jury submitted in December 1636. Yet Connacht plantation did not go ahead. Wentworth over-reached himself, and English political issues led to him being recalled in 1639. D'Arcy was again elected to the Irish House of Commons in 1641 and it was there that his reputation reached another level. D'Arcy's Argument During a conference held in the dining room of Dublin Castle on 9 June 1641, D'Arcy delivered his famous Argument. Published in 1643 and reprinted in 1764, it was the first forceful and detailed statement of the rule of law in Ireland, articulating an effective constitutional position for her as England's colonial country. He was followed by William Molyneux that "no parliament but an Irish one can properly legislate for Ireland", which is the central summation of his work. In 1961, the American constitutional expert C.H. McIlwain said of Argument that it,"constitutes the first definite statement of the central point of the American opposition more than a century later. Patrick Darcy deserves a place in American constitutional history." The format of the 142-page Argument comprises a series of legal questions on the powers of the Parliament of Ireland in 1640–41. It refers to and suggests the extent to which the parliament's general self-governing powers are superior to all ad-hoc (and possible illegal, unlawful or illicit) arbitrary decisions by judges and royal officials in the Kingdom of Ireland. The relevant text nearest to the subject of Irish self-government is on page 130: Whither [i.e. whether] the Subjects of this kingdome bee a free people, and to be governed onely by the Common-lawes of England, and statutes of force in this kingdome. The subjects of this his Majesties kingdome of Ireland, are a free people, and to be governed one∣ly according to the Common-law of England, and Statutes made & established by Parliament in this kingdome of Ireland, and according to the lawfull customes used in the same. D'Arcy and Confederate Ireland 1642–1649 The outbreak of the Irish Rebellion of 1641 put the Old English into alliance with the Gaelic Irish. Returning to Galway in February 1642, D'Arcy and Martyn seem to have tried at first to work out a common policy that would not lead them into outright rebellion. But events soon took a course of their own leaving D'Arcy and his friends no option but to lead the townspeople instead of letting chaos loose. Matters were not helped by the