The Sociopolitical Problem of the All-volunteer Military: Vietnam


“One of the lessons of Vietnam, which we failed to heed in the Iraq war and the Afghanistan surge, is that before you commit U.S. military forces to aid or assist, it is essential to know what you want them to achieve,” – Kathleen Troia McFarland, Deputy Assistant Secretary of Defense for Public Affairs under President Ronald Regan

From its inception, first in 1940 and subsequently reenacted throughout the Cold War, the Selective Service System was something that every man for several generations was suspect to; however, the system began to fall under heavy scrutiny as military deferments for attending college or other reasons that typically were associated with a person’s wealth began to increase even as the American involvement in Southeast Asia grew.[1] Research in the 1970s, as illustrated by Christian Appy in his book and others, clearly showed that “low-income or disadvantaged backgrounds were more likely to fight in Vietnam than men from middle-and high-income families who could avoid being drafted by going to college or finding a slot in a stateside National Guard unit.”[2] Not surprisingly, Americans caught on to the disparity and began to loudly protest the country’s involvement in the war. Bernard Rostker, a director of the Selective Service System who authored a book about the AVF titled I Want You! The Evolution of the All-Volunteer Force, said that “The American people lost confidence in the draft as a means of raising an army when it ceased to require equal sacrifice from everyone that was eligible to serve.”[3] So why did deferments increase during the Vietnam War, and, more importantly, why did the U.S. involve itself in the war? The typical answer might look like something along these lines, “The U.S. was trying to spread Communism from taking hold in Southeast Asia.” Like most of history, it the answer is much more nuanced and would take much more than a chapter to sparse out, but to understand why Vietnam lead to the creation of the AVF it’s important to understand just how disastrous the campaign was from a foreign policy point of view.

The last draftee in the before the implementation describes the widespread sentiment among the draft eligible men of the Vietnam Era in a USA Today article when he’s quoted as saying, “I just wanted to do my two years and get the hell out.”[4] In the 1960s and early 70s, many viewed the military draft as worse than a prison sentence. To give a good example at the scale of discontent, on Jan. 21, 1977 President Jimmy Carter pardoned more than 100,000 men who had fled the country to avoid the military draft.[5] The situation in Vietnam had been such a disaster that a sitting president pardoned those called to protect and serve their nation. Appy and others insist that the war’s failure was due, essentially, to the disparity between the rich and the poor who were drafted and who received a deferment.

Appy writes about Vietnam that, “The military may never have been truly representative of the general male population, but in the 1960s it was overwhelmingly the domain of the working class.”[6] Though I agree with his assessment in regard to the disparity between the economic class of those served and those who found reasons not to, his statement rings hollow, especially when you consider the statistical analysis earlier in this thesis contradicts his claim here. As Appy emphatically stated earlier in his Working-Class War, every segment of society served during World War II, a little less so in Korea and the tide really turned during Vietnam. However, it is disingenuous to state the military never represented the male population. Appy’s assessment of the fighting force make-up during the war wasn’t exclusive to just the enlisted corps.

“It may well have been the least privileged officer corps of the twentieth century.”[7] It’s interesting to not that Appy says “may well have been” because there is no statistical evidence that truly proves his statement false. He further asserts that, “West Point increasingly attracted military brats and sons of the working class.”[8] While Appy concerns himself with proving his point about the disparity between the working-class and poor vice the well-to-do, he fails to realize that though those attending the prestigious military schools were no longer exclusively the domain of the wealthy it did provide social and economic mobility to the working-class who were able to send their children to West Point, the Naval Academy or the Air Force Academy. Much like the AVF, the growing number of working-class and less wealthy students who began to attend these schools is more of a double-edged sword than an obvious example of his assertion that West Point allowing children of those less economically wealthy is simply an indicator of classism. However, this isn’t to say that Appy and the numerous authors who write about the failure of the Vietnam War are wrong in their assertion that many Administrative and foreign policy blunders were the cause of the failure itself.

