Introduction: The Strange Americanism of Canadian Libertarians
Since 2011 when I attended one of the Institute for Liberal Studies’ Liberty Summer Seminars (LSS), I’ve noticed that Canadian libertarians often demonstrate a strange American streak, and that their understanding of constitutions and systems of government are steeped in quintessentially American attitudes. In my view, too many Canadian libertarians discount and dismiss the virtues of parliamentary government because of their anti-monarchism.
For instance, the libertarians at LSS kept banging on about William Lyon Mackenzie and the “Republic of Canada” which he proclaimed on Navy Island, Ontario in 1837; they held it up as some kind of ideal country and system of government and thereby failed to take into account the true achievement of the Rebellions of 1837, namely, convincing Lord Durham and the British government to implement Responsible Government in British North America in order to encourage harmony and prevent further civil strife. Mackenzie even created a new flag for his non-existent polity, “The Republic of Canada,” whose top half contained two American stars and whose bottom half bore the word “Liberty.” But they were merely upholding the idea of the Republic of Canada out of a reflexive anti-monarchism, ironically without at all considering how revolution most often destroys liberty and the rule of law. In reality, of course, this fake polity left behind no public records, and no written constitution that we could judge on its own merits.
As I concluded at the time, “Writing “Liberty” on the flag and advocating for the violent overthrow of the Crown through armed rebellion in favour of a republic do not automatically secure liberty.” I would add, it certainly also does not secure the rule of law.
Over the years, I encountered other bizarre arguments from self-described libertarians which seem to spring forth from a general disdain for parliamentary Responsible Government and constitutional monarchy. Some examples of this are Jesse Kline’s column in the National Post, “The Best Legislature Is A Prorogued Legislature,” and Anthony Furey’s “Canada Needs a Debt Ceiling” of the Fort Erie Times, along with an amusing conversation which I had with a prominent libertarian at the Macdonald-Laurier Institute’s annual February soiree in 2013. This is ironic because parliamentary government and constitutional monarchy better secure liberty than do presidential systems.
Prolonged Prorogations and Part-Time Legislatures
Kline wrote his piece during the intersession of McGuinty’s tactical prorogation, on 22 October 2012, and argues, from a libertarian viewpoint, in favour of prorogation and subsequent long intersessions, in which the legislative assembly does not meet and the legislature passes no laws, on the grounds that they prevent the State from interfering in the economy and curtailing individual liberty with new laws.
Kline does also acknowledge that the executive can take action on its own.
There are few pieces of business that actually require the legislature’s immediate attention. Sure there are laws that need to be updated and modernized as the world changes around us, but the government doesn’t shut down when parliament is prorogued. The executive continues to function; public servants continue providing services to the public; and the Premier and his Cabinet are not prevented from making decisions and reacting to current events.
But he does not take into account the overall structure of the regulatory state and the fact that the executive alone possesses the authority to pass secondary legislation, i.e., regulations, through Orders-in-Council and that secondary legislation promulgated under existing statutes could potentially restrict individual liberty or interfere with the free market almost or just as extensively as new statute laws.
Legislatures, on the other hand, pump out thousands of pages of legislation that make it harder for people to live their lives and make a living, while saddling future generations with billions of dollars worth of debt.
It would be nice if we could put some constitutional limits on how long legislatures are allowed to sit, to at least slow down the encroachment of big government into every aspect of our lives. Until then, I’ll take prorogation over question period any day.
First, the executive could also pump out thousands of pages of secondary legislation just as legislatures could produce thousands of pages of primary legislation. Primary legislation alone makes for a bad measure of the State’s total activity, whether you look at this from a progressive point of view and see it as generally good and promoting equality, or from a libertarian point of view and see most of it as bad and an infringement on individual liberty. Second, Kline misses the most crucial point of all: it is not the legislative assembly acting alone or independently which imposes annual budget deficits and accumulated debt on us, but rather, the legislative assembly which approves or rejects the bad fiscal policies that the Ministry introduces through money bills and the Royal Recommendation. The tandem formed between the principles that money bills be introduced in the lower house (which, admittedly, only applies to Ottawa at this stage since none of the provinces any longer have legislative councils), where the people’s elected representations sit, and the Royal Recommendation, through which Ministers — most or all of them are also elected MPs in that same lower house (depending on whether we’re looking at Ottawa or one of the provincial capitals) — take responsibility for all money bills, secures Responsible Government. Third, reverting back to part-time legislatures would not in and of itself prevent bad fiscal policy and the accumulation of deficits and debt. Whether the legislature sits three months every two years or nine months every year, it must still pass supply, and the Ministry must still take responsibility for it. A part-time legislature could still pass deficits, just as a full-time legislature can pass balanced budgets.
