Dir. James Cameron. Brandywine Productions, 1986.Avatar. Dir. James Cameron. Lightstorm Entertainment et al., 2009.The Core. Dir. Jon Amiel. Paramount Pictures, 2003.The Day after Tomorrow. Dir. Roland Emmerich. 20th Century Fox, 2004.The Invasion of the Body Snatchers. Dir. Don Siegel. Allied Artists, 1956; also 1978 and 1993.The Invasion. Dirs. Oliver Hirschbiegel and Jame McTeigue. Village Roadshow et al, 2007.Prometheus. Dir. Ridley Scott. Scott Free and Brandywine Productions, 2012Star Wars Episode IV: A New Hope. Dir. George Lucas. Lucasfilm, 1977.Star Wars Episode VI: Return of the Jedi. Dir. George Lucas. Lucasfilm, 1983.Volcano. Dir. Mick Jackson. 20th Century Fox, 1997.War of the Worlds. Dir. George Pal. Paramount, 1953; also Steven Spielberg. Paramount, 2005.Acknowledgments The authors are grateful to Oenone Rooksby and Joely-Kym Sobott for their assistance and advice when preparing this article. It was also made possible in part by a grant from the Australian Research Council.

Photo by Patrick Tomasso on Unsplash ABSTRACT In cases where the law conflicts with bioethics, the status of rights must be determined to resolve some of the tensions. This paper considers the origins of both legal and philosophical rights, arguing that rights per se do not exist naturally. Even natural rights that are constitutional or statutory came from relationships rather than existing in nature. Once agreed upon, rights develop moral influence. INTRODUCTION l. The Question of Rights The language of rights is omnipresent in current discourse in law, bioethics, and many other disciplines. Rights dialogue is frequently contentious – some thinkers take issue with various uses of rights in the modern dialogue. For example, some criticize “rights talk,” which heightens social conflict when used as a “trump” against disfavored arguments.[1] Others are displeased by what is termed “rights inflation,” where too many novel rights are developed, such that the rights these scholars view as “more important” become devalued.[2] Some solutions have been proposed: one recommendation is that rights should be restricted to extremely important or essential ones. Some Supreme Court justices make arguments for applying original meanings in legal cases.[3] Conflict over the quantity and status of rights has long been a subject of debate in law and philosophy. Even Jefferson had to balance his own strict reading of the Constitution with tendencies to exceed the plain text of the document.[4] This thread of discourse has grown in political prominence over the years, with more Supreme Court cases that suggest newly developed (or, perhaps, newly recognized) rights. The theoretical conflict between textualists and those looking to intent or context could lead to repealing rights to abortion, sterilization, or marital privacy and deeply impacts our daily lives. Bioethics is ubiquitous, and rights discourse is fundamental. This paper analyzes the assumptions that underlie the existence of rights. The law is steeped in philosophy, though philosophical theories have an often-unacknowledged role. This is especially true in cases that navigate difficult bioethical issues. As a result of this interleaving, the ontological status of rights is necessary to resolve some of the theoretical tensions. Many philosophers have either argued for or implicitly included human rights in their theories of morality and legality. However, there is no universally accepted definition of rights; various philosophers have their own approaches. For example: Louden comments, “Rights are permissions rather than requirements. Rights tell us what the bearer is at liberty to do”; Martin thinks that a right is “an established way of acting”; Hohfeld concludes that all rights are claims.[5] Similarly, there is dissent about the qualities of rights: The Declaration of Independence characterizes rights as unalienable, but not all thinkers agree. Nickel comments, “Inalienability does not mean that rights are absolute or can never be overridden by other considerations. . . Perhaps it is sufficient to say that [human] rights are very hard to lose.”[6] This discord necessitates additional analysis. “Many people tend to take the validity of. . . rights for granted. . . However, moral philosophers do not enjoy such license for epistemological complacency.”[7] Because of the fundamental impact that political and moral philosophy enacted as the law have, this paper considers the origins of both legal and philosophical rights, arguing that rights per se do not exist naturally. Even natural rights that are constitutional or statutory came from relationships rather than existing in nature. Once agreed upon, rights take on moral force. ll. Legal Rights: From Case to Constitution Bioethics and law sometimes address rights differently. Three Supreme Court cases marked the development of privacy rights in the United States: Griswold v. Connecticut (1965), Roe v. Wade (1973) and Cruzan v. Director, Missouri Department of Health (1990). These cases shape the normative dialogue and consider complex moral quandaries. Griswold v. Connecticut concerned providing contraception to married couples in contravention of state law. Justice Douglas writes for the majority that, based in “a right of privacy older than the Bill of Rights,” legally protected zones of privacy extend from the text of the Constitution. “Specific guarantees in the Bill of Rights have penumbras, formed by emanations from those guarantees that help give them life and substance.”[8] Writing in dissent, Justice Black argues that there is not a broad right to privacy included in the provisions of the Constitution, and expresses concern over “dilut[ion] or expans[ion]” of enumerated rights by terms such as privacy, which he characterizes as abstract and ambiguous – and subject to liberal reinterpretation.[9] He concludes that the government does have the right to invade privacy “unless prohibited by some specific constitutional provision.”[10] Also dissenting, Justice Stewart finetunes the argument: rather than look to community values beyond the Constitution, the Court ought to rely solely on text of the document, in which he “can find no such general right of privacy in the Bill of Rights, in any other part of the Constitution, or in any case ever decided by this court.”[11] Thus, Griswold v. Connecticut is an example of the tensions within the Supreme Court over strict textualism or broader interpretations of the Constitution that look to intent and purpose. Roe v. Wade held that there is a right to privacy found through the Due Process Clause of the Fourteenth Amendment that includes the right to make medical decisions including abortion. While the conclusion – that there is a Constitutionally protected right to abortion, with certain limits seems to expand the Griswold doctrine of privacy rights, dissent to the ruling stems from much the same concern as before. Justice Rehnquist writes: A transaction resulting in an operation such as this is not "private" in the ordinary usage of that word. Nor is the "privacy" that the Court finds here even a distant relative of the freedom from searches and seizures protected by the Fourth Amendment to the Constitution, which the Court has referred to as embodying a right to privacy.[12] However, he then departs from the stricter approach of Justices Black and Stewart: I agree… that the "liberty," against deprivation of which without due process the Fourteenth Amendment protects, embraces more than the rights found in the Bill of Rights. But that liberty is not guaranteed absolutely against deprivation, only against deprivation without due process of law.[13] This is a tempering of the stricter constructionism found earlier, where more latitude is allowed for the interpretation of the text of the Constitution, even though there are clearly limits on how far the words may be stretched, with the genesis of a new right. Later, in Planned Parenthood of Southwestern Pennsylvania v. Casey, the Court further refined Roe v. Wade implementing an “undue burden” test.[14] In Cruzan v. Director, Missouri Department of Health, the Court held that there is a general liberty interest in the refusal of medical treatment. The case continues the tradition of Griswold and Roe v. Wade ensuring a liberty that is beyond the text, but also allows states to impose a strict evidentiary burden to shape how the right is exercised. The Court affirmed the lower court’s decision that “because there was no clear and convincing evidence of Nancy [Cruzan’s] desire to have life-sustaining treatment withdrawn. . . her parents lacked authority to effectuate such a request.”[15] The Supreme Court found that the clear and convincing evidentiary burden applied by the Missouri Supreme Court was consistent with the Due Process clause. Justice Scalia notes that even though he agrees with the Court’s decision, he finds this judgment unnecessary or, perhaps counterproductive, because the philosophical underpinnings of the case “are neither set forth in the Constitution nor known to the nine Justices of this Court any better than they are known to nine people picked at random from the Kansas City telephone directory” and should be left to the states to legislate as they see fit.[16] He goes on to further argue that the Due Process clause “does not protect individuals against deprivations of liberty simpliciter”; rather, it protects them from infringements of liberty that are not accompanied by due process.[17] Justice Scalia’s textualist position likely influenced his remarks.[18] Comparing these cases, I argue there is a distinct effort to make the Constitution amenable to contemporary mores and able to address present issues that is moderated by justices who adhere to the text. The legal evolution of rights that are beyond the text of the Constitution may reflect social norms as well as the framers’ intent. Rights are protected by the Constitution, but the Constitution is mutable, through both case law and legislation. Prior to the adoption of the Constitution, the Declaration of Independence declared: We hold these truths to be self-evident, that all men are created equal, that they are endowed by their Creator with certain unalienable Rights, that among these are Life, Liberty and the pursuit of Happiness.--That to secure these rights, Governments are instituted among Men, deriving their just powers from the consent of the governed.[19] The Declaration of Independence gives insight into rights prior to the Constitution by referring to a priori rights extended by a creator, sheltered and supported by the state.[20] For earlier evidence of rights, Supreme Court cases often reference English common law doctrines. The common law was informed by preexisting principles and drew on a historical body of thought: philosophy. Exploring philosophy can give insight about the evolution of law. lll. Philosophical Rights: Issues of Ontology A moral right, the precursor to many legal rights, in some ways is a claim that bears moral weight. One relevant distinction is between positive and negative rights: a positive right is a claim on another to do something for the right holder; a negative right is a claim on others to leave the rights holder alone. Some rights are per se (that is, rights that have a de novo ontological origin) and some are constructed (rights that are secondary to some other theoretical apparatus). We must appeal to the state of nature to understand the origin of rights. If rights exist in the state of nature, they are de novo; if not, they are constructed. The state of nature is the theoretical realm where there are no social conventions or no normative rules. The theoretical state of nature is stateless. Hobbes writes about the state of nature. He constructs the person within as incorporating two normative qualities: the law of nature, “whereby individuals are forbidden to do anything destructive of their lives or to omit the means of self-preservation,” and the right of nature, where the person has the “right to all things” – those things required for self-preservation.[21] Similarly, more contemporary philosophers have also inferred that the right to freedom is a natural right.[22] I argue that nature allows every person the freedom to all things, or a natural right against limitation on freedom. Every person has the capacity to do whatever they want, in accordance with their reason; liberty, rather than being a normative claim, is a component of the essence of beings. Yet both nature and other people pose some limitations. Early modern contractarians’ status theories maintain that human attributes engender rights. [23] A specific formulation of human status ethics can be found in Kantian deontology. From the autonomous and rational will, Kant evolves his Categorical Imperative: “Act only according to that maxim whereby you can at the same time will that it should become a universal law.”[24] Without (or before) law, philosophers suggested behaviors should reflect moral rights. Like Rawls, I maintain that the state of nature includes both a scarcity of resources and individuals with whom we may develop conflicts of interest.[25] Individually, we are vulnerable to others, and because of that natural vulnerability, we have an inclination toward self-interest.[26] Therefore, we eventually find the state of nature unsatisfactory and move to create a civil society. Then the subsequent pathway to creating “rights” is well known. People agree on them and act accordingly. Then, they are enshrined in the law.[27] I attribute the impetus to move from the state of nature toward government to interpersonal interaction that creates a form of the social contract. Rawls qualitatively describes this when he notes the “identity of interests” that powers interpersonal cooperation.[28] To me, the development of positive social relations has three components. The first is the human capacity for empathy. Empathy is commonly accepted by psychologists as universal.[29] Kittay deepens the concept of human empathy, arguing that there is a “register of inevitable human dependency” – a natural sense of care found in the human experience of suffering and decay and death to which we all eventually succumb, necessitating a recognition of interdependence and cooperation.[30] The second is the importance of identity in generating social cooperation.[31] There is a sense of familial resemblance that resonates when we see others in our lives, forming the base of the identification that allows us to create bonds of mutual assent. A microsociety develops when people are exposed to each other and acts as a miniaturized state, governed by what is at first an implicit social contract. An internal order is generated and can be codified. The third component of social relations is the extension of the otherness-yet-sameness beyond human adults. Mirroring connects the fully abled adult man and the woman, as well as the child, the physically and mentally disabled, and could extend to animals as well.[32] Therefore, to me, it seems that rights do not exist per se in the state of nature, but because of our human capacities, relationships yield a social contract. This contract governs interpersonal relations with normative power: rights are constructed. Once constructed based on people in micro-society and then larger groups, rights were codified. Negative rights like those found in the U.S. Constitution allow people in liberal society to codify nearly universal ground rules in certain arenas while respecting minority views and differing priorities. However, the social contract is not absolute: it may be broken by any party with the power to enforce their will upon the other and it will evolve to reflect changing standards. So, there is a subtle distinction to be made: in unequal contractual social relations, there are not constructed rights but rather privileges. In a social relationship that aims at equal status among members, these privileges are normative claims – rights that are not inherent or a priori but mandated to be equally applied by society’s governing body. In this way, I differ from Rawls. To me, justice is a fundamental moral principle only for societies that aim at cooperation, where advancing the interests of all is valued.[33] CONCLUSION From Liberty to Law Social contractualism purports to provide moral rules for its followers even when other ethical systems flounder in the state of nature. Relationships consider the needs and wants of others. Rights exist, with the stipulation that they are constructed under social contracts that aim for equality of application. I also suggest that contractualist approaches may even expand the parties who may be allowed rights, something that has significant bearing on the law and practical bioethics. The strict/loose constructionism debate that has played out in the Supreme Court’s decisions focuses on whether rights are enumerated or implied. Theoretical or implicit contracts may be change quickly, based on the power dynamics in a social relationship. Theoretical bounds of the social contract (possibly including animals, nonhumans, etc.) may be constricted by an official contract, so these concerns would need to be adjudicated in the context of the Constitution. In certain cases, strict interpretation reflects the rights determined by the social compact and limits new positive rights; in others, a broad interpretation keeps government out of certain decisions, expanding negative rights to reflect changing social norms. The negative rights afforded in the Constitution provide a framework meant to allow expansive individual choices and freedom. The underlying social compact has more to do with the norms behind societal structure than forcing a set of agreed upon social norms at the level of individual behavior. The Constitution’s text can be unclear, arbitrary, or open to multiple meanings. The literary theorist may be willing to accept contradiction or multiple meanings, but the legal scholar may not. The issue of whether the social compact is set or evolving affects constitutional interpretation. The law is itself may be stuck in a state of indeterminacy: the law, in the eyes of the framers, was centered on a discourse steeped in natural, human rights, attributed to a creator. Today, there is an impulse toward inherent human dignity to support rights. The strict/loose constructionism debate concerns interpretation.[34] In conclusion, rights have no ontological status per se, but are derived from a complex framework that springs from our relationships and dictates the appropriateness of our actions. While the Constitution establishes the negative rights reflecting a social compact, interpretations recognize the limitations on rights that are also rooted in societal relationships. The author would like to thank Stephen G. Post, PhD, and Caitlyn Tabor, JD, for providing feedback on early drafts of this paper. [1] Mary Ann Glendon, A World Made New: Eleanor Roosevelt and the Universal Declaration of Human Rights (New York: Random House, 2001), 14. [2] James Griffin, On Human Rights (Oxford: Oxford University, 2008). [3] Maurice Cranston, What Are Human Rights? (London: Bodley Head, 1973). [4] Barry Balleck, “When The Ends Justify the Means: Thomas Jefferson and the Louisiana Purchase,” Presidential Studies Quarterly 22, no. 4 (1992): 679-680. [5] Robert Louden, “Rights Infatuation and the Impoverishment of Moral Theory,” Journal of Value Inquiry 17 (1983): 95; Rex Martin, A System of Rights (Oxford: Oxford University, 1993), 1; Wesley Hohfeld, Fundamental Legal Conceptions (New Haven: Yale University, 1919), 36. [6] James Nickel, "Human Rights", The Stanford Encyclopedia of Philosophy (Summer 2019 Edition), ed. Edward N. Zalta, accessed 27 April 2021, https://plato.stanford.edu/archives/sum2019/entries/rights-human/. [7] Andrew Fagan, “Human Rights,” Internet Encyclopedia of Philosophy, ed. James Fieser and Bradley Dowden, accessed 27 April 2021, https://iep.utm.edu/hum-rts/. [8] Griswold v. Connecticut 381 U.S. 479 (1965), para. 18, https://www.law.cornell.edu/supremecourt/text/381/479. [9] Griswold v. Connecticut 381 U.S. 479 (1965), para. 69 https://www.law.cornell.edu/supremecourt/text/381/479. [10] Griswold v. Connecticut 381 U.S. 479 (1965), para. 69 https://www.law.cornell.edu/supremecourt/text/381/479. [11] Griswold v. Connecticut 381 U.S. 479 (1965), para. 92 https://www.law.cornell.edu/supremecourt/text/381/479. [12] Roe v. Wade 410 U.S. 113 (1973), 172, https://www.law.cornell.edu/supremecourt/text/410/113%26amp. [13] Roe v. Wade 410 U.S. 113 (1973), 172-173, https://www.law.cornell.edu/supremecourt/text/410/113%26amp. [14] Planned Parenthood of Southeastern Pa. v. Casey, 505 U.S. 833 (1992), https://supreme.justia.com/cases/federal/us/505/833/#:~:text=Casey%2C%20505%20U.S.%20833%20(1992)&text=A%20person%20retains%20the%20right,the%20mother%20is%20at%20risk. [15] Cruzan v. Director, Missouri Department of Health 497 U.S. 261 (1990), https://www.law.cornell.edu/supct/html/88-1503.ZO.html. [16] Cruzan v. Director, Missouri Department of Health 497 U.S. 261 (1990), https://www.law.cornell.edu/supct/html/88-1503.ZO.html. [17] Cruzan v. Director, Missouri Department of Health 497 U.S. 261 (1990), https://www.law.cornell.edu/supct/html/88-1503.ZO.html. [18] It is worth noting that some of the Supreme Court’s conservatives – like Scalia, Thomas, Roberts – have expressed explicit disdain for the right to privacy introduced in Griswold. Jamal Greene, “The So-Called Right to Privacy,” UC Davis Law Review 43 (2010): 715-747, https://scholarship.law.columbia.edu/faculty_scholarship/622. [19] National Archives. “Declaration of Independence: A Transcription.” July 4, 1776; reviewed July 24, 2020, https://www.archives.gov/founding-docs/declaration-transcript. [20] However, the reference to a creator has come to mean a natural right and a priori best describes it rather than a religious underpinning. To borrow from Husserl, this approach will be bracketed out. [21] DJC Carmichael, “Hobbes on Natural Right in Society: The ‘Leviathan’ Account,” Canadian Journal of Political Science 23, no. 1 (1990): 4-5. [22] HLA Hart, “Are There Any Natural Rights?” The Philosophical Review 64, no. 2 (1955): 175. [23] Warren Quinn, Morality and Action (Cambridge: Cambridge UP, 1993), 170. [24] Immanuel Kant, Groundwork of the Metaphysic of Morals, trans. James Ellington, 3rd ed. (Indianapolis: Hackett, 1993), 30. [25] John Rawls, A Theory of Justice: Revised Edition (Cambridge: Belknap, 1999), 109. [26] JS Mill, Remarks on Bentham’s Philosophy, in Collected Works of John Stuart Mill, Vol. X, ed. JM Robson (Toronto: U of Toronto Press, 1985), 13-14. [27] Rex Martin, A System of Rights (Oxford: Oxford University, 1993), 1; Kenneth Baynes, “Kant on Property Rights and the Social Contract,” The Monist 72, no. 3 (1989): 433-453. [28] John Rawls, A Theory of Justice: Revised Edition (Cambridge: Belknap, 1999), 109. [29] Frederik von Harbou, “A Remedy Called Empathy: The Neglected Element of Human Rights Theory,” Archives for Philosophy of Law and Social Philosophy 99, no. 2 (2013): 141. [30] Eva Feder Kittay. Learning from My Daughter: The Value and Care of Disabled Minds (Oxford: Oxford UP, 2019), 145-146. [31] Jane Gallop, “Lacan’s ‘Mirror Stage’: Where to Begin,” SubStance 11, no. 4 (1983): 121; Lacan, Jacques. The Seminar of Jacques Lacan: Book X: Anxiety: 1962-1963, trans. Cormac Gallagher, 26-27, https://www.valas.fr/IMG/pdf/THE-SEMINAR-OF-JACQUES-LACAN-X_l_angoisse.pdf. (In Lacanian psychoanalytic theory, human development necessitates both recognition of the Self and the separation of the Self from the Other.) [32] Lacan, Jacques. The Seminar of Jacques Lacan: Book X: Anxiety: 1962-1963, trans. Cormac Gallagher, 27-28, https://www.valas.fr/IMG/pdf/THE-SEMINAR-OF-JACQUES-LACAN-X_l_angoisse.pdf. [33] There is an interesting discussion to be had about whether social contract theory allows for this gradation in quality of contracts, or whether the two are fundamentally different phenomena. I cannot answer this question here; John Rawls, A Theory of Justice: Revised Edition (Cambridge: Belknap, 1999), 102-103. [34] Ruthellen Josselson, “The Hermeneutics of Faith and the Hermeneutics of Suspicion,” Narrative Inquiry 14, no. 1 (2004): 2-4.

