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Strong interests, passions, and prejudices may degenerate into obstinacy, perverseness, or disingenuity. In Federalist 37, Madison says, In some, it has been too evident from their own publications, that they have scanned the proposed Constitution, not only with a predisposition to censure, but with a predetermination to condemn. On the other hand, (The Federalist Papers) solicit the attention of those only, who add to a sincere zeal for the happiness of their country, a temper favorable to a just estimate of the means of promoting it

Those falls can be largely attributed to further setbacks regarding litigation from private individuals and the Federal Government

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