In terms of the policies that Kline advocates — namely, a responsible fiscal policy — I wholeheartedly agree and pine for the old 1990s Consensus on that issue. But we must still understand the system of government in which we operate, and the proper protest against deficits and debt is to elect a majority of MPs from a party which would never stand for these bad policies and mortgaging our debt to our children and grandchildren’s generations. Proroguing the legislature for long intersessions or making it part-time would do nothing to abolish bad fiscal policy but merely postpone a profligate government’s tabling of a bad budget.
The Permanent Dissolution
At the Third Annual Macdonald-Laurier Institute’s Soiree in February 2013, A friend and I were discussing our column on McGuinty’s prorogation, as well as his subsequent resignation and the transition of power to the Wynne ministry which had happened two days before. A prominent libertarian inserted himself into the conversation and started talking along similar lines to Kline’s article, which, presumably, he had read a few weeks before. Like Kline, he explained that he liked the long prorogation because it had prevented the legislature from meeting and adding more reams of burdensome statute laws which derogate from liberty. I think that I mentioned something about how the Ministry can still pass new secondary legislation — regulations, under delegated statutory authority — through orders-in-council, even if the prorogued legislature cannot pass new primary legislation. He then proclaimed, “I’m waiting for the permanent dissolution” — or perhaps, judging by how he intoned the phrase as if referring to an existing anarchist or anarcho-libertarian concept, I should render it in capital letters as in, “I’m waiting for The Permanent Dissolution.” At this point, my friend wisely walked away, but I remained, perhaps out of inertia, the most powerful force in politics. Political theorist William Edward Hall explained the concept of “the permanent dissolution of the State” — closely related to the succession of states — in his Treatise on International Law:
Even when internal change takes the form of temporary dissolution, so that the state, either from social anarchy or local disruption, is momentarily unable to fulfil its international duties, personal identity remains unaffected; it is only lost when the permanent dissolution of the state is proved by the erection of fresh states, or by the continuance of anarchy so prolonged as to render reconstitution impossible or in a very high degree improbable.
As if there could be justice and liberty in the State of Nature! History shows that Hobbes is right and Rousseau is wrong; monstrous tyrants always emerge from such chaos. However, judging by the context and his subsequent statements, this prominent self-described libertarian was not referring to the permanent dissolution of Ontario or Canada as polities, but instead to the permanent dissolution of the Legislature of Ontario or the Parliament of Canada. Of course, permanently dissolving a legislature would be wholly unconstitutional and ultra vires of section 5 of the Constitution Act, 1982. But his remark was only semi-facetious; it contained a germ of wistful, aspirational truth. I replied that permanently dissolving the legislatures or parliament, or the legislative branch more broadly, would not in and of itself also dissolve the Cabinets, or the executive branch more broadly, because the Queen’s representatives appoint Ministers of the Crown, who, in turn, derive their executive authority and station from the Crown and not from the legislatures. The executive government, in other words, would remain in place. So much for that idea then.
Responsible Government Is About the Money
More bizarre still than advocating for permanent prorogations and dissolutions is Anthony Furey’s suggestion that Canada adopt a debt ceiling. His article, “Canada Needs A Debt Ceiling,” coincided with the American Debt Ceiling Crisis of 2013. Furey even summarized the American situation inaccurately:
This is all a lead up to the Oct. 17 deadline to raise the debt ceiling. America will default if the increase isn’t authorized. This is a much bigger deal than a shutdown.
But here’s the truth you’re not being told. Raising the debt ceiling isn’t the only option. As anyone who calculates the family budget will tell you, not accumulating so much debt is the other one. And it’s the only solution sustainable over the long run.
The first paragraph was true, but the second is not quite right. As the US Treasury Department explains, the debt ceiling refers to “the total amount of money that the United States government is authorized to borrow to meet its existing legal obligations”, which means that raising the debt ceiling does not in and of itself allows Congress to assume new debts. In other words, “The debt limit does not authorize new spending commitments.” Congress would have to authorize new expenditures through separate appropriations bills. Perhaps one could say, more precisely, that the general trend of raising the debt ceiling allows for accumulating more debt.
