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DOMA, Prop 8 and standing: what exactly did last Friday’s Supreme Court order mean?
December 10, 2012
DOMA trials Prop 8 trial Supreme Court Windsor
By Jacob Combs
Last Friday, in a late afternoon order, the U.S. Supreme Court announced that it will take up the Prop 8 case and the Windsor challenge to DOMA and issue rulings on the two laws’ constitutionality by the end of its 2013 session. Following the order, we had a great Q&A session with readers and Shannon Minter and Chris Stoll of the National Center for Lesbian Rights (if you missed it, check it out here) about just what the Court’s move really means. Here’s a (fairly) detailed look at how important the Court’s additional questions of standing could be to the eventual resolution of the two cases in the spring.
The Court’s Friday order not only makes clear that it is interested in considering not only the core constitutional arguments at the center of the Prop 8 case (now called Hollingsworth v. Perry) and the Windsor v. USA challenge to DOMA, but also several key procedural issues presented by the two cases. In the Prop 8 case, the Court’s order reads, “The petition for a writ of certiorari is granted. In addition to the question presented by the petition, the parties are directed to brief and argue the following question: Whether petitioners have standing under Article III, §2 of the Constitution in this case.”
In effect, what this means is that the Supreme Court will consider arguments on the central constitutional question presented to the Court by the proponents of Proposition 8: “Whether the Equal Protection Clause of the Fourteenth Amendment prohibits the State of California from defining marriage as the union of a man and a woman.” This question is substantially similar to the one presented to Judge Vaughn Walker during trial in a Northern California district court. Judge Walker ruled that California’s denial of marriage equality to same-sex couples violates those couples’ equal protection and due process rights. In his opinion, Judge Walker wrote that while strict scrutiny (a more searching constitutional test used to protect the rights of disadvantaged minorities) was designed specifically to safeguard the liberties of groups such as gays and lesbians, Prop 8 fails to pass even the much more lenient rational basis test.
The Supreme Court’s additional question in the order granting review of the Prop 8 case, however, means that the Court might not even reach the equal protection question at all. Federal courts are only allowed to hear challenges brought by parties that have what is called Article III standing–essentially, a direct stake in the case by which they can demonstrate that an adverse court ruling would affect them. Because the official defendants in the Prop 8 case (the Governor and Attorney General of California at the time, as well as the clerks of Alameda and Los Angeles counties) declined to defend the constitutional amendment in court, the official ballot proponents of the measure sought and were granted the opportunity to defend the law in their stead.
In arguments before the Ninth Circuit Court of Appeals, the plaintiffs in the Prop 8 case argued that the proponents of Prop 8 do not have standing under federal law to pursue the case–implicitly arguing that the circuit court and indeed the Supreme Court lack jurisdiction in the case. The Ninth Circuit asked the California Supreme Court to issue an opinion on whether or not the proponents had standing under state law to defend Proposition 8 (which the state court said they did), and then used this opinion to grant the proponents federal standing and declare Prop 8 unconstitutional.
The Supreme Court’s additional question regarding standing, however, means that if the high court decides the proponents do not have standing, the Court cannot issue a ruling on Prop 8′s constitutionality and the Ninth Circuit’s decision becomes moot, leaving the district court ruling in place (but possibly limited in effect to only the couples who brought the suit). The Court has demonstrated skepticism in the past regarding the standing of ballot proponents when it comes to defending those measures in court, but it is free to rely on the California Supreme Court’s ruling (as the Ninth Circuit did) to support a decision granting the proponents Article III standing.
In the DOMA case, the Supreme Court specifically decided to hear the Windsor challenge, brought in November 2010 on behalf of Edie Windsor, an 83-year old New York resident forced to pay over $363,000 in estate tax upon the death of her wife, Thea Spyer, whom she wed in Canada in 2007. In June 2012, a New York circuit court ruled in Windsor’s favor using the most referential rational basis test and citing the lack of Second Circuit precedent regarding the proper level of scrutiny for gays and lesbians in its decision to do so. A few months later, in October 2012, a 3-judge panel of the Second Circuit of Appeals ruled 2-1 to uphold the district court’s ruling, but based its decision on a heightened level of constitutional scrutiny.
