the Frame of 1701 required all claims relating to properties to be directed to ordinary courts of justice, and thus neutralized the power of the Board of Propriety, the center of proprietary land administration. Another significant concession in the Frame of 1701 was that the Lower Counties, or Territories, are permitted to establish their home rules. In 1705, the Territories took advantage of this provision and set up their own assembly. Although Penn steadfastly refused to approve the Frame of 1696, he yielded to the Frame of 1701, which was different from the Frame of 1696 only in details. Some writers regarded his concession as a sign of his losing control over the colony. He admitted that he approved the Frame of 1701 only because he saw a majority had been convinced by David Lloyd that it was a form of government "nearer to English methods, which they called for so often." Also, in anticipation of the possibility that his rights of government in the colony might be stripped of by the English Parliament, a more democratic governmental structure might provide the Quakers in the colony with a shelter from an arbitrary royal governor. The Frame of 1701 remained the governing constitutional document in Pennsylvania in the following seventy-five years until the Pennsylvania Constitution of 1776 replaced it. Characteristics The establishment of Pennsylvania may be the most successful effort of Quakers in colonizing in America. Penn's close relationship with the Crown significantly contributed to the success. His ruling over Pennsylvania was largely based on the royal charter, which curbed his political experiment and led to a hierarchical governmental structure. The compromise diluted the liberalism in the constitution of government, which Penn and his contemporary political thinkers had been promoting. However, the human rights provisions in the Frame of Government successfully reflected certain important values inherent in human thinking prevailing in the colony and Quakerism and contributed to the development of constitutionalism in America. Legacy and reception The Frame of Government has been seen as a significant move towards democracy in America. The political philosophy expounded in the preface to the Frame of 1682 has often been cited and quoted. Voltaire applauded Penn's efforts, saying he might "with reason, boast of having brought down upon earth the Golden Age, which in all probability, never had any real existence but in his dominions." The Supreme Court of the United States quoted the