Mill on Censorship of COVID-19 Misinformation

Content

Abstract

1. Introduction

2. Social Media Censorship

3. Censorship of True Statements

4. Censorship of Wrong Statements
4.1. Perceived Infallibility Hinders Exchange from Error to Truth
4.2. Danger of Dead Dogma
4.3. Censorship Forbids the Most Persuasive Form of an Argument
4.4. Legitimacy of Opinion through Debate
4.5. Every Opinion is Worth Being Heard

5. Eventual Limitations

6. Conclusion

7. Literature

Abstract

With a surging number of COVID cases, social media companies come under pressure to restrict the free flowing and harmful misinformation on the effectiveness of the measures against COVID and the vaccinations. Whilst the detrimental effects of misinformation on public health are being researched thoroughly, the negative consequences of censoring misinformation receive only little attention. This paper presents John S. Mill’s arguments against censorship of misinformation and applies them to COVID. The main five findings are the following: Firstly, there is always a possibility that COVID-related “mis”information is true and the truth is being censored. Secondly, with censorship, the scientific opinion on COVID loses its clear perception of truth. Thirdly, censorship comes with the risk of creating a dead dogma, where people accept the COVID measures and vaccines without questioning them first. Fourthly, the censorship of COVID-critics comes with a delegitimisation of the scientific opinion as an opinion is only complete when it also considers counterarguments. Fifthly, censorship is wrong in every case and according to Mill, silencing one person is equally unjustified as silencing mankind. Finally, these applications are to be viewed critically, as with the invention of the internet came disruptive societal change for social interaction and deliberation. In light of these developments, Mill nowadays would be likely to take a less strict approach on the necessity of free speech and the illegitimacy of censorship.

1. Introduction

The invention of the internet allowed for an unprecedented flow of information. In forums, people can now share their beliefs, be they right or wrong, with the whole world. The internet does not discriminate between the owner of a PhD and someone who failed basic education. This egalitarian internet world comes with its consequences; the spread of misinformation or upright fake news has never been easier and more powerful. Simultaneously to COVID-19 spreading, there has been a rise of misinformation and upright fake news about the virus, which is described by the term “infodemic”¹. The internet greatly facilitates the spread of misinformation and conspiracies, which has negative effects on the “individual responses” to COVID. Misinformation can be the cause for inappropriate responses to the virus, such as people not respecting social distancing or wearing a mask. Additionally, misinformation has the power to slow down the vaccination process.² Hence, by impeding measures on combating the spread of the virus as well as hindering the vaccination process, misinformation can have disastrous consequences on public health.³

Due to these detrimental effects of misinformation on public health, social media enterprises have faced increased pressure to stop the spread of misinformation on COVID-19. Facebook and Instagram, to name the two most notable examples, have set measures in place which rely on fact-checking and censorship.⁴

When misinformation is partly responsible for poor public health, it seems obvious that the censoring of such posts on social media is beneficial for the common good. However, there are more questions to be asked. Some of these questions include if it is morally desirable to allow censorship out of utilitarian calculations and if censorship should not be opposed in all cases, as censorship is wrong in itself and cannot ever become acceptable by providing better outcomes in a utilitarian sense.

Assuming that the spread of false information is protected by the freedom of speech, censorship of misinformation on COVID constitutes an offense against the Universal Declaration of Human Rights, where the preamble depicts the freedom of speech as one of the universal goals:

“ […] the advent of a world in which human beings shall enjoy freedom of speech and belief and freedom from fear and want has been proclaimed as the highest aspiration of the common people […] ”⁵

In order to answer the question if censorship regarding misinformation on COVID-19 can ever be justified, this paper will consider John Stuart Mill’s famous work “On Liberty”, where Mill makes strong claims for an unlimited freedom of speech and hence opposes censorship. Since freedom of speech and censorship are diametral, one can assume that more censorship leads to less freedom of speech. An urge for the necessity of freedom of speech can therefore also be considered an urge for the necessity of no censorship. This paper will use Mill’s general statements on freedom of speech and apply them to the contemporary discussion of censorship in light of misinformation on the spread and the prevention of COVID-19.

2. Social Media Censorship

Freedom of speech is generally considered as “right […] to express information, ideas, and opinions free of government restrictions based on content”⁶.