But before delving further into the reasons the war failed so spectacularly it’s helpful to understand the state of the military toward the end of the war. From a military perspective, there’s perhaps no better read to understanding the state of the military than Col. Robert D. Heinl, Jr.’s article in the Armed Forces Journal in 1971 titled, “The Collapse of the Armed Forces.” In his opening paragraph Col. Heinl writes, “The Morale, discipline and battleworthiness of the U.S. Armed Forces are, with a few salient exceptions, lower and worse than at anytime in this century and possibly in the history of the United States. By every conceivable indicator, our army that now remains in Vietnam is in a state approaching collapse, with individual units avoiding or having refuse combat, murdering their officers and non-commission officers, drug-ridden, and dispirited where not near mutinous.”[9] As the author indicates, it’s fair to say that the situation in 1971 was no longer one that the U.S. could continue because the military had become a farce. Heinl gives many reasons throughout his article for the collapse of the military in Vietnam, but what he often alludes to, as many before him, was that the failure was in large measure due “bright civilians” who helped the military get into the war, but who turned right around and “are now back on campus writing books about the folly of it all.”[10] Many scholars who study the Vietnam War conclude that there were a multitude of problems that faced the war effort with civilian decision-making being one of the more prominent issues. Jeffery Record, a professor of military strategy at the Air War College in Montgomery, Alabama, wrote in his book Why We Lost in Vietnam that civilian leadership was partly to blame, but that there were a multitude of reasons.

“I contend that, whereas the primary responsibility for the U.S. share of the war’s outcome clearly rests with civilian decision-making authorities – which were, after all, constitutionally and politically responsible – the military’s accountability was significant and cannot and should not be overlooked.”[11] Record continues his argument over the military part in the failure of Vietnam wrote, “The armed forces, he argues, contributed to their own defeat in Vietnam ‘by fighting the war they wanted to fight rather than the one at hand.’”[12] Though many have argued that the military was tied down by inept civilian control, Record contends that it didn’t matter stating “A decisive U.S. military victory in Vietnam … was probably unattainable except via measures – an invasion of North Vietnam or an unrestricted air attack on its population – that were never seriously considered by either civilian or military authorities.”[13]

Record’s argument, though acknowledging multiple factors in the outcome of the Vietnam War, places a large burden of guilt with the military, which is a view that isn’t as popular with most scholars and certainly any Vietnam veteran. His argument about no possible solutions rings hollow when you consider he said there was no viable military route, and then subsequently listing two viable military options. As mentioned earlier in this thesis, scholars and the layperson alike largely blame civilian leadership for the failure in Vietnam.

Defense Secretary Robert S. McNamara, the top civilian leadership next to the president during Vietnam, wrote a book in the mid-1990s that criticized him and other civilian leaders for being responsible for the debacle. So, though Record makes a valid argument for the military’s mismanagement of the war being most to blame, it’s hard to rebuke the civilian who presided over the military during the war. McNamara in his memoir wrote throughout that the war should have been avoided and that there were many instances when it could have been.[14] McNamara claims that he and President Lyndon B. Johnson’s other advisors failed in their duties by not ensuring Vietnam never became an issue.[15] Thomas Lippman in his review of McNamara’s memoir wrote, “Even when he and Johnson’s other aides knew that their Vietnam strategy had little chance of success, according to McNamara, they pressed ahead with it, ravaging a beautiful country and sending young Americans to their deaths year after year, because they had not other plan.”[16] So, McNamara admitted it was civilian leadership in Vietnam that lost the war because it shouldn’t have been fought in the first place. But, as Appy alluded to in Working-Class War, the American public and especially those eligible for the draft were outraged by the prospect of serving a war for the elite. In this case, a team of super geniuses who used statistics and their college educations to use working-class and poor as pawns in a game of chess with consequences. The consequences of that game was 58, 148 killed in action, 75,000 severely wounded and a civilian casualty toll that is said to be in the millions. So, having a more firm idea of who pulled the strategic strings, it’s just as important to understand what lead to the U.S. involvement.

Most people in the United States don’t understand that the country’s involvement in Vietnam actually began in the 1950s with President Dwight D. Eisenhower.[17] Vietnam had split into two different countries with the North declaring itself a communist nation, and by the logic of the current Administration it was paramount to combat communism wherever it threatened a democratic nation such as South Vietnam. The idea was that “the rest of Southeast Asia would fall like dominoes,” if communism in North Vietnam proved successful.[18] When John F. Kennedy became president in 1961 he was determined to help South Vietnam become a successful democracy and not let it fall into the hands of the communist North Vietnamese.[19] What eventually lead to what the Vietnamese called the “War Against the Americans to Save the Nation,” was in large part “a manifestation of the Cold War between the United States and the Soviet Union and their respective allies.”[20] In short, it was a proxy war.

