1 MC origins: rap and spoken word poetry
The shared forms and tenets of spoken word poetry and rap are prominent and many. Just as the boundaries between genres of music ebb and flow, the lines and limits between rap and poetry are likewise fluid and open. It can be difficult attempting to fully separate the two when defining their relationship, as their function and history intertwine so.
Some see rap as one natural progression in African American oral forms, and strong cases can be made tracing the lineage between rap and forms such as the talking blues and oral storytelling. Amiri Baraka, marked figure of contemporary African American arts and founder of the Black Arts Movement (BAM), discusses what he terms as the “changing same” in his criticism of Black music and art forms, referring to the constant evolution of art that is necessary in order to keep the core spirit of expression consistent. Of contemporary rap he stated in 2010:
Music changes because the people change…but the forms are more closely related than people think. Rap is nothing but a modern blues. You listen to old Lightnin’ Hopkins or one of them old blues singers, the form is not too far from something say Tupac would use…There’s no great difference between rap and talking blues. That’s why rappers are always sampling people, because they can feel the continuity.1
Sarah Webster Fabio, another influential proponent of African American art and education, describes this intrinsic connection between African American art forms as “a lifeline which extends from the early slave/work songs and religious spirituals and folktales to James Brown’s ‘Staggolee’ and Jimi Hendrix’s ‘Dolly Dagger.’”2 Therefore, when tracing the lineage of rap and its forebears, it can be appreciated that this extends much further back into history than the immediately preceding forms, such as the blues or spoken word of the twentieth century.
To chart the history of modern spoken word and rap, it is crucial to recognize the age-old traditions of oral performance and storytelling in African culture. From oral folk tales to traveling griots, oral forms have long been an integral element of communication within African communities. And, despite historic attempts to suppress indigenous African culture in America, these forms remain a congenital part of African American expression. As Baraka stated: “Afro-American culture is strong, that’s why it still exists…You can remove people from a place, but they carry their culture with them…because that’s shaped their way of thinking, that’s the way they think.”3
African-style orality in the form of spoken word poetry came to notable prominence in the American popular conscience in the twentieth century. Around the time of the Harlem Renaissance of the 1920s, jazz poetry became popular, as poets like Langston Hughes experimented with developing their writing in accordance with jazz rhythms, utilizing freestyle approaches and incorporating various subversions to form.
Free-form jazz poetry was then embraced in the 1950s by figures of the Beat Generation, such as Allan Ginsberg, William S. Burroughs, and Jack Kerouac, who were drawn to the style as an alternative to mainstream, nuclear America. The immediacy and spontaneity of live performance and creation also suited the Beat taste for hedonistic forms and pursuits.
Popular spoken word poetry became more overtly political in the 1960s as artists such as the Last Poets, Sonia Sanchez, the Watts Poets, and Amiri Baraka, among others, spoke out in accordance with the era’s civil rights movement (see case study 1, on the BAM below). During this epoch, the direct nature of oral forms, coupled with the inherent Black aesthetic, served to carry pressing messages of racial inequality.
In the 1970s came the greatly influential poet and musician Gil Scott-Heron, whose political poems such as “Whitey on the Moon” (1970) and “B-Movie” (1981) remain pertinent examples of how rhythm and melody can perfectly offset uncomfortable truths and deep messages. In more recent times modern spoken word artists such as Saul Williams, Paul Beatty, and Ursula Rucker, to name just a select few, continue to create spoken word poetry and frequently collaborate with contemporary musicians.
Both African American music and literature have historically gravitated toward each other. Scholar Fahashima Patricia Brown has noted that “Both African American poets and musicians have recognized interrelationship between their arts…a continuum between music and literature.”4 Furthermore, African American forms of literature and music both tend to have ingrained speech-like rhythms. For instance on the use of rhythm and nuance in the blues, Baraka states that “Afro-American speech is itself close to the blues. It’s the way people talk; the way they slur the words, the way they draw out the words and the meanings. You can give one word several different meanings just on emphasis of it.”5 The diverse array of sounds that can be used in order to play and communicate different meanings is reflective of the pastiche nature of African American speech that Brown describes:
In the sacred and secular traditions of African American vernacular cultural expression, we can identify modes of language performance: sermon, testimony, and prayer as performed in the traditional Black Church; public orator in the spheres of political and social life; children’s games and jump-rope rhymes: “playin the dozens”; rappin’ and signifyin’; tall tales, including toasts and boasts; and the lyrics of the spirituals, shouts, jubilees, gospel songs, field hollers, work songs, blues, jazz, and popular songs. In form, subject, and theme, all of these elements are present in African American poetry.6
Rap likewise incorporates a spectrum of aural styles and techniques, often mimicking the various modes that Brown outlines above. However, it is essential to recognize rap’s unique quality of being an oral form that arose from hip-hop and that shares a certain sensibility and “cadence” with the genre, particularly in order to resolve the confusion that can arise when considering rap that is not poetry.7 Many raps are formulated with no designs or intention for the poetic, often more for entertainment value. Styles of rap and lyrical content can vary greatly, but the unifying quality that, for better or for worse, links up the diverse array of rap is the signature hip-hop flow and aesthetic. Rap is not simply a type of spoken poetry, but a relation in the family tree of Black artistic expression. Rap can therefore take inspiration and borrow from preceding spoken word works and styles, while standing independently as an individual member of the family.
So while it is not quite so simple as to state that the spoken word poets such as Amiri Baraka and the Last Poets were somehow the original rappers, the influence and similarities between the poets that preceded rap and rap innovators are apparent.
When tracing the lineage of rap and poetry, active poet and MC of the Project Blowed movement in Los Angeles, Abstract Rude, clarifies that “poetry is old as dirt; rap is dated back to early ’70s with roots out of funk/soul movements.”8 Credited with being the first MCs are the likes of Coke La Rock, Kool Herc, DJ Hollywood, and Kurtis Blow, who would “talk-over”9 the DJ with the intention of encouraging people to dance and raise the energy levels of a crowd. DJ Eddie Cheeba, frequently touted as a “pioneer” of rap, says of the need for MCing over the music in nightclubs: “These people go to discos every week and they need more than music to motivate them…I not only play records, but I rap to them and they answer me.”10 The original intention of MCing was to engage with the audience and build a rapport, and in order to do so and maintain interest levels, the art of MCing expanded. Kurtis Blow says of DJ Hollywood’s rhythm and how he inspired him to want to rap:
Before 1976, MCs would just work the crowd; introduce people and stuff. “You’re rocking with the number one DJ, somebody say, ‘Oh yeah’” type of stuff. But DJ Hollywood was a rapper too, and he was actually the first rhythmic rapper I ever encountered.…He’d do long, rhythmic verses and just moved the audience.11
Similarly credited with being the first “rhyme technicians” to advance their rapping by engaging poetic nuances and innovations in rhythm were DJ Kool Herc’s MC Coke La Rock and the Furious Five’s Kid Creole and Melle Mel. Forefather DJ Grandmaster Flash summarizes: “Kid Creole and Melle Mel were the first to really flow and have a poetic feel to their rhymes. They were the first rhyme technicians. They were the first to toss a sentence back and forth…Along with Coke La Rock with Herc, they were the root.”12
Then, as the hip-hop movement gained ground and grew, with more artists taking inspiration and becoming involved, developments in styles of rap began to surface and push the form forward. Once innovation in rap began to perpetuate, the parallels between rap and spoken word poetry became more pronounced, and instances where the two cross over became plentiful. Many factors can be attributed to rap flourishing, as increased participation and a need to carve out one’s own distinct voice or niche, coupled with hip-hop’s intrinsic competitiveness, pushed the attention paid to form and creative intent. In exploring the possibilities of rap as a medium, rappers were able to experiment, channeling and taking cues from spoken word poets before them, and thus strengthening the connection between rap and spoken word.
For some, the influence of spoken word poetry on certain rappers is clear, whether through delivery style, explorations in poetic form, or through allusions to those poets and their work. For instance, on the classic hip-hop track “DWYCK” (1994) by Gang Starr and Nice & Smooth, Guru states, “Poet like Langston Hughes and can’t lose when I cruise,” which follows the tradition of boast rap by lining himself up alongside the highly influential and respectable figure Langston Hughes, who was a key proponent of jazz poetry. Earmarking an influence of his, he simultaneously partakes in the ancient African mode of “toasting” and “boasting” by comparing his status to that of Hughes and, like an African griot, educates his audience by dropping in the name of a seminal African American literary figure.13
Just as Baraka is keen to outline the influence of Black music and rhythm on the content and aesthetic feel to his poetry and writing, several MCs who are noted for dexterous lyrical composition and flow have been likened to preceding jazz artists for the similarities in their sound, including Nas, Busta Rhymes, and Big Daddy Kane, to name just a few. Frequently touted as one of the most accomplished and influential MCs, Rakim readily notes the influence of jazz artists on his rap style: “The thing about the way I styled my rap, drawing from Coltrane and Parker or James B., and building off the flow that they had, that was because that’s the music that surrounded me.”14 Similar ripples of inspiration can often be traced in the respective works of poets and rap artists who have been exposed to the same canon of music, as both take influence from those sources. In the case of twentieth-century poetry and rap, the history and times are close enough for rappers with an awareness and alertness of history to be reacting to shared, or at least partly shared, reference points to those who came before.
As well as being labeled a “poet” by key BAM figure and spoken word poet Sonia Sanchez, Rakim has been credited with raising the bar for rap by initiating the use of multi-syllable flows.15 Noah Callahan-Bever, editor of Complex Magazine, says: “Before him people rhymed very simply, one syllable the last word of every line would rhyme, very much in the style of Run DMC. He came and brought the idea of variable multi-syllable flow, and that really set the tone for everything that would come after it.”16
Within both underground and mainstream hip-hop, those who use such rhyme patterns are often regarded as lyrically adept at mastering dense and more complex multi-syllabic formations. The former Juice Crew member Masta Ace, for instance, utilizes very measured compound rhymes in his lyrics, serving his stylized and clean delivery. In “Born to Roll” (1994) he tells us how he: “Throws crazy blows and they knows I be plastering.” The flow is unique and recognizably Ace’s. Alongside this Ace also frequently uses repetition in his verses for flair, which lightens and makes his lines more catching. Later in “Born to Roll” he relays: “Drivin’ down the block like what else should a brother do/ It’s Saturday, it’s Saturday, the heat might smother you.”
Another prominent rapper to use dense multi-syllabic rhyme formations is the former Leaders of the New School member Busta Rhymes.17 In contrast to Ace, Rhymes works with his own distinct style which is arresting and frenetic, though still tight and consistent. His flow has been likened to that of a “jazz trumpeter” by contemporary jazz musician and producer Robert Glasper: “He’s an underrated rapper in general to me. Rhythmically? He phrases his rhymes like a jazz trumpeter; it’s like listening to a jazz trumpet listening to Busta Rhymes. And you can understand everything he’s saying.”18 On 1998’s “Gimme Some More,” Rhymes comes in on the second verse with “Flash with a rash gimme my cash, flickin’ my ash/ Runnin’ with my money son go out with a blast,” squeezing four rhymes into the first line, and returning to the same half-rhyme at the end of the second line.
Just as the rhyme schemes and structures used by rappers vary greatly with regard to style, so does the level of complexity within the lyrics. When talking of Rakim, Bay area poet and writer D. Scot Miller says: “Lyrically I can’t think of anybody who could even come close to him, still. Except one person: Q-Tip. When I find myself in intellectual or existential crisis, a lyric from him can actually pull me out of the doldrums.”19
Native Tongues MC Q-Tip,20 of the widely influential group A Tribe Called Quest, tends to rhyme in couplets, for instance the playful “I Left my Wallet in El Segundo” (1990) opens with the simple and straightforward: “My mother went away for a month-long trip/ Her and some friends on a ocean liner ship/ She made a big mistake by leaving me home/ I had to roam so I picked up the phone.” And so the cult story of mischief and variable luck starts. The real complexity to Q-Tip’s lines, however, lies within the layered meanings and strong metaphors that he conjures and implements to communicate his messages.
On the same album as “I Left my Wallet in El Segundo,” People’s Instinctive Travels and the Paths of Rhythm, is the prophetic track “Footprints.” In this song Q-Tip draws parallels between creating new music and traversing the globe, as well as directly comparing the members of his “Tribe” to roamers exploring the world, charting new musical territory. “The valleys of time, are always on my feet/ At least the beat will combine/ The calluses and corns with the funky bassline.” He plays on the idea of how success and wealth can alter what you create and leave behind, advocating organic formats: “If you’re a megastar, worth will buy you a car/ I’d rather go barefooting, for prints I will be putting.” Painting an image of himself and his fellow musicians as pilgrims on a mission he says: “Hand in hand ’cross the land as Muhammad cross the fade/ It’s a Tribe who meanders, precious like a jade.” He offers up wisdom on deviating from the beaten path, using wordplay on the double meaning of track as either song or path: “Catch the track, track to track, get a map to track a trail/ You will find yourself behind for a map does not prevail.” Throughout “Footprints” the use of imagery and metaphor is consistent, cohesive, and multi-faceted.
The progression made in rap to incorporate innovative structural and stylistic form, as well as conscious and intelligent lyrical content, akin to spoken word poetry, follows a tradition in African American music and oral forms to have words and content alongside music and rhythms.
On this evolution, Fahashima Patricia Brown has noted: “Each generation brings its own vocabulary and its own set of issues to the mix that constitutes African American vernacular culture, including its poetry…generations mark the changes on the tradition of the vernacular ‘same.’”21 The sounds and content may differ, but the common thread of expressing and communicating topical issues alongside rhythm is present through to the hip-hop generation. With a multitude of similarities, shared influences, and also of marked differences, spoken word poetry and rap stand separately and complementarily alongside one another in the lineage of African American artistic forms.
Case study 1: the Black Arts Movement (BAM)
Following on from the Harlem Renaissance of the 1920s, which embraced and elevated African American modes and styles of expression, creating art pour l’art, the BAM was birthed in the mid 1960s and lived through until the mid 1970s. The BAM continued to advocate and celebrate distinctly Black aesthetics to the point of differentiation, but, blossoming around the same time as the Civil Rights movement in America, did so with very acute political prerogatives. As radical ideas about Black identity for the time were pushing forward, the BAM took a markedly confrontational and provocative approach.
Spearheaded by poet, playwright, and political activist Amiri Baraka (formerly LeRoi Jones), the movement sought to uphold and utilize distinctly Black modes of expression and empower the Black community. The BAM is often viewed in line with the Black Power and Black Panther movements, and it has been noted how “black poets, literary critics, and theorists achieved an exceptional level of national visibility…[and] produced a body of texts that exuded the spirit of Black Power self-determination and amplified the vibrant, versatile rhythms of African American expressive culture.”22
The Black Arts Repertory Theater/School was established in Harlem in 1965. Fittingly, performance and oral forms were the favored modes used, and while not the only medium explored, spoken word poetry played a considerable role within the movement. The potential to play with and manipulate sound and words ignited the movement’s deliberately provocative and revolutionary messages. The visceral element to spoken word also allowed the poetry to create an immediate impact upon listeners, in line with the movement’s intentions. Baraka’s iconic poem “Black Art,” which calls for “poems that kill” and in delivery mimics bullet shots and war-planes, has been deemed a poetic manifesto of the Black Arts literary movement.23
While the movement garnered much criticism for its aggressive tone and violent imagery, the powerful example that it set has inspired, and continues to inspire, many. James Edward Smethurst writes on how this relates to the hip-hop generation:
The Black Arts movement made a considerable impression on artists and intellectuals too young to remember its events first hand. Many of the more explicitly political hip-hop artists owe and acknowledge a large debt to the militancy, urgent tone, and multimedia aesthetics of the Black Arts movement and other forms of literary and artistic nationalism.24
As a result, interactions between BAM poets and contemporary hip-hop artists have tended to be potent, natural, and numerous. When Amiri Baraka collaborated with hip-hop group the Roots on the track “Something in the Way of Things (In Town)” (2002), his style of poetry was made relevant to modern, underground audiences through the juxtaposition of his distinctive voice and delivery against jazz and drum and bass inflected electronic production. Similarly, in the collaboration between Chuck D of Public Enemy and the Last Poets on The Time Has Come, the shared experiences and sensibilities between their respective generations is made clear, as is the likely influence of the Last Poets on key outspoken figures in hip-hop such as Chuck D.
Also reflective of the mutual respect that the spoken word and hip-hop scenes hold for one another, and how easily they can interplay, is Def Jam’s Russell Simmons’s HBO venture Def Poetry (also known as Def Poetry Jam). Hosted by Mos Def, the show has seen performances by Sonia Sanchez, Nikki Giovanni, and Amiri Baraka alongside contemporary artists such as Jamie Foxx, Erykah Badu, and Jill Scott, as well as up and coming young poets. In this set-up oral traditions once again provide a means for older generations to communicate and engage with the youth, and for the young to learn from and interact with those who came before them.
Case study 2: Project Blowed
Like a cross between a church and a sports locker room.
A family-run health food café in South Central, Los Angeles was the perfect setting for a unique movement that served up raw hip-hop: Project Blowed. In the documentary This Is the Life, Monalisa Murray astutely recalls, “If you are into organically grown, unmanufactured, unprocessed hip-hop, just raw hip-hop, that’s where you go.”26
The movement grew out of a hip-hop open-mic night which started in 1994, run by B. Hall and her son R. Kain Blaze at the Good Life Café. The weekly session ran each Thursday, and provided a space for young MCs, poets, producers, and dancers to perform and share their work. As Marcyliena Morgan writes in the introduction to The Real Hiphop: Battling for Knowledge, Power, and Respect in the LA Underground, “If you were a young person who loved hip-hop and could rhyme, dance, write, and draw, and you searched for real knowledge and wanted to be recognized and respected – and had respect for others – then the Good Life was a lyrical heaven on earth.”27 Many underground West Coast artists came up through the Good Life, including Freestyle Fellowship, Abstract Rude, and Jurassic 5, and, as the cult status of the open-mic night grew, many influential names in hip-hop, as well as celebrities, began to pass through.
The Good Life Café operated various rules, which contributed to the unique energy and output tremendously. B. Hall enforced a strictly no-cussing rule, which elevated the feeling that it was a serious arts workshop, and also made rapping and freestyling more challenging. Of the decision B. Hall says: “You can’t move forward. And that’s what we were trying to do, use culture, go back to our original culture, which is honoring the word. That is why you don’t use profanity.”28 This boundary in particular encouraged MCs and poets to stretch their creativity, which in turn pushed the poetic quality to their rhyming and freestyling. Those who took part in the Good Life were challenged to experiment with form, concept, and delivery. As a result many prominent figures of the scene developed brilliantly original personas, such as NgaFsh, a part of the Chillin’ Villian Empire (C.V.E.), whose output centered on aquatic imagery and allusions.
The atmosphere of the Good Life was notoriously honest and unforgiving to those who did perform. If the crowd were unimpressed, chants of “please pass the mic” would oust performers from the stage, humiliating them in the process. It was this harsh standard-setting, however, that encouraged those involved to push and hone their respective crafts further, and inspired those young artists to be the very best that they could. For this, the deep-voiced MC Chali 2na of Jurassic 5 states that it “became a mecca for skill.”29
While the predominant form of expression at the Good Life was rap, when asked about the balance of spoken word and rap, Abstract Rude concedes that: “the best, most entertaining rappers had this element of spoken word to their flow. If the beat would stop they could keep going acapella or freestyle even, or, they would do a long acapella before or after their set. So it definitely had a strong spoken word undertone more so than an equal balance of the two.”30 Within this rap setting there is a strong reverence for spoken word freestyle.
Arguably one of the most crucial acts to arise from the Good Life Café was the Freestyle Fellowship. Consisting of MCs Aceyalone, Myka 9, P.E.A.C.E., and Self Jupiter, the quartet incorporated experimental jazz styles into their rap patterns and delivery. They were also adept at incorporating spoken word flows into their verses. Myka 9 talks of how he started out visiting coffee houses:
I’d get sparked on the coffee and would kick my hip-hop lyrics in a spoken word cadence. At some point I’d start writing spoken word rhymes. It grows in a rap cadence when on a hip-hop beat. You might have a verse or a chorus or a bridge, and want to sacrifice or supplement that with a spoken word segment. It’s another way to be creative with your approach to the arrangement of a song, the composition.31
Also in keeping with the spirit of the Good Life Café, and their group name, the members of Freestyle Fellowship are firm proponents of the merits of being able to freestyle as an artist. Myka 9 continues:
You can freestyle as a ride to your approaches. Freestyle holds on to your skill and your cypher, and also helps break your own melody if you are writing a song. You can freestyle and then go back and re-transcribe your material. Also, you can do a “one-take-Jake” when you are so tapped in that it’s like a song is flowing through you spontaneously. Those are bright moments indeed.32
Freestyle Fellowship’s fluid and experimental approach to creating music blurs the boundaries between rap and spoken word, thus exemplifying how closely connected the two artistic forms are.
Conclusion
Both case studies serve to show the interplay between spoken word poetry and hip-hop, in light of their unique histories and shared lineage. When considering the BAM the impact and influence that political spoken word poetry of the movement has had on the hip-hop generation is clearly discerned. In highlighting Project Blowed of the Good Life Café it is possible to see how the experimental and progressive nature of rap as an oral form so closely relates to spoken word poetry, and how rap borrows from spoken word. In comparing the two forms of rap and spoken word, the merits and achievements of both are illuminated and the two can be appreciated as important and equal entities.
Notes
1 Amiri Baraka, interview with the author (London: Southbank Centre), December 20, 2010.
2 , “Boss Soul Notes,” in Boss Soul (New York: Folkways Records and Service Corp., 1972).
3 Baraka interview.
4 , “Song/Talk: African American Music and Song as Poetic References,” in her Performing the Word: African American Poetry as Vernacular Culture (New Jersey: Rutgers University Press, 1999), p. 74.
5 Baraka interview.
6 Brown, Performing the Word, p. 8.
7 Myka 9, interview with the author (Los Angeles: The Vanguard), October 8, 2011.
8 Aaron Pointer, Abstract Rude, interview with the author (London–Los Angeles), June 10, 2013.
9 Similar behavior was occurring in the Jamaican music scene with a similar phenomenon of DJ “talk over” or “toasting” by DJs such as U-Roy and King Stitt in the 1960s and 1970s.
10 , “Jive Talking N.Y. DJs Rapping Away in Black Discos,” Billboard, May 5, 1979, p. 3, in and (eds.), That’s the Joint! The Hip-Hop Studies Reader (New York: Routledge, 2004), p. 43.
11 , “Blessed the Mic: The Kurtis Blow Interview,” Wax Poetics, August 13, 2012.
12 Nelson George, “Hip-Hop’s Founding Fathers Speak the Truth,” in Forman and Neal, That’s the Joint!, pp. 51–52.
13 , “Soul Sonic Forces: Technology, Orality, and Black Cultural Practice in Rap Music,” in her Black Noise: Rap Music and Black Culture in Contemporary America (Middletown, CT: Wesleyan University Press, 1994), p. 64.
14 , “Dedicated: Microphone Fiend Rakim is Back,” Wax Poetics, May 2, 2010. For more on Rakim, see Chapter 24 in this volume.
15 Rakim interview on BET. Available at www.youtube.com/watch?v=OLB3oLSzY5A (accessed October 13, 2013).
16 Rakim: The Definition of a Classic. Available at http://vimeo.com/45722608 (accessed October 13, 2013).
17 Leaders of the New School were a New York hip-hop group formed in 1989 and consisting of Busta Rhymes, Charlie Brown, Dinco D, and Cut Monitor Milo.
18 Robert Glasper, interview with the author (San Francisco: Yerba Buena Center of the Arts), September 29, 2011.
19 D. Scot Miller, interview with the author (Oakland, CA), October 13, 2011.
20 The Native Tongues were a hip-hop collective of like-minded groups, primarily based on the East Coast. Notable core members include the Jungle Brothers, A Tribe Called Quest, De La Soul, Black Sheep, and Monie Love, among others.
21 Brown, Performing the Word, p. 122.
22 and , “Reform and Revolution, 1965–1976: The Black Aesthetic at Work,” in The Cambridge History of African American Literature (Cambridge University Press, 2011), p. 405.
23 , Black Art (with LeRoi Jones reading) (USA: Jihad Productions, 1965).
24 , “Introduction,” in The Black Arts Movement: Literary Nationalism in the 1960s and 1970s (University of North Carolina Press, 2005), p. 3.
25 Aaron Pointer, Abstract Rude interview.
26 This Is the Life: How the West Was Won, dir. Ava DuVernay (Forward Movement, 2009).
27 , “Introduction: I Am Hip-Hop,” in her The Real Hiphop: Battling for Knowledge, Power, and Respect in the LA Underground (Durham, NC: Duke University Press, 2009), p. 3.
28 This Is the Life.
29 Ibid.
30 Pointer, Abstract Rude interview.
31 Myka 9, interview with the author.
32 Ibid.
