the eponymous philosopher's condemnation of the same. Becker did address the multivalent consequences of "free trade" ideas in history, but decidedly argued that these ideas ran counter to the aspirations of representative democracy. In his 1919 free trade in ideas dissent for Abrams v. United States, at the height of the First Red Scare, Oliver Wendell Holmes, Jr., held that a dichotomous understanding of Progressive Era "negative freedom," between civil liberties in society on the one hand, and degrees of "free trade" in private as well as public economic sectors on the other, could still potentially result in the latter branch shaping, and even subsuming, the former branch. After the Holmes dissent, Becker began to study conflicts over natural rights philosophy in United States history. James Ceaser argues that Becker ultimately found "natural rights" to be "meaningless" in the "modern world." In his 1922 The Declaration of Independence: A Study in the History of Political Ideas, for example, Becker concluded that debates over establishing "authority" in "essential natural rights," while crucial for the "emotional inspiration" and "justification" of the "Founding," nevertheless had been rendered "meaningless" by attempts to enumerate seemingly countless natural rights ("What were they? Was there any sure way of finding out?") and by the "harsh realities of the modern world"—the "trend of action," "trenchant scientific criticism," and "temporary hypotheses" inherent in nationalism, industrialism, and an "aggressive imperialism." Given that Becker did not examine federalism, he did not fully explicate the legal history of the Ninth Amendment in addressing the former dilemma. Becker continued criticizing natural rights philosophy revivals in his 1932 The Heavenly City of the Eighteenth-Century Philosophers, but both implicitly and explicitly indicated that such ideas could not be effaced from polities past, present, and future. Becker subsequently turned to examining enumerated natural rights as civil liberties within the changes and continuities that underpinned the Atlantic history of his previous Progressive Era social liberalism and, at the end of the interwar period, his endorsement of a United States variant of early twentieth-century social democracy. Alexander Jacobs contends that, in Becker's later writings, such as the 1936-41 essays collected in New Liberties for Old and the 1944-45 "Freedom and Responsibility in the American Way of Life ," Becker found " 'democracy' " to be the preferred mode of government if " 'traditional democratic ideology' " sought to "secure these values with a 'minimum of coercion.' " But