be reckoned the right of enjoying and defending their lives and liberties; that of acquiring, possessing, and protecting property; in fine, that of seeking and obtaining their safety and happiness." The plaintiffs in the cases of Brom and Bett v. John Ashley and Commonwealth v. Nathaniel Jennison argued that this provision abolished slavery in Massachusetts. The latter case resulted in a "sweeping declaration . . . that the institution of slavery was incompatible with the principles of liberty and legal equality articulated in the new Massachusetts Constitution". The phrase has since been considered a hallmark statement in democratic constitutions and similar human rights instruments, many of which have adopted the phrase or variants thereof. Slavery The contradiction between the claim that "all men are created equal" and the existence of American slavery, including Thomas Jefferson himself owning slaves, attracted comment when the Declaration of Independence was first published. Before final approval, Congress, having made a few alterations to some of the wording, also deleted nearly a fourth of the draft, including a passage criticizing the slave trade. At that time many other members of Congress also owned slaves, which clearly factored into their decision to delete the controversial "anti-slavery" passage. Jefferson believed adding such a passage would dissolve the independence movement. Jefferson argued many cases to free enslaved people. In Howell v. Netherland (April 1770), the most famous of these, Jefferson argued for the freedom of Samuel Howell, a mixed-race indentured servant, but was unsuccessful. In writing the declaration, Jefferson believed the phrase "all men are created equal" to be self-evident, and would ultimately resolve slavery. In 1776, abolitionist Thomas Day wrote: "If there be an object truly ridiculous in nature, it is an American patriot, signing resolutions of independency with the one hand, and with the other brandishing a whip over his affrighted slaves." This phrase is further used in Martin Luther King Jr.'s "I Have a Dream" speech for many of these same reasons. Criticism The phrase "all men are created equal" has received criticism from elitists and traditional conservatives. Richard M. Weaver writing in one of the cornerstone works of traditional conservatism, Ideas Have Consequences (1948), paraphrased a 19th-century writer in writing that "no man was ever created free and no two men [were] ever created equal". He continues: "The comity of peoples in groups large or small rests not upon this chimerical notion of equality but