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Notes -
Well, yes, that's the argument that secession is never justified, which Jefferson rejects. What I'm claiming here is that the question isn't solvable at the meta level--you must engage with the object-level dispute concerning why this group wants to secede from the larger polity.
Jefferson's bill of particulars (the section that I skipped past, but is available in the link to the original) bears a remarkable and not-at-all-accidental similarity to the provisions of the Bill of Rights. When the early Americans were debating whether to ratify the Constitution, which would create a more centralized authority than that created by the Articles of Confederation, a common concern was avoiding the abuses of the previous system under the British Crown. Each of the first eight Amendments instructs the new federal government that it is not allowed to abuse the people in the following ways, which were all things that the Founders had suffered in living memory. The Bill of Rights isn't a random collection of priorities generated by philosophical musing, but a set of very practical, real-world concerns during that period.
At the object level, the American Revolution was about whether comprehensive and systemic violations of what later became the Bill of Rights was sufficient to justify secession.
Also at the object level, the American Civil War was about whether actual or potential violations of Southerners' right to own slaves was sufficient to justify secession.
If the argument above is correct, and justified secession is contingent on the object-level dispute, then I see no inconsistency in describing the secessionary movement that gave rise to the American Revolution as justified, and the secessionary movement that gave rise to the American Civil War as not justified. In my view, this is an easy call, though different people may form their own opinions as they wish.
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