Photograph by Gonzalo Echeverria (2010)The Screen would light up. They would feel a thrill of satisfaction. But the colours had faded with age, the picture wobbled on the screen, the women were of another age; they would come out they would be sad. It was not the film they had dreamt of. It was not the total film each of them had inside himself, the perfect film they could have enjoyed forever and ever. The film they would have liked to make. Or, more secretly, no doubt, the film they would have liked to live. (Perec 57) Over the years that I have watched and thought about Jean-Luc Godard’s films I have been struck by the idea of him as an artist who works with the moving image and perhaps just as importantly the idea of cinema as an irresolvable series of problems. Most obviously this ‘problematic condition’ of Godard’s practice is evidenced in the series of crises and renunciations that pepper the historical trace of his work. A trace that is often characterised thus: criticism, the Nouvelle Vague, May 1968, the Dziga Vertov group, the adoption of video, the return to narrative form, etc. etc. Of all these events it is the rejection of both the dominant cinematic narrative form and its attendant models of production that so clearly indicated the depth and intensity of Godard’s doubt in the artistic viability of the institution of cinema. Historically and ideologically congruent with the events of May 1968, this turning away from tradition was foreshadowed by the closing titles of his 1967 opus Week End: fin de cinema (the end of cinema). Godard’s relentless application to the task of engaging a more discursive and politically informed mode of operation had implications not only for the films that were made in the wake of his disavowal of cinema but also for those that preceded it. In writing this paper it was my initial intention to selectively consider the vast oeuvre of the filmmaker as a type of conceptual project that has in some way been defined by the condition of doubt. While to certain degree I have followed this remit, I have found it necessary to focus on a small number of historically correspondent filmic instances to make my point. The sheer size and complexity of Godard’s output would effectively doom any other approach to deal in generalities. To this end I am interested in the ways that these films have embodied doubt as both an aesthetic and philosophical position. There is an enduring sense of contentiousness that surrounds both the work and perceived motives of the filmmaker Jean-Luc Godard that has never come at the cost of discourse. Through a period of activity that now stretches into its sixth decade Godard has shaped an oeuvre that is as stylistically diverse as it is theoretically challenging. This span of practice is noteworthy not only for its sheer length but for its enduring ability to polarise both audiences and critical opinion. Indeed these opposing critical positions are so well inscribed in our historical understanding of Godard’s practice that they function as a type of secondary narrative. It is a narrative that the artist himself has been more than happy to cultivate and at times even engage. One hardly needs to be reminded that Godard came to making films as a critic. He asserted in the pages of his former employer Cahiers du Cinema in 1962 that “As a critic, I thought of myself as a filmmaker. Today I still think of myself as a critic, and in a sense I am, more than ever before. Instead of writing criticism, I make a film, but the critical dimension is subsumed” (59). If Godard did at this point in time believe that the criticality of practice as a filmmaker was “subsumed”, the ensuing years would see a more overt sense of criticality emerge in his work. By 1968 he was to largely reject both traditional cinematic form and production models in a concerted effort to explore the possibilities of a revolutionary cinema. In the same interview the director went on to extol the virtues of the cine-literacy that to a large part defined the loose alignment of Nouvelle Vague directors (Chabrol, Godard, Rohmer, Rivette, Truffaut) referred to as the Cahiers group claiming that “We were the first directors to know that Griffiths exists” (Godard 60). It is a statement that is as persuasive as it is dramatic, foregrounding the hitherto obscured history of cinema while positioning the group firmly within its master narrative. However, given the benefit of hindsight one realises that perhaps the filmmaker’s motives were not as simple as historical posturing. For Godard what is at stake is not just the history of cinema but cinema itself. When he states that “We were thinking cinema and at a certain moment we felt the need to extend that thought” one is struck by how far and for how long he has continued to think about and through cinema. In spite of the hours of strict ideological orthodoxy that accompanied his most politically informed works of the late 1960s and early 1970s or the sustained sense of wilful obtuseness that permeates his most “difficult” work, there is a sense of commitment to extending “that thought” that is without peer. The name “Godard”, in the words of the late critic Serge Daney, “designates an auteur but it is also synonymous with a tenacious passion for that region of the world of images we call the cinema” (Daney 68). It is a passion that is both the crux of his practice as an artist and the source of a restless experimentation and interrogation of the moving image. For Godard the passion of cinema is one that verges on religiosity. This carries with it all the philosophical and spiritual implications that the term implies. Cinema functions here as a system of signs that at once allows us to make sense of and live in the world. But this is a faith for Godard that is nothing if not tested. From the radical formal experimentation of his first feature film À Bout de soufflé (Breathless) onwards Godard has sought to place the idea of cinema in doubt. In this sense doubt becomes a type of critical engine that at once informs the shape of individual works and animates the constantly shifting positions the artist has occupied. Serge Daney's characterisation of the Nouvelle Vague as possessed of a “lucidity tinged with nostalgia” (70) is especially pertinent in understanding the way in which doubt came to animate Godard’s practice across the 1960s and beyond. Daney’s contention that the movement was both essentially nostalgic and saturated with an acute awareness that the past could not be recreated, casts the cinema itself as type of irresolvable proposition. Across the dazzling arc of films (15 features in 8 years) that Godard produced prior to his renunciation of narrative cinematic form in 1967, one can trace an unravelling of faith. During this period we can consider Godard's work and its increasingly complex engagement with the political as being predicated by the condition of doubt. The idea of the cinema as an industrial and social force increasingly permeates this work. For Godard the cinema becomes a site of questioning and ultimately reinvention. In his 1963 short film Le Grand Escroc (The Great Rogue) a character asserts that “cinema is the most beautiful fraud in the world”. Indeed it is this sense of the paradoxical that shadows much of his work. The binary of beauty and fraud, like that of faith and doubt, calls forth a questioning of the cinema that stands to this day. It is of no small consequence that so many of Godard’s 1960s works contain scenes of people watching films within the confines of a movie theatre. For Godard and his Nouvelle Vague peers the sale de cinema was both the hallowed site of cinematic reception and the terrain of the everyday. It is perhaps not surprising then he chooses the movie theatre as a site to play out some of his most profound engagements with the cinema. Considered in relation to each other these scenes of cinematic viewing trace a narrative in which an undeniable affection for the cinema is undercut by both a sense of loss and doubt. Perhaps the most famous of Godard’s ‘viewing’ scenes is from the film Vivre Sa Vie (My Life to Live). Essentially a tale of existential trauma, the film follows the downward spiral of a young woman Nana (played by Anna Karina) into prostitution and then death at the hands of ruthless pimps. Championed (with qualifications) by Susan Sontag as a “perfect film” (207), it garnered just as many detractors, including famously the director Roberto Rosellini, for what was perceived to be its nihilistic content and overly stylised form. Seeking refuge in a cinema after being cast out from her apartment for non payment of rent the increasingly desperate Nana is shown engrossed in the starkly silent images of Carl Dreyer’s 1928 film La Passion de Jeanne d’Arc (The Passion of Joan of Arc). Godard cuts from the action of his film to quote at length from Dreyer’s classic, returning from the mute intensity of Maria Faloconetti’s portrayal of the condemned Joan of Arc to Karina’s enraptured face. As Falconetti’s tears swell and fall so do Karina’s, the emotional rawness of the performance on the screen mirrored and internalised by the doomed character of Nana. Nana’s identification with that of the screen heroine is at once total and immaculate as her own brutal death at the hands of men is foretold. There is an ominous silence to this sequence that serves not only to foreground the sheer visual intensity of what is being shown but also to separate it from the world outside this purely cinematic space. However, if we are to read this scene as a testament to the power of the cinematic we must also admit to the doubt that resides within it. Godard’s act of separation invites us to consider the scene not only as a meditation on the emotional and existential state of the character of Nana but also on the foreshortened possibilities of the cinema itself. As Godard’s shots mirror those of Dreyer we are presented with a consummate portrait of irrevocable loss. This is a complex system of imagery that places Dreyer’s faith against Godard’s doubt without care for the possibility of resolution. Of all Godard’s 1960s films that feature cinema spectatorship the sequence belonging to Masculin Féminin (Masculine Feminine) from 1966 is perhaps the most confounding and certainly the most digressive. A series of events largely driven by a single character’s inability or unwillingness to surrender to the projected image serve to frustrate, fracture and complexify the cinema-viewing experience. It is however, a viewing experience that articulates the depth of Godard’s doubt in the viability of the cinematic form. The sequence, like much of the film itself, centres on the trials of the character Paul played by Jean-Pierre Léaud. Locked in a struggle against the pop-cultural currents of the day and the attendant culture of consumption and appearances, Paul is positioned within the film as a somewhat conflicted and ultimately doomed romantic. His relationship with Madeleine played by real life yé-yé singer Chantal Goya is a source of constant anxiety. The world that he inhabits, however marginally, of nightclubs, pop records and publicity seems philosophically at odds with the classical music and literature that he avidly devours. If the cinema-viewing scene of Vivre Sa Vie is defined by the enraptured intensity of Anna Karina’s gaze, the corresponding scene in Masculin Féminin stands, at least initially, as the very model of distracted spectatorship. As the film in the theatre starts, Paul who has been squeezed out of his seat next to Madeleine by her jealous girlfriend, declares that he needs to go to the toilet. On entering the bathroom he is confronted by the sight of a pair of men locked in a passionate kiss. It is a strange and disarming turn of events that prompts his hastily composed graffiti response: down with the republic of cowards. For theorist Nicole Brenez the appearance of these male lovers “is practically a fantasmatic image evoked by the amorous situation that Paul is experiencing” (Brenez 174). This quasi-spectral appearance of embracing lovers and grafitti writing is echoed in the following sequence where Paul once again leaves the theatre, this time to fervently inform the largely indifferent theatre projectionist about the correct projection ratio of the film being shown. On his graffiti strewn journey back inside Paul encounters an embracing man and woman nestled in an outer corner of the theatre building. Silent and motionless the presence of this intertwined couple is at once unsettling and prescient providing “a background real for what is being projected inside on the screen” (Brenez 174). On returning to the theatre Paul asks Madeleine to fill him in on what he has missed to which she replies, “It is about a man and woman in a foreign city who…”. Shot in Stockholm to appease the Swedish co-producers that stipulated that part of the production be made in Sweden, the film within a film occupies a fine line between restrained formal artfulness and pornographic violence. What could have been a creatively stifling demand on the part of his financial backers was inverted by Godard to become a complex exploration of power relations played out through an unsettling sexual encounter. When questioned on set by a Swedish television reporter what the film was about the filmmaker curtly replied, “The film has a lot to do with sex and the Swedish are known for that” (Masculin Féminin). The film possesses a barely concealed undertow of violence. A drama of resistance and submission is played out within the confines of a starkly decorated apartment. The apartment itself is a zone in which language ceases to operate or at the least is reduced to its barest components. The man’s imploring grunts are met with the woman’s repeated reply of “no”. What seemingly begins as a homage to the contemporaneous work of Swedish director Ingmar Bergman quickly slides into a chronicle of coercion. As the final scene of seduction/debasement is played out on the screen the camera pulls away to reveal the captivated gazes of Madeleine and her friends. It finally rests on Paul who then shuts his eyes, unable to bear what is being shown on the screen. It is a moment of refusal that marks a turning away not only from this projected image but from cinema itself. A point made all the clearer by Paul’s voiceover that accompanies the scene: We went to the movies often. The screen would light up and we would feel a thrill. But Madeleine and I were usually disappointed. The images were dated and jumpy. Marilyn Monroe had aged badly. We felt sad. It wasn't the movie of our dreams. It wasn't that total film we carried inside ourselves. That film we would have liked to make. Or, more secretly, no doubt the film we wanted to live. (Masculin Féminin) There was a dogged relentlessness to Godard’s interrogation of the cinema through the very space of its display. 1963’s Le Mépris (Contempt) swapped the public movie theatre for the private screening room; a theatrette emblazoned with the words Il cinema é un’invenzione senza avvenire. The phrase, presented in a style that recalled Soviet revolutionary graphics, is an Italian translation of Louis Lumiere’s 1895 appraisal of his new creation: “The cinema is an invention without a future.” The words have an almost physical presence in the space providing a fatalistic backdrop to the ensuing scene of conflict and commerce. As an exercise in self reflexivity it at once serves to remind us that even at its inception the cinema was cast in doubt. In Le Mépris the pleasures of spectatorship are played against the commercial demands of the cinema as industry. Following a screening of rushes for a troubled production of Homer’s Odyssey a tempestuous exchange ensues between a hot-headed producer (Jeremy Prokosch played by Jack Palance) and a calmly philosophical director (Fritz Lang as himself). It is a scene that attests to Godard’s view of the cinema as an art form that is creatively compromised by its own modes of production. In a film that plays the disintegration of a relationship against the production of a movie and that features a cast of Germans, Italians and French it is of no small consequence that the movie producer is played by an American. An American who, when faced with a creative impasse, utters the phrase “when I hear the word culture I bring out my checkbook”. It is one of Godard’s most acerbic and doubt filled sequences pitting as he does the implied genius of Lang against the tantrum throwing demands of the rapacious movie producer. We are presented with a model of industrial relations that is both creatively stifling and practically unworkable. Certainly it was no coincidence that Le Mépris had the biggest budget ($1 million) that Godard has ever worked with. In Godard’s 1965 film Une Femme Mariée (A Married Woman), he would once again use the movie theatre as a location. The film, which dealt with the philosophical implications of an adulterous affair, is also notable for its examination of the Holocaust and that defining event’s relationship to personal and collective memory. Biographer Richard Brody has observed that, “Godard introduced the Auschwitz trial into The Married Woman (sic) as a way of inserting his view of another sort of forgetting that he suggested had taken hold of France—the conjoined failures of historical and personal memory that resulted from the world of mass media and the ideology of gratification” (Brody 196-7). Whatever the causes, there is a pervading sense of amnesia that surrounds the Holocaust in the film. In one exchange the character of Charlotte, the married woman in question, momentarily confuses Auschwitz with thalidomide going on to later exclaim that “the past isn’t fun”. But like the barely repressed memories of her past indiscretions, the Holocaust returns at the most unexpected juncture in the film. In what starts out as Godard’s most overt reference to the work of Alfred Hitchcock, Charlotte and her lover secretly meet under the cover of darkness in a movie theatre. Each arriving separately and kitted out in dark sunglasses, there is breezy energy to this clandestine rendezvous highly reminiscent of the work of the great director. It is a stylistic point that is underscored in the film by the inclusion of a full-frame shot of Hitchcock’s portrait in the theatre’s foyer. However, as the lovers embrace the curtain rises on Alain Resnais’s 1955 documentary Nuit et Brouillard (Night and Fog). The screen is filled with images of barbed wire as the voice of narrator Jean Cayrol informs the audience that “even a vacation village with a fair and a steeple can lead very simply to a concentration camp.” It is an incredibly shocking moment, in which the repressed returns to confirm that while memory “isn’t fun”, it is indeed necessary. An uncanny sense of recognition pervades the scene as the two lovers are faced with the horrendous evidence of a past that refuses to stay subsumed. The scene is all the more powerful for the seemingly casual manner it is relayed. There is no suspenseful unveiling or affected gauging of the viewers’ reactions. What is simply is. In this moment of recognition the Hitchcockian mood of the anticipation of an illicit rendezvous is supplanted by a numbness as swift as it is complete. Needless to say the couple make a swift retreat from the now forever compromised space of the theatre. Indeed this scene is one of the most complex and historically layered of any that Godard had produced up to this point in his career. By making overt reference to Hitchcock he intimates that the cinema itself is deeply implicated in this perceived crisis of memory. What begins as a homage to the work of one of the most valorised influences of the Nouvelle Vague ends as a doubt filled meditation on the shortcomings of a system of representation. The question stands: how do we remember through the cinema? In this regard the scene signposts a line of investigation that would become a defining obsession of Godard’s expansive Histoire(s) du cinéma, a project that was to occupy him throughout the 1990s. Across four chapters and four and half hours Histoire(s) du cinéma examines the inextricable relationship between the history of the twentieth century and the cinema. Comprised almost completely of filmic quotations, images and text, the work employs a video-based visual language that unremittingly layers image upon image to dissolve and realign the past. In the words of theorist Junji Hori “Godard's historiography in Histoire(s) du cinéma is based principally on the concept of montage in his idiosyncratic sense of the term” (336). In identifying montage as the key strategy in Histoire(s) du cinéma Hori implicates the cinema itself as central to both Godard’s process of retelling history and remembering it. However, it is a process of remembering that is essentially compromised. Just as the relationship of the cinema to the Holocaust is bought into question in Une Femme Mariée, so too it becomes a central concern of Histoire(s) du cinéma. It is Godard’s assertion “that the cinema failed to honour its ethical commitment to presenting the unthinkable barbarity of the Nazi extermination camps” (Temple 332). This was a failure that for Godard moved beyond the realm of doubt to represent “nothing less than the end of cinema” (Brody 512). In October 1976 the New Yorker magazine published a profile of Jean Luc Godard by Penelope Gilliatt a writer who shared the post of film critic at the magazine with Pauline Kael. The article was based on an interview that took place at Godard’s production studio in Grenoble Switzerland. It was notable for two things: Namely, the most succinct statement that Godard has made regarding the enduring sense of criticality that pervades his work: “A good film is a matter of questions properly put.” (74) And secondly, surely the shortest sentence ever written about the filmmaker: “Doubt stands.” (77)ReferencesÀ Bout de soufflé. Dir. Jean Luc Godard. 