On May 7, 1954, the Viet Minh overran the French headquarters in Dien Bien Phu after the battle for Northern Vietnam lasted 55 days.[21] The French suffered 3,000 killed in action along with roughly 8,000 wounded, and though the Viet Minh suffered much higher casualties and deaths, the French resolve to continue colonizing Vietnam finally faltered and a communist North Vietnam was born.[22] North Vietnam defeated the French colonial empire in 1954 and turned its sights on unifying the North and South under a communist government that mirrored the governments of the Soviet Union and China.[23] However, South Vietnam wanted to continue to represent a nation more aligned with the Western Powers and their ideals of democracy. American military advisors had operated in South Vietnam beginning in the early 1950s, but the ramp up of American military personnel, beginning with advisors, didn’t begin in earnest until after President Kennedy took office in 1961.[24] However, the height of military involvement in Vietnam didn’t reach its peak until 1969 where there were more than a half-million service men and women serving in the Southeast Asian country.[25]

However, the United States employed only military advisors until 1965, which is when combat units started showing up in Vietnam. So, while the United States began to ramp up their effort to defend South Vietnam and prevent the takeover of the nation by the North, the U.S.S.R and China began to increase the amount of money, supplies and military advisors into North Vietnam.[26] Unlike the United States, the political turmoil in the Soviet Union and China weren’t on par with the domestic turmoil that was prevalent throughout 1960s American, and, ultimately, the cost of the war and rising causality count proved too much for the average American and their politicians to endure.[27] So, in 1973 the last U.S. combat units fought their last fight and were withdrawn from Vietnam.[28] In 1975, South Vietnam fell to an invasion from the North and Vietnam became unified under communist rule.[29] But why was the U.S. involved in a Southeast Asian country that some claimed had no strategic importance? It’s easy to write out the dates and highlight the important details, but it’s less certain as to why the American foreign policy lead to U.S. troops on the ground in the swamps, rivers and valleys of Vietnam.

The reason the United States involved itself in Vietnam was due to the Cold War and policy created to contain the threat of communism. The Cold War is often considered to have begun at the conclusion of World War II as Europe and Asia stood in ruins and the United States and the Soviet Union were left as the beckons of two completely different forms of government. The United States developed The Marshall Plan to curb the threat of communism by utilizing a policy of containment. The plan was developed by George Marshall who served as the chief of staff of the Army in 1939 at the onset of World War II, and he eventually became President Harry Truman’s secretary of state.[30] The Marshall Plan was essentially an economic recovery plan for Europe, which earned Marshall the Nobel Peace Prize in 1953.[31] Debatably “the most respected soldier in American history,” after George Washington, Marshall never led troops into battle but still remains one of the more decorated soldiers in American military history.[32] Marshall didn’t have the battlefield victories of the Pattons, Eisenhowers or Chesty Pullers, but what he represented was the ability to act more as a diplomat and policy maker, hallmarks of a great modern military officer.[33] However, though he received a Nobel Peace Prize for his efforts, it’s important to remember that the Marshall Plan wasn’t an altruistic attempt to rebuild Europe.

Though initially hailed by the international community as $10.25 billion humanitarian effort, the Marshall Plan was more an effort to prevent communism from spreading throughout Europe, and, eventually, throughout Asia. The Soviet Union began building its Iron Curtain by absorbing the smaller nations of Estonia, Latvia and Lithuania as the Red Army marched toward Germany.[34] By the end of 1945, the Soviet Union had absorbed Romania and Bulgaria, but more importantly the U.S.S.R. violated the Yalta promise and absorbed Poland as well by rigging the elections.[35] Soon thereafter, the Soviet Union also absorbed Hungary, Czechoslovakia and, essentially, Yugoslavia.[36] President Harry Truman and his Administration began desperately trying to figure out how to stop the Soviet Union from taking complete control over all of Europe. Shortly after World War II had concluded the possibility of all of Germany and even France being taken over by the Soviet Union remained critically high.[37] In fact, East Germany had already fallen and it looked for a time that Greece and Turkey would also join the Iron Curtain, but the Administration acted and sent roughly $400 million in aide to the countries, which eventually, with the help of the aide, able to fend off communist guerilla attempts at a take over.[38] The American policy of containment during the Cold War was born.