Furey acknowledges that a debt ceiling under Canada’s parliament system would do nothing to mandate better fiscal policy and prevent the accumulation of more debt, so perhaps we should attribute the headline “Canada Needs a Debt Ceiling” to the newspaper editors rather than to Furey himself; it often happens that the editors, not the columnists, choose the headline:
What about us? Does Canada have a debt-ceiling limit?
Not really. MPs pass budget implementation bills that authorize spending. Invariably that spending goes up. Last year we crossed the $600-billion debt mark for the first time. It was around $475 billion when Stephen Harper was elected prime minister. […]
Because of our structure of government, adding to our debt can happen almost as an afterthought.
Down south, President Barack Obama has to get funding authorized outside of the White House, by Congress. It’s one of their patented checks and balances.
But the Canadian prime minister just has to get his House of Commons colleagues to vote for the budget. In a majority, this is a breeze. Only in a minority, where challenging the budget brings the threat of an election, is there the opportunity for the opposition to make it a big deal.
That’s why we need mechanisms in place to even make sure Canadians know we’re spending more of their money and putting them further in debt.
The options include legislating a national referendum on raising the debt. This would be like the Alberta Taxpayer Protection Act that Ralph Klein introduced in 1995. The Act requires a provincial referendum to approve the creation of a provincial sales tax. So much for massive sweeping taxes to enable spending by the likes of Alberta Premier Alison Redford.
We can also simply legislate a set budget level, requiring a repeal or an amendment to exceed the figure. MP Maxime Bernier’s riding of Beauce has proposed balanced budget legislation as a policy discussion for the upcoming Conservative convention. 
Indeed, there is no statutory debt ceiling in Canada like that in the United States; the deficits and debt are, ultimately, what Parliament make them. The US Congress does not need to impose a debt ceiling either and operated for over a century without. But the existence or absence of a debt ceiling does not affect the strict separation between the President and Congress over budgetary matters. However, this strict separation of powers under a presidential system, like that in the United States, promotes irresponsibility, as the numerous government shutdowns in Washington, including one in 2013, demonstrate. The President and Congress alike can, quite plausibly, blame one another for various policy mishaps, and since they are elected independently, neither needs to retain the confidence of the other. Like Kline, Furey here demonstrates a lack of appreciation for Responsible Government and the Royal Recommendation — even though classical liberals and libertarians should support them. Whigs like Lord Durham promoted them in the 19th century.
In principle, holding a referendum on raising the debt would allow the Ministry to abdicate its responsibility and, in practice, would be inefficacious. Furthermore, any such statutory provision on a referendum, as well as one “legislating a set budget level” would accomplish nothing, since a profligate government could introduce a bill to repeal such a measure at any time.
The Constitution Act, 1867 entrenches Responsible Government and this balance between the executive and legislature through sections 53 and 54. Section 53 mandates that all money bills must originate in the House of Commons, from which the bulk of the Ministry is drawn; section 54 states that all money bills must receive the Royal Recommendation, which the Governor General grants on ministerial advice.
53. Bills for appropriating any Part of the Public Revenue, or for imposing any Tax or Impost, shall originate in the House of Commons.
54. It shall not be lawful for the House of Commons to adopt or pass any Vote, Resolution, Address, or Bill for the Appropriation of any Part of the Public Revenue, or of any Tax or Impost, to any Purpose that has not been first recommended to that House by Message of the Governor General in the Session in which such Vote, Resolution, Address, or Bill is proposed.
In other words, only the people’s elected representatives can introduce bills that would levy tax or grant expenditures, and that bill can only proceed if the executive wishes to take responsibility for it. Lord Durham referred to this arrangement as “the real protection of the people” because this tandem ensures that parliament only approves appropriations which have the support of a majority of elected MPs, and thus those who represent the majority of the people.
Furthermore, Responsible Government does not “fuse” the legislature and executive, as many incurious political scientists say. Sadly, this bad metaphor seems to have started with the over-rated British journalist Walter Bagehot in the 19th century.
The efficient secret of the English Constitution may be described as the close union and complete fusion of the executive and legislative powers.
The independence of the legislative and executive powers is the specific quality of Presidential Government, just as their fusion and combination is the precise principle of Cabinet Government.
