California's 12th congressional district election, 1946
Encyclopedia
An election
Election
An election is a formal decision-making process by which a population chooses an individual to hold public office. Elections have been the usual mechanism by which modern representative democracy operates since the 17th century. Elections may fill offices in the legislature, sometimes in the...

 for a seat in the United States House of Representatives
United States House of Representatives
The United States House of Representatives is one of the two Houses of the United States Congress, the bicameral legislature which also includes the Senate.The composition and powers of the House are established in Article One of the Constitution...

 took place in California's 12th congressional district
California's 12th congressional district
California's 12th congressional district is a congressional district in the U.S. state of California that spans from the southwestern portions of San Francisco in the north down to San Mateo in the south, and from Moss Beach in the west to the edge of San Mateo in the east, where it borders...

 on November 5, 1946, the date set by law
Election Day (United States)
Election Day in the United States is the day set by law for the general elections of public officials. It occurs on the Tuesday after the first Monday in November. The earliest possible date is November 2 and the latest possible date is November 8...

 for the elections for the 80th United States Congress
80th United States Congress
The Eightieth United States Congress was a meeting of the legislative branch of the United States federal government, composed of the United States Senate and the United States House of Representatives. It met in Washington, DC from January 3, 1947 to January 3, 1949, during the third and fourth...

. In the 12th district election, the candidates were five-term incumbent Democrat
Democratic Party (United States)
The Democratic Party is one of two major contemporary political parties in the United States, along with the Republican Party. The party's socially liberal and progressive platform is largely considered center-left in the U.S. political spectrum. The party has the lengthiest record of continuous...

 Jerry Voorhis
Jerry Voorhis
Horace Jeremiah "Jerry" Voorhis was a Democratic politician from California. He served five terms in the United States House of Representatives from 1937 to 1947, representing the 12th Congressional district in Los Angeles County...

, Republican
Republican Party (United States)
The Republican Party is one of the two major contemporary political parties in the United States, along with the Democratic Party. Founded by anti-slavery expansion activists in 1854, it is often called the GOP . The party's platform generally reflects American conservatism in the U.S...

 challenger Richard Nixon
Richard Nixon
Richard Milhous Nixon was the 37th President of the United States, serving from 1969 to 1974. The only president to resign the office, Nixon had previously served as a US representative and senator from California and as the 36th Vice President of the United States from 1953 to 1961 under...

, and former congressman and Prohibition Party
Prohibition Party
The Prohibition Party is a political party in the United States best known for its historic opposition to the sale or consumption of alcoholic beverages. It is the oldest existing third party in the US. The party was an integral part of the temperance movement...

 candidate John Hoeppel. Nixon was elected with 56% of the vote, starting him on the road that would, almost a quarter century later, lead to the presidency.

First elected to Congress in 1936, Voorhis had defeated lackluster Republican opposition four times in the then-rural Los Angeles County
Los Angeles County, California
Los Angeles County is a county in the U.S. state of California. As of 2010 U.S. Census, the county had a population of 9,818,605, making it the most populous county in the United States. Los Angeles County alone is more populous than 42 individual U.S. states...

 district to win re-election. For the 1946 election, Republicans sought a candidate who could unite the party and run a strong race against Voorhis in the Republican-leaning district. After failing to secure the candidacy of General George Patton, in November 1945 they settled on Lieutenant Commander Richard Nixon, who had lived in the district prior to his World War II service.

Nixon spent most of 1946 campaigning in the district, while Voorhis did not return from Washington D.C. until the end of August. Nixon's campaign worked hard to generate publicity in the district, while Voorhis, dealing with congressional business in the capital, received little newspaper coverage. Voorhis received the most votes in the June primary elections, but his percentage of the vote decreased from his share in the 1944 primaries. At five debates held across the district in September and October, Nixon was able to paint the incumbent as ineffectual and to suggest that Voorhis was connected to communist-linked organizations. Voorhis and his campaign were constantly on the defensive and were ineffective in rebutting Nixon's contentions. The challenger defeated Voorhis in the November general election
General election
In a parliamentary political system, a general election is an election in which all or most members of a given political body are chosen. The term is usually used to refer to elections held for a nation's primary legislative body, as distinguished from by-elections and local elections.The term...

.

Various explanations have been put forward for Nixon's victory, from national political trends to red-baiting
Red-baiting
Red-baiting is the act of accusing, denouncing, attacking or persecuting an individual or group as communist, socialist, or anarchist, or sympathetic toward communism, socialism, or anarchism. The word "red" in "red-baiting" is derived from the red flag signifying radical left-wing politics. In the...

 on the part of the challenger. Some historians contend that Nixon received large amounts of funding from wealthy backers determined to defeat Voorhis, while others dismiss such allegations. These matters remain subjects of historical debate.

District and campaigns

Since its creation following the 1930 census, the 12th district had been represented by Democrats. The 12th stretched from just south of Pasadena
Pasadena, California
Pasadena is a city in Los Angeles County, California, United States. Although famous for hosting the annual Rose Bowl football game and Tournament of Roses Parade, Pasadena is the home to many scientific and cultural institutions, including the California Institute of Technology , the Jet...

 to the Orange
Orange County, California
Orange County is a county in the U.S. state of California. Its county seat is Santa Ana. As of the 2010 census, its population was 3,010,232, up from 2,846,293 at the 2000 census, making it the third most populous county in California, behind Los Angeles County and San Diego County...

 and San Bernardino
San Bernardino County, California
San Bernardino County is a county in the U.S. state of California. As of the 2010 census, the population was 2,035,210, up from 1,709,434 as of the 2000 census...

 county lines, encompassing such small towns as Whittier
Whittier, California
Whittier is a city in Los Angeles County, California about southeast of Los Angeles. The city had a population of 85,331 at the 2010 census, up from 83,680 as of the 2000 census, and encompasses 14.7 square miles . Like nearby Montebello, the city constitutes part of the Gateway Cities...

, Pomona
Pomona, California
-2010:The 2010 United States Census reported that Pomona had a population of 149,058, a slight decline from the 2000 census population. The population density was 6,491.2 people per square mile...

 and Covina
Covina, California
Covina is a small city in Los Angeles County, California about east of downtown Los Angeles, in the San Gabriel Valley region. The population was 47,796 at the 2010 census, up from 46,837 at the 2000 census...