1960. DVD. Criterion, 2007. Brenez, Nicole. “The Forms of the Question.” For Ever Godard. Eds. Michael Temple, James S. Williams, and Michael Witt. London: Black Dog, 2004. Brody, Richard. Everything Is Cinema: The Working Life of Jean-Luc Godard. New York: Metropolitan Books / Henry Holt & Co., 2008. Daney, Serge. “The Godard Paradox.” For Ever Godard. Eds. Michael Temple, James S. Williams, and Michael Witt. London: Black Dog, 2004. Gilliat, Penelope. “The Urgent Whisper.” Jean-Luc Godard Interviews. Ed. David Sterritt. Jackson: University Press of Mississippi, 1998. Godard, Jean-Luc. “Jean-Luc Godard: 'From Critic to Film-Maker': Godard in Interview (extracts). ('Entretien', Cahiers du Cinema 138, December 1962).” Cahiers du Cinéma: 1960-1968 New Wave, New Cinema, Reevaluating Hollywood. Ed. Jim Hillier. Cambridge, Mass.: Harvard University Press, 1986. Histoires du Cinema. Dir. and writ. Jean Luc Godard. 1988-98. DVD, Artificial Eye, 2008. Hori, Junji. “Godard’s Two Histiographies.” For Ever Godard. Eds. Michael Temple, James S. Williams, and Michael Witt. London: Black Dog, 2004. Le Grand Escroc. Dir. Jean Luc Godard. Perf. Jean Seberg. Film. Ulysse Productions, 1963. Le Mépris. Dir. Jean Luc Godard. Perf. Jack Palance, Fritz Lang. 1964. DVD. Criterion, 2002. La Passion de Jeanne d’Arc. Dir. Carl Theodor Dreyer. Film. Janus films, 1928. MacCabe, Colin. Godard: A Portrait of the Artist at 70. London: Bloomsbury, 2003. Masculin Féminin. Dir. and writ. Jean Luc Godard. Perf. Jean-Pierre Léaud. 1966. DVD. Criterion, 2005. Nuit et Brouillard. Dir Alain Resnais. Film. Janus Films, 1958. Perec, Georges. Things: A Story of the Sixties. Trans. David Bellos. London: Collins Harvill, 1990. (Originally published 1965.) Sontag, Susan. “Godard’s Vivre Sa Vie.” Against Interpretation and Other Essays. New York: Picador, 2001. Temple, Michael, James S. Williams, and Michael Witt, eds. For Ever Godard. London: Black Dog, 2004. Une Femme Mariée. Dir. and writ. Jean Luc Godard. Perf. Macha Meril. 1964. DVD. Eureka, 2009. Vivre Sa Vie. Dir. and writ. Jean Luc Godard. Perf. Anna Karina. 1962. DVD. Criterion, 2005. Week End, Dir. and writ. Jean Luc Godard. 1967. DVD. Distinction Series, 2005.

Many films of the Australian New Wave (or Australian film renaissance) of the 1970s and 1980s can be defined as gothic, especially following Jonathan Rayner’s suggestion that “Instead of a genre, Australian Gothic represents a mode, a stance and an atmosphere, after the fashion of American Film Noir, with the appellation suggesting the inclusion of horrific and fantastic materials comparable to those of Gothic literature” (25). The American comparison is revealing. The 400 or so film productions of the Australian New Wave emerged, not in a vacuum, but in an increasingly connected and inter-mixed international space (Godden). Putatively discrete national cinemas weave in and out of each other on many levels. One such level concerns the reception critics give to films. This article will drill down to the level of the reception of two examples of Australian gothic film-making by two well-known American critics. Rayner’s comparison of Australian gothic with American film noir is useful; however, it begs the question of how American critics such as Pauline Kael and Andrew Sarris influentially shaped the reception of Australian gothic in America and in other locations (such as Australia itself) where their reviews found an audience either at the time or afterwards. The significance of the present article rests on the fact that, as William McClain observes, following in Rick Altman’s footsteps, “critics form one of the key material institutions that support generic formations” (54). This article nurtures the suggestion that knowing how Australian gothic cinema was shaped, in its infancy, in the increasingly important American market (a market of both commerce and ideas) might usefully inform revisionist studies of Australian cinema as a national mode. A more nuanced, globally informed representation of the origins and development of Australian gothic cinema emerges at this juncture, particularly given that American film reviewing in the 1970s and 1980s more closely resembled what might today be called film criticism or even film theory. The length of individual reviews back then, the more specialized vocabulary used, and above all the tendency for critics to assume more knowledge of film history than could safely be assumed in 2014—all this shows up the contrast with today. As Christos Tsiolkas notes, “in our age… film reviewing has been reduced to a thumbs-up or a thumbs-down” (56)! The 1970s and 1980s is largely pre-Internet, and critical voices such as Kael and Sarris dominated in print. The American reviews of Australian gothic films demonstrate how a different consciousness suffuses Kael’s and Sarris’s engagements with “Antipodean” (broadly Australian and New Zealand) cinema. Rayner’s locally specific definition of Australian gothic is distorted in their interpretations of examples of the genre. It will be argued that this is symptomatic of a particular blindspot, related to the politics and art of place, in the American reception of Wake in Fright (initially called Outback in America), directed by the Canadian Ted Kotcheff (1971) and The Year of Living Dangerously, directed by Peter Weir (1982). Space and argument considerations force this article to focus on the reviews of these films, engaging less in analysis of the films themselves. Suffice to say that they all fit broadly within Rayner’s definition of Australian gothic cinema. As Rayner states, three thematic concerns which permeate all the films related to the Gothic sensibility provide links across the distinctions of era, environment and character. They are: a questioning of established authority; a disillusionment with the social reality that that authority maintains; and the protagonist’s search for a valid and tenable identity once the true nature of the human environment has been revealed. (25) “The true nature of the human environment….” Here is the element upon which the American reviews of the Australian gothic founder. Explicitly in many films of this mode, and implicitly in nearly all of them, is the “human environment” of the Australian landscape, which operates less as a backdrop and more as a participating element, even a character, in the drama, saturating the mise-en-scène. In “Out of Place: Reading (Post) Colonial Landscapes as Gothic Space in Jane Campion’s Films,” Eva Rueschmann quotes Ross Gibson’s thesis from South of the West: Postcolonialism and the Narrative Construction of Australia that By featuring the land so emphatically… [Australian] films stake out something more significant than decorative pictorialism. Knowingly or unknowingly, they are all engaging with the dominant mythology of white Australia. They are all partaking of the landscape tradition which, for two hundred years, has been used by white Australians to promote a sense of the significance of European society in the “Antipodes”. (Rueschmann) The “emphatic” nature of the land in films like Wake in Fright, Mad Max 2 and Picnic at Hanging Rock actively contributes to the “atmosphere” of Australian gothic cinema (Rayner 25). This atmosphere floats across Australian film and literature. Many of the films mentioned in this article are adaptations from books, and Rayner himself stresses the similarity between Australian gothic and gothic literature (25). Significantly, the atmosphere of Australian gothic also floats across the fuzzy boundary between the gothic and road movies or road literature. Mad Max 2: The Road Warrior is obviously a road movie as well as a gothic text; so is Wake in Fright in its way; even Picnic at Hanging Rock contains elements of the road movie in all that travelling to and from the rock. Roads, then, are significant for Australian gothic cinema, for the road traverses the Australian (gothic) landscape and, in the opportunity it provides for moving through it at speed, tantalizes with the (unfulfillable) promise of an escape from its gothic horror. Australian roads are familiar, part of White European culture referencing the geometric precision of Roman roads. The Australian outback, by contrast, is unfamiliar, uncanny. Veined with roads, the outback invites the taming by “the landscape tradition” that it simultaneously rejects (Rueschmann). In the opening 360° pan of Wake in Fright the land frightens with its immensity and intensity, even as the camera displays the land’s “conquering” agent: not a road, but the road’s surrogate—a railway line. Thus, the land introduces the uncanny into Australian gothic cinema. In Freudian terms, the uncanny is that unsettling combination of the familiar and the unfamiliar. R. Gray calls it “the class of frightening things that leads us back to what is known and familiar” (Gray). The “frightening” land is the very condition of the “comforting” road; no roads without a space for roads, and places for them to go. In her introduction to The Penguin Book of the Road, Delia Falconer similarly sutures the land to the uncanny, linking both of these with the first peoples of the Australian land: "Of course there is another 'poetry of the earth' whispering from the edges of our roads that gives so many of our road stories an extra charge, and that is the history of Aboriginal presence in this land. Thousands of years of paths and tribal boundaries also account for the uncanny sense of being haunted that dogs our travellers on their journeys (xvii). White Australia, as the local saying goes, has a black past, played out across the land. The film The Proposition instances this, with its gothic portrayal of the uncanny encroachments of the Australian “wilderness” into the domain of “civilization”. Furthermore, “our” overweening literal and metaphoric investment in the traditional quarter-acre block, not to mention in our roads, shows that “we” haven’t reconciled either with the land of Australia or with its original inhabitants: the Aboriginal peoples. Little wonder that Kael and Sarris couldn’t do so, as White Americans writing some forty years ago, and at such a huge geographic remove from Australia. As will be seen, the failure of these American film critics to comprehend the Australian landscape comes out—as both a “critical reaction” and a “reactive compensation”—in two, interwoven strands of their interpretations of Australian New Wave gothic cinema. A repulsion from, and an attraction to, the unrecognized uncanny is evidenced. The first strand is constituted in the markedly anthropological aspect to the film reviews: anthropological elements of the text itself are either disproportionately magnified or longed for. Here, “anthropological” includes the sociological and the historical. Secondly, Kael and Sarris use the films they review from Australian gothic cinema as sites upon which to trial answers to the old and persistent question of how the very categories of art and politics relate. Initially sucked out of the reviews (strand one), politics and art thus rush back in (strand two). In other words, the American failure to engage deeply with the land triggers an initial reading of films like Wake in Fright less as films per se and more as primary texts or one-to-one documentations of Australia. Australia presents for anthropological, even scientific atomization, rather than as a place in active, creative and complex relationship with its rendering in mise-en-scène. Simultaneously though, the absence of the land nags—eats away at the edges of critical thinking—and re-emerges (like a Freudian return of the repressed) in an attempt by the American critics to exploit their film subjects as an opportunity for working out how politics and art (here cinema) relate. The “un-seen” land creates a mis-reading amongst the American critics (strand one), only to force a compensatory, if somewhat blindsided, re-reading (strand two). For after all, in this critical “over-looking” of the land, and thus of the (ongoing) Aboriginal existence in and with the land, it is politics and art that is most at stake. How peoples (indigenous, settler or hybrid peoples) are connected to and through the land has perhaps always been Australia’s principal political and artistic question. How do the American reviews speak to this question? Sarris did not review Wake in Fright. Kael reviewed it, primarily, as a text at the intersection of fiction and documentary, ultimately privileging the latter. Throughout, her critical coordinates are American and, to a degree, literary. Noting the “stale whiff of Conrad” she also cites Outback’s “additional interest” in its similarity with “recent American movies [about] American racism and capitalist exploitation and the Vietnam war” (415). But her most pointed intervention comes in the assertion that there is “enough narrative to hold the social material together,” as if this were all narrative were good for: scaffolding for sociology (416). Art and culture are left out. Even as Kael mentions the “treatment of the Aborigines,” she misses the Aboriginal cultural moment of the opening shot of the land; this terrain, she writes, is “without a trace of culture” (416). Then, after critiquing what she sees as the unconvincing lesson of the schoolteacher’s moral demise, comes this: “But a more serious problem is that (despite the banal photography) the semi-documentary aspects of the film are so much more vivid and authentic and original than the factitious Conradian hero that we want to see more of that material—we want to learn more” (416-417). Further on, in this final paragraph, Kael notes that, while “there have been other Australian films, so it’s not all new” the director and scriptwriter “have seen the life in a more objective way, almost as if they were cultural anthropologists…. Maybe Kotcheff didn’t dare to expand this vision at the expense of the plot line, but he got onto something bigger than the plot” (417). Kael’s “error”, as it were, is to over-look how the land itself stretches the space of the film, beyond plot, to occupy the same space as her so-called “something bigger”, which itself is filled out by the uncanniness of the land as the intersections of both indigenous and settler (road-based) cultures and their representations in art (417). The “banal photography” might be better read as the film’s inhabitation of these artistic/cultural intersections (416). Kael’s Wake in Fright piece illustrates the first strand of the American reviews of Australian gothic cinema. Missing the land’s uncanniness effectively distributes throughout the review an elision of culture and art, and a reactive engagement with the broadly anthropological elements of Kotcheff’s film. Reviews of The Year of Living Dangerously by Kael and Sarris also illustrate the first strand of the American-Australian reviewing nexus, with the addition, also by each critic, of the second strand: the attempt to reconnect and revitalize the categories of politics and art. As with Wake in Fright, Kael introduces an anthropological gambit into Weir’s film, privileging its documentary elements over its qualities as fiction (strand one). “To a degree,” she writes, “Weir is the victim of his own skill at creating the illusion of authentic Third World misery, rioting, and chaos” (454). By comparison with “earlier, studio-set films” (like Casablanca [452]), where such “backgrounds (with their picturesque natives) were perfectly acceptable as backdrops…. Here… it’s a little obscene” (454). Kael continues: “Documentaries, TV coverage, print journalism, and modern history itself have changed audiences’ responses, and when fake dilemmas about ‘involvement’ are cooked up for the hero they’re an embarrassment” (454-455). Film is pushed to cater to anthropology besides art. Mirroring Kael’s strand-one response, Sarris puts a lot of pressure on Weir’s film to “perform” anthropologically—as well as, even instead of, artistically. The “movie”, he complains “could have been enjoyed thoroughly as a rousingly old-fashioned Hollywood big-star entertainment were it not for the disturbing vistas of somnolent poverty on view in the Philippines, the location in which Indonesian poverty in 1965 was simulated” (59). Indeed, the intrusive reality of poverty elicits from Sarris something very similar to Kael’s charge of the “obscenity of the backdrop” (454): We cannot go back to Manderley in our movie romances. That much is certain. We must go forward into the real world, but in the process, we should be careful not to dwarf our heroes and heroines with the cosmic futility of it all. They must be capable of acting on the stage of history, and by acting, make a difference in our moral perception of life on this planet. (59) Sarris places an extreme, even outrageous, strand-one demand on Weir’s film to re-purpose its fiction (what Kael calls “romantic melodrama” [454]) to elicit the categories of history and anthropology—that last phrase, “life on this planet”, sounds like David Attenborough speaking! More so, anthropological atomization is matched swiftly to a strand-two demand, for this passage also anticipates the rapprochement of politics and art, whereby art rises to the level of politics, requiring movie “heroes and heroines” to make a “moral difference” on a historical if not on a “cosmic” level (59). It is precisely in this, however, that Weir’s film falls down for Sarris. “The peculiar hollowness that the more perceptive reviewers have noted in The Year of Living Dangerously arises from the discrepancy between the thrilling charisma of the stars and the antiheroic irrelevance of the characters they play to the world around them” (59). Sarris’s spatialized phrase here (“peculiar hollowness”) recalls Kael’s observation that Wake in Fright contains “something bigger than the plot” (417). In each case, the description is doubling, dis-locating—uncanny. Echoing the title of Eva Rueschmann’s article, both films, like the Australian landscape itself, are “out of place” in their interpretation by these American critics. What, really, does Sarris’s “peculiar