While Bagehot weakened his fusion metaphor by cloaking it with “union” and “combination,” contemporary sources do not. Fusion refers to “combining two or more distinct entities into a new whole” and thus entails an outright transformation from one thing into a different thing. But this is clearly not what parliamentary government does — and nothing better demonstrates this fact than the writ, when parliament is dissolved but the executive remains in place. Cabinet ministers lose their status as MPs during the writ but retain their status as Privy Councillors within the governing Ministry. If the legislature and executive were truly “fused,” then this state of affairs could not happen because it would be a logical impossibility. Instead, Responsible Government maintains a narrow separation of powers, in contrast to the broad separation of powers under a presidential system, and brings the executive and legislature into balance and “harmony,” as 19th-century constitutional historian Alpheus Todd said, and makes them act in concert. When that harmony breaks down and becomes a discordant cacophony, either there must be a new Ministry, or a new parliament. British political scientists Rod Hague and Martin Harrop (amongst our living contemporaries) say, much more accurately than most, that “the executive in parliamentary government is organically linked to the legislature” because “the government emerges from parliament.”
In contrast, the United States Constitution sets up a presidential-congressional system that relies on a rigid separation of powers and something resembling a republican analogue of the 18-century British system, “The Balanced Constitution, before the modern party system and complete collective ministerial responsibility had emerged. The Ineligibility Clause prevents the executive and legislature from operating on the same harmonic wavelength because it expressly forbids congressional representatives from serving simultaneously as cabinet secretaries. This provision of the US Constitution prevented anything like Responsible Government (or “Cabinet Government,” as the British would say) from ever evolving organically in the United States.
No Senator or Representative shall, during the Time for which he was elected, be appointed to any civil Office under the Authority of the United States, which shall have been created, or the Emoluments whereof shall have been increased during such time; and no Person holding any Office under the United States, shall be a Member of either House during his Continuance in Office.
While the Origination Clause of United States Constitution also drew upon the British tradition and mandated that money bills must be introduced in the lower house, the House of Representations, the US Constitution contains no equivalent to the Royal Recommendation.
All Bills for raising Revenue shall originate in the House of Representatives; but the Senate may propose or concur with Amendments as on other Bills.
The absence of anything providing for executive responsibility over money bills also would have hampered the emergence of something resembling Cabinet Government in the United States, even without the Ineligibility Clause. While the President can introduce a budget to Congress, Congress can amend or reject it at will because it retains the absolute and ultimate power of the purse. Neither the President nor the Secretary of the Treasury are responsible for the budget that Congress passes. The President and cabinet secretaries remain in office pursuant to Article II of the US Constitution, not at all based on whether they command the confidence of Congress.
Responsible Government is all about the money: who proposes taxation and spending (the executive), who approves taxation and spending (the legislature), and who takes responsibility for taxation and spending (the executive).
In short, Canada does not need a debt ceiling. Canada’s system of government already accommodates and encourages good fiscal policy; what the country now needs is a government that value fiscal prudence, like Chretien’s.
Canadian libertarians derive their fundamental misunderstandings of our system of government from the belief that the American system of government — presidentialism with an absolute separation of executive and legislative powers — better secures liberty. But this is false. In fact, parliamentarism better secures liberty and the rule of law than presidentialism. As Frank Buckley (a Canadian living in the United States) has empirically demonstrated in his book Crown Government, the United States of America has remained a free country in spite of, not because of, its system of government. And as Juan Linz before him showed, presidentialism has been America’s most dangerous and least successful export, especially in Latin America. In other words, the United States of America and its experiment in government succeeded because of factors other than presidentialism: namely, having a British heritage and retaining core British legal principles like the Common Law itself and trial by jury.
All good classical liberals and Whigs understand that good government fundamentally depends upon a strong link between taxation, representation, and expenditure, which bind together the accountability and responsibility of the government and the consent of the governed. We know what happens when that relationship breaks down: many petro-States are authoritarian precisely because the government can rely on royalties from natural resources for revenue rather than having to rely on taxation taken from the people. Consent and accountability break down because the people have no stake in the government. Classical liberals in the 19th century also well understood this principle, especially Lord Durham. Parliamentarism better secures the link between taxation, representation, and expenditure than does presidentialism. That the United States has avoided this fate when most other countries with presidential systems have succumbed to corruption and limited freedom is — if I can be so cavalier about it — evidence for American Exceptionalism after all.