This is the definition by the Constitution of the United States. It is congruent with the definition of the German term “Meinungsfreiheit”. It is important to note that only government restrictions are considered as a limit of freedom of speech. However, this paper argues that the main threats to the freedom of speech in Western countries do not come in the form of government restrictions but rather in company-issued censorship and self-censorship out of the fear of negative repercussions of stating one’s opinion. These findings are consistent with the National Coalition against Censorship, which found Self-Censorship to be the third-most relevant threat to Freedom of Speech and social media sites such as Facebook and Instagram increasingly cracking down on misinformation and hence fostering self-censorship.⁷,⁸

This paper will widen the definition of freedom of speech by adapting the definition to “right to express information, ideas, and opinions free of restrictions based on content”. By eliminating the premise that limitations of freedom of speech must come in the form of restrictions imposed by the government, this paper can also consider the restrictions by companies as constraints to the freedom of speech. This new definition now allows to reflect on the question, what the renowned utilitarian philosopher John Stuart Mill would think about present-day measures of COVID-related censorship and its implications for the freedom of speech.

3. Censorship of True Statements

During each time period, there are beliefs and scientific evidence which enables some statements to be true and some to be false. However, the methods differ over time and humanity therefore comes to different conclusions in different times. While a few decades ago, it was nearly unanimously accepted that the sun evolves around the earth, current evidence suggests respectively proves that it is the other way round, that the earth revolves around the sun. Another example for science being wrong lies in atomic theory. Ancient Greek philosophers called the ultimate particle of something “atomos”, which translates to “uncut”.⁹ Atoms were believed to be “uncuttable” for centuries to come, with science still approving this premise in the 19th century¹⁰, until Ernest Rutherford disproved the indivisibility of atoms in 1918.¹¹

The point of these comparison is to bring attention to the fact that certain present-day statements which everyone assumes to be true, will prove to be wrong in the future. Of course, scientific methods are more reliable today than they were a hundred years ago. There, however, can never be absolute certainty on any subject, as it is always possible that any scientific observation is not based on regularity and occurred purely randomly. It would hence be wrong to speak of “misinformation” in this paragraph, as this chapter assumes that the information published by critics of COVID-measures and vaccinations is factual. These considerations are best being considered in Mill’s own words:

“The peculiar evil of silencing the expression of an opinion is, that […] if the opinion is right, they are deprived of the opportunity of exchanging error for truth […]¹²

The main outtake of this quote, which will be examined in detail in the next chapter, is that if a correct opinion is being expressed, as we assume it to be, the defendant of the correct opinion has the chance to “exchange error for truth”, to convince other people of the truth. Applied to the present-day situation with censorship of COVID critics, and assuming science to be wrong and these critics on social media being right, the human race loses the opportunity to listen to critics and exchange its wrong opinion with the truth.

In sum, a wrong piece of information does not become truth by many people believing in it. Despite the reliability of today’s scientific methods, one can never be totally sure about what is true and what is not. If one decides to censor the contrary opinion, with the contrary opinion actually depicting the truth, a society censors the truth. By this act, society loses the valuable opportunity of exchanging error for truth.

4. Censorship of Wrong Statements

4.1. Perceived Infallibility Hinders Exchange from Error to Truth

Another argument which Mill makes in his work “On Liberty” is concerned about the impact of silencing the expression of an opinion on the quality of deliberation. By limiting the freedom of speech, he argues, the human race loses an opportunity of fruitful debate. This argument becomes clearer when considering the aforementioned quote in greater detail:

“The peculiar evil of silencing the expression of an opinion is, that it is robbing the human race; posterity as well as the existing generation; those who dissent from the opinion, still more than those who hold it. If the opinion is right, they are deprived of the opportunity of exchanging error for truth: if wrong, they lose, what is almost as great a benefit, the clearer perception and livelier impression of truth, produced by its collision with error.”¹³

This argument can be summarised in three main points. Firstly, Mill argues that debate has two benefits.

- If a wrong opinion is being expressed, there is the opportunity for the defendant of the correct opinion to gain a clearer perception of truth by considering the arguments for the wrong opinion. It allows him to gain a true understanding of an idea.
- As discussed before: If a correct opinion is being expressed, the defendant of the correct opinion has the chance to “exchange error for truth”, to convince other people of the truth.

