I think it is Phytoplankton.
In district of Columbia V. Heller, the supreme court found that the district of Columbia's strict gun control law :
C. was unconstitutional
This decision is based on its potential to harm others
hope this helps
Southern states had slaves and Northern States was more about the industrial items. And even though northern states had less slaves they both had slaves. Richer soil in southern states allowed cropping which had to be farmed by slaves, weaker not good soil caused northern to use machines in others stuff so slaves where not need as much.
New York metropolitan area
In 1607 and 1608, Hudson made two attempts on behalf of English merchants to find a rumoured Northeast Passage to Cathay via a route above the Arctic Circle. In 1609, he landed in North America on behalf of the Dutch East India Company and explored the region around the modern New York metropolitan area.