Accountability over taxation, representation, and expediture forms only one of element of parliamentarism’s success. Another element of parliamentary government — especially those countries which are also constitutional monarchies — explains why they better secure liberty and the rule of law. This has more to do with concepts of power, authority, loyalty, and dissent than money and boils down to the separation of the head of state from the head of government under parliamentary systems versus their fusion — and this is a correct instance to invoke that word! — of the two functions in presidential systems, where the president is both. This distinction would also apply to parliamentary republics, but temporary non-executive presidents still lack the sort of personal authority that monarchs possess. I suspect that, deep down, monarchists and republicans alike would agree that replacing a parliamentary republic with a presidential republic is still less radical than replacing a constitutional monarchy and parliamentary system with either a parliamentary republic or a presidential republic.
In our parliamentary system, the Prime Minister and Cabinet represent Canada as a State and as an international legal person (as in le pays), and they govern in a way that should promote Canada’s national interest; however, the Prime Minister and Cabinet most certainly cannot “represent all Canadians” in the sense of “reflecting their values in government.” The Sovereign and Governor General represent Canada in the sense of la patrie, in something like a “head of the nation” role. But only the House of Commons as a whole “represents all Canadians” as a political nation because we elect Members of Parliament. Within the House of Commons, the loyal opposition represents “the political minority” and makes the representation of political dissent integral to Westminster parliamentarism, and the government’s legitimacy depends on commanding the confidence of a majority of MPs within the chamber. Therefore, no Prime Minister could ever claim to “represent all Canadians” unless his party won all 338 seats in the House of Commons and Canada became a one-party State. As Janet Ajzenstat states, “the supreme benefit of parliamentary government is that it protects political opposition, the right to dissent.”
F.H. Buckley adds that this is precisely why politicians in parliamentary countries can be freely mocked without a hint of disloyalty. But in presidential systems, even in the United States, criticizing the president as vociferously as one would criticize the prime minister of a Commonwealth Realm in practice carries a hint of disloyalty to the country itself — even though, in principle, it should not because the US Constitution itself, not the office of President, is the object of American oaths of allegiance. (This probably reveals something about human psychology, that we tend more easily to place our confidence in a person than in a text). Buckley writes that by fusing the head of state and head of government into one office, and by enforcing a strict separation of the executive and legislature, presidential systems “insulate [the president] from accountability” and also “encourage a president to surmount the gridlock resulting from the separation of powers and rule personally.” Buckley concludes:
Threats to freedom come from stuffy politicians and angry demagogues, not from jug-eared princes. Where the kings, not the politician or demagogue, commands our affection and loyalty, where the monarch reigns over all his subjects without regard to party or faction, where we are encouraged to laugh at prime ministers, we will see less of political oppression and tyranny.
Canadian libertarians should understand that parliamentary government better protects liberty, and they should therefore enthusiastically support it. Libertarians should support this vital separation between the head of state and head of government and the concomitant fact that this separation renders the prime minister and cabinet ministers mere politicians whom we can freely mock without even the faintest hint of treason or disloyalty. Libertarians should support this system, in which only the House of Commons as a whole represents the people — not the Ministry, which can never make such dictatorial and lofty claims. Libertarians should support the dynamic between the Ministry and the loyal opposition — loyal because opposing the Ministry, the government of the day, in no way equates to opposing the country itself. Libertarians should support the principles of money bills originating in the lower house and the Royal Recommendation, by which Ministers of the Crown must take responsibility for any and all taxation and expenditure, because this vital tandem entrenches what is perhaps the most fundamental feature of good government: inextricably linking taxation, representation, and expenditure together. There is no pork-barrelling in a parliamentary system because backbenchers lack both the responsibility and the authority to initiate appropriations which the Ministry itself opposes.
Finally, libertarians should support a system of government which puts the executive and legislature in harmony, and thereby obviates the need for a strongman president to assume more authority for himself in order to break deadlock. When the executive and legislature come into directly conflict under a parliamentary system, the deadlock cannot long endure, for it would necessitate either a mid-parliamentary change of government, or a dissolution of parliament and fresh elections. In either case, either the people’s representatives or the people themselves would decide the outcome — not a strongman president.
In particular, deadlock over a budget would soon be resolved. Either the Ministry would succeed in shepherding their appropriations bills — for which they take responsibility through the Royal Recommendation — through the House of Commons, or the House of Commons would defeat these money bills, thereby withdrawing its confidence from the Ministry, and forcing the Prime Minister either to advise dissolution and fresh elections or, in some hung parliaments, to resign and make way for a new ministry immediately. Either way, the deadlock would be resolved in a matter of weeks at most, with a definitive end always in sight.
Instead, too many Canadian libertarians remain content to indulge themselves on these American Exceptionalist myths. It is indeed very strange, because “Freedom wears a Crown.”
- Presidentialism vs Parliamentarism
- The “Republic of Canada, Est. 1837”: Distortion of History and Responsible Government
- Why the Finance Minister Is Most Important After the Prime Minister
- The House of Commons Should Not Authorize Military Deployments
- Review of It’s Even Worse Than It Looks: How the American Constitutional System Collided With The New Politics of Extremism, by Ornstein and Mann
- The Contradictory American Presidency: How An Elected, Executive Head of State Can Only Ever Be a Divider, Not a Uniter
- The Deleterious Effects of Bipartisanship and the Separation of Powers on Good Government
- Presidentialism vs Parliamentarism in The West Wing
 Jesse Kline, “The Best Legislature Is a Prorogued Legislature,” National Post, 22 October 2012.
 William Edward Hall, A Treatise on International Law, 3rd Edition (Oxford: Clarendon Press, 1890), 23.|
 Anthony Furey, “Canada Needs a Debt Ceiling,” Fort Erie Times, 1 October 2013.
 United States, Department of the Treasury, “The Debt Limit,” 16 March 2016.
 Furey 2013.
 Janet Ajzenstat, The Once and Future Canadian Democracy: An Essay in Political Thought (McGill-Queen’s University Press, 2003), 64, 66-67.
 John Lambton (The Earl of Durham), The Report and Despatches of the Earl of Durham, Her Majesty’s High Commissioner and Governor-General of British North America (London: Ridgways, 1839), 211.
 Kenneth Newton and Jan W. Van Deth, Foundations of Comparative Politics: Democracies in the Modern World, 2nd Edition (Cambridge University Press, 2010), 100; David Judge and David Earnshaw, The European Parliament, 2nd Edition (Hampshire: Palgrave-Macmillian, 2008), 16. Mark Kesselman et al, Introduction to Comparative Politics: Political Challenges and Changing Agendas, 7th Edition (Boston: Cengage Learning, 2016), 99; Alan Fenna et al., Government and Politics in Australia (Frenchs Forest, New South Wales: Pearson Australia), 15; Mark Garnett and Philip Lynch, Exploring British Politics, 4th Edition (London: Routledge, 2016), page number not provided for some daft reason; Ronald L. Watts, Executive Federalism: A Comparative Analysis (Kingston, Ontario: Queen’s University, Institute of Intergovernmental Relations, 1989), 7.
 Walter Bagehot, The English Constitution (London: Capman and Hall, 1867), 12.
 Ibid., 18.
 Alpheus Todd, Parliamentary Government in the British Colonies, 2nd Edition (London: Longmans, Green, and Co., 1894), 26.
 Rod Hague and Martin Harrop, Political Science: A Comparative Introduction, 5th Edition. (New York: Palgrave-MacMillan, 2007), 336.
 Frank H. Buckley, The Once and Future King: The Rise of Crown Government in America (New York: Encounter Books, 2014), 309-319.
 Juan Linz, “The Perils of Presidentialism” Journal of Democracy 1, no. 1 (Fall-Winter1990): 51-69.
 Daniel Hannan, “David Cameron Should Give Scotland Full Fiscal Autonomy Immediately,” Cap X Author, 8 May 2015.
 Janet Ajzenstat, “Bicameralism and Canada’s Founders: The Origins of the Canadian Senate,” in Protecting Canadian Democracy: The Senate You Never Knew, ed. Serge Joyal (Toronto: University of Toronto Press, 2003): 3, 7.
 Ibid., 7.
 Frank H. Buckley, The Once and Future King: The Rise of Crown Government in America (New York: Encounter Books, 2014), 181, 205.
 Ibid., 163.
 Ibid., 195.
 Eugene Forsey, How Canadians Govern Themselves 7th Ed (Ottawa: Her Majesty the Queen in Right of Canada, 2007), 25-27.
 John Farthing, Freedom Wears a Crown (Toronto: Kingswood House), 1957.