hollowness” originate in (59)? In what “discrepancy” (59)? There is a small but, in the context of this article, telling error in Sarris’s review of Weir’s film. Kael, correctly, notes that “the Indonesian settings had to be faked (in the Philippines and Australia)” (inserted emphasis) (452). Sarris mentions only the Philippines. From little things big things grow. Similar to how Kael overlooks the uncanny in Wake in Fright’s mise-en-scène, Sarris “sees” a “peculiar hollowness” where the land would otherwise be. Otherwise, that is, in the perspective of a cinema (Kotcheff’s, Weir’s) that comprehends “the true nature of the [Australian, gothic] human environment” (Rayner 25). Of course, it is not primarily a matter of how much footage Weir shot in Australia. It is the nature of the cinematography that matters most. For his part, Sarris damns it as “pretentiously picturesque” (59). Kael, meanwhile, gets closer perhaps to the ethics of the uncanny cinematography of The Year of Living Dangerously in her description of “intimations, fragments, hints and portents… on a very wide screen” (451). Even so, it will be remembered, she does call the “backgrounds… obscene” (454). Kael and Sarris see less than they “see”. Again like Sarris, Kael goes looking in Weir’s film for a strand-two rapprochement of politics and art, as evidenced by the line “The movie displays left-wing attitudes, but it shows no particular interest in politics” (453). It does though, only Kael is blind to it because she is blind to the land and, equally, to the political circumstances of the people of the land. Kael likely never realized the “discrepancy” in her critique of The Year of Living Dangerously’s Billy Kwan as “the same sort of in-on-the-mysteries-of-the-cosmos character that the aborigine actor Gulpilil played in Weir’s 1977 The Last Wave” (455). All this, she concludes, “might be boiled down to the mysticism of L.A.: ‘Go with the flow’” (455)! Grouping characters and places together like this, under the banner of L.A. mysticism, brutally erases the variations across different, uncanny, gothic, post-colonial landscapes. It is precisely here that politics and art do meet, in Weir’s film (and Kotcheff’s): in the artistic representation of the land as an index of the political relations of indigenous, settler and hybrid communities. (And not down the rabbit hole of the “specifics” of politics that Kael claims to want [453]). The American critics considered in this article are not in “bad faith” or a-political. Sarris produced a perceptive, left-leaning study entitled Politics and Cinema, and many of Kael’s reviews, along with essays like “Saddle Sore: El Dorado, The War Wagon, The Way West,” contain sophisticated, liberalist analyses of the political circumstances of Native Americans. The crucial point is that, as “critics form[ing] one of the key material institutions that support generic formations,” Sarris and Kael impacted majorly on the development of Australian gothic cinema, in the American context—impacted especially, one could say, on the (mis-)understanding of the land-based, uncanny politics of this mode in its Australian setting (McClain 54). Kael’s and Sarris’s reviews of My Brilliant Career, along with Judith Maslin’s review, contain traits similar to those considered in depth in the reviews studied above. Future research might usefully study this significant impact more closely, weaving in an awareness of the developing dynamics of global film productions and co-productions since the 1970s, and thereby focusing on Australian gothic as international cinema. Was, for example, the political impact of later films like The Proposition influenced, even marginally, by the (mis-)readings of Sarris and Kael? In conclusion here, it suffices to note that, even as the American reviewers reduced Australian cinema art to “blank” documentary or “neutral” anthropology, nevertheless they evidenced, in their strand-two responses, the power of the land (as presented in the cinematography and mise-en-scène) to call out—across an increasingly globalized domain of cinematic reception—for the fundamental importance of the connection between politics and art. Forging this connection, in which all lands and the peoples of all lands are implicated, should be, perhaps, the primary and ongoing concern of national and global cinemas of the uncanny, gothic mode, or perhaps even any mode. References Casablanca. Dir. Michael Curtiz. Warner Bros, 1942. Falconer, Delia. “Introduction.” The Penguin Book of the Road. Ed. Delia Falconer. Melbourne: Viking-Penguin Books, 2008. xi-xxvi. Gibson, Ross. South of the West: Postcolonialism and the Narrative Construction of Australia. Bloomington, Indiana: Indiana University Press, 1992. Godden, Matt. “An Essay on Australian New Wave Cinema.” 9 Jan. 2013. 18 Aug. 2014 ‹http://www.golgotha.com.au/2013/01/09/an-essay-on-australian-new-wave-cinema/›. Gray, R. “Freud, ‘The Uncanny.’” 15 Nov. 2013. 18 Aug. 2014 ‹http://courses.washington.edu/freudlit/Uncanny.Notes.html›. Kael, Pauline. “Australians.” Review of My Brilliant Career. 15 Sep. 1980. Taking It All In. London: Marion Boyars, 1986. 54-62. Kael, Pauline. “Literary Echoes—Muffled.” Review of Outback [Wake in Fright]. 4 March 1972. Deeper into Movies. Boston: Atlantic Monthly Press-Little, Brown and Company, 1973. 413-419. Kael, Pauline. “Saddle Sore: El Dorado, The War Wagon, The Way West.” Kiss Kiss Bang Bang. London: Arrow Books, 1987. 38-46. Kael, Pauline. “Torrid Zone.” Review of The Year of Living Dangerously. 21 Feb. 1983. Taking It All In. London: Marion Boyars, 1986. 451-456. Mad Max 2: The Road Warrior. Dir. George Miller. Warner Bros, 1981. Maslin, Janet. “Film: Australian ‘Brilliant Career’ by Gillian Armstrong.” Review of My Brilliant Career. New York Times (6 Oct. 1979.): np. McClain, William. “Western, Go Home! Sergio Leone and the ‘Death of the Western’ in American Film Criticism.” Journal of Film and Video 62.1-2 (Spring/Summer 2010): 52-66. My Brilliant Career. Dir. Gillian Armstrong. Peace Arch, 1979. Picnic at Hanging Rock. Dir. Peter Weir. Picnic Productions, 1975. Rayner, Jonathan. Contemporary Australian Cinema: An Introduction. Manchester: Manchester University Press, 2000. Rueschmann, Eva. “Out of Place: Reading (Post) Colonial Landscapes as Gothic Space in Jane Campion’s Films.” Post Script (22 Dec. 2005). 18 Aug. 2014 ‹http://www.thefreelibrary.com/Out+of+place%3A+reading+%28post%29+colonial+landscapes+as+Gothic+space+in...-a0172169169›. Sarris, Andrew. “Films in Focus.” Review of My Brilliant Career. Village Voice (4 Feb. 1980): np. Sarris, Andrew. “Films in Focus: Journalistic Ethics in Java.” Review of The Year of Living Dangerously. Village Voice 28 (1 Feb. 1983): 59. Sarris, Andrew. “Liberation, Australian Style.” Review of My Brilliant Career. Village Voice (15 Oct. 1979): np. Sarris, Andrew. Politics and Cinema. New York: Columbia University Press, 1978. The Last Wave. Dir. Peter Weir. Ayer Productions, 1977. The Proposition. Dir. John Hillcoat. First Look Pictures, 2005. The Year of Living Dangerously. Dir. Peter Weir. MGM, 1982. Tsiolkas, Christos. “Citizen Kael.” Review of Pauline Kael: A Life in the Dark by Brian Kellow. The Monthly (Feb. 2012): 54-56. Wake in Fright. Dir. Ted Kotcheff. United Artists, 1971.

As the distinction between disclosure-fuelled celebrity and lasting fame becomes difficult to discern, the “based on a true story” label has gained a particular traction among readers and viewers. This is despite much public approbation and private angst sometimes resulting from such disclosure as “little in the law or in society protects people from the consequences of others’ revelations about them” (Smith 537). Even fiction writers can stray into difficult ethical and artistic territory when they disclose the private facts of real lives—that is, recognisably biographical information—in their work, with autoethnographic fiction where authors base their fiction on their own lives (Davis and Ellis) not immune as this often discloses others’ stories (Ellis) as well. F. Scott Fitzgerald famously counselled writers to take their subjects from life and, moreover, to look to the singular, specific life, although this then had to be abstracted: “Begin with an individual, and before you know it, you find that you have created a type; begin with a type, and you find that you have created—nothing” (139). One of the problems when assessing fiction through this lens, however, is that, although many writers are inspired in their work by an actual life, event or historical period, the resulting work is usually ultimately guided by literary concerns—what writers often term the quest for aesthetic truth—rather than historical accuracy (Owen et al. 2008). In contrast, a biography is, and continues to be, by definition, an accurate account of a real persons’ life. Despite postmodern assertions regarding the relativity of truth and decades of investigation into the incorporation of fiction into biography, other non-fiction texts and research narratives (see, for instance: Wyatt), many biographers attest to still feeling irrevocably tied to the factual evidence in a way that novelists and the scriptors of biographically-based fictional television drama, movies and theatrical pieces do not (Wolpert; Murphy; Inglis). To cite a recent example, Louis Nowra’s Ice takes the life of nineteenth-century self-made entrepreneur and politician Malcolm McEacharn as its base, but never aspires to be classified as creative nonfiction, history or biography. The history in a historical novel is thus often, and legitimately, skewed or sidelined in order to achieve the most satisfying work of art, although some have argued that fiction may uniquely represent the real, as it is able to “play […] in the gap between the narratives of history and the actualities of the past” (Nelson n.p.). Fiction and non-fictional forms are, moreover, increasingly intermingling and intertwining in content and intent. The ugly word “faction” was an attempt to suggest that the two could simply be elided but, acknowledging wide-ranging debates about whether literature can represent the complexities of life with any accuracy and post-structuralist assertions that the idea of any absolute truth is outmoded, contemporary authors play with, and across, these boundaries, creating hybrid texts that consciously slide between invention and disclosure, but which publishers, critics and readers continue to define firmly as either fiction or biography. This dancing between forms is not particularly new. A striking example was Marion Halligan’s 2001 novel The Fog Garden which opens with a personal essay about the then recent death of her own much-loved husband. This had been previously published as an autobiographical memoir, “Cathedral of Love,” and again in an essay collection as “Lapping.” The protagonist of the novel is a recently widowed writer named Clare, but the inclusion of Halligan’s essay, together with the book’s marketing campaign which made much of the author’s own sadness, encourages readers to read the novel as a disclosure of the author’s own personal experience. This is despite Halligan’s attempt to keep the two separate: “Clare isn’t me. She’s like me. Some of her experience, terrors, have been mine. Some haven’t” (Fog Garden 9). In such acts of disclosure and denial, fiction and non-fiction can interrogate, test and even create each other, however quite vicious criticism can result when readers feel the boundaries demarking the two are breached. This is most common when authors admit to some dishonesty in terms of self-disclosure as can be seen, for instance, in the furore surrounding highly inflated and even wholly fabricated memoirs such as James Frey’s A Million Little Pieces, Margaret B. Jones’s Love and Consequences and Misha Defonseca’s A Mémoire of the Holocaust Years. Related problems and anxieties arise when authors move beyond incorporating and disclosing the facts of their own lives in memoir or (autobiographical) fiction, to using the lives of others in this way. Daphne Patai sums up the difference: “A person telling her life story is, in a sense, offering up her self for her own and her listener’s scrutiny […] Whether we should appropriate another’s life in this way becomes a legitimate question” (24–5). While this is difficult but seemingly manageable for non-fiction writers because of their foundational reliance on evidence, this anxiety escalates for fiction writers. This seems particularly extreme in relation to how audience expectations and prior knowledge of actual events can shape perceptions and interpretations of the resulting work, even when those events are changed and the work is declared to be one of fiction. I have discussed elsewhere, for instance, the difficult terrain of crafting fiction from well-known criminal cases (Brien, “Based on a True Story”). The reception of such work shows how difficult it is to dissociate creative product from its source material once the public and media has made this connection, no matter how distant that finished product may be from the original facts.As the field of biography continues to evolve for writers, critics and theorists, a study of one key text at a moment in that evolution—Jill Shearer’s play Georgia and its reliance on disclosing the life of artist Georgia O’Keeffe for its content and dramatic power—reveals not only some of the challenges and opportunities this close relationship offers to the writers and readers of life stories, but also the pitfalls of attempting to dissemble regarding artistic intention. This award-winning play has been staged a number of times in the past decade but has attracted little critical attention. Yet, when I attended a performance of Georgia at La Boite Theatre in Brisbane in 1999, I was moved by the production and admiring of Shearer’s writing which was, I told anyone who would listen, a powerfully dramatic interpretation of O’Keeffe’s life, one of my favourite artists. A full decade on, aspects of the work and its performance still resonate through my thinking. Author of more than twenty plays performed throughout Australia and New Zealand as well as on Broadway, Shearer was then (and is) one of Australia’s leading playwrights, and I judged Georgia to be a major, mature work: clear, challenging and confident. Reading the Currency Press script a year or so after seeing the play reinforced for me how distinctive and successful a piece of theatre Shearer had created utilising a literary technique which has been described elsewhere as fictionalised biography—biography which utilises fictional forms in its presentation but stays as close to the historical record as conventional biography (Brien, The Case of Mary Dean).The published version of the script indeed acknowledges on its title page that Georgia is “inspired by the later life of the American artist Georgia O’Keeffe” (Shearer). The back cover blurb begins with a quote attributed to O’Keeffe and then describes the content of the play entirely in terms of biographical detail: The great American artist Georgia O’Keeffe is physically, emotionally and artistically debilitated by her failing eyesight. Living amidst the Navajo spiritual landscape in her desert home in New Mexico, she becomes prey to the ghosts of her past. Her solitude is broken by Juan, a young potter, whose curious influence on her life remains until her death at 98 (Georgia back cover). This short text ends by unequivocally reinforcing the relation between the play and the artist’s life: “Georgia is a passionate play that explores with sensitivity and wry humour the contradictions and the paradoxes of the life of Georgia O’Keeffe” (Georgia back cover). These few lines of plot synopsis actually contain a surprisingly large number of facts regarding O’Keeffe’s later life. After the death of her husband (the photographer and modern art impresario Alfred Steiglitz whose ghost is a central character in the play), O’Keeffe did indeed relocate permanently to Abiquiú in New Mexico. In 1971, aged 84, she was suffering from an irreversible degenerative disease, had lost her central vision and stopped painting. One autumn day in 1973, Juan Hamilton, a young potter, appeared at her adobe house looking for work. She hired him and he became her lover, closest confidante and business manager until her death at 98. These facts form not only the background story but also much of the riveting content for Georgia which, as the published script’s introduction states, takes as its central themes: “the dilemma of the artist as a an older woman; her yearning to create against the fear of failing artistic powers; her mental strength and vulnerability; her sexuality in the face of physical deterioration; her need for companionship and the paradoxical love of solitude” (Rider vii). These issues are not only those which art historians identify as animating the O’Keeffe’s later life and painting, but ones which are discussed at length in many of the biographies of the artist published from 1980 to 2007 (see, for instance: Arrowsmith and West; Berry; Calloway and Bry; Castro; Drohojowska-Philp; Eisler; Eldredge; Harris; Hogrefe; Lisle; Peters; Reily; Robinson).Despite this clear focus on disclosing aspects of O’Keeffe’s life, both the director’s and playwright’s notes prefacing the published script declare firmly that Georgia is fiction, not biography. While accepting that these statements may be related to copyright and privacy concerns, the stridency of the denials of the biography label with its implied intention of disclosing the facts of a life, are worthy of analysis. Although noting that Georgia is “about the American artist Georgia O’Keeffe”, director of the La Boite production Sue Rider asserts that not only that the play moves “beyond the biographical” (vii) but, a few pages later, that it is “thankfully not biography” (xii). This is despite Rider’s own underscoring of the connection to O’Keeffe by setting up an exhibition of the artist’s work adjacent to the theatre. Shearer, whose research acknowledgments include a number of works about O’Keeffe, is even more overtly strident in her denial of any biographical links stating that her characters, “this Juan, Anna Marie and Dorothy Norman are a work of dramatic fiction, as is the play, and should be taken as such” (xiii).Yet, set against a reading of the biographies of the artist, including those written in the intervening decade, Georgia clearly and remarkably accurately discloses the tensions and contradictions of O’Keeffe’s life. It also draws on a significant amount of documented biographical data to enhance the dramatic power of what is disclosed by the play for audiences with this knowledge. The play does work as a coherent narrative for a viewer without any prior knowledge of O’Keeffe’s life, but the meaning of the dramatic action is enhanced by any biographical knowledge the audience possesses. In this way, the play’s act of disclosure is reinforced by this externally held knowledge. Although O’Keeffe’s oeuvre is less well known and much anecdotal detail about her life is not as familiar for Australian viewers as for those in the artist’s homeland, Shearer writes for an international as well as an Australian audience, and the program and adjacent exhibition for the Brisbane performance included biographical information. It is also worth noting that large slabs of biographical detail are also omitted from the play. These omissions to disclosure include O’Keeffe’s early life from her birth in 1887 in Wisconsin to her studies in Chicago and New York from 1904 to 1908, as well as her work as a commercial artist and art teacher in Texas and other Southern American states from 1912 to 1916. It is from this moment in 1916, however, that the play (although opening in 1946) constructs O’Keeffe’s life right through to her death in 1986 by utilising such literary devices as flashbacks, dream sequences and verbal and visual references.An indication of the level of accuracy of the play as biographical disclosure can be