The Supreme Court’s decision to take up the Windsor challenge, as opposed to the other three DOMA cases before it, probably stems from the fact that the Court very strongly prefers to hear cases that have been through the appellate court process and ruled on by a circuit court. Two of the DOMA cases (Golinski and Pedersen) were appealed to the Supreme Court before they could be decided on by the circuit courts, making the other two cases Windsor and Gill much more likely candidates for review. Regarding the Gill case, however, which arose from Massachusetts and the First Circuit, which struck down DOMA using the so-called rational basis plus test, it is extremely likely that Justice Elana Kagan had a hand in preparing the government’s position on the case during her time as Obama’s Solicitor General. Because she would have had to recuse herself from hearing the Gill case (setting up a possible 4-4 split in the Court’s decision, which would not stand as binding precedent), Windsor remained as the most likely choice for the Supreme Court to hear.
The main constitutional question presented in the DOMA cases (and Windsor specifically) is this: “Whether Section 3 of DOMA violates the Fifth Amendment’s guarantee of equal protection of the laws as applied to persons of the same sex who are legally married under the laws of their State.” Section 3 is the part of DOMA which created an official federal definition of marriage that was limited to opposite-sex couples. Every lower court to consider DOMA in the four cases that are now before the Supreme Court declared the law unconstitutional, and it is very likely the Supreme Court will issue a ruling on the merits by June.
Still, the Supreme Court’s order granting review of the Windsor case did raise two additional procedural questions in the case: “Whether the Executive Branch’s agreement with the court below that DOMA is unconstitutional deprives this Court of jurisdiction to decide this case; and whether the Bipartisan Legal Advisory Group of the United States House of Representatives has Article III standing in this case.”
The issues here are similar, but distinct, from the standing issues behind Prop 8. When DOMA was first challenged in the federal courts, the Obama administration filed briefs in defense of the law, arguing in favor of its constitutionality. In February 2011, however, the administration reversed course, with Attorney General Eric Holder writing in a letter to the Republican leadership of the House of Representatives that, in his view (as well as President Barack Obama’s), gays and lesbians were deserving of heightened constitutional scrutiny and that therefore DOMA was unconstitutional. The Justice Department also announced it would no longer defend DOMA in court. In light of this decision, the House’s Bipartisan Legal Advisory Group (BLAG), composed of both parties’ House leadership, voted on party lines to step in and defend the law in Court.
The two procedural questions posed by the Court to the parties in the Windsor case are separate but related. In the first, the Court questions whether the fact that the federal government, which is the official defendant in the case, agrees with the circuit court’s ruling essentially obviates the need for the Supreme Court to address the constitutional question at hand. Supreme Court precedent recognizes what is called a “case or controversy” requirement for the courts to consider a challenge: in the Windsor order, the Court questions whether or not the agreement between the official plaintiffs and defendants that the Second Circuit’s ruling is correct means there is no controversy for the high court to decide.
The second question is quite similar to the standing question in the Prop 8 case. Since the official defendants in the Windsor case have declined to defend the law and BLAG has asked to intervene on its behalf, there is an open question as to whether BLAG can demonstrate the kind of direct, specific stake in the outcome of the case to have standing to appeal the Second Circuit’s decision with the Supreme Court.
If the Supreme Court were to rule on the procedural issues in either case, the district court decisions striking down DOMA and/or Prop 8 would stand. If the Court rules that the proponents of Prop 8 do have standing, or that the BLAG/Justice Department history regarding DOMA does not preclude it from hearing the Windsor case, the legal challenges will be decided on the merits and the Court will decide the constitutionality of one, or both, of the laws.