A State Department official named George Kennan is credited with proposing a Policy of Containment.[39] The argument made was that the American people were tired of war after the deadliest war in human history had just concluded, so the prospect of sending American troops into Europe to fend off the Soviet Red Army was off the table.[40] “But in places where communism threatened to expand, American aid might prevent a takeover.”[41] Truman’s Administration became instant advocates for the policy, which soon became the Truman Doctrine, and saw initial success with Turkey and Greece.

On June 5, 1947, Secretary of State George Marshall rolled out the European Recovery Program, which leant more than $10 billion in aide to help Europe rebuild.[42] The program was the U.S. attempt at assuring no further European nations fell to the influence of the Soviet Union. But, the U.S. as previously mentioned had no intention of provoking a military conflict between the two nations and thus providing monetary help in the guise of aid to ensure nations such as Turkey, Greece, Western Germany and France didn’t become communist nations. Initially, the U.S. even offered this aid to the Eastern European countries that had fallen under Stalin’s rule.[43] The plan was initially considered “an economic miracle in Western Europe.”[44] Within just four years, the Western European nations that received aid from the U.S. were producing more than they were pre-World War II.[45] None of the Western European nations that had been on the brink of succumbing to communism became a communist nation. “The Marshall Plan served as the economic and political foundation for the Western alliance that waged the Cold War.”[46] While the plan initially saw only U.S. foreign aid involve economic help, as communism began to spread from Russia and Europe to Asia the U.S. found itself in a situation where it was now using military force in order to enforce the Policy of Containment and Marshall’s Plan.

Diane Kunz, a historian who taught diplomatic history at Yale, argues in her article for Foreign Affairs that the Policy of Containment and the Marshall Plan, which can often be seen as one and the same, will go down as a success due to the U.S. “winning” the Cold War. However, Kunz and David J. Dallin, a Soviet Union scholar, in his contemporary review of the policy in 1952 at the height of the Cold War, saw the policy as a mixed bag. From a more modern perspective the U.S. achieved their aim when the Soviet Union collapsed and the Berlin Wall fell. But, as Dallin noted in his article “that help must be given to Europe has become an almost universal precept in this country; on the other hand, there is a growing disappointment with Europe’s insufficient efforts and anti-American sentiments. Finally, there is the juxtaposition of Europe and the Far East: shall we concentrate on Europe and try to solve the Far Eastern conflict in a compromise, or shall we pay more attention and send more men and supplies to the sore spot of international affairs, Korean and Japan?”[47] As Dallin and to some extent Kunz allude, the initially success the United States had in containing the communist threat in Western Europe wasn’t always as successful in Eastern Asia.

On June 25, 1950, roughly 75,000 North Korean soldiers streamed across the 38th parallel, separating communist North from the U.S.-backed democratic South, sparking the first military action of the Cold War.[48] By July of 1950, the United States military had entered the war on South Korea’s behalf. “It was a war against the forces of international communism itself.”[49] For three years the Soviet and Chinese-backed North Korea faced off against the U.S.-backed South Korea, but an armistice was reached in July of 1953.[50] Though roughly 5 million soldiers and civilians died during the three years of conflict, the war was largely seen as a success for the Americans because they had contained communism to North Korea. However, the U.S. belief that “that any communist victory anywhere would threaten their vital interests.”[51] Though initially, and for many historically, successful, the U.S. Policy of Containment or the Truman Doctrine met it’s match in the jungles of Vietnam.

Sometimes referred to as the “Domino Theory,” the United States Policy of Containment operated under the belief that if one nation fell to communism then the neighboring countries would soon follow suite, which was the justification the Administrations beginning with Eisenhower held in regard to Vietnam.[52] “By early 1950, makers of U.S. foreign policy had firmly embraced the idea that the fall of Indochina to communism would lead rapidly to the collapse of other nations in Southeast Asia.”[53] Eisenhower believed that “The possible consequences of the loss [of Indochina] are just incalculable to the free world.”[54] The worry wasn’t just that Vietnam’s neighbors Laos and Cambodia, which in fact did adopt communist regimes after Vietnam was unified under a communist government, but that many Asian countries to include Japan, the Philippines, Indonesia and even more impossibly Australia an New Zealand.[55]