ascertained by unpacking the few lines of opening stage directions, “The Steiglitz’s suite in the old mid-range Shelton Hotel, New York, 1946 ... Georgia, 59, in black, enters, dragging a coffin” (1). In 1946, when O’Keeffe was indeed aged 59, Steiglitz died. The couple had lived part of every year at the Shelton Towers Hotel at 525 Lexington Avenue (now the New York Marriott East Side), a moderately priced hotel made famous by its depiction in O’Keeffe’s paintings and Steiglitz’s photographs. When Stieglitz suffered a cerebral thrombosis, O’Keeffe was spending the summer in New Mexico, but she returned to New York where her husband died on 13 July. This level of biographical accuracy continues throughout Georgia. Halfway through the first page “Anita, 52” enters. This character represents Anita Pollitzer, artist, critic and O’Keeffe’s lifelong friend. The publication of her biography of O’Keeffe, A Woman on Paper, and Georgia’s disapproval of this, is discussed in the play, as are their letters, which were collected and published in 1990 as Lovingly, Georgia (Gibiore). Anita’s first lines in the play after greeting her friend refer to this substantial correspondence: “You write beautifully. I always tell people: “I have a friend who writes the most beautiful letters” (1). In the play, as in life, it is Anita who introduces O’Keeffe’s work to Stieglitz who is, in turn, accurately described as: “Gallery owner. Two Nine One, Fifth Avenue. Leader of the New York avant-garde, the first to bring in the European moderns” (6). The play also chronicles how (unknown to O’Keeffe) Steiglitz exhibited the drawings Pollitzer gave him under the incorrect name, a scene which continues with Steiglitz persuading Georgia to allow her drawings to remain in his gallery (as he did in life) and ends with a reference to his famous photographs of her hands and nude form. Although the action of a substantial amount of real time is collapsed into a few dramatic minutes and, without doubt, the dialogue is invented, this invention achieves the level of aesthetic truth aimed for by many contemporary biographers (Jones)—as can be assessed when referring back to the accepted biographical account. What actually appears to have happened was that, in the autumn 1915, while teaching art in South Carolina, O’Keeffe was working on a series of abstract charcoal drawings that are now recognised as among the most innovative in American art of that time. She mailed some of these drawings to Pollitzer, who showed them Steiglitz, who exhibited ten of them in April 1916, O’Keeffe only learning of this through an acquaintance. O’Keeffe, who had first visited 291 in 1908 but never spoken to Stieglitz, held his critical opinion in high regard, and although confronting him over not seeking her permission and citing her name incorrectly, eventually agreed to let her drawings hang (Harris). Despite Shearer’s denial, the other characters in Georgia are also largely biographical sketches. Her “Anna Marie”, who never appears in the play but is spoken of, is Juan’s wife (in real life Anna Marie Hamilton), and “Dorothy Norman” is the character who has an affair with Steiglitz—the discovery of which leads to Georgia’s nervous breakdown in the play. In life, while O’Keeffe was in New Mexico, Stieglitz became involved with the much younger Norman who was, he claimed, only his gallery assistant. When O’Keeffe discovered Norman posing nude for her husband (this is vividly imagined in Georgia), O’Keeffe moved out of the Shelton and suffered from the depression that led to her nervous breakdown. “ Juan,” who ages from 26 to 39 in the play, represents the potter Juan Hamilton who encouraged the nearly blind O’Keeffe to paint again. In the biographical record there is much conjecture about Hamilton’s motives, and Shearer sensitively portrays her interpretation of this liaison and the difficult territory of sexual desire between a man and a much older woman, as she also too discloses the complex relationship between O’Keeffe and the much older Steiglitz.This complexity is described through the action of the play, but its disclosure is best appreciated if the biographical data is known. There are also a number of moments of biographical disclosure in the play that can only be fully understood with biographical knowledge in hand. For instance, Juan refers to Georgia’s paintings as “Beautiful, sexy flowers [... especially] the calla lilies” (24). All attending the play are aware (from the exhibition, program and technical aspects of the production) that, in life, O’Keeffe was famous for her flower paintings. However, knowing that these had brought her fame and fortune early in her career with, in 1928, a work titled Calla Lily selling for U.S. $25,000, then an enormous sum for any living American artist, adds to the meaning of this line in the play. Conversely, the significant level of biographical disclosure throughout Georgia does not diminish, in any way, the power or integrity of Shearer’s play as a literary work. Universal literary (and biographical) themes—love, desire and betrayal—animate Georgia; Steiglitz’s spirit haunts Georgia years after his death and much of the play’s dramatic energy is generated by her passion for both her dead husband and her younger lover, with some of her hopeless desire sublimated through her relationship with Juan. Nadia Wheatley reads such a relationship between invention and disclosure in terms of myth—relating how, in the process of writing her biography of Charmain Clift, she came to see Clift and her husband George Johnson take on a larger significance than their individual lives: “They were archetypes; ourselves writ large; experimenters who could test and try things for us; legendary figures through whom we could live vicariously” (5). In this, Wheatley finds that “while myth has no real beginning or end, it also does not bother itself with cause and effect. Nor does it worry about contradictions. Parallel tellings are vital to the fabric” (5). In contrast with both Rider and Shearer’s insistence that Georgia was “not biography”, it could be posited that (at least part of) Georgia’s power arises from the creation of such mythic value, and expressly through its nuanced disclosure of the relevant factual (biographical) elements in parallel to the development of its dramatic (invented) elements. Alongside this, accepting Georgia as such a form of biographical disclosure would mean that as well as a superbly inventive creative work, the highly original insights Shearer offers to the mass of O’Keeffe biography—something of an American industry—could be celebrated, rather than excused or denied. ReferencesArrowsmith, Alexandra, and Thomas West, eds. Georgia O’Keeffe & Alfred Stieglitz: Two Lives—A Conversation in Paintings and Photographs. Washington DC: HarperCollins and Calloway Editions, and The Phillips Collection, 1992.Berry, Michael. Georgia O’Keeffe. New York: Chelsea House, 1988.Brien, Donna Lee. The Case of Mary Dean: Sex, Poisoning and Gender Relations in Australia. Unpublished PhD Thesis. Queensland University of Technology, 2004. –––. “‘Based on a True Story’: The Problem of the Perception of Biographical Truth in Narratives Based on Real Lives”. TEXT: Journal of Writers and Writing Programs 13.2 (Oct. 2009). 19 Oct. 2009 < http://www.textjournal.com.au >.Calloway, Nicholas, and Doris Bry, eds. Georgia O’Keeffe in the West. New York: Knopf, 1989.Castro, Jan G. The Art and Life of Georgia O’Keeffe. New York: Crown Publishing, Random House, 1985.Davis, Christine S., and Carolyn Ellis. “Autoethnographic Introspection in Ethnographic Fiction: A Method of Inquiry.” In Pranee Liamputtong and Jean Rumbold, eds. Knowing Differently: Arts-Based and Collaborative Research. New York: Nova Science, 2008. 99–117.Defonseca, Misha. Misha: A Mémoire of the Holocaust Years. Bluebell, PA: Mt. Ivy Press, 1997.Drohojowska-Philp, Hunter. Full Bloom: The Art and Life of Georgia O’Keeffe. New York: WW Norton, 2004.Ellis, Carolyn. “Telling Secrets, Revealing Lives: Relational Ethics in Research with Intimate Others.” Qualitative Inquiry 13.1 (2007): 3–29. Eisler, Benita. O’Keeffe and Stieglitz: An American Romance. New York: Doubleday, 1991.Eldredge, Charles C. Georgia O’Keeffe: American and Modern. New Haven: Yale UP, 1993.Fitzgerald, F. Scott. The Diamond as Big as the Ritz and Other Stories. Harmondsworth, U.K.: Penguin, 1962.Frey, James. A Million Little Pieces. New York: N.A. Talese/Doubleday, 2003.Gibiore, Clive, ed. Lovingly, Georgia. New York: Simon and Schuster, 1990.Halligan, Marion. “Lapping.” In Peter Craven, ed. Best Australian Essays. Melbourne: Bookman P, 1999. 208–13.Halligan, Marion. The Fog Garden. Sydney: Allen and Unwin, 2001.Halligan, Marion. “The Cathedral of Love.” The Age 27 Nov. 1999: Saturday Extra 1.Harris, J. C. “Georgia O’Keeffe at 291”. Archives of General Psychiatry 64.2 (Feb. 2007): 135–37.Hogrefe, Jeffrey. O’Keeffe: The Life of an American Legend. New York: Bantam, 1994.Inglis, Ian. “Popular Music History on Screen: The Pop/Rock Biopic.” Popular Music History 2.1 (2007): 77–93.Jones, Kip. “A Biographic Researcher in Pursuit of an Aesthetic: The Use of Arts-Based (Re)presentations in “Performative” Dissemination of Life Stories”. Qualitative Sociology Review 2.1 (Apr. 2006): 66–85. Jones, Margaret B. Love and Consequences: A Memoir of Hope and Survival. New York: Riverhead Books, 2008.Lisle, Laurie. Portrait of an Artist: A Biography of Georgia O’Keeffe. New York: Seaview Books, 1980.Murphy, Mary. “Limited Lives: The Problem of the Literary Biopic”. Kinema 17 (Spr. 2002): 67–74. Nelson, Camilla. “Faking It: History and Creative Writing.” TEXT: Journal of Writing and Writing Courses 11.2 (Oct. 2007). 19 Oct. 2009 < http://www.textjournal.com.au/oct07/nelson.htm >.Nowra, Louis. Ice. Crows Nest: Allen and Unwin, 2008.Owen, Jillian A. Tullis, Chris McRae, Tony E. Adams, and Alisha Vitale. “Truth Troubles.” Qualitative Inquiry 15.1 (2008): 178–200.Patai, Daphne. “Ethical Problems of Personal Narratives, or, Who Should Eat the Last Piece of Cake.” International Journal of Oral History 8 (1987): 5–27.Peters, Sarah W. Becoming O’Keeffe. New York: Abbeville Press, 1991.Pollitzer, Anita. A Woman on Paper. New York: Simon and Schuster, 1988.Reily, Nancy Hopkins. Georgia O’Keeffe. A Private Friendship, Part II. Santa Fe, NM: Sunstone Press, 2009.Rider, Sue. “Director’s Note.” Georgia [playscript]. Sydney: Currency Press, 2000. vii–xii.Robinson, Roxana. Georgia O’Keeffe: A Life. London: Bloomsbury Publishing, 1990. Shearer, Jill. Georgia [playscript]. Sydney: Currency Press, 2000.Smith, Thomas R. “How Our Lives Become Stories: Making Selves [review]”. Biography 23.3 (2000): 534–38.Wheatley, Nadia. The Life and Myth of Charmian Clift. Sydney: Flamingo, 2001.Wolpert, Stanley. “Biography as History: A Personal Reflection”. Journal of Interdisciplinary History 40.3 (2010): 399–412. Pub. online (Oct. 2009). 19 Oct. 2009 < http://www.mitpressjournals.org/toc/jinh/40/3 >.Wyatt, Jonathan. “Research, Narrative and Fiction: Conference Story”. The Qualitative Report 12.2 (Jun. 2007): 318–31.

Introduction This paper offers a survey of familiar popular music performers and songwriters who reference coffee in their work. It examines three areas of discourse: the psychoactive effects of caffeine, coffee and courtship rituals, and the politics of coffee consumption. I claim that coffee carries a cultural and musicological significance comparable to that of the chemical stimulants and consumer goods more readily associated with popular music. Songs about coffee may not be as potent as those featuring drugs and alcohol (Primack; Schapiro), or as common as those referencing commodities like clothes and cars (Englis; McCracken), but they do feature across a wide range of genres, some of which enjoy archetypal associations with this beverage. m.o.m.m.y. Needs c.o.f.f.e.e.: The Psychoactive Effect of Coffee The act of performing and listening to popular music involves psychological elements comparable to the overwhelming sensory experience of drug taking: altered perceptions, repetitive grooves, improvisation, self-expression, and psychological empathy—such as that between musician and audience (Curry). Most popular music genres are, as a result, culturally and sociologically identified with the consumption of at least one mind-altering substance (Lyttle; Primack; Schapiro). While the analysis of lyrics referring to this theme has hitherto focused on illegal drugs and alcoholic beverages (Cooper), coffee and its psychoactive ingredient caffeine have been almost entirely overlooked (Summer). The most recent study of drugs in popular music, for example, defined substance use as “tobacco, alcohol, marijuana, cocaine and other stimulants, heroin and other opiates, hallucinogens, inhalants, prescription drugs, over-the-counter drugs, and nonspecific substances” (Primack 172), thereby ignoring a chemical stimulant consumed by 90 per cent of adult Americans every day (Lovett). The wide availability of coffee and the comparatively mild effect of caffeine means that its consumption rarely causes harm. One researcher has described it as a ubiquitous and unobtrusive “generalised public activity […] ‘invisible’ to analysts seeking distinctive social events” (Cooper 92). Coffee may provide only a relatively mild “buzz”—but it is now accepted that caffeine is an addictive substance (Juliano) and, due to its universal legality, coffee is also the world’s most extensively traded and enthusiastically consumed psychoactive consumer product (Juliano 1). The musical genre of jazz has a longstanding relationship with marijuana and narcotics (Curry; Singer; Tolson; Winick). Unsurprisingly, given its Round Midnight connotations, jazz standards also celebrate the restorative impact of coffee. Exemplary compositions include Burke/Webster’s insomniac torch song Black Coffee, which provided hits for Sarah Vaughan (1949), Ella Fitzgerald (1953), and Peggy Lee (1960); and Frank Sinatra’s recordings of Hilliard/Dick’s The Coffee Song (1946, 1960), which satirised the coffee surplus in Brazil at a time when this nation enjoyed a near monopoly on production. Sinatra joked that this ubiquitous drink was that country’s only means of liquid refreshment, in a refrain that has since become a headline writer’s phrasal template: “There’s an Awful Lot of Coffee in Vietnam,” “An Awful Lot of Coffee in the Bin,” and “There’s an Awful Lot of Taxes in Brazil.” Ethnographer Aaron Fox has shown how country music gives expression to the lived social experience of blue-collar and agrarian workers (Real 29). Coffee’s role in energising working class America (Cooper) is featured in such recordings as Dolly Parton’s Nine To Five (1980), which describes her morning routine using a memorable “kitchen/cup of ambition” rhyme, and Don't Forget the Coffee Billy Joe (1973) by Tom T. Hall which laments the hardship of unemployment, hunger, cold, and lack of healthcare. Country music’s “tired truck driver” is the most enduring blue-collar trope celebrating coffee’s analeptic powers. Versions include Truck Drivin' Man by Buck Owens (1964), host of the country TV show Hee Haw and pioneer of the Bakersfield sound, and Driving My Life Away from pop-country crossover star Eddie Rabbitt (1980). Both feature characteristically gendered stereotypes of male truck drivers pushing on through the night with the help of a truck stop waitress who has fuelled them with caffeine. Johnny Cash’s A Cup of Coffee (1966), recorded at the nadir of his addiction to pills and alcohol, has an incoherent improvised lyric on this subject; while Jerry Reed even prescribed amphetamines to keep drivers awake in Caffein [sic], Nicotine, Benzedrine (And Wish Me Luck) (1980). Doye O’Dell’s Diesel Smoke, Dangerous Curves (1952) is the archetypal “truck drivin’ country” song and the most exciting track of its type. It subsequently became a hit for the doyen of the subgenre, Red Simpson (1966). An exhausted driver, having spent the night with a woman whose name he cannot now recall, is fighting fatigue and wrestling his hot-rod low-loader around hairpin mountain curves in an attempt to rendezvous with a pretty truck stop waitress. The song’s palpable energy comes from its frenetic guitar picking and the danger implicit in trailing a heavy load downhill while falling asleep at the wheel. Tommy Faile’s Phantom 309, a hit for Red Sovine (1967) that was later covered by Tom Waits (Big Joe and the Phantom 309, 1975), elevates the “tired truck driver” narrative to gothic literary form. Reflecting country music’s moral code of citizenship and its culture of performative storytelling (Fox, Real 23), it tells of a drenched and exhausted young hitchhiker picked up by Big Joe—the driver of a handsome eighteen-wheeler. On arriving at a truck stop, Joe drops the traveller off, giving him money for a restorative coffee. The diner falls silent as the hitchhiker orders up his “cup of mud”. Big Joe, it transpires, is a phantom trucker. After running off the road to avoid a school bus, his distinctive ghost rig now only reappears to rescue stranded travellers. Punk rock, a genre closely associated with recreational amphetamines (McNeil 76, 87), also features a number of caffeine-as-stimulant songs. Californian punk band, Descendents, identified caffeine as their drug of choice in two 1996 releases, Coffee Mug and Kids on Coffee. These songs describe chugging the drink with much the same relish and energy that others might pull at the neck of a beer bottle, and vividly compare the effects of the drug to the intense rush of speed. The host of “New Music News” (a segment of MTV’s 120 Minutes) references this correlation in 1986 while introducing the band’s video—in which they literally bounce off the walls: “You know, while everybody is cracking down on crack, what about that most respectable of toxic substances or stimulants, the good old cup of coffee? That is the preferred high, actually, of California’s own Descendents—it is also the subject of their brand new video” (“New Music News”). Descendents’s Sessions EP (1997) featured an overflowing cup of coffee on the sleeve, while punk’s caffeine-as-amphetamine trope is also promulgated by Hellbender (Caffeinated 1996), Lagwagon (Mr. Coffee 1997), and Regatta 69 (Addicted to Coffee 2005). Coffee in the Morning and Kisses in the Night: Coffee and Courtship Coffee as romantic metaphor in song corroborates the findings of early researchers who examined courtship rituals in popular music. Donald Horton’s 1957 study found that hit songs codified the socially constructed self-image and limited life expectations of young people during the 1950s by depicting conservative, idealised, and traditional relationship scenarios. He summarised these as initial courtship, honeymoon period, uncertainty, and parting (570-4). Eleven years after this landmark analysis, James Carey replicated Horton’s method. His results revealed that pop lyrics had become more realistic and less bound by convention during the 1960s. They incorporated a wider variety of discourse including the temporariness of romantic commitment, the importance of individual autonomy in relationships, more liberal attitudes, and increasingly unconventional courtship behaviours (725). Socially conservative coffee songs include Coffee in the Morning and Kisses in the Night by The Boswell Sisters (1933) in which the protagonist swears fidelity to her partner on condition that this desire is expressed strictly in the appropriate social context of marriage. It encapsulates the restrictions Horton identified on courtship discourse in popular song prior to the arrival of rock and roll. The Henderson/DeSylva/Brown composition You're the Cream in My Coffee, recorded by Annette Hanshaw (1928) and by Nat King Cole (1946), also celebrates the social ideal of monogamous devotion. The persistence of such idealised traditional themes continued into the 1960s. American pop singer Don Cherry had a hit with Then You Can Tell Me Goodbye (1962) that used coffee as a metaphor for