Secondly, Mill is of the opinion that:

- Being able to change one’s opinion and face truth is more beneficial than gaining a clearer perception of truth by confirming existing believes.
- By limiting the expression of an opinion, the opponents of said opinion lose more than the defendants of said opinion.
- Censorship has negative implications for the human race in the present as well as in the future.

In a next step, it is crucial to apply these finding of Mill’s view on freedom of speech to our contemporary example of COVID-19 censorship of misinformation. With already having discussed the case of true statements being censored, one will now assume that science is trustworthy and leads to correct results. In this case censorship of factually incorrect information on COVID-19 strips pro-science defendants of the opportunity of gaining a livelier impression of truth. By not fully being able to consider the arguments of the wrong opinion, the defendants who are in the right lose their full perception of the truth.

In order to understand this, it is important to note that Mill not only points out the necessity of knowing the arguments for one position, but also knowing the counterarguments against said position. Only this allows the person to have a clear perception of an issue. These thoughts will further be discussed in a next chapter.

Mill’s quote comes with three more assumptions, of which the last two are relevant for this discussion. It is particularly interesting how Mill regards the defendants of the popular and uncensored opinion as losing more from censorship than the ones who are being censored.

Mill’s argument on how the defendants of the popular and uncensored opinion lose more from censorship than their counterparts, makes perfect sense. Here it is vital to shine a light upon what is at stake for both parties. The defendants of the popular opinion can lose two benefits of freedom of speech. Due to censorship, they either lose the opportunity to face truth (if they are wrong) or they lose a clearer perception of truth (if they are right).

The defendants of the unpopular opinion, however, only experience a loss from censorship if they are right. In this case, due to censorship, they cannot discuss with other-minded people and hence they cannot gain a clearer perception of truth. If the unpopular party is wrong, its defendants can still exchange error for truth, as the arguments for the other, the correct opinion, are readily available. This is not the case for the popular party when the unpopular opinion is right. The censorship hinders defendants of the popular party to exchange error for truth. This slightly complicated scenario is portrayed in simpler terms in the following table.

Abbildung in dieser Leseprobe nicht enthalten

Figure 1: Losses from Censorship

Now, one can apply the findings from Mill’s utilitarian philosophy on freedom of speech on today’s situation. Regarding COVID-19, and assuming that science is correct and the measures as well as the vaccination against COVID work, there is one major loss which occurs. By censoring the people who are critical of the COVID measures and the vaccination, defendants of the dominant opinion (“The measures against COVID and the vaccinations against it work”) lose their clear perception of truth. They can no longer enjoy full awareness of the truth, as they are not able to appropriately consider the counterarguments. Why counterarguments are of high importance for a clear perception of truth will be further elaborated upon in the next chapter, where Mill’s writings on the danger of dead dogma are being considered.

To conclude, Mill is of the opinion that in the case of censorship, the censoring party loses more than the censored party. With censorship, both the censoring and the censored party may lose a clearer perception of truth in the case that they are correct. In the case of either the censoring or the censored party being wrong, the censored party is still able to exchange error for truth by considering the arguments of the other side. However, the censoring party cannot ever exchange error for truth, as censorship forbade the expression of the true opinion and the people in the wrong hence cannot come into contact with arguments of the truthful side. Applied to COVID, censorship of the unpopular opinion results in the censoring party having a less clear perception of truth, as counterarguments to their argument were censored and cannot help anymore to improve the perception of truth of the censoring party.

4.2. Danger of Dead Dogma

Mill uses the term “Dead Dogma” to describe “a belief that has gone unquestioned for so long and to such a degree that people have little idea why they accept it or why they continue to believe it”¹⁴. Dead dogma can therefore have grave consequences for people’s perception of truth. The existence of dead dogma and its negative implications can itself pose an argument against censorship, as censorship forbids arguments against an established opinion. By not being able to consider the counterarguments, the quality of deliberation suffers. This in turn leads to a lacking perception of truth. If this goes on, eventually a dead dogma is being created. People are not aware anymore of why they support or oppose a certain opinion and cannot find any reason why someone might object to the dominating consensus. The important question of “Why?” is not being asked anymore. The establishment of a dead dogma can be harmful in many ways.