As mentioned earlier, it was Eisenhower who first put South Vietnam on a pedestal. The President and his Administration helped form the Southeast Asia Treaty Organization to combat communist threats.[56] However, despite Eisenhower’s dire warnings it wasn’t until President John F. Kennedy that the American presence in South Vietnam really began to grow by sending advisors to Southeast Asia. Kennedy sent resources to Vietnam, to include troops, to ensure the Ngo Dinh Diem regime stayed in power despite domestic opposition to Diem in Vietnam.[57] Diem and Kennedy were assassinated within weeks of each other, but Kennedy’s successor Lyndon B. Johnson affirmed the U.S. Policy of Containment and belief in the domino theory. Johnson eventually increased the presence of several thousands advisors during Kennedy’s reign to a half-million serve men and women within five years of taking office.[58] However, as those remotely interested in history know, the U.S. effort in Vietnam was met with huge domestic opposition, controversy over the military draft and, eventually, the service members serving in Vietnam began to degrade in morale and ethical behavior. Saigon fell in 1975, and Vietnam was united as a communist nation. However, besides the country’s immediate neighbors, communism never took hold the way the Administrations from Eisenhower to Nixon believed.

Though some revisionist historians assert that Vietnam was a success, Vietnam was indeed a spectacular failure. It’s been argued that since the U.S. defeated the Soviet Union in the Cold War that Vietnam was more like a lost battle, but democracy won out over communism, so all should be forgiven. However, to sum up the reality of the Vietnam War it’s worth noting the exchange between Army Col. Harry G. Summers, Jr., who said “You know, you never beat us on the battlefield,” to which Col. Tu responded, “That may be so, but it is also irrelevant.”[59] Summers was on a mission from the U.S. to try to return missing Americans in 1973 when he had his famous encounter.[60] Though Summers was widely regarded as an intellectual within the Army, the Vietnamese colonel’s retort captured the true nature of the war. The United States government had failed to realize that the North Vietnamese weren’t merely Stalin’s puppets, but instead, Ho Chi Minh and his movement wanted a true revolution in the form of communism.[61] It’s been often said that the Vietnamese simply wanted in more than the American people did.[62] To emphasize Vietnam’s failures it’s important to understand the fundamental derailing of one of he country’s most prized institutions – the military – an institution that today is often cited as the most respected, which has been partly attributed to the AVF. Though, it’s important to note, and it’ll be discussed in more detail later, that the military’s high approval ratings are due largely to the publics malaise toward civic and military obligations, which in turn automatically places those willing to sacrifice for the nation on a pedestal. But, right before the fall of Saigon, the military was anything but the professional and honorable force it is considered today.

The war had spun into such chaos that toward the end of the war it was estimated that 109 fragging incidents took place in Vietnam.[63] By 1971, there was an estimated one fragging incident a week.[64] In fact, the term fragging wasn’t even invented until the Vietnam War to describe the utter lack of discipline and breakdown of the fabric of Army values that lead to Soldiers committing one of the most heinous acts – the murder of their own commanders.[65] “Fragging – derived from the hard-to-trace weapon of choice in such attacks, the fragmentation grenade – has varying definitions, from the killing of any superior to the murder of a Soldier’s direct commander to avoid combat.”[66]

By contrast, only one Soldier who deployed to Iraq in support of Operation Iraqi Freedom has been charged for fragging.[67] In fact, at the time of his arraignment in 2007, Staff Sgt. Alberto B. Martinez of the New York Army National Guard it was argued shouldn’t had been tried for the crime because his motives were unclear.[68] Admittedly, one of the reasons for the lack of fragging incidents in recent American wars has been attributed to the All-volunteer Military.[69] However, in Vietnam, “only the Marines – who have made news this year by their hard line against indiscipline and general permissiveness – seem with their expected staunchness and tough tradition, to be weathering the storm.”[70] But, Marines have, typically, never truly been representative of the nation as whole. Their small numbers allow them to be more selective and to recruit from a higher-caliber citizen, which in turn produces a higher-caliber Soldier or Marine. However, the Army as a much larger force had always, prior to the creation of the AVF in 1973, been more representative of the nation. Therefore, by highlighting the almost complete disintegration of Soldierly virtue toward the end of the war, an accurate assumption can be made about how the American public viewed and acted toward the war. “It is a truism that national armies closely reflect societies from which they have been raised. It would be strange indeed if the Armed Forces did not today mirror the agonizing divisions and social traumas of American society, and of course they do.”[71] America was changing, and the civilian authorities who presided over the military were determined that the military structure would also change.

[1] Moody

[2] Ibid

[3] Ibid

[4] Ibid

[5] History.com Staff, “President Carter Pardons Draft Dodgers,” History.com (2009) accessed Aug. 4, 2016 from http://www.history.com/this-day-in-history/president-carter-pardons-draft-dodgers

[6] Appy, pp. 116

[7] Ibid, pp. 122

[8] Ibid, pp.123

[9] Heinl, Jr., Robert, “The Collapse of the Armed Forces,” Armed Forces Journal (June 7, 1971)

[10] Ibid

[11] Record, Jeffery, Why We Lost in Vietnam (Annapolis, MD: Naval Institute, 1998)

[12] Record, Jeffery, Why We Lost in Vietnam. Reviewed by Joseph L. Galloway for The New York Times (September 1998)

[13] Ibid

[14] Lippman, Thomas, “McNamara Takes Much of Blame for Vietnam,” The Washington Post (April 9, 1995)

[15] Ibid

[16] Ibid

[17] McLaughlin, Katie, “The Vietnam War: 5 things you might not know,” CNN (Aug. 25, 2014)

[18] Ibid

[19] Ibid

[20] Encyclopædia Britannica Online, s. v. “Vietnam War”, accessed August 10, 2016, https://www.britannica.com/event/Vietnam-War.

[21] Battlefield: Vietnam. PBS accessed Aug. 13, 2016 from http://www.pbs.org/battlefieldvietnam/timeline/

[22] Ibid

[23] Ibid

[24] Ibid

[25] Ibid

[26] Ibid

[27] Ibid

[28] Ibid

[29] Ibid

[30] History.com Staff, “George C. Marshall,” History.com (2009). Accessed Aug. 13, 2016 from http://www.history.com/topics/george-c-marshall

[31] Ibid

[32] Ibid

[33] Ibid

[34] ushistory.org, “Containment and the Marshall Plan,” U.S. History Online Textbook (2016) accessed Aug. 13, 2016 from http://www.ushistory.org/us/52c.asp

[35] Ibid

[36] Ibid

[37] Ibid

[38] Ibid

[39] Ibid

[40] Ibid

[41] Ibid

[42] Ibid

[43] Ibid

[44] Ibid

[45] Ibid

[46] Kunz, Diane B. “The Marshall Plan Reconsidered: A Complex of Motives,” Foreign Affairs, vol. 76, no. 3 (May-June, 1997), pp. 162

[47] Dallin, David J. “Policy of Containment,” The Annals of the American Academy of Political and Social Science, vol. 283, Meaning of the 1952 Presidential Election (Sept., 1952), pp. 22

[48] History.com Staff, “Korean War,” History.com (2009) accessed Aug. 14, 2016 from http://www.history.com/topics/korean-war

[49] Ibid

[50] Ibid

[51] Park, Hong-Kyu, “American Involvement in the Korean War,” The History Teacher, vol. 16, no. 2 (Feb. 1983), pp. 249

[52] History.com Staff, “Domino Theory,” History.com (2009) accessed Aug. 25, 2016 from http://www.history.com/topics/cold-war/domino-theory

[53] Ibid

[54] Ibid

[55] Ibid

[56] Ibid

[57] Ibid

[58] Ibid

[59] Summers, Harry G. “Interview with General Frederick C. Weyland About the American Troops Who Fought in the Vietnam War,” History.net (June 12, 2006) accessed Aug. 15, 2016 from http://www.historynet.com/interview-with-general-frederick-c-weyand-about-the-american-troops-who-fought-in-the-vietnam-war.htm

[60] Ibid

[61] History.com Staff, “Domino Theory”

[62] Ibid

[63] Heinl, Jr., “The Collapse of the Armed Forces”

[64] Ibid

[65] Associated Press, “Fragging Rare in Iraq, Afghanistan,” Military.com (Oct. 18, 2007) accessed Aug. 16, 2016 from http://www.military.com/NewsContent/0,13319,153101,00.html?ESRC=iraq.RSS

[66] Ibid

[67] Ibid

[68] Ibid

[69] Ibid

[70] Heinl, Jr.

[71] Ibid

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