Having technical problems? E-mail equalityontrial AT couragecampaign DOT org for assistance!
44 Comments Leave a Comment
1.
S-L | December 10, 2012 at 9:52 am
If section III of DOMA is struck down, would a couple who live in a state without marriage equality but are married in a state that does be able to file joint federal taxes? I'm seeing conflicting opinions…
2.
sfbob | December 10, 2012 at 10:11 am
It's an interesting question. The rules on the way the federal government recognizes marriages have a great deal to do with who is eligible to receive military pensions, as well as Social Security survivor benefits. I have read a great deal about this stuff, most of it pertinent to discussions of marriage equality, but some of it has escaped my pea-sized brain. Many of those rules were crafted in an era when there were quite a few states that did not recognize interracial marriages. It was necessary to be conscious of the delicate feelings of the less tolerant states while also not creating a circumstance where a widow (it was presumed of course that the breadwinner was male, and that presumption is still implicit in a wide range of federal statutes, including Social Security and tax law) would suddenly lose a survivor benefit were she to move from one state to another. I think it was also pretty much assumed that the couple in question married in the state where they lived, where their marriage presumably was legal. So if a surviving spouse later moved his or her financial and tax situation would not suddenly change in a way that would render him or her destitute. What we see now is that a large number of gay and lesbians couples, living in states that would neither permit them to marry nor recognize their marriages, nonetheless decide to go to a state with marriage equality that also permits out-of-staters to marry there, in order to have legal recognition of their relationship in some jurisdiction. This could well mean that each marriage, were there any question at all, might have to be reviewed individually in order for a determination to be made as to whether or not they could file their federal taxes jointly. Needless to say they'd be unable to file their state taxes (if any) jointly if the state they lived in refused to recognize their marriage. This is generally the subject of Section II of DOMA, which has NOT been the subject of litigation.
3.
Bob | December 10, 2012 at 11:07 am
off topic,,,, but interesting options for people looking some changes to Canada's immigration policy,,, looking for skilled workers
http://news.nationalpost.com/2012/12/10/new-immig…
4.
MichaelinFlorida | December 10, 2012 at 11:38 am
I read Article III, how is it that Protect Marriage has suffered "injury". Doesn't the injored party have to be actual people.? Who are the actual people that suffered injury?
5.
MFargo | December 10, 2012 at 11:40 am
[Apologies if this question has been covered elsewhere] In the case of the Executive Branch deciding that a case is unconstitutional, is there precedent? It seems to me that SCOTUS wasn't snubbed, but only "forced" to consider the ruling. We had both a District Federal Court and a Federal Court's ruling that the matter was unconsitutional which Holder then sided with. Why does SCOTUS consider this an issue, since they may (hopefully not) eventually order the enforcement of DOMA and Prop 8? Nothing has been taken from SCOTUS' authority any more than the lower courts' decisions which SCOTUS can and does have the power to overrule.
6.
Steve | December 10, 2012 at 12:09 pm
It doesn't happen often, but you can find examples reaching back to WWII:
See pages 17 and following of the following paper: http://papers.ssrn.com/sol3/papers.cfm?abstract_i…
7.
Johyn | December 10, 2012 at 12:10 pm
All the public interest in these two cases, and the effort SCOTUS will make to hear and resolve these cases only as procedural – housekeeping issues (standing) sure seems like a waste of the courts (and publics time).
8.
Steven | December 10, 2012 at 12:12 pm
I had a feeling that SCOTUS would taken the Prop 8 case. Before Friday, I thought I don't know.. Can we argue its illegal to take away existing rights still?
I'm glad that the court took the case and if they rule in our favor "narrow ruling" it d mean alot because other states like Iowa can't take away existing rights especially it was given by a court.
9.
sfbob | December 10, 2012 at 12:13 pm
It doesn't often happen but it happens predictably. There is in fact a statute to cover such a situation, which AG Holder cited in his February 2011 memo to Congress stating that the Executive Branch would no longer defend DOMA in court.