undying and everlasting love. Otis Redding’s version of Butler/Thomas/Walker’s Cigarettes and Coffee (1966)—arguably soul music’s exemplary romantic coffee song—carries a similar message as a couple proclaim their devotion in a late night conversation over coffee. Like much of the Stax catalogue, Cigarettes and Coffee, has a distinctly “down home” feel and timbre. The lovers are simply content with each other; they don’t need “cream” or “sugar.” Horton found 1950s blues and R&B lyrics much more sexually explicit than pop songs (567). Dawson (1994) subsequently characterised black popular music as a distinct public sphere, and Squires (2002) argued that it displayed elements of what she defined as “enclave” and “counterpublic” traits. Lawson (2010) has argued that marginalised and/or subversive blues artists offered a form of countercultural resistance against prevailing social norms. Indeed, several blues and R&B coffee songs disregard established courtship ideals and associate the product with non-normative and even transgressive relationship circumstances—including infidelity, divorce, and domestic violence. Lightnin’ Hopkins’s Coffee Blues (1950) references child neglect and spousal abuse, while the narrative of Muddy Waters’s scorching Iodine in my Coffee (1952) tells of an attempted poisoning by his Waters’s partner. In 40 Cups of Coffee (1953) Ella Mae Morse is waiting for her husband to return home, fuelling her anger and anxiety with caffeine. This song does eventually comply with traditional courtship ideals: when her lover eventually returns home at five in the morning, he is greeted with a relieved kiss. In Keep That Coffee Hot (1955), Scatman Crothers supplies a counterpoint to Morse’s late-night-abandonment narrative, asking his partner to keep his favourite drink warm during his adulterous absence. Brook Benton’s Another Cup of Coffee (1964) expresses acute feelings of regret and loneliness after a failed relationship. More obliquely, in Coffee Blues (1966) Mississippi John Hurt sings affectionately about his favourite brand, a “lovin’ spoonful” of Maxwell House. In this, he bequeathed the moniker of folk-rock band The Lovin’ Spoonful, whose hits included Do You Believe in Magic (1965) and Summer in the City (1966). However, an alternative reading of Hurt’s lyric suggests that this particular phrase is a metaphorical device proclaiming the author’s sexual potency. Hurt’s “lovin’ spoonful” may actually be a portion of his seminal emission. In the 1950s, Horton identified country as particularly “doleful” (570), and coffee provides a common metaphor for failed romance in a genre dominated by “metanarratives of loss and desire” (Fox, Jukebox 54). Claude Gray’s I'll Have Another Cup of Coffee (Then I’ll Go) (1961) tells of a protagonist delivering child support payments according to his divorce lawyer’s instructions. The couple share late night coffee as their children sleep through the conversation. This song was subsequently recorded by seventeen-year-old Bob Marley (One Cup of Coffee, 1962) under the pseudonym Bobby Martell, a decade prior to his breakthrough as an international reggae star. Marley’s youngest son Damian has also performed the track while, interestingly in the context of this discussion, his older sibling Rohan co-founded Marley Coffee, an organic farm in the Jamaican Blue Mountains. Following Carey’s demonstration of mainstream pop’s increasingly realistic depiction of courtship behaviours during the 1960s, songwriters continued to draw on coffee as a metaphor for failed romance. In Carly Simon’s You’re So Vain (1972), she dreams of clouds in her coffee while contemplating an ostentatious ex-lover. Squeeze’s Black Coffee In Bed (1982) uses a coffee stain metaphor to describe the end of what appears to be yet another dead-end relationship for the protagonist. Sarah Harmer’s Coffee Stain (1998) expands on this device by reworking the familiar “lipstick on your collar” trope, while Sexsmith & Kerr’s duet Raindrops in my Coffee (2005) superimposes teardrops in coffee and raindrops on the pavement with compelling effect. Kate Bush’s Coffee Homeground (1978) provides the most extreme narrative of relationship breakdown: the true story of Cora Henrietta Crippin’s poisoning. Researchers who replicated Horton’s and Carey’s methodology in the late 1970s (Bridges; Denisoff) were surprised to find their results dominated by traditional courtship ideals. The new liberal values unearthed by Carey in the late 1960s simply failed to materialise in subsequent decades. In this context, it is interesting to observe how romantic coffee songs in contemporary soul and jazz continue to disavow the post-1960s trend towards realistic social narratives, adopting instead a conspicuously consumerist outlook accompanied by smooth musical timbres. This phenomenon possibly betrays the influence of contemporary coffee advertising. From the 1980s, television commercials have sought to establish coffee as a desirable high end product, enjoyed by bohemian lovers in a conspicuously up-market environment (Werder). All Saints’s Black Coffee (2000) and Lebrado’s Coffee (2006) identify strongly with the culture industry’s image of coffee as a luxurious beverage whose consumption signifies prominent social status. All Saints’s promotional video is set in a opulent location (although its visuals emphasise the lyric’s romantic disharmony), while Natalie Cole’s Coffee Time (2008) might have been itself written as a commercial. Busting Up a Starbucks: The Politics of Coffee Politics and coffee meet most palpably at the coffee shop. This conjunction has a well-documented history beginning with the establishment of coffee houses in Europe and the birth of the public sphere (Habermas; Love; Pincus). The first popular songs to reference coffee shops include Jaybird Coleman’s Coffee Grinder Blues (1930), which boasts of skills that precede the contemporary notion of a barista by four decades; and Let's Have Another Cup of Coffee (1932) from Irving Berlin’s depression-era musical Face The Music, where the protagonists decide to stay in a restaurant drinking coffee and eating pie until the economy improves. Coffee in a Cardboard Cup (1971) from the Broadway musical 70 Girls 70 is an unambiguous condemnation of consumerism, however, it was written, recorded and produced a generation before Starbucks’ aggressive expansion and rapid dominance of the coffee house market during the 1990s. The growth of this company caused significant criticism and protest against what seemed to be a ruthless homogenising force that sought to overwhelm local competition (Holt; Thomson). In response, Starbucks has sought to be defined as a more responsive and interactive brand that encourages “glocalisation” (de Larios; Thompson). Koller, however, has characterised glocalisation as the manipulative fabrication of an “imagined community”—whose heterogeneity is in fact maintained by the aesthetics and purchasing choices of consumers who make distinctive and conscious anti-brand statements (114). Neat Capitalism is a more useful concept here, one that intercedes between corporate ideology and postmodern cultural logic, where such notions as community relations and customer satisfaction are deliberately and perhaps somewhat cynically conflated with the goal of profit maximisation (Rojek). As the world’s largest chain of coffee houses with over 19,400 stores in March 2012 (Loxcel), Starbucks is an exemplar of this phenomenon. Their apparent commitment to environmental stewardship, community relations, and ethical sourcing is outlined in the company’s annual “Global Responsibility Report” (Vimac). It is also demonstrated in their engagement with charitable and environmental non-governmental organisations such as Fairtrade and Co-operative for Assistance and Relief Everywhere (CARE). By emphasising this, Starbucks are able to interpellate (that is, “call forth”, “summon”, or “hail” in Althusserian terms) those consumers who value environmental protection, social justice and ethical business practices (Rojek 117). Bob Dylan and Sheryl Crow provide interesting case studies of the persuasive cultural influence evoked by Neat Capitalism. Dylan’s 1962 song Talkin’ New York satirised his formative experiences as an impoverished performer in Greenwich Village’s coffee houses. In 1995, however, his decision to distribute the Bob Dylan: Live At The Gaslight 1962 CD exclusively via Starbucks generated significant media controversy. Prominent commentators expressed their disapproval (Wilson Harris) and HMV Canada withdrew Dylan’s product from their shelves (Lynskey). Despite this, the success of this and other projects resulted in the launch of Starbucks’s in-house record company, Hear Music, which released entirely new recordings from major artists such as Ray Charles, Paul McCartney, Joni Mitchell, Carly Simon and Elvis Costello—although the company has recently announced a restructuring of their involvement in this venture (O’Neil). Sheryl Crow disparaged her former life as a waitress in Coffee Shop (1995), a song recorded for her second album. “Yes, I was a waitress. I was a waitress not so long ago; then I won a Grammy” she affirmed in a YouTube clip of a live performance from the same year. More recently, however, Crow has become an avowed self-proclaimed “Starbucks groupie” (Tickle), releasing an Artist’s Choice (2003) compilation album exclusively via Hear Music and performing at the company’s 2010 Annual Shareholders’s Meeting. Songs voicing more unequivocal dissatisfaction with Starbucks’s particular variant of Neat Capitalism include Busting Up a Starbucks (Mike Doughty, 2005), and Starbucks Takes All My Money (KJ-52, 2008). The most successful of these is undoubtedly Ron Sexsmith’s Jazz at the Bookstore (2006). Sexsmith bemoans the irony of intense original blues artists such as Leadbelly being drowned out by the cacophony of coffee grinding machines while customers queue up to purchase expensive coffees whose names they can’t pronounce. In this, he juxtaposes the progressive patina of corporate culture against the circumstances of African-American labour conditions in the deep South, the shocking incongruity of which eventually cause the old bluesman to turn in his grave. Fredric Jameson may have good reason to lament the depthless a-historical pastiche of postmodern popular culture, but this is no “nostalgia film”: Sexsmith articulates an artfully framed set of subtle, sensitive, and carefully contextualised observations. Songs about coffee also intersect with politics via lyrics that play on the mid-brown colour of the beverage, by employing it as a metaphor for the sociological meta-narratives of acculturation and assimilation. First popularised in Israel Zangwill’s 1905 stage play, The Melting Pot, this term is more commonly associated with Americanisation rather than miscegenation in the United States—a nuanced distinction that British band Blue Mink failed to grasp with their memorable invocation of “coffee-coloured people” in Melting Pot (1969). Re-titled in the US as People Are Together (Mickey Murray, 1970) the song was considered too extreme for mainstream radio airplay (Thompson). Ike and Tina Turner’s Black Coffee (1972) provided a more accomplished articulation of coffee as a signifier of racial identity; first by associating it with the history of slavery and the post-Civil Rights discourse of African-American autonomy, then by celebrating its role as an energising force for African-American workers seeking economic self-determination. Anyone familiar with the re-casting of black popular music in an industry dominated by Caucasian interests and aesthetics (Cashmore; Garofalo) will be unsurprised to find British super-group Humble Pie’s (1973) version of this song more recognisable. Conclusion Coffee-flavoured popular songs celebrate the stimulant effects of caffeine, provide metaphors for courtship rituals, and offer critiques of Neat Capitalism. Harold Love and Guthrie Ramsey have each argued (from different perspectives) that the cultural micro-narratives of small social groups allow us to identify important “ethnographic truths” (Ramsey 22). Aesthetically satisfying and intellectually stimulating coffee songs are found where these micro-narratives intersect with the ethnographic truths of coffee culture. Examples include the unconventional courtship narratives of blues singers Muddy Waters and Mississippi John Hurt, the ritualised storytelling tradition of country performers Doye O’Dell and Tommy Faile, and historicised accounts of the Civil Rights struggle provided by Ron Sexsmith and Tina Turner. References Argenti, Paul. “Collaborating With Activists: How Starbucks Works With NGOs.” California Management Review 47.1 (2004): 91–116. Althusser, Louis. “Ideology and Ideological State Apparatuses.” Lenin and Philosophy and Other Essays. London: Monthly Review Press, 1971. Bridges, John, and R. Serge Denisoff. “Changing Courtship Patterns in the Popular Song: Horton and Carey revisited.” Popular Music and Society 10.3 (1986): 29–45. Carey, James. “Changing Courtship Patterns in the Popular Song.” The American Journal of Sociology 74.6 (1969): 720–31. Cashmere, Ellis. The Black Culture Industry. London: Routledge, 1997. “Coffee.” Theme Time Radio Hour hosted by Bob Dylan, XM Satellite Radio. 31 May 2006. Cooper, B. Lee, and William L. Schurk. “You’re the Cream in My Coffee: A Discography of Java Jive.” Popular Music and Society 23.2 (1999): 91–100. Crow, Sheryl. “Coffee Shop.” Beacon Theatre, New York City. 17 Mar. 1995. YouTube 1 Feb. 2012 ‹http://www.youtube.com/watch?v=j_-bDAjASQI ›. Curry, Andrew. “Drugs in Jazz and Rock Music.” Clinical Toxicology 1.2 (1968): 235–44. Dawson, Michael C. “A Black Counterpublic?: Economic Earthquakes, Racial Agenda(s) and Black Politics.” Public Culture 7.1 (1994): 195–223. de Larios, Margaret. “Alone, Together: The Social Culture of Music and the Coffee Shop.” URC Student Scholarship Paper 604 (2011). 1 Feb. 2012 ‹http://scholar.oxy.edu/urc_student/604›. Englis, Basil, Michael Solomon and Anna Olofsson. “Consumption Imagery in Music Television: A Bi-Cultural Perspective.” Journal of Advertising 22.4 (1993): 21–33. Fox, Aaron. Real Country: Music and Language in Working-Class Culture. Durham: Duke UP, 2004. Fox, Aaron. “The Jukebox of History: Narratives of Loss and Desire in the Discourse of Country Music.” Popular Music 11.1 (1992): 53–72. Garofalo, Reebee. “Culture Versus Commerce: The Marketing of Black Popular Music.” Public Culture 7.1 (1994): 275–87. Habermas, Jurgen. The Structural Transformation of the Public Sphere: An Inquiry Into a Category of Bourgeois Society. Cambridge: Polity Press, 1989. Hamilton, Andy. Aesthetics and Music. London: Continuum, 2007. Harris, Craig. “Starbucks Opens Hear Music Shop in Bellevue.” Seattle Post Intelligencer 23 Nov. 2006. 1 Feb. 2012 ‹http://www.seattlepi.com/business/article/Starbucks-opens-Hear-Music-shop-in-Bellevue-1220637.php›. Harris, John. “Lay Latte Lay.” The Guardian 1 Jul. 2005. 1 Feb. 2012 ‹http://www.guardian.co.uk/music/2005/jul/01/2?INTCMP=SRCH›. Holt, Douglas. “Why Do Brands Cause Trouble? A Dialectical Theory of Consumer Culture and Branding.” Journal of Consumer Research 29 (2002): 70–90. Horton, Donald. “The Dialogue of Courtship in Popular Songs.” American Journal of Sociology 62.6 (1957): 569–78. Jameson, Fredric. Postmodernism, or the Cultural Logic of Late Capitalism. Durham: Duke UP, 1991. Juliano, Laura, and Roland Griffiths. “A Critical Review of Caffeine Withdrawal: Empirical Validation of Symptoms and Signs, Incidence, Severity, and Associated Features.” Psychopharmacology 176 (2004): 1–29. Koller, Veronika. “‘The World’s Local Bank’: Glocalisation as a Strategy in Corporate Branding Discourse.” Social Semiotics 17.1 (2007): 111–31. Lawson, Rob A. Jim Crow’s Counterculture: The Blues and Black Southerners, 1890-1945 (Making the Modern South). Baton Rouge: Louisiana State UP, 2010. Love, Harold. “How Music Created A Public.” Criticism 46.2 (2004): 257–72. “Loxcel Starbucks Map”. Loxcel.com 1 Mar. 2012 ‹loxcel.com/sbux-faq.hmtl›. Lovett, Richard. “Coffee: The Demon Drink?” New Scientist 2518. 24 Sep. 2005. 1 Apr. 2012 ‹http://www.newscientist.com/article/mg18725181.700›. Lynskey, Dorian. “Stir It Up: Starbucks Has Changed the Music Industry with its Deals with Dylan and Alanis. What’s Next?”. The Guardian 6 Oct. 2005: 18. 1 Feb. 2012 ‹http://www.guardian.co.uk/music/2005/oct/06/popandrock.marketingandpr›. Lyttle, Thomas, and Michael Montagne. “Drugs, Music, and Ideology: A Social Pharmacological Interpretation of the Acid House Movement.” The International Journal of the Addictions 27.10 (1992): 1159–77. McCracken, Grant. “Culture and Consumption: A Theoretical Account of the Structure and Movement of the Cultural Meaning of Consumer Goods.” Journal of Consumer Research 13.1 (1986): 71–84. McNeil, Legs, and Gillian McCain. Please Kill Me: The Uncensored Oral History of Punk. London: Abacus, 1997. “New Music News” 120 Minutes MTV 28 Sep. 1986. 1 Feb. 2012 ‹http://www.youtube.com/watch?v=TnqjqXztc0o›. O’Neil, Valerie. “Starbucks Refines its Entertainment Strategy.” Starbucks Newsroom 24 Apr. 2008. 1 Feb. 2012 ‹http://news.starbucks.com/article_display.cfm?article_id=48›. Pincus, Steve. “‘Coffee Politicians Does Create’: Coffeehouses and Restoration Political Culture.” The Journal of Modern History 67 (1995): 807–34. Primack, Brian, Madeline Dalton, Mary Carroll, Aaron Agarwal, and Michael Fine. “Content Analysis of Tobacco, Alcohol, and Other Drugs in Popular Music.” Archives of Pediatrics & Adolescent Medicine 162.2 (2008): 169–75. 1 Feb. 2012 ‹http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3004676/›. Ramsey, Guthrie P. Race Music: Black Cultures from Bebop to Hip-Hop. Berkeley: U of California P, 2003. Rojek, Chris. Cultural Studies. Cambridge: Polity P, 2007. Rosenbaum, Jill, and Lorraine Prinsky. “Sex, Violence and Rock ‘N’ Roll: Youths’ Perceptions of Popular Music.” Popular Music and Society 11.2 (1987): 79–89. Shapiro, Harry. Waiting for the Man: The Story of Drugs and Popular Music. London: Quartet Books, 1988. Singer, Merrill, and Greg Mirhej. “High Notes: The Role of Drugs in the Making of Jazz.” Journal of Ethnicity in Substance Abuse 5.4 (2006):1–38. Squires, Catherine R. “Rethinking the Black Public Sphere: An Alternative Vocabulary for Multiple Public Spheres.” Communication Theory 12.4 (2002): 446–68. Thompson, Craig J., and Zeynep Arsel. “The Starbucks Brandscape and Consumers’ (Anticorporate) Experiences of Glocalization.” Journal of Consumer Research 31 (2004.): 631–42. Thompson, Erik. “Secret Stash Records Releases Forgotten Music in Stylish Packages: Meet Founders Cory Wong and Eric Foss.” CityPages 18 Jan. 2012. 1 Feb. 2012 ‹http://www.citypages.com/2012-01-18/music/secret-stash-records-releases-forgotten-music-in-stylish-packages/›.Tickle, Cindy. “Sheryl Crow Performs at Starbucks Annual Shareholders Meeting.” Examiner.com24 Mar. 2010. 1 Feb. 2012 ‹http://www.examiner.com/starbucks-in-national/sheryl-crow-performs-at-starbucks-annual-shareholders-meeting-photos›.Tolson, Gerald H., and Michael J. Cuyjet. “Jazz and Substance Abuse: Road to Creative Genius or Pathway to Premature Death?”. International Journal of Law and Psychiatry 30 (2007): 530–38. Varma, Vivek, and Ben Packard. “Starbucks Global Responsibility Report Goals and Progress 2011”. Starbucks Corporation 1 Apr. 2012 ‹http://assets.starbucks.com/assets/goals-progress-report-2011.pdf›. Werder, Olaf. “Brewing Romance The Romantic Fantasy Theme of the Taster’s Choice ‘Couple’ Advertising Campaign.” Critical Thinking About Sex, Love, And Romance In The Mass Media: Media Literacy Applications. Eds. Mary-Lou Galician and Debra L. Merskin. New Jersey: Taylor & Francis, 2009. 35–48. Wilson, Jeremy “Desolation Row: Dylan Signs With Starbucks.” The Guardian 29 Jun. 2005. 1 Feb. 2012 ‹http://www.guardian.co.uk/world/2005/jun/29/bobdylan.digitalmedia?INTCMP=SRCH›. Winick, Charles. “The Use of Drugs by Jazz Musicians.” Social Problems 7.3 (1959): 240–53.

Introduction In 2017, 250 Indigenous delegates from across the country convened at the National Constitution Convention at Uluru to discuss a strategy towards the implementation of constitutional reform and recognition of Aboriginal and Torres Strait Islander peoples (Referendum Council). Informed by community consultations arising out of 12 regional dialogues conducted by the government appointed Referendum Council, the resulting Uluru Statement from the Heart was unlike any constitutional reform previously proposed (Appleby & Synot). Within the Statement, the delegation outlined that to build a more equitable and reconciled nation, an enshrined Voice to Parliament was needed. Such a voice would embed Indigenous participation in parliamentary dialogues and debates while facilitating further discussion pertaining to truth telling and negotiating a Treaty between Indigenous and non-Indigenous peoples. The reforms proposed are based on the collective input of Indigenous communities that were expressed in good faith during the consultation process. Arising out of a government appointed and funded initiative that directly sought Indigenous perspectives on constitutional reform, the trust and good faith invested by Indigenous people was quickly shut down when the Prime Minster, Malcolm Turnbull, rejected the reforms without parliamentary debate or taking them to the people via a referendum (Wahlquist Indigenous Voice Proposal; Appleby and McKinnon). In this article, we argue that through its dismissal the government treated the Uluru Statement from the Heart as a passing phase or mere “thought bubble” that was envisioned to disappear as quickly as it emerged. The Uluru Statement is a gift to the nation. One that genuinely offers new ways of envisioning and enacting reconciliation through equitable relationships between Indigenous and non-Indigenous populations. Indigenous voices lie at the heart of reconciliation but require constitutional enshrinement to ensure that Indigenous peoples and cultures are represented across all levels of government. Filter Bubbles of Distortion Constitutional change is often spoken of by politicians, its critics, and within the media as something unachievable. For example, in 2017, before even reading the accompanying report, MP Barnaby Joyce (in Fergus) publicly denounced the Uluru Statement as “unwinnable” and not “saleable”. He stated that “if you overreach in politics and ask for something that will not be supported by the Australian people such as another chamber in politics or something that sort of sits above or beside the Senate, that idea just won't fly”. Criticisms such as these are laced with paternalistic rhetoric that suggests its potential defeat at a referendum would be counterproductive and “self-defeating”, meaning that the proposed changes should be rejected for a more digestible version, ultimately saving the movement from itself. While efforts to communicate the necessity of the proposed reforms continues, presumptions that it does not have public support is simply unfounded. The Centre for Governance and Public Policy shows that 71 per cent of the public support constitutional recognition of Indigenous Australians. Furthermore, an online survey conducted by Cox Inall Ridgeway found that the majority of those surveyed supported constitutional reform to curb racism; remove section 25 and references to race; establish an Indigenous Voice to Parliament; and formally recognise Indigenous peoples through a statement of acknowledgment (Referendum Council). In fact, public support for constitutional reform is growing, with Reconciliation Australia’s reconciliation barometer survey showing an increase from 77 per cent in 2018 to 88 per cent in 2020 (Reconciliation Australia). Media – whether news, social, databases, or search engines – undoubtedly shape the lens through which people come to encounter and understand the world. The information a person receives can be the result of what Eli Pariser has described as “filter bubbles”, in which digital algorithms determine what perspectives, outlooks, and sources of information are considered important, and those that are readily accessible. Misinformation towards constitutional reform, such as that commonly circulated within mainstream and social media and propelled by high profile voices, further creates what neuroscientist Don Vaughn calls “reinforcement bubbles” (Rose Gould). This propagates particular views and stunts informed debate. Despite public support, the reforms proposed in the Uluru Statement continue to be distorted within public and political discourses, with the media used as a means to spread misinformation that equates an Indigenous Voice to Parliament to the establishment of a new “third chamber” (Wahlquist ‘Barnaby’; Karp). In a 2018 interview, PM Scott Morrison suggested that advocates and commentators in favour of constitutional reform were engaging in spin by claiming that a Voice did not function as a third chamber (Prime Minister of Australia). Morrison claimed, “people can dress it up any way they like but I think two chambers is enough”. After a decade of consultative work, eight government reports and inquiries, and countless publications and commentaries, the Uluru Statement continues to be played down as if it were a mere thought bubble, a convoluted work in progress that is in need of refinement. In the same interview, Morrison went on to say that the proposal as it stands now is “unworkable”. Throughout the ongoing movement towards constitutional reform, extensive effort has been invested into ensuring that the reforms proposed are achievable and practical. The Uluru Statement from the Heart represents the culmination of decades of work and proposes clear, concise, and relatively minimal constitutional changes that would translate to potentially significant outcomes for Indigenous Australians (Fredericks & Bradfield). International examples demonstrate how such reforms can translate into parliamentary and governing structures. The Treaty of Waitangi (Palmer) for example seeks to inform Māori and Pākehā (non-Maori) relationships in New Zealand/Aotearoa, whilst designated “Māori Seats” ensure Indigenous representation in parliament (Webster & Cheyne). More recently, 17 of 155 seats were reserved for Indigenous delegates as Chile re-writes its own constitution (Bartlett; Reuters). Indigenous communities and its leaders are more than aware of the necessity of working within the realms of possibility and the need to exhibit caution when presenting such reforms to the public. An expert panel on constitutional reform (Dodson 73), before the conception of the Uluru Statement, acknowledged this, stating “any proposal relating to constitutional recognition of the sovereign status of Aboriginal and Torres Strait Islander peoples would be highly contested by many Australians, and likely to jeopardise broad public support for the Panel’s recommendations”. As outlined in the Joint Select Committee’s final report on Constitutional Recognition relating to Aboriginal and Torres Strait Islander peoples (Referendum Council), the Voice to parliament would have no veto powers over parliamentary votes or decisions. It operates as a non-binding advisory body that remains external to parliamentary processes. Peak organisations such as the Law Council of Australia (Dolar) reiterate the fact that the proposed reforms are for a voice to Parliament rather than a voice in Parliament. Although not binding, the Voice should not be dismissed as symbolic or something that may be easily circumvented. Its effectiveness lies in its ability to place parliament in a position where they are forced to confront and address Indigenous questions, concerns, opinions, and suggestions within debates before decisions are made. Bursting the ‘Self-Referential Bubble’ Indigenous affairs continue to be one of the few areas where a rhetoric of bipartisan agreement is continuously referenced by both major parties. Disagreement, debate, and conflict is often avoided as governments seek to portray an image of unity, and in doing so, circumvent accusations of turning Indigenous peoples into the subjects of political point scoring. Within parliamentary debates, there is an understandable reservation and discomfort associated with discussions about what is often seen as an Indigenous “other” (Moreton-Robinson) and the policies that a predominantly white government enact over their lives. Yet, it is through rigorous, open, and informed debate that policies may be developed, challenged, and reformed. Although bipartisanship can portray an image of a united front in addressing a so-called “Indigenous problem”, it also stunts the conception of effective and culturally responsive policy. In other words, it often overlooks Indigenous voices. Whilst education and cultural competency plays a significant role within the reconciliation process, the most pressing obstacle is not necessarily non-Indigenous people’s inability to fully comprehend Indigenous lives and socio-cultural understandings. Even within an ideal world where non-Indigenous peoples attain a thorough understanding of Indigenous cultures, they will never truly comprehend what it means to be Indigenous (Fanon; de Sousa Santos). For non-Indigenous peoples, accepting one’s own limitations in fully comprehending Indigenous ontologies – and avoiding filling such gaps with one’s own interpretations and preconceptions – is a necessary component of decolonisation and the movement towards reconciliation (Grosfoguel; Mignolo). As parliament continues to be dominated by non-Indigenous representatives, structural changes are necessary to ensure that Indigenous voices are adequality represented. The structural reforms not only empower Indigenous voices through their inclusion within the parliamentary process but alleviates some of the pressures that arise out of non-Indigenous people having to make decisions in attempts to solve so-called Indigenous “problems”. Government response to constitutional reform, however, is ridden with symbolic piecemeal offerings that equate recognition to a form of acknowledgment without the structural changes necessary to protect and enshrine Indigenous Voices and parliamentary participation. Davis and her colleagues (Davis et al. “The Uluru Statement”) note how the Referendum Council’s recommendations were rejected by the then minister of Indigenous affairs Nigel Scullion on account that it privileged Aboriginal and Torres Strait Islander voices. They note that, until the Referendum Council's report, the nation had no real assessment of what communities wanted. Yet by all accounts, the government had spent too much time talking to elites who have regular access to them and purport to speak on the mob's behalf. If he [Scullion] got the sense constitutional symbolism and minimalism was going to fly, then it says a lot about the self-referential bubble in which the Canberra elites live. The Uluru Statement from the Heart stands as testament to Indigenous people’s refusal to be the passive recipients of the decisions of the non-Indigenous political elite. As suggested, “symbolism and minimalism was not going to fly”. Ken Wyatt, Scullion’s replacement, reiterated the importance of co-design, the limitations of government bureaucracy, and the necessity of moving beyond the “Canberra bubble”. Wyatt stated that the Voice is saying clearly that government and the bureaucracy does not know best. It can not be a Canberra-designed approach in the bubble of Canberra. We have to co-design with Aboriginal communities in the same way that we do with state and territory governments and the corporate sector. The Voice would be the mechanism through which Aboriginal and Torres Strait Islander interests and perspectives may be strategically placed within parliamentary dialogues. Despite accusations of it operating as a “third chamber”, Indigenous representatives have no interest in functioning in a similar manner to a political party. The language associated with our current parliamentary system demonstrates the constrictive nature of political debate. Ministers are expected to “toe the party line”, “crossing the floor” is presented as an act of defiance, and members must be granted permission to enter a “conscience vote”. An Indigenous Voice to Parliament would be an advisory body that works alongside, but remains external to political ideologies. Their priority is to seek and implement the best outcome for their communities. Negotiations would be fluid, with no floor to cross, whilst a conscience vote would be reflected in every perspective gifted to the parliament. In the 2020 Australia and the World Annual Lecture, Pat Turner described the Voice’s co-design process as convoluted and a continuing example of the government’s neglect to hear and respond to Indigenous peoples’ interests. In the address, Turner points to the Coalition of the Peaks as an exemplar of how co-design negotiations may be facilitated by and through organisations entirely formed and run by Indigenous peoples. The Coalition of the Peaks comprises of fifty Aboriginal and Torres Strait Islander community-controlled peak organisations and was established to address concerns relating to closing the gap targets. As Indigenous peak organisations are accountable to their membership and reliant on government funding, some have questioned whether they are appropriate representative bodies; cautioning that they could potentially compromise the Voice as a community-centric body free from political interference. While there is some debate over which Indigenous representatives should facilitate the co-design of a treaty and Makarrata (truth-telling), there remains a unanimous call for a constitutionally enshrined Voice to Parliament that may lead negotiations and secure its place within decision-making processes. Makarrata, Garma, and the Bubbling of New Possibilities An Indigenous Voice to Parliament can be seen as the bubbling spring that provides the source for greater growth and further reform. The Uluru Statement from the Heart calls for a three-staged approach comprising of establishing an Indigenous Voice, followed by Treaty, and then Truth-Telling. This sequence has been criticised by some who prioritise Truth and Treaty as the foundation for reform and reconciliation. Their argument is based on the notion that Indigenous Sovereignty must first be acknowledged in Parliament through an agreement-making process and signing of a Treaty. While the Uluru Statement has never lost sight of treaty, the agreement-making process must begin with the acknowledgment of Indigenous people’s inherent right to participate in the conversation. This very basic and foundational right is yet to be acknowledged within Australia’s constitution. The Uluru Statement sets the Voice as its first priority as the Voice establishes the structural foundation on which the conversation pertaining to treaty may take place. It is through the Voice that a Makarrata Commission can be formed and Indigenous and non-Indigenous peoples may “come together after a struggle” – the translation of the word’s Yolngu origins (Gaykamangu; Pearson). Only then may we engage in truth telling and forge new paths towards agreement-making and treaty. This however raises the question as to how a Voice to Parliament may look and what outcomes it aims to achieve. As discussed in the previous section, it is a question that is often distorted by disinformation and conjecture within public, political, and news-media discourses. In order to unpack what a Voice to Parliament may entail, we turn to another Yolngu word, Garma. Garma refers to an epistemic and ontological positioning in which knowledge is attained from a point where differences converge and new insights arise. For Yolngu people, Garma is the place where salt and fresh water intersect within the sea. Fresh and Salt water are the embodiments of two Yolngu clans, the Dhuwa and Yirritja, with Garma referring to the point where the knowledge and laws of each clan come into contact, seeking harmonious balance. When the ebb and flow of the tides are in balance, it causes the water to foam and bubble taking on new form and representing innovative ideas and possibilities. Yolngu embrace this phenomenon as an epistemology