Traditions often include a certain number of dead dogmata. An example therefor can be family values. Families are usually considered as a group of a man, a woman, and children. The woman is supposed to look after the children and do housework, whilst her husband is expected to work in order to provide the finances for his family. This is a good example for a dead dogma, as this belief is rarely being questioned and when questioned on why they follow the norm of having a traditional family, people will often answer “because it has always been like this”, without being able to name actual arguments and counterarguments for living within a traditional family model. Mill mentions the term “dead dogma” just once in his famous work “On Liberty”, and puts it into contrast with the “living truth” in the following quote:

“However unwillingly a person who has a strong opinion may admit the possibility that his opinion may be false, he ought to be moved by the consideration that however true it may be, if it is not fully, frequently, and fearlessly discussed, it will be held as a dead dogma, not a living truth.”¹⁵

This quote further strikes the necessity of debate. Even if one believes an opinion to be fully true, it is still crucial to fully discuss it in order for it not to become a dead dogma. This finding can be applied to the contemporary challenges humanity faces with the COVID-19 pandemic and the ongoing censorship of social media corporations. Therefore, the censorship of unpopular opinions comes with the danger of making the establishment of a dead dogma possible. This dead dogma could then impede people’s ability to think critically, which can have harmful effects on democracies as the counterarguments for i.e. freedom-restricting measures imposed by the government are not being considered.

To sum up, censorship comes with the risk of providing a fertile ground for the establishment of a dead dogma. By not being able to openly question and refute arguments for an opinion, society starts to accept things for what they are and stops asking the more important “Why?” questions. Regarding COVID, censorship of unpopular, critical voices can result in a dead dogma; people lose their ability to think critically, which is especially harmful for democracies.

4.3. Censorship Forbids the Most Persuasive Form of an Argument

Mill is of the opinion that, in order to really understand an opinion, one must not only consider the arguments in favour of the opinion, but one must as well be aware of the counterarguments and then weigh both of these against each other. Without considering any counterarguments, an opinion is worth little more than nothing. Mill then writes that an opinion can only be represented properly by its true believers. Only genuine supporters can portray an opinion in its most persuasive form, and it cannot be depicted by teachers in schools. Those are Mill’s words:

“He who knows only his own side of the case knows little of that. His reasons may be good, and no one may have been able to refute them. But if he is equally unable to refute the reasons on the opposite side, if he does not so much as know what they are, he has no ground for preferring either opinion... Nor is it enough that he should hear the opinions of adversaries from his own teachers, presented as they state them, and accompanied by what they offer as refutations. He must be able to hear them from persons who actually believe them...he must know them in their most plausible and persuasive form.”¹⁶

Applying these findings to the COVID situation, one finds that in order to fully understand the popular opinion on why the measures and vaccinations against COVID are important, one must also consider the counterarguments. Censorship renders this impossible. Additionally, censoring unpopular opinions on social media results in the counterarguments to the popular opinion not being properly represented anymore.

In brief, censorship forbids the counterarguments to a popular opinion, which makes it impossible to prefer any opinion, as it is crucial to consider both sides; arguments in favour as well as arguments opposed to an opinion in order to have a firm grasp on the underlying issue. Moreover, censorship leads to an unpopular opinion not being adequately and persuasively represented. With censorship, a legitimate opinion on COVID measures is not possible and critical voices are not represented satisfactorily.

4.4. Legitimacy of Opinion through Debate

In another argument, John Stuart Mill questions the legitimacy of an opinion if it arose not out of the failing of every counterargument but rather out of the outlawing of its refutation. In Mill’s own words:

“There is the greatest difference between presuming an opinion to be true, because, with every opportunity for contesting it, it has not been refuted, and assuming its truth for the purpose of not permitting its refutation.”¹⁷

Applied to the current situation of an ongoing pandemic, censorship of critical voices only reduces the legitimacy of scientific answers which are in favour of measures being taken against the spread of the virus and for a thorough vaccination process. This lower legitimacy comes from the fact that the dominance of the scientific opinion is not necessarily the outcome of extensive debate and deliberation, but rather resulted out of hindering dissenting voices from making themselves heard.

All in all, it is wiser to accept an opinion as true if every counterargument failed, than when it was forbidden to refute said opinion. Nowadays, censorship regarding COVID therefore makes the pro-science stance less legitimate, as its refutation was artificially made difficult by censorship.

4.5. Every Opinion is Worth Being Heard

John Stuart Mill thinks that even if a people’s stance on an issue is nearly unanimous, the opposing opinion is still absolutely legitimate and to be welcomed, as dissidence will always contribute to a discussion. In Mill’s own words:

“When there are persons to be found, who form an exception to the apparent unanimity of the world on any subject, even if the world is in the right, it is always probable that dissentients have something worth hearing to say for themselves, and that truth would lose something by their silence.”¹⁸

In another quote, Mill directly refers to censorship and proclaims that the silencing of opinions can never be justified:

“If all mankind minus one, were of one opinion, and only one person were of the contrary opinion, mankind would be no more justified in silencing that one person, than he, if he had the power, would be justified in silencing mankind.”¹⁹

Mill’s firm stance regarding the allowing of even the most unpopular opinion can be best described by the words “Every voice counts”. Therefore, social media’s censorship of critics of COVID measures and vaccinations can never be legitimised.

To me, such an opinion can only be applauded to. In an increasingly polarised society, it is crucial to recognise and listen to all voices and foster the art of debate. For if censorship takes over, the freedom of speech is infringed upon and debate is made impossible, which allows for stereotypes and resentments to flourish as well as the slow but steady erosion of democracy to proceed.

5. Eventual Limitations

In a last step, it is key to discuss the limitations of applying Mill’s thoughts on the necessity of freedom of speech and debate to contemporary society. First and foremost, technological advances since Mill have had tremendous effects on humanity. Not only does the internet enable the global exchange of information at the speed of light, but also it allows the spreading of extensive misinformation to be easier than ever by providing a global reach as well as anonymity. With anonymity comes a lower hurdle for propagating harmful opinions. Additionally, humans tend to seek information which validates their beliefs. This confirmation bias is being paired with social media’s tendency to create filter bubbles, where one only sees posts which validate one’s opinion. Hence, social media has the power to ameliorate human weaknesses.

Mill could have never imagined the flow of information which would eventually be enabled by the invention of the internet. Back in his days, mass media, which first emerged in the United States in the 1920s²⁰, was not yet part of everyday life and people relied on face-to-face discussions and debates. Considering the massive technological changes since the 19th century, it is possible that Mill, who wrote “On Liberty” in a time where mass media did not yet exist and people were being held accountable for their opinions by their social circle, would now favour a more restrictive approach on the freedom of speech.

6. Conclusion

All in all, this paper could identify five main arguments of John Stuart Mill on censorship. By applying Mill’s arguments to the contemporary debate on censorship of misinformation on the Coronavirus pandemic, one finds him to be a stark opponent of any measures that impede freedom of speech.

Firstly, Mill argues that there is always room for error in what the majority of people believes to be true. In such a case, censorship makes the exchange of error for truth impossible. Applied to today, this means that even though many rumours concerning the pandemic are factually wrong, there is always the possibility that one of the rumours is true. By social media censoring the true rumour, society will have to live in error, as it cannot learn from the censored people.

Secondly, Mill is convinced that the censoring party loses more than the censored party. Applying this to COVID, this means that censorship of the unpopular opinion on social media leads to the censoring party having a less clear perception of truth, as counterarguments to their argument were censored and cannot help to improve their perception of truth anymore.

Thirdly, censorship comes with the risk of creating a dead dogma, where people accept an opinion without questioning, therefore stopping to think critically. As critical thinking is essential for democracies, social media censorship regarding the pandemic might negatively affect the very base of democracy, the educated yet critical individual.

Fourthly, censorship forbids the counterarguments to a popular opinion, which in Mill’s eyes renders the popular opinion illegitimate, as a proper opinion not only consists out of supporting arguments, but also out of counterarguments which failed to change one’s stance. Concerning COVID, the censorship of critics comes with a delegitimisation of the popular scientific opinion.

Fifthly, Mill believes that silencing one person is equally unjustified as silencing mankind.²¹ Silencing one man is as bad as silencing mankind. Hence, social media’s censorship of COVID misinformation can never be justified in Mill’s view.

Furthermore, it is important to consider eventual limitations of the application of Mill’s thoughts to the present; technological advances such as the invention of the internet have revolutionised the world in a way that Mill could not have anticipated. The spread of harmful misinformation on COVID has never been easier, as the internet provides a global network and a lack of accountability.

Finally, at his time, Mill opposed any limits to the freedom of speech. Nowadays however, it is possible that he, in light of the revolutionary technological advances in the last two centuries and considering the ongoing pandemic, would be in favour of imposing restrictions on the freedom of speech.

7. Literature

Barua, Zapan, Sajib Barua, Salma Aktar, Najma Kabir, and Mingze Li. 2020. ‘Effects of Misinformation on COVID-19 Individual Responses and Recommendations for Resilience of Disastrous Consequences of Misinformation’. Progress in Disaster Science 8: 100119. https://doi.org/10.1016/j.pdisas.2020.100119.

Cellan-Jones, Rory. 2020. ‘Tech Tent: Social Media Fights a Fresh Flood of Fake News’. BBC News. 2020. https://www.bbc.com/news/technology-52245992.

Encyclopedia Britannica. n.d. ‘Atom - Development of Atomic Theory’. Encyclopedia Britannica. Accessed 8 April 2021a. https://www.britannica.com/science/atom.

———. n.d. ‘Freedom of Speech | Definition, Amendments, Examples, & Facts’. Encyclopedia Britannica. Accessed 8 April 2021b. https://www.britannica.com/topic/freedom-of-speech.

Howe, Robert S. Van. 2013. ‘Infant Circumcision: The Last Stand for the Dead Dogma of Parental (Sovereignal) Rights’. Journal of Medical Ethics 39 (7): 475–81. https://doi.org/10.1136/medethics-2012-101209.

Hutchful, Abena. 2014. ‘Top 40 Threats to Free Speech Right Now!’ National Coalition Against Censorship. 2014. https://ncac.org/news/blog/top-40-threats-to-free-speech-right-now.

LibreTexts. 2020. ‘Postulates of Dalton’s Atomic Theory’. Chemistry LibreTexts. 2020. https://chem.libretexts.org/Bookshelves/Physical_and_Theoretical_Chemistry_Textbook_Maps/Supplemental_Modules_(Physical_and_Theoretical_Chemistry)/Atomic_Theory/Dalton's_Atomic_Theory/Postulates_of_Dalton's_Atomic_Theory.

Loomba, Sahil, Alexandre De Figueiredo, Simon J. Piatek, Kristen de Graaf, and Heidi J. Larson. 2021. ‘Measuring the Impact of COVID-19 Vaccine Misinformation on Vaccination Intent in the UK and USA’. Nature Human Behaviour 5 (3). https://doi.org/10.1038/s41562-021-01056-1.

Mill, John Stuart. 2009. On Liberty. 1909th ed. The Floating Press.

Novacic, Ines. 2020. ‘Censorship on Social Media? It’s Not What You Think’. 2020. https://www.cbsnews.com/news/censorship-social-media-conservative-liberal-cbsn-originals/.

Rutherford Organisation. n.d. ‘Ernest Rutherford - Scientist Supreme’. Accessed 8 April 2021. https://www.rutherford.org.nz/msmyths.htm.

United Nations. 1948. ‘Universal Declaration of Human Rights’. United Nations. United Nations. 1948. https://www.un.org/en/about-us/universal-declaration-of-human-rights.

University of Minnesota. 2016. ‘The Evolution of Media’. Understanding Media and Culture. 2016. https://open.lib.umn.edu/mediaandculture/chapter/1-3-the-evolution-of-media/.

WHO. n.d. ‘Infodemic’. Accessed 8 April 2021. https://www.who.int/westernpacific/health-topics/infodemic.

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¹ (WHO, n.d.)

² (Loomba et al., 2021)

³ (Barua et al., 2020)

⁴ (Cellan-Jones, 2020)

⁵ (United Nations, 1948)

⁶ (Encyclopedia Britannica, n.d.)

⁷ (Hutchful, 2014)

⁸ (Novacic, 2020)

⁹ (Encyclopedia Britannica, n.d.)

¹⁰ (LibreTexts, 2020)

¹¹ (Rutherford Organisation, n.d.)

¹² (Mill, 2009, p. 29)

¹³ (Mill, 2009, p. 29)

¹⁴ (Howe, 2013)

¹⁵ (Mill, 2009, p. 58)

¹⁶ (Mill, 2009, p. 61)

¹⁷ (Mill, 2009, p. 34)

¹⁸ (Mill, 2009, p. 81)

¹⁹ (Mill, 2009, p. 29)

²⁰ (University of Minnesota, 2016)

²¹ (Mill, 2009, p. 29)