Any argument that such an action is "unprecedented" or that the Executive Branch is somehow violating its Constitutional responsibilities is therefore without any merit whatsoever.
10.
Sagesse | December 10, 2012 at 12:19 pm
They would have Article III standing based, not on injury to them, but because they could, if the CA Supreme Court is right, 'step in' and legally represent the state when its officers will not. That is another kind of standing, of acting as one of the parties to the conflict or controversy.
11.
davep | December 10, 2012 at 12:26 pm
Yup, that's one of the questions that goes to the core of the matter of constitutionality. Since there is no particularized harm caused to opponents of same sex marriage (or anyone, really) when gay couples get access to civil marriage, this alone proves most of the argument that these laws don't even pass rational basis scrutiny. They do not serve the purpose of preventing any harm from happening to anyone and they are not rationally related to any valid governmental purpose.
12.
MFargo | December 10, 2012 at 12:51 pm
Thanks, Bob and Steve. I wondered if this somehow reflected (at least) some members of The Court.
13.
Straight Dave | December 10, 2012 at 12:57 pm
I always thought that was a terrible argument by the court, and even legally suspect. It allowed them to dance around the injury issue, but I'm not sure SCOTUS will let them get away with it.
The CA constitution endows the Attorney General with power to make all legal decisions for the state. He decided not to appeal. The proponents took it upon themselves to act "on behalf of the state", even though the state didn't ask them to and the state even took the opposite position. Purporting to act "as authorized agents of the state" is a major stretch.
The people of CA could rightly claim they were deprived of due process by having their constitution flatly ignored. It wouldn't be too diffficult for SCOTUS to use this approach to deny standing.
14.
Reformed | December 10, 2012 at 12:59 pm
Could the state of California step in and represent themselves at this point, and if so, would that eliminate the "standi ins". Also, if the "stand ins" are found not to have standing, could the court request some other party to represent the side that that believes prop 8 to be constitutional. Seems like there was a similar situation in Bob Jones Univeristy vs Unites States, but I can t find the specifics. BJU vs United States has a lot of similar concepts that are applicable to much of what we discuss here. Specifically, whether organizations can remain tax exempt when discriminating counter to a governmental interest.
15.
MichaelinFlorida | December 10, 2012 at 1:54 pm
None of the Prop 8 ballot material or the campaign mentioned that ProtectMarriage disagreed with the Ca. Supreme Court. Most of the campaign focused on "protecting"
childern,
16.
Jamie | December 10, 2012 at 2:37 pm
I don't think so. The state is tasked with upholding the laws, and therefore they suffer injury if those laws are invalidated. That's why they have Article III standing. Protect Marriage does not have to enforce the laws of the state of California, and therefore they are not injured when the law is vacated. Just because the California Supreme Court said that the Proponents can defend the law, does not give them Article III standing.
In fact, the California Supreme Court said explicitly that they didn't even look at whether proponents had Article III standing and left that up to the federal courts, who didn't look at it very closely either. These facts seem to have been forgotten by everyone.
17.
Johyn | December 10, 2012 at 2:40 pm
Will SCOTUS at least resolve the level of scrutiny?
18.
Jamie | December 10, 2012 at 2:54 pm
The 9th Circuit didn't say it was because they "took away an existing right." It was because they took away an existing right without any rational reason for doing do.
19.
Jamie | December 10, 2012 at 2:55 pm
Neither the Governor or Attorney General are going to step in. They all agree with the District Court's decision, and would prefer for that to stand so that they can start treating all people equally again.
20.
davep | December 10, 2012 at 3:19 pm
I'm not sure what you're saying here… Yes, the campaign material said all sorts of things, but when the facts were examined in court, the defendant interveners could not name one single example of how anyone is harmed when same sex couples are allowed to legally marry. Remember the famous "Your Honor, I don't know" quote from the closing statements? