amounted to a native German tradition of social contract and sovereignty. From 1884 until 1887 he held a professorship at Heidelberg University and he served as professor at the prestigious Friedrich Wilhelm University in Berlin from 1887 until his death in 1921. Influence on the 1900 Civil Code Gierke became a vocal critic of the 1888 draft for a Civil Code to harmonize private law on property, family, and obligations, following the Unification of Germany in 1871. Imperial Germany under Otto von Bismarck consisted of 25 federal states with legal systems based on Roman law, customary law that had developed out of Germanic law, as well as elements of the Napoleonic Code. Gierke opposed the 1888 draft for a new Civil Code because parts of it were based on Roman law. In the course of the academic debate on the draft, Gierke emerged as an outspoken Germanist within the German Historical School of Jurisprudence. Gierke formulated a historic critique of the draft civil code by relying on ancient and medieval German laws that the jurist and folklorist Jacob Grimm had collected on the municipality (Gemeinde) and the Mark currency. Gierke plausibly argued that the legal norms found in feudal contracts, town charters, as well as the letters patent governing merchant and craft guilds amounted to a native Germanic legal tradition. Throughout 1888 and 1889 Gierke criticized the draft civil code in articles that were published in the leading German language economics journal. Its editor Gustav von Schmoller took the view that the norms of the Roman law tradition did not adequately support the business models of a market economy that was industrialized. Gierke further bolstered his critique of the draft civil code by publishing the first of a three-volume opus on German private law (Deutsches Privatrecht) in 1895. The first draft civil code was revised to remove Roman law influences and a further draft was published in 1896. It did not consider the social needs of its times and prompted Gierke to publish his most quoted criticism of the German civil code: "In our private law a drop of social oil has to seep through!". Gierke was especially opinionated when criticizing the tenancy law in the new draft for ignoring the burning issues in modern German cities. He demanded that the German civil code should protect tenants against usury by placing legal restrictions on the freedom of contract. Gierke's demands