. The area has since been entirely absorbed into the Los Angeles megalopolis, but at the time it was principally agricultural. The freeway system had barely touched the 12th district; only a small segment of the Pasadena Freeway
Pasadena Freeway
The Arroyo Seco Parkway, formerly known as the Pasadena Freeway, is the first freeway in California and the western United States. It connects Los Angeles with Pasadena alongside the Arroyo Seco. It is notable not only for being the first, mostly opened in 1940, but for representing the...

 cut across its northwest corner.

In 1932, John Hoeppel was elected to represent the 12th district. In 1936, Hoeppel was vulnerable as he had been convicted for trying to sell a nomination to West Point
United States Military Academy
The United States Military Academy at West Point is a four-year coeducational federal service academy located at West Point, New York. The academy sits on scenic high ground overlooking the Hudson River, north of New York City...

. Voorhis defeated Hoeppel in the Democratic primary and easily won the general election. Voorhis, who gained a reputation as a respected and hard-working representative, nicknamed "Kid Atlas" by the press for taking the weight of the world on his shoulders, was loyal to the New Deal
New Deal
The New Deal was a series of economic programs implemented in the United States between 1933 and 1936. They were passed by the U.S. Congress during the first term of President Franklin D. Roosevelt. The programs were Roosevelt's responses to the Great Depression, and focused on what historians call...

.

The 12th district leaned Republican, the more so after 1941 when the Republican-dominated California State Legislature
California State Legislature
The California State Legislature is the state legislature of the U.S. state of California. It is a bicameral body consisting of the lower house, the California State Assembly, with 80 members, and the upper house, the California State Senate, with 40 members...

 attempted to gerrymander Congressman Voorhis out of office by removing strong Democratic precincts in East Los Angeles
East Los Angeles, California
East Los Angeles is an unincorporated area and census-designated place in Los Angeles County, California, United States...

 from the district during the decennial
United States Census
The United States Census is a decennial census mandated by the United States Constitution. The population is enumerated every 10 years and the results are used to allocate Congressional seats , electoral votes, and government program funding. The United States Census Bureau The United States Census...

 redistricting
Redistricting
Redistricting is the process of drawing United States electoral district boundaries, often in response to population changes determined by the results of the decennial census. In 36 states, the state legislature has primary responsibility for creating a redistricting plan, in many cases subject to...

. The revamped 12th district had little industry and almost no union influence. Voorhis was left with such Republican strongholds as San Marino
San Marino, California
San Marino is a small, affluent city in Los Angeles County, California. Incorporated in 1913, the City founders designed the community to be uniquely residential, with expansive properties surrounded by beautiful gardens, wide streets, and well maintained parkways...

, where he did not even bother to campaign, concluding that he would receive the same number of votes whether he visited there or not. Despite the maneuvers of the Republicans in the legislature, Voorhis was re-elected in 1942, receiving 57% of the vote, and won with a similar percentage two years later. Voorhis had not faced strong opposition prior to 1946. In his initial election, Voorhis benefited from the Roosevelt landslide of 1936
United States presidential election, 1936
The United States presidential election of 1936 was the most lopsided presidential election in the history of the United States in terms of electoral votes. In terms of the popular vote, it was the third biggest victory since the election of 1820, which was not seriously contested.The election took...

. His 1938 opponent was so shy that Voorhis had to introduce him to the crowd at a joint appearance. In 1940, he faced Captain Irwin Minger, a little-known commandant of a military school, and his 1942 opponent, radio preacher and former Prohibition Party gubernatorial candidate Robert P. Shuler
Robert P. Shuler
Robert Pierce "Fighting Bob" Shuler, Sr. , was an American evangelist and political figure. His radio broadcasts from his Southern Methodist church in Los Angeles, California, during the 1920s and early 1930s attracted a large audience and also drew controversy with his attacks on politicians,...

, "embarrassed GOP regulars". In 1944, the 12th district Republicans were bitterly divided, and Voorhis easily triumphed.

Republican search for a candidate

As Voorhis served his fifth term in the House, Republicans searched for a candidate capable of defeating him. Local Republicans formed what became known as the "Committee of One Hundred" (officially, the "Candidate and Fact-Finding Committee") to select a candidate with broad support in advance of the June 1946 primary election. This move caused some editorial concern in the district: The Alhambra Tribune and News, fearing the choice of a candidate was being taken away from voters in favor of a small group, editorialized that the committee formation was "a step in the wrong direction" and an attempt to "shove Tammany Hall
Tammany Hall
Tammany Hall, also known as the Society of St. Tammany, the Sons of St. Tammany, or the Columbian Order, was a New York political organization founded in 1786 and incorporated on May 12, 1789 as the Tammany Society...

 tactics down our throats".

The Committee initially wooed State Commissioner of Education (and former Whittier College
Whittier College
Whittier College is a private liberal arts college in Whittier, California. As of January 2009, the college has approximately 1540 enrolled students.-Overview:...

 president) Walter Dexter. Dexter was reluctant to give up his state post to run and sought a guarantee that he would receive another job if his candidacy failed. He continued to consider running for several months without reaching a decision, frustrating local Republicans. As Dexter dithered, Republicans tried to get General George Patton to run, though they were not certain if the general was a Republican. However, a day after the Los Angeles Times speculated on the run, Patton announced from Germany his intent to "keep completely out of politics". The Committee also contacted Stanley Barnes, a rising young Republican attorney and former football star at the University of California, Berkeley
University of California, Berkeley
The University of California, Berkeley , is a teaching and research university established in 1868 and located in Berkeley, California, USA...

. Barnes declined to be considered, skeptical of the chances of defeating Voorhis.

With little progress made on securing a high-profile candidate, Committee working groups held interviews. Of the eight men who applied, the most prominent was former congressman John Hoeppel, who promised to keep "the Jews and the niggers" out of the district. On October 6, 1945, the Monrovia News Post reported that while Dexter seemed the likely candidate, "of course anything can happen in politics and generally does". The News Post stated that other names discussed by the Committee included "Lt. Richard Nixon, U.S.N.R., of Whittier." Congressman Voorhis wrote his father and political adviser, Charles Voorhis, on October 15, "I understand the General has decided not to run in the 12th district. Dr. Dexter would, in my opinion, be hard to beat. But at least it would be a clean, decent campaign, and I'm not so sure I wouldn't prefer that even if I lost." Herman Perry, Whittier Bank of America
Bank of America
Bank of America Corporation, an American multinational banking and financial services corporation, is the second largest bank holding company in the United States by assets, and the fourth largest bank in the U.S. by market capitalization. The bank is headquartered in Charlotte, North Carolina...

 branch manager and Nixon family friend, wrote to Nixon, who was then a lieutenant commander in the Navy, telling him he should apply for the Committee's endorsement. Nixon replied enthusiastically. When Dexter finally turned the Committee down, he recommended Nixon, his onetime student. Dexter died only days later of a heart attack, and Patton died in an auto accident before the 1946 campaign began.

At the time, Nixon was stationed in Baltimore, Maryland, using his legal training to deal with military contract terminations. On November 1, 1945, he flew to California to meet influential Republicans and give a speech at a Committee meeting. The meeting was advertised throughout the district and was open to any potential candidate. However, the advertisements for the meeting noted that Nixon would be flying in to speak. A number of potential rivals also showed up at the meeting on November 2, 1945, including a local judge and assemblyman. Nixon, who spoke last, was "electrifying", according to one Committee member. When the Committee met to vote on November 28, Nixon received over two-thirds of the vote, which was then made unanimous. Committee chairman Roy Day immediately notified the victor of the Committee's endorsement.

Nixon was already arranging to research Voorhis's record and to meet with Republican leaders in Washington, including House Minority Leader (and future Speaker
Speaker of the United States House of Representatives
The Speaker of the United States House of Representatives, or Speaker of the House, is the presiding officer of the United States House of Representatives...

) Joseph W. Martin, Jr.  The newly minted candidate wrote to Day regarding Voorhis, "His 'conservative' reputation must be blasted. But my main efforts are being directed toward building up a positive, progressive group of speeches which tell what we want to do, not what the Democrats have failed to do ... I'm really hopped up over this deal, and I believe we can win." However, "wheelhorse" Republicans deemed Nixon's campaign hopeless. Nixon was a virtual unknown outside of his hometown of Whittier and was facing a popular and respected incumbent. Charles Voorhis wrote his son that the Republicans had endorsed a Quaker
Religious Society of Friends
The Religious Society of Friends, or Friends Church, is a Christian movement which stresses the doctrine of the priesthood of all believers. Members are known as Friends, or popularly as Quakers. It is made of independent organisations, which have split from one another due to doctrinal differences...

 named Richard Nixon, but hoped that his son would retain a large part of the Quaker vote. The elder Voorhis was confident that his son would triumph again, writing, "It is just another campaign that we have to go through ... In any event, we have nothing to worry about now."

Primary campaign

Nixon was discharged from the Navy at the start of 1946. Within days, he and his wife Pat Nixon
Pat Nixon
Thelma Catherine "Pat" Ryan Nixon was the wife of Richard Nixon, 37th President of the United States, and was First Lady of the United States from 1969 to 1974. She was commonly known as Patricia or Pat Nixon.Born in Nevada, Pat Ryan grew up in Los Angeles, California...

, the latter almost eight months pregnant, returned to Whittier. They initially moved in with the candidate's parents, Frank
Francis A. Nixon
Francis Anthony "Frank" Nixon was an American businessman and the father of U.S. President Richard Nixon....

 and Hannah
Hannah Milhous Nixon
Hannah Milhous Nixon was the mother of President Richard Nixon.She was born near Butlerville, Indiana, the daughter of Almira Park , who was from Columbiana County, Ohio, and Franklin Milhous, a native of Colerain Township, Belmont County, Ohio. She was married to Francis A...

. Nixon returned to his old law firm, but spent most of his time campaigning. Roy Day, chairman of the now-dissolved Committee, appointed himself as Nixon's campaign manager. This self-appointment dismayed the candidate somewhat, and Nixon unsuccessfully sought to replace Day.

Voorhis had been in Washington since August 1945, attending to congressional business. He did not return to the district until August 1946, well after the June primary. By his own account, he was busy dealing with:
[The a]mendment of the Social Security Act, the Case Labor bill, the British loan, terminal leave pay for soldiers, and several appropriation bills [and] the most important problem our country had ever faced in all its history—the problem of what to do about atomic energy. I felt sure that the people of the district would rather have me stay on the job than come home to campaign.


Beginning in February, the Republican hopeful began a heavy speaking schedule, addressing civic groups across the 400 square miles (1,036 km²) district. Nixon's efforts to get publicity were aided by the birth of his daughter Tricia
Patricia Nixon Cox
Patricia "Tricia" Nixon Cox is the elder daughter of the 37th U.S. President Richard M. Nixon and First Lady Pat Nixon, and sister to Julie Nixon Eisenhower....

 in late February. The new father was extensively interviewed and photographed with his infant daughter. Congressman Voorhis's office sent the Nixons a government pamphlet entitled Infant Care, of which representatives received 150 per month to distribute to their constituents. When Richard Nixon sent his rival a note of thanks in early April, the congressman responded with a letter proposing that the two debate once Congress adjourned in August.
In mid-March, Nixon was approached by former congressman Hoeppel, who hated Voorhis. Hoeppel offered to enter the Democratic primary in exchange for a payment of several hundred dollars plus the promise of a civil service
Civil service
The term civil service has two distinct meanings:* A branch of governmental service in which individuals are employed on the basis of professional merit as proven by competitive examinations....

 job once the Republican was elected. After consulting with his aides, Nixon turned him down. Subsequently, Hoeppel filed as a Prohibition Party
Prohibition Party
The Prohibition Party is a political party in the United States best known for its historic opposition to the sale or consumption of alcoholic beverages. It is the oldest existing third party in the US. The party was an integral part of the temperance movement...

 candidate. Voorhis was privy to these events through an informant close to the former representative, and was convinced that Roy Day had arranged to pay Hoeppel's filing fee. The congressman feared that Hoeppel would serve as a stalking horse
Stalking horse
A stalking horse is a person who tests a concept with someone or mounts a challenge against them on behalf of an anonymous third party. If the idea proves viable and/or popular, the anonymous figure can then declare their interest and advance the concept with little risk of failure...

 for Nixon, sparing the Republican from any "mudslinging". Voorhis responded to Hoeppel's filing with a letter to his campaign manager, Baldwin Park
Baldwin Park, California
Baldwin Park is a city located in the central San Gabriel Valley region of Los Angeles County, California, United States. As of the 2010 census, the population was 75,390, down from 75,837 at the 2000 census.- History :...

 realtor Jack Long, stating that "it would be worthwhile for us to try our level best to beat him in the Prohibition primary by a write-in campaign".

On March 18, two days before the filing deadline, Nixon filed in both the Republican and Democratic primaries under California's cross-filing
Cross-filing
In American politics, cross-filing occurs when a candidate runs in the primary election of not only his own party, but also that of one or more other parties, generally in the hope of reducing or eliminating his competition at the general election...

 system. Voorhis also filed in the two major party primaries. Under cross-filing, if the same candidate won both major party endorsements, he would be effectively elected, with only minor party candidates to stand against him. Day advanced the $200 (the current equivalent of $2,230) for Nixon's filing fees, later noting that he had great difficulty being reimbursed.

By late March, Nixon's stock speeches to civic groups were becoming worn. Day hired political consultant Murray Chotiner
Murray Chotiner
Murray M Chotiner was an American political strategist, attorney, government official, and close associate and friend of President Richard Nixon during much of the 37th President's political career...

 for $580 for the primary campaign, and the consultant warned that unless new life came into the campaign, it was in serious danger. In the following years, Chotiner was to become Nixon's campaign manager, adviser, and friend in an association that lasted until Chotiner's death a few months before President Nixon's 1974 resignation.

Chotiner arranged for stories in local papers alleging that Voorhis had been endorsed by "the PAC", hoping that voters would take that to mean the Congress of Industrial Organizations
Congress of Industrial Organizations
The Congress of Industrial Organizations, or CIO, proposed by John L. Lewis in 1932, was a federation of unions that organized workers in industrial unions in the United States and Canada from 1935 to 1955. The Taft-Hartley Act of 1947 required union leaders to swear that they were not...

's Political Action Committee
Political action committee
In the United States, a political action committee, or PAC, is the name commonly given to a private group, regardless of size, organized to elect political candidates or to advance the outcome of a political issue or legislation. Legally, what constitutes a "PAC" for purposes of regulation is a...

 (CIO-PAC). The CIO was a labor federation which later merged with the American Federation of Labor
American Federation of Labor
The American Federation of Labor was one of the first federations of labor unions in the United States. It was founded in 1886 by an alliance of craft unions disaffected from the Knights of Labor, a national labor association. Samuel Gompers was elected president of the Federation at its...

 to form the AFL-CIO
AFL-CIO
The American Federation of Labor and Congress of Industrial Organizations, commonly AFL–CIO, is a national trade union center, the largest federation of unions in the United States, made up of 56 national and international unions, together representing more than 11 million workers...

. It had been organized in 1943 and took left-wing stands; its PAC was seen as a communist front organization by some. A second PAC, the National Citizen's Political Action Committee (NCPAC) was also affiliated with the CIO, but was open to those outside the labor movement. Among the 1946 members of the NCPAC were actors Melvyn Douglas
Melvyn Douglas
Melvyn Edouard Hesselberg , better known as Melvyn Douglas, was an American actor.Coming to prominence in the 1930s as a suave leading man , Douglas later transitioned into more mature and fatherly roles as in his Academy Award-winning performances in Hud...

 and Ronald Reagan
Ronald Reagan
Ronald Wilson Reagan was the 40th President of the United States , the 33rd Governor of California and, prior to that, a radio, film and television actor....

. Both PACs had been headed by the late labor leader, Sidney Hillman
Sidney Hillman
Sidney Hillman was an American labor leader. Head of the Amalgamated Clothing Workers of America, he was a key figure in the founding of the Congress of Industrial Organizations and in marshaling labor's support for Franklin Delano Roosevelt and the Democratic Party.-Early years:Sidney Hillman was...

, and the two organizations shared office space in New York City. While the CIO's national leadership decried communism; some of the local CIO-PAC branches were dominated by Communist Party members. The CIO-PAC, which had endorsed Voorhis in 1944, refused to back him again. The Southern California chapter of the NCPAC endorsed Voorhis on April 1, 1946. Chotiner's strategy was to conflate the two PACs in the public eye.

Nourished by the PAC controversy, the Republican campaign gained new life as Nixon returned to the speaking circuit. After Nixon spoke to a Lions Club meeting on May 1, a worried Voorhis supporter wrote to the congressman, "He carried the group by storm. He is dangerous. You will have the fight of your life to beat him."

The primary was held on June 4, 1946. Both Voorhis and Nixon won his own party's primary, with Voorhis garnering a considerable number of votes in the Republican poll. When all the votes from all primaries were added together, Voorhis outpolled Nixon by 7,000 votes. Voorhis's total percentage of the vote decreased from 60% in the 1944 primaries to 53.5% in 1946. Hoeppel survived the write-in campaign to advance to the general election.

General election

Following a two-week vacation in British Columbia
British Columbia
British Columbia is the westernmost of Canada's provinces and is known for its natural beauty, as reflected in its Latin motto, Splendor sine occasu . Its name was chosen by Queen Victoria in 1858...

 after the primary, Nixon returned to the 12th district. The Republican began the general election campaign by replacing Roy Day with South Pasadena
South Pasadena, California
South Pasadena is a city in Los Angeles County, California, United States. As of the 2010 census, it had a population of 25,619, up from 24,292 at the 2000 census. It is located in in the West San Gabriel Valley...

 engineer Harrison McCall as campaign manager. As Chotiner was increasingly distracted by his position as Southern California campaign manager for the (successful) reelection bid of Republican Senator William Knowland, the Nixon campaign added publicist William Arnold. Voorhis, on the other hand, remained in Washington, dealing with Congressional business and generating little publicity. He corresponded with his father and with his campaign manager, Jack Long, by letter. Voorhis hoped to return to California in mid-August but while returning from Washington in August, he was forced to have surgery for hemorrhoids in Ogden, Utah
Ogden, Utah
Ogden is a city in Weber County, Utah, United States. Ogden serves as the county seat of Weber County. The population was 82,825 according to the 2010 Census. The city served as a major railway hub through much of its history, and still handles a great deal of freight rail traffic which makes it a...

. Voorhis spent two weeks in an Ogden hotel recuperating from the operation and did not return to the district until the end of August. Voorhis wrote later, "I can't say I was exactly 'ready for the fray'. But the 'fray' was certainly ready for me."

South Pasadena debate

Nixon did not reply to Voorhis's April debate proposal. In May, the congressman wrote to Long as Nixon's campaign initially made the alleged PAC endorsement an issue. Voorhis suggested that Nixon be challenged to debates as a matter of urgency. Long responded in June, saying that though Nixon was known as a champion debater during his Whittier College days, "with your age and experience the general public might not take kindly to your challenging a boy like Nixon". Long advised awaiting a challenge from Nixon. By August, the two campaigns had settled on a debate to be held before a veteran's group in Whittier on September 20. However, the "Independent Voters of South Pasadena" (IVSP), headed by future Voorhis biographer Paul Bullock, announced a September 13 town meeting on campaign issues at South Pasadena Junior High School. The IVSP's actual purpose in having the meeting was to get a vulnerable Republican assemblyman (who declined his invitation) to debate his Democratic rival, but Senate and 12th district Republican and Democratic candidates were invited. Given that the debate sponsors were liberals, some of Nixon's aides advised him to refuse, but he overrode them. Voorhis also accepted; when it was suggested to him later he should have sent a spokesman, he responded, "I suppose so, but I just couldn't bring myself to refuse." Both Senate candidates declined their invitations, with Senator Knowland sending Chotiner in his place, while Democratic candidate Will Rogers, Jr.
Will Rogers, Jr.
William Vann Rogers, generally known as Will Rogers, Jr. , was a son of legendary humorist Will Rogers and his wife, the former Betty Blake . He was a Democratic U. S. Representative from California from January 3, 1943 until May 23, 1944, when he resigned to return to the United States Army...

 sent Representative Chester E. Holifield
Chester E. Holifield
Chester Earl Holifield was a United States Representative from California. He was born in Mayfield, Graves County, Kentucky. He moved with his family to Springdale, Arkansas in 1912. He attended the public schools and moved to Montebello, California in 1920 where he engaged in the manufacture and...

 of the neighboring 19th district.

The town meeting attracted a packed crowd of over a thousand, with Nixon supporters distributing anti-Voorhis literature at the door. The Senate proxies spoke first for their candidates, followed by Voorhis. Nixon, who had notified organizers that he would be late due to another commitment, arrived during Voorhis's speech, and remained backstage until the congressman had completed his talk. He then came onstage, shook hands with Voorhis, and delivered a fifteen minute address. A question-and-answer period then followed, with a Nixon supporter asking Voorhis about his onetime Socialist registration, and about his views on monetary policy. After the representative responded, a Voorhis supporter asked Nixon why he was making "false charges" about the supposed Voorhis CIO-PAC endorsement. In response, Nixon reached into his pocket and pulled out a copy of a Southern California NCPAC bulletin mentioning the group's endorsement of Voorhis. The congressman was unaware of the endorsement; those of his aides in the know had "completely forgotten" to tell him. Nixon walked halfway across the stage and displayed it to Voorhis, asking him to read it for himself. Voorhis came from his seat and took it, and (according to Bullock, who served as timekeeper at the debate) "mumbled" that this seemed to be a different organization from the CIO-PAC. Nixon reclaimed the document, and began to read out names of the members of the boards of directors of the two groups, "It's the same thing, virtually, when they have the same directors." The crowd began to cheer Nixon, who later wrote, "I could tell by the audience reaction that I had made my point", and to jeer Voorhis, who wrote, "They'd boo and laugh at my remarks, and this disturbed me."

In the midst of the turmoil, Prohibition Party candidate Hoeppel came down the aisle (according to Bullock, possibly drunk) and demanded to know why he had been excluded from the debate. He was permitted to ask one question, of Voorhis, and the evening ended. According to Bullock, "the magnitude of Nixon's triumph did not immediately dawn on us." Congressman Holifield had grasped it, and when Voorhis asked him, "How did it go?" he responded, "Jerry, he cut you to pieces."

Additional debates

On September 19, Voorhis wired the NCPAC's Los Angeles and New York offices, requesting that "whatever qualified endorsement the Citizens PAC may have given me be withdrawn". By this time, newspapers across the district had printed Nixon's charges, along with a Nixon advertisement castigating Voorhis for allegedly accusing Nixon of lying about the PAC endorsement. According to Nixon biographer Roger Morris
Roger Morris (American writer)
Roger Morris, born 1937, is an American public servant, historian, and political writer.-Biography:Roger Morris earned his doctorate in government from Harvard University. He entered government service in 1966 as an aide to former United States Secretary of State Dean Acheson. He first joined the...

, the repudiation of NCPAC endorsements did not help Voorhis, as his actions "would seem to many a half-guilty shedding of sinister backing he never had. To the end, as Chotiner had calculated, the PACs were hopelessly entangled." The Nixon campaign distributed 25,000 thimbles labeled "Nixon for Congress/Put the needle in the P.A.C."

The second debate was held at Patriotic Hall in Whittier on September 20. As the debate was sponsored by the Whittier Ex-Servicemen's Association, attendance was limited to veterans. The candidates debated the best way of dealing with the postwar housing shortage. Voorhis favored restricting building of commercial structures to free up materials for housing, while Nixon urged the removal of all building restrictions. When Nixon repeated his PAC allegations, Voorhis noted his request to the NCPAC, stating that he could not be held responsible for its actions. According to Morris, the debate ended as a draw, or perhaps even a Voorhis victory. Chotiner convinced Nixon that he needed to run an aggressive campaign to the end, and McCall challenged the Voorhis campaign to as many as eight additional debates, of which three were actually held.
The debates captured the interest of the public in the district and attracted large crowds. The candidates were compared to Abraham Lincoln
Abraham Lincoln
Abraham Lincoln was the 16th President of the United States, serving from March 1861 until his assassination in April 1865. He successfully led his country through a great constitutional, military and moral crisis – the American Civil War – preserving the Union, while ending slavery, and...

 and Stephen Douglas, who had famously debated
Lincoln-Douglas debates of 1858
The Lincoln–Douglas Debates of 1858 were a series of seven debates between Abraham Lincoln, the Republican candidate for Senate in Illinois, and the incumbent Senator Stephen Douglas, the Democratic Party candidate. At the time, U.S. senators were elected by state legislatures; thus Lincoln and...

 in their 1858 senatorial campaign, and bands played marches as each candidate entered the venue. The two candidates' third meeting was held at Bridges Auditorium in Claremont
Claremont, California
Claremont is a small affluent college town in eastern Los Angeles County, California, United States, about east of downtown Los Angeles at the base of the San Gabriel Mountains. The population as of the 2010 census is 34,926. Claremont is known for its seven higher-education institutions, its...

 on October 11. Voorhis was, by his own admission, "awfully tired". The candidates discussed labor policy, and Nixon "scored" by detailing a policy for dealing with public strikes that Voorhis too late realized was taken from a bill he had drafted. Nixon took Voorhis aside after the debate and lambasted him for addressing him as "Lieutenant Commander Nixon", accusing him of pandering to former enlisted men's dislike of officers.
In the fourth debate, on October 23 at Monrovia High School
Monrovia High School
Monrovia High School is a public high school located in Monrovia, California, a northeastern suburb of Los Angeles. Monrovia High School is the only 9-12 comprehensive high school in the Monrovia Unified School District...

, Nixon attacked Voorhis' congressional record. The challenger alleged that in the previous four years, Voorhis only had been able to pass a single bill through Congress and into law. The bill in question transferred jurisdiction over rabbit farming from the Department of the Interior to the Department of Agriculture. Nixon chided, "One has to be a rabbit to get effective representation in this congressional district." Voorhis responded that he had sponsored an act to employ the physically handicapped, but Nixon stated that it was not a law, but a joint resolution
Joint resolution
In the United States Congress, a joint resolution is a legislative measure that requires approval by the Senate and the House and is presented to the President for his/her approval or disapproval, in exactly the same case as a bill....

. Nixon restated his allegation regarding Voorhis and the PAC; Voorhis retorted that he had repudiated the NCPAC endorsement. Nixon parried with a comment that Voorhis's voting record "earned him the endorsement, whether he wanted it or not". Nixon also contended that in 46 votes, Voorhis had almost entirely followed the CIO-PAC agenda. Distraught, Voorhis stayed up until 4 a.m. studying the votes Nixon had taxed him with. He concluded that due to duplications, there were actually only 27 roll calls in question, on many of which he had opposed the CIO-PAC position. The congressman also found that the votes "friendly" to the CIO-PAC included one authorizing a school lunch program.

The final debate took place October 28 at the San Gabriel
San Gabriel, California
San Gabriel is a city in Los Angeles County, California, United States. It is named after the Mission San Gabriel Arcángel, founded by Junipero Serra. The city grew outward from the mission and in 1852 became the original township of Los Angeles County. San Gabriel was incorporated in 1913...

 Civic Auditorium, to an overflow crowd in excess of a thousand. Voorhis went on the attack, charging Nixon with misrepresenting the "46 votes" to avoid real debate and any discussion of where Nixon himself stood on issues. The Republican candidate stated that he was fighting for "the person on a pension trying to keep up with the rising cost of living  ... the white-collar worker who has not had a raise ... Americans have had enough, and they have come to the conclusion that they are going to do something." Nixon sat down to thunderous applause, and the San Gabriel Sun described Voorhis: "He pauses, breathes heavily, scans the audience with tired eyes, adjusts his glasses nervously with both hands, and then strikes the podium with an open hand."

Final days

In mid October, the Nixon campaign unveiled an advertisement which foreshadowed his run for Senate four years later. After stating that Nixon, at the South Pasadena debate, confronted the congressman with "a photostatic copy of his endorsement by the communist-dominated PAC", the ad stated, "Among the extreme left-wingers with whom Voorhis kept company in voting the PAC line are Helen Gahagan Douglas, Vito Marcantonio
Vito Marcantonio
Vito Anthony Marcantonio was an American lawyer and democratic socialist politician. Originally a member of the Republican Party and a supporter of Fiorello LaGuardia, he switched to the American Labor Party.-Early life:...

 ..." On October 29, the Alhambra Post-Advocate and Monrovia News-Post printed identical pieces entitled "How Jerry and Vito voted", comparing the California congressman's voting record with that of Marcantonio, a leftist New York congressman. In 1950, a similar comparison between the voting record of Marcantonio and Democratic Senate nominee Douglas, printed on pink paper, came to be known as the "Pink Sheet".

The Nixon campaign continued to run newspaper ads touching on the PAC issue. One ad suggested Radio Moscow had urged the election of the CIO slate. Others touched on Voorhis's past registration as a Socialist, and stated that his congressional record "is more Socialistic and Communistic than Democratic". The Democrats brought James Roosevelt
James Roosevelt
James Roosevelt was the oldest son of U.S. President Franklin D. Roosevelt. He was a United States Congressman, an officer in the United States Marine Corps, an aide to his father, the official Secretary to the President, a Democratic Party activist, and a businessman.-Early life:Roosevelt was...

 and other prominent Democrats into the district to campaign for Voorhis. Nixon proposed that his wartime acquaintance, former Minnesota Governor Harold Stassen
Harold Stassen
Harold Edward Stassen was the 25th Governor of Minnesota from 1939 to 1943. After service in World War II, from 1948 to 1953 he was president of the University of Pennsylvania...

 campaign for him. However, the candidate could not get permission from the California Republican committee for Stassen to visit. Voorhis publicized a letter he had received from Republican Governor Earl Warren
Earl Warren
Earl Warren was the 14th Chief Justice of the United States.He is known for the sweeping decisions of the Warren Court, which ended school segregation and transformed many areas of American law, especially regarding the rights of the accused, ending public-school-sponsored prayer, and requiring...

 praising him for a disability insurance proposal he had made. Nixon supporters asked Warren for a letter praising Nixon, or at least a retraction of the Voorhis letter. Warren refused, saying that Voorhis deserved the compliment, and Nixon would not receive an endorsement. This conflict began a contentious relationship between Nixon and Warren which lasted until Warren's death shortly before Nixon's resignation as President.

No polls had been taken during the campaign. On election night, Voorhis took an early lead in the vote count, but was soon overtaken by his challenger, whose margin increased as the night went on. Nixon defeated Voorhis by over 15,000 votes. The Republican won 19 of the 22 municipalities in the district, including Voorhis's home town of San Dimas
San Dimas, California
San Dimas is a city located in the San Gabriel Valley, in Los Angeles County, California. As of the 2010 census, the city had a total population of 33,371. The city historically took its name from San Dismas Canyon in the San Gabriel Mountains above the northern section of present day San Dimas...

. Voorhis won the Democratic strongholds of El Monte
El Monte, California
El Monte is a residential, industrial, and commercial city in Los Angeles County, California, United States. The city's slogan is "Welcome to Friendly El Monte," and historically is known as "The End of the Santa Fe Trail." As of the 2010 census, the city had a total population of 113,475,...

 and Monterey Park
Monterey Park, California
Monterey Park is a city in Los Angeles County, California, United States, east of downtown Los Angeles. The city's motto is "Pride in the past, Faith in the future"...

, as well as rural Baldwin Park
Baldwin Park, California
Baldwin Park is a city located in the central San Gabriel Valley region of Los Angeles County, California, United States. As of the 2010 census, the population was 75,390, down from 75,837 at the 2000 census.- History :...

. Time magazine's post-election issue came out in mid-November, and it praised the future president for "politely avoid[ing] personal attacks on his opponent".

Candidates

The day after the election, Voorhis issued a concession statement, wishing Nixon well in his new position, and stating:

I have given the best years of my life to serving this district in Congress. By the will of the people that work is ended. I have no regrets about the record I have written. I know the principles I have stood for and the measures I have fought for are right. I know, too, that, in broad outline at least, they are vital to the future safety and welfare of our country. I know the day will come when a lot more people will recognize this than was the case on November fifth.


Former congressman Hoeppel, who gathered just over one percent of the vote, wrote Nixon after the election, stating that he had never expected to win, and that his purpose had been "to expose what I considered to be the alien-minded, un-American, PAC, Red, congressional record of the Democratic incumbent". Despite any hard feelings, Voorhis sent Nixon a letter of congratulations in early December 1946. Nixon and Voorhis met for an hour at Voorhis's office, and parted, according to Voorhis, as friends. In 1971, Voorhis said that the two had never spoken again. Voorhis's final letter as a congressman, written on December 31, was to his father, who had been his political adviser throughout his congressional career. Representative Voorhis wrote, "It has been primarily due to your help, your confidence, your advice ... above all to a feeling I have always had that your hand was on my shoulder. Thanks ... God bless you."

Voorhis never ran again for political office, working as an executive in the cooperative
Cooperative
A cooperative is a business organization owned and operated by a group of individuals for their mutual benefit...

 movement for twenty years after his defeat. Hoeppel continued as publisher and editor of National Defense magazine, a publication for veterans, until his 1960 retirement, and died in Arcadia
Arcadia, California
Arcadia is an affluent city in Los Angeles County, California, United States, and located approximately northeast of downtown Los Angeles in the San Gabriel Valley and at the base of the San Gabriel Mountains....

 in 1976 at age 95. Nixon served two terms in the House, and in 1950 was elected to the United States Senate
United States Senate
The United States Senate is the upper house of the bicameral legislature of the United States, and together with the United States House of Representatives comprises the United States Congress. The composition and powers of the Senate are established in Article One of the U.S. Constitution. Each...

, continuing his political rise, which would lead him to the White House in 1969.

Historical issues

The 12th district race of 1946 was little noticed at the time. As Nixon became prominent, the 1946 race was scrutinized more closely. Nixon biographer Herbert Parmet noted, "Except for Nixon's subsequent reputation, what happened in California's Twelfth would have been indistinguishable from campaigns across the country to elect the Eightieth Congress." Jonathan Aitken
Jonathan Aitken
Jonathan William Patrick Aitken is a former Conservative Member of Parliament in the United Kingdom, and British government minister. He was convicted of perjury in 1999 and received an 18-month prison sentence, of which he served seven months...

, also a biographer of Nixon, attributes the later scrutiny to "the unexpected toppling of a liberal icon and [the Democratic Party's] regret over the meteoric rise of the new Republican hero who won the seat".

Nixon's defeat of Voorhis has been cited as the first of a number of red-baiting campaigns by the future President which elevated him to the House, the Senate, the Vice Presidency, and eventually put him in position to run for President. Nixon, in his 1978 memoir, stated that the central issue in the 1946 campaign was "the quality of life in postwar America", and he won because voters "had 'had enough,' and they decided to do something about it". Voorhis, in his 1947 memoir, indicated that the "most important single factor in the campaign of 1946 was the difference in general attitude between the 'outs' and the 'ins'. Anyone seeking to unseat an incumbent needed only to point out all the things that had gone wrong and all the trouble of the war period and its aftermath."

In later years, Voorhis had more to say about the reasons for his defeat. In 1958, he alleged that voters had received anonymous phone calls saying that he was a communist, that newspapers had stated that he was a fellow traveler, and that when Nixon got angry, he would "do anything". In November 1962, after Nixon's defeat in the California gubernatorial race, Voorhis appeared on Howard K. Smith
Howard K. Smith
Howard Kingsbury Smith was an American journalist, radio reporter, television anchorman, political commentator, and film actor. He was one of the original Edward R. Murrow boys.-Early life:...

's News and Comment
Howard K. Smith: News and Comment
Howard K. Smith: News and Comment was a half-hour ABC news and documentary program hosted by commentator Howard K. Smith , which aired from February 14, 1962, to June 16, 1963...

program on ABC
American Broadcasting Company
The American Broadcasting Company is an American commercial broadcasting television network. Created in 1943 from the former NBC Blue radio network, ABC is owned by The Walt Disney Company and is part of Disney-ABC Television Group. Its first broadcast on television was in 1948...

 in the episode entitled "The Political Obituary of Richard M. Nixon" and complained about the way Nixon had conducted himself in the 1946 race. Voorhis's appearance was overshadowed by the controversial participation of Nixon adversary Alger Hiss
Alger Hiss
Alger Hiss was an American lawyer, government official, author, and lecturer. He was involved in the establishment of the United Nations both as a U.S. State Department and U.N. official...

. In 1972, Voorhis authored a book, The Strange Case of Richard Milhous Nixon, in which he stated that Nixon was "quite a ruthless opponent" whose "one cardinal and unbreakable rule of conduct" was "to win, whatever it takes to do it". In 1981, three years before his death, Voorhis denied in an interview that he had been endorsed by the NCPAC.

In his memoirs, Voorhis alleged that in October 1945, "a representative of a large New York financial house" journeyed to California to meet with a number of influential Californians and "bawl them out" for allowing Voorhis, whom the New Yorker supposedly described as "one of the most dangerous men in Washington", to remain in Congress. In an early draft of his memoir, Voorhis wrote that he had documentation showing that "the Nixon campaign was a creature of big eastern financial interests". Nixon biographer Roger Morris
Roger Morris (American writer)
Roger Morris, born 1937, is an American public servant, historian, and political writer.-Biography:Roger Morris earned his doctorate in government from Harvard University. He entered government service in 1966 as an aide to former United States Secretary of State Dean Acheson. He first joined the...

 suggested that the amount the Nixon campaign reported "was only a small fraction of what actually went into the campaign." According to Morris, the Committee of One Hundred represented wealthy interests, and Nixon benefited from "the University Club ... the corporate levies, the vastly larger forces arrayed against Voorhis". Nixon himself addressed this point in his memoir:
As I moved up the political ladder, my adversaries tried to picture me as the hand-picked stooge of oil magnates, rich bankers, real estate tycoons and conservative millionaires. But a look at the list of my early supporters shows that they were typical representatives of the Southern California middle class: an auto dealer, a bank manager, a printing salesman, and a furniture dealer.

Nixon biographer Irwin Gellman, writing in 1999, nine years after Morris, disagreed with the latter's conclusions. Gellman argued that the Committee was a "grassroots" group which was "far from sophisticated" in its efforts to find a candidate. Parmet wrote that the campaign was not well financed, "Nixon had to learn that money would be scarce until he became a winner ... The Nixon campaign of 1946 did look like a shoestring affair." Aitken points out that Nixon spent no money on radio advertising during the campaign.

Other allegations center on Murray Chotiner, painting him as the evil genius of the campaign. Voorhis, for example, in his 1972 book, deemed himself "the first victim of the Nixon-Chotiner formula for political success." Several writers, including Kenneth Kurz in his book, Nixon's Enemies, and Ingrid Scobie in her biography of Helen Douglas, Center Stage, describe Chotiner incorrectly as Nixon's 1946 campaign manager. Part of this inflation is due to Chotiner himself, who, in later years, lost no opportunity to exaggerate his role in the 1946 race, to the annoyance of Day and McCall. According to Nixon biographer Stephen Ambrose
Stephen Ambrose
Stephen Edward Ambrose was an American historian and biographer of U.S. Presidents Dwight D. Eisenhower and Richard Nixon. He was a long time professor of history at the University of New Orleans and the author of many best selling volumes of American popular history...

, "Nevertheless, the legend grew. In the eyes of Nixon's critics, as a candidate he was merely a front man for Chotiner's evil manipulations. But it simply was not so."

A number of biographies on Nixon or Voorhis, or which otherwise touch on the 1946 campaign, state with varying degrees of certainty that during the final weekend of the campaign, anonymous calls were made to district households. The caller would ask "Did you know Jerry Voorhis is a communist?" and then hang up. According to Bullock, there was a phone bank staffed by workers who had responded to a newspaper ad, run by the Nixon organization in Alhambra. Bullock cites as his source for this Zita Remley, a "Voorhis admirer", who stated that her niece had worked there. Though the niece died before Bullock's book was written, according to Bullock, Remley's "reputation for veracity is unchallengeable".

Campaigns

Nixon spent most of 1946 campaigning in the district, and worked hard to extend his name recognition beyond his hometown of Whittier. In 1952, as Nixon ran for Vice President, the Madera News-Tribune set forth its view of why Nixon beat Voorhis, "He rang doorbells, he talked on street corners and in auditoriums, he kissed babies, patted old ladies on the cheek, and otherwise made himself known wherever and whenever two people would stop and listen to him. He made friends with the press and radio, he went out of his way to be congenial and likable." Bullock indicated that regardless of the tactics used, Nixon would likely have beaten the incumbent given the national Republican tide that swept the party into power in the House of Representatives for the first time since 1931.

Starting in the primary, the Nixon campaign made determined efforts to woo the district's newspapers. The campaign targeted smaller papers, especially the small weekly newspapers that were distributed for free; Republican surveys found that these were widely read and trusted. Nixon supporter and Republican National Committee
Republican National Committee
The Republican National Committee is an American political committee that provides national leadership for the Republican Party of the United States. It is responsible for developing and promoting the Republican political platform, as well as coordinating fundraising and election strategy. It is...

man from California McIntyre Faries arranged to buy ads on behalf of the Nixon campaign on condition that the newspaper run an editorial at its direction (most of the papers were, in any event, Republican in their outlook). These efforts paid off; 26 of the 30 newspapers serving the district endorsed Nixon. According to Nixon biographer Morris, Voorhis was given no coverage in newspapers, or limited to small paid advertisements. The paper owners told the Voorhis campaign that, with the postwar paper shortage, space had to be saved for regular customers.

Voorhis's campaign, described by Bullock as "traditionally amateurish and poorly put together", was slow to perceive the threat presented by Nixon and remained continually on the defensive. In 1971, in an article marking the 25th anniversary of the campaign, Voorhis acknowledged that "I never had much of an organization; frankly, there was no form to it. And we needed it badly in 1946." In the same article, the Los Angeles Times
Los Angeles Times
The Los Angeles Times is a daily newspaper published in Los Angeles, California, since 1881. It was the second-largest metropolitan newspaper in circulation in the United States in 2008 and the fourth most widely distributed newspaper in the country....

described Voorhis's campaign as "undermanned, underfinanced, outgunned, outmaneuvered and he apparently was on the wrong side of most of the issues of the day". His one avenue of outreach in the press was his newspaper column, People's Business, which ran in most local newspapers. In July 1946, Voorhis chose to suspend this column lest it be thought that he was using it as a means of campaigning. According to Gellman, this weakened Voorhis's political outreach.

One blunder identified by Gellman was Voorhis's decision to debate Nixon, as it raised the challenger's profile to the same level as the incumbent's. This decision was described by Morris as "quiet hubris". Nixon later stated, "In 1946, a damn fool incumbent named Jerry Voorhis debated a young unknown lawyer, and it cost him the election." Gellman itemized Voorhis's other errors: "He never established a viable Democratic organization; instead he relied on his father and friends to evaluate voters' likely habits. Rather than return to campaign in the primary when he recognized Nixon's attractiveness, he remained in the capital, allowing Nixon to court newspaper publishers and reporters as well as constituents who wanted to have firsthand contact with their congressional representative. Even when Voorhis returned to the district, he made one blunder after another."

Ambrose summed up his chapter on the 1946 campaign:

For Whittier and the 12th district, Nixon's first campaign produced the first Nixon haters and the first group of Nixon supporters. This was a consequence of his campaigning style and his penchant for polarizing his constituents over basic issues. The numbers of both groups would grow in the years ahead, until virtually everyone in the nation belonged to either one or the other.

General election, November 5, 1946

Democratic

Republican

Prohibition

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