written by Benjamin Franklin and a speech by the Iroquois chief Canasatego in 1744. Tooker concluded that the documents only indicate that some groups of Iroquois and white settlers realized the advantages of a confederation, and that ultimately there is little evidence to support the idea that eighteenth century colonists were knowledgeable regarding the Iroquois system of governance. What little evidence there is regarding this system indicates chiefs of different tribes were permitted representation in the Iroquois League council, and this ability to represent the tribe was hereditary. The council itself did not practice representative government, and there were no elections; deceased chiefs' successors were selected by the most senior woman within the hereditary lineage in consultation with other women in the clan. Decision making occurred through lengthy discussion and decisions were unanimous, with topics discussed being introduced by a single tribe. Tooker concludes that "...there is virtually no evidence that the framers borrowed from the Iroquois" and that the myth is largely based on a claim made by Iroquois linguist and ethnographer J.N.B. Hewitt which was exaggerated and misinterpreted after his death in 1937. The Aztecs also practiced elections, but the elected officials elected a supreme speaker, not a ruler. However, a contemporary civilisation, Tlaxcallan, along with other Mesoamerican city states, are likely to have practiced collective rule. Rise of democracy in modern national governments Early Modern Era milestones Norman Davies notes that Golden Liberty, the Nobles' Democracy (Rzeczpospolita Szlachecka) arose in the Kingdom of Poland and Polish–Lithuanian Commonwealth. This foreshadowed a democracy of about ten percent of the population of the Commonwealth, consisting of the nobility, who were an electorate for the office of the King. They observed Nihil novi of 1505, Pacta conventa and King Henry's Articles (1573). See also: Szlachta history and political privileges, Sejm of the Kingdom of Poland and the Polish–Lithuanian Commonwealth, Organisation and politics of the Polish–Lithuanian Commonwealth. 1610: The Case of Proclamations in England decided that "the King by his proclamation or other ways cannot change any part of the common law, or statute law, or the customs of the realm" and that "the King hath no prerogative, but that which the law of the land allows him." 1610: Dr. Bonham's Case decided that "in many cases, the common law will control Acts of Parliament". 1619: The Virginia House of Burgesses, the first representative legislative body in the New World, is established.