that teaches responsibility and obligations towards the care of Country. It acknowledges the autonomy of others and finds a space where all may mutually benefit. When the properties of either water type, or the knowledge belonging a single clan dominates, ecological, social, political, and cosmological balance is overthrown. Raymattja Marika-Munungguritj (5) describes Garma as a dynamic interaction of knowledge traditions. Fresh water from the land, bubbling up in fresh water springs to make waterholes, and salt water from the sea are interacting with each other with the energy of the tide and the energy of the bubbling spring. When the tide is high the water rises to its full. When the tide goes out the water reduces its capacity. In the same way Milngurr ebbs and flows. In this way the Dhuwa and Yirritja sides of Yolngu life work together. And in this way Balanda and Yolngu traditions can work together. There must be balance, if not either one will be stronger and will harm the other. The Ganma Theory is Yirritja, the Milngurr Theory is Dhuwa. Like the current push for constitutional change and its rejection of symbolic reforms, Indigenous peoples have demanded real-action and “not just talk” (Synott “The Uluru statement”). In doing so, they implored that Aboriginal and Torres Strait Islander peoples be involved in all decision-making processes, for they are most knowledgeable of their community’s needs and the most effective methods of service delivery and policy. Indigenous peoples have repeatedly expressed this mandate, which is also legislated under international law through the UN Declaration on the Rights of Indigenous Peoples. Coming together after a struggle does not mean that conflict and disagreement between and amongst Indigenous and non-Indigenous communities will cease. In fact, in alignment with political theories such as agonism and pluralism, coming together within a democratic system necessitates a constructive and responsive embrace of different, competing, and in some cases incommensurable views. A Voice to Parliament will operate in a manner where Indigenous perspectives and truths, as well as disagreements, may be included within negotiations and debates (Larkin & Galloway). Governments and non-Indigenous representatives will no longer speak for or on behalf of Indigenous peoples, for an Indigenous body will enact its own autonomous voice. Indigenous input therefore will not be reduced to reactionary responses and calls for reforms after the damage of mismanagement and policy failure has been caused. Indigenous voices will be permanently documented within parliamentary records and governments forced to respond to the agendas that Indigenous peoples set. Collectively, this amounts to greater participation within the democratic process and facilitates a space where “salt water” and the “bubbling springs” of fresh water may meet, mitigating the risk of harm, and bringing forth new possibilities. Conclusion When salt and fresh water combine during Garma, it begins to take on new form, eventually materialising as foam. Appearing as a singular solid object from afar, foam is but a cluster of interlocking bubbles that gain increased stability and equilibrium through sticking together. When a bubble stands alone, or a person remains within a figurative bubble that is isolated from its surroundings and other ways of knowing, doing, and being, its vulnerabilities and insecurities are exposed. Similarly, when one bubble bursts the collective cluster becomes weaker and unstable. The Uluru Statement from the Heart is a vision conceived and presented by Indigenous peoples in good faith. It offers a path forward for not only Indigenous peoples and their future generations but the entire nation (Synott “Constitutional Reform”). It is a gift and an invitation “to walk with us in a movement of the Australian people for a better future”. Through calling for the establishment of an Indigenous Voice to Parliament, a Makarrata Commission, and seeking Truth, Indigenous advocates for constitutional reform are looking to secure their own foothold and self-determination. The Uluru Statement from the Heart is more than a “thought bubble”, for it is the culmination of Indigenous people’s diverse lived experiences, outlooks, perspectives, and priorities. When the delegates met at Uluru in 2017, the thoughts, experiences, memories, and hopes of Indigenous peoples converged in a manner that created a unified front and collectively called for Voice, Treaty, and Truth. Indigenous people will never cease to pursue self-determination and the best outcomes for their peoples and all Australians. As an offering and gift, the Uluru Statement from the Heart provides the structural foundations needed to achieve this. It just requires governments and the wider public to move beyond their own bubbles and avail themselves of different outlooks and new possibilities. References Anderson, Pat, Megan Davis, and Noel Pearson. “Don’t Silence Our Voice, Minister: Uluru Leaders Condemn Backward Step.” Sydney Morning Herald 20 Oct. 2017. <https://www.smh.com.au/national/don-t-silence-our-voice-minister-uluru-leaders-condemn-backward-step-20191020-p532h0.html>. Appleby, Gabrielle, and Megan Davis. “The Uluru Statement and the Promises of Truth.” Australian Historical Studies 49.4 (2018): 501–9. Appleby, Gabrielle, and Gemma Mckinnon. “Indigenous Recognition: The Uluru Statement.” LSJ: Law Society of NSW Journal 37.36 (2017): 36-39. Appleby, Gabrielle, and Eddie Synot. “A First Nations Voice: Institutionalising Political Listening. Federal Law Review 48.4 (2020): 529-542. Bailes, Morry. “Why the Law Council Backs an Indigenous Voice to Parliament.” InDaily 31 July 2018. <https://indaily.com.au/opinion/2018/07/31/why-the-law-council-backs-an-indigenous-voice-to-parliament/>. Bartlett, John. "Chile’s Largest Indigenous Group Sees Opportunity in a New Constitution." New York Times, 16 Sep. 2020. 19 Nov. 2020 <https://www.nytimes.com/2020/09/16/world/americas/chile-mapuche-constitution.html>. Brennan, Bridget. “Indigenous Leaders Enraged as Advisory Board Referendum is Rejected by Malcolm Turnbull.” ABC News 27 Oct. 2017. <https://www.abc.net.au/news/2017-10-27/indigenous-leaders-enraged-by-pms-referendum-rejection/9090762>. Centre for Governance and Public Policy. OmniPoll Australian Constitutional Values Survey 2017. Griffith University: Centre for Governance and Public Policy, 30 Oct. 2017. <https://news.griffith.edu.au/wp-content/uploads/2017/10/Griffith-University-UNSW-Australian-Constitutional-Values-Survey-Sept-2017-Results-2.pdf>. Davidson, Helen, and Katherine Murphy. “Referendum Council Endorses Uluru Call for Indigenous Voice to Parliament.” The Guardian 17 July 2017. <https://www.theguardian.com/australia-news/2017/jul/17/referendum-council-endorses-uluru-call-indigenous-voice-parliament>. Davis, Megan. “Some Say a Voice to Parliament Is Toothless. But Together Our Voices Are Powerful.” The Guardian 13 Aug. 2020. <https://www.theguardian.com/commentisfree/2020/aug/13/some-say-a-voice-to-parliament-is-toothless-but-together-our-voices-are-powerful>. ———. “No Time for the Meek.” The Monthly Oct. 2019. <https://www.themonthly.com.au/issue/2019/october/1569370776/megan-davis/no-time-meek>. ———. “Moment of Truth.” Quarterly Essay 69 (2019). <https://www.quarterlyessay.com.au/content/correspondence-megan-davis>. ———. “The Long Road to Uluru – Truth before Justice.” Griffith Review 2018. <https://www.griffithreview.com/articles/long-road-uluru-walking-together-truth-before-justice-megan-davis/>. ———. “The Status Quo Ain’t Working: The Uluru Statement from the Heart Is the Blueprint for an Australian Republic.” The Monthly 7 June 2018. <https://www.themonthly.com.au/blog/megan-davis/2018/07/2018/1528335353/status-quo-ain-t-working>. Davis, Megan, Rosalind Dixon, Gabrielle Appleby, and Noel Pearson. “The Uluru Statement.” Bar News: The Journal of the NSW Bar Association Autumn (2018): 41–48. <https://search-informit-com.au.ezproxy.library.uq.edu.au/fullText;dn=20180726000224;res=AGISPT>. Davis, Megan, Cheryl Saunders, Mark McKenna, Shireen Morris, Christopher Mayes, and Maria Giannacopoulos. “The Uluru Statement from Heart, One Year On: Can a First Nations Voice Yet Be Heard?” ABC Religion and Ethics 26 May 2018. <https://www.abc.net.au/religion/the-uluru-statement-from-heart-one-year-on-can-a-first-nations-v/10094678>. De Sousa Santos, Boaventura. Epistemologies of the South: Justice against Epistemicide. Routledge, 2015. Dodson, P. 2012. Recognising Aboriginal and Torres Strait Islander Peoples in the Constitution: Report of the Expert Panel. <http://australianpolitics.com/downloads/issues/indigenous/12-01-16_indigenous-recognition-expert-panel-report.pdf>. Dolar, Sol. “Law Council Explains Government’s Key Misunderstanding of the Uluru Statement.” Australasian Lawyer 5 Nov. 2019. <https://www.thelawyermag.com/au/news/general/law-council-explains-governments-key-misunderstanding-of-the-uluru-statement/208247?m=1>. Fanon, Frantz. The Wretched of the Earth. Macgibbon & Kee, 1965. Fredericks, Bronwyn, and Abraham Bradfield. “We Don’t Want to Go Back to ‘Normal’, When ‘Normal’ Wasn’t Good for Everyone.” Axon: Creative Explorations 10.2 (2020). <https://www.axonjournal.com.au/issue-vol-10-no-2-dec-2020/we-don-t-want-go-back-normal-when-normal-wasn-t-good-everyone>. Ford, Mazoe, and Clare Blumer. “Vote Compass: Most Australians Back Constitutional Recognition for Indigenous Australians.” ABC News 20 May 2016. <https://www.abc.net.au/news/2016-05-20/vote-compass-indigenous-recognition/7428030?nw=0>. Gaykamangu, James, and Danial Terence Kelly. “Ngarra Law: Aboriginal Customary Law from Arnhem Land.” Northern Territory Law Journal 2.4 (2012): 236-248. Grant, Stan. “Three Years on From Uluru, We Must Lift the Blindfolds of Liberalism to Make Progress.” The Conversation 25 May 2020. <https://theconversation.com/three-years-on-from-uluru-we-must-lift-the-blindfolds-of-liberalism-to-make-progress-138930>. Grosfoguel, Ramón. "Decolonizing Post-Colonial Studies and Paradigms of Political Economy: Transmodernity, Decolonial Thinking, and Global Coloniality." Transmodernity 1.1 (2011): 1-36. Hunter, Fergus. “'It's Not Going to Happen': Barnaby Joyce Rejects Push for Aboriginal Body in Constitution.” Sydney Morning Herald 29 May 2017. <https://www.smh.com.au/politics/federal/its-not-going-to-happen-barnaby-joyce-rejects-push-for-aboriginal-body-in-constitution-20170529-gwf5ld.html>. Karp, Paul. “Scott Morrison Claims Indigenous Voice to Parliament Would Be a Third Chamber.” The Guardian, 26 Sep. 2018. <https://www.theguardian.com/australia-news/2018/sep/26/scott-morrison-claims-indigenous-voice-to-parliament-would-be-a-third-chamber>. Koziol, Michael. “Joyce Admits He Was Wrong to Call Indigenous Voice a 'Third Chamber’.” Sydney Morning Herald 18 July 2019. <https://www.smh.com.au/politics/federal/barnaby-joyce-admits-he-was-wrong-to-call-indigenous-voice-a-third-chamber-20190718-p528ki.html>. Larkin, Dani, and Kate Galloway. “Uluru Statement from the Heart: Australian Public Law Pluralism.” Bond Law Review 30.2 (2018): 335–345. Law Council of Australia. “Nothing ‘Un-Australian’ about Human Rights, the Constitution and the Rule of Law.” 14 Aug. 2017. <https://www.lawcouncil.asn.au/media/media-releases/nothing-unaustralian-about-human-rights-the-constitution-and-the-rule-of-law>. Law Council of Australia. “Law Council Supports Calls for Voice to Parliament.” 15 June 2018. <https://www.lawcouncil.asn.au/media/media-releases/law-council-supports-calls-for-voice-to-parliament>. Marika-Munugurritj, Raymattja. Workshops as Teaching Learning Environments. Paper presented to Yirrkala Action Group, 1992. Martin, Wayne AC. Constitutional Law Dinner 2018 Address by Wayne Martin AC Chief Justice of Western Australia. Sydney: Parliament House, 23 Feb. 2018. Mignolo, Walter. Local Histories/Global Designs: Coloniality, Subaltern Knowledges, and Border Thinking. Princeton University Press, 2012. Moreton-Robinson, Aileen. The White Possessive: Property, Power, and Indigenous Sovereignty. U of Minnesota P, 2015. Norman, Heidi. “From Recognition to Reform: The Uluru Statement from the Heart.” Does the Media Fail Aboriginal Political Aspirations? Eds. Amy Thomas, Andrew Jakubowicz, and Heidi Norman. Canberra: Aboriginal Studies Press, 2019. 216–231. Pearson, Luke. “What Is a Makarrata? The Yolngu Word Is More than a Synonym for Treaty.” ABC Radio National 10 Aug. 2017. <https://www.abc.net.au/news/2017-08-10/makarrata-explainer-yolngu-word-more-than-synonym-for-treaty/8790452>. Praiser, Eli. The Filter Bubble: How the New Personalized Web Is Changing What We Read and How We Think. Penguin, 2012. Prime Minister, Attorney General, and Minister for Indigenous Affairs. Response to Referendum Council's Report on Constitutional Recognition. 26 Oct. 2017. <https://www.malcolmturnbull.com.au/media/response-to-referendum-councils-report-on-constitutional-recognition>. Prime Minister of Australia. Radio interview with Fran Kelly. ABC Radio National 26 Sep 2018. <https://www.pm.gov.au/media/radio-interview-fran-kelly-abc-rn>. Reconciliation Australia. 2020 Australian Reconciliation Barometer, 2020. <https://www.reconciliation.org.au/wp-content/uploads/2020/11/australian_reconciliation_barometer_2020_-full-report_web.pdf>. Referendum Council. Referendum Council Final Report, 2017. <https://www.referendumcouncil.org.au/sites/default/files/report_attachments/Referendum_Council_Final_Report.pdf>. Reuters. "Chile Reserves Seats for Indigenous as It Prepares to Rewrite Constitution." Reuters, 16 Dec. 2020. 19 Nov. 2020 <https://www.reuters.com/article/chile-constitution-indigenous-idUSKBN28Q05J>. Rose Gould, Wendy. “Are You in a Social Media Bubble? Here's How to Tell.” NBC News 22 Oct. 2019. <https://www.nbcnews.com/better/lifestyle/problem-social-media-reinforcement-bubbles-what-you-can-do-about-ncna1063896>. Rubenstein, Kim. “Power, Control and Citizenship: The Uluru Statement from the Heart as Active Citizenship.” Bond Law Review 30.1 (2018): 19-29. Synott, Eddie. “The Uluru Statement Showed How to Give First Nations People a Real Voice – Now It’s the Time for Action.” The Conversation 5 Mar. 2019. <https://theconversation.com/the-uluru statement-showed-how-to-give-first-nations-people-a-real-voice-now-its-time-for-action-110707>. ———. “Constitutional Reform Made Easy: How to Achieve the Uluru Statement and a Voice.” The Conversation 7 May 2019. <https://theconversation.com/constitutional-reform-made-easy-how-to-achieve-the-uluru-statement-and-a-first-nations-voice-116141>. Turner, Pat. “The Long Cry of Indigenous Peoples to Be Heard – a Defining Moment in Australia.” The 'Australia and the World' 2020 Annual Lecture. National Press Club of Australia, 30 Sep. 2020. <https://ausi.anu.edu.au/events/australia-and-world-2020-annual-lecture-pat-turner-am>. Wahlquist, Calla. “A Year On, the Key Goal of Uluru Statement Remains Elusive.” The Guardian 26 May 2018. <https://www.theguardian.com/australia-news/2018/may/26/a-year-on-the-key-goal-of-uluru-statement-remains-elusive>. ———. “Barnaby Joyce Criticised for Misinterpreting Proposed Indigenous Voice to Parliament.” The Guardian 29 May 2017. <https://www.theguardian.com/australia-news/2017/may/29/barnaby-joyce-criticised-for-misinterpreting-proposed-indigenous-voice-to-parliament>. ———. “Indigenous Voice Proposal ‘Not Desirable’, Says Turnbull.” The Guardian 26 Oct. 2017. <https://www.theguardian.com/australia-news/2017/oct/26/indigenous-voice-proposal-not-desirable-says-turnbull>. ———. “Turnbull’s Uluru Statement Rejection Is ‘Mean-Spirited Bastardry’ – Legal Expert.” The Guardian 26 Oct. 2017. <https://www.theguardian.com/australia-news/2017/oct/26/turnbulls-uluru-statement-rejection-mean-spirited-bastardry-legal-expert>. Wyatt, Ken. “Indigenous Australia: A New Way of Working.” 15 Sep. 2020. <https://ministers.pmc.gov.au/wyatt/2020/indigenous-australia-new-way-working>. Yunupingu, Galarrwuy. “Rom Watangu: An Indigenous Leader Reflects on a Lifetime Following the Law of the Land.” The Monthly (2016). Zillman, Stephanie. “Indigenous Advisory Body Would Be Supported by Australians, Survey Finds.” ABC News 30 Oct. 2017. <https://www.abc.net.au/news/2017-10-30/australians-would-support-referendum-indigenous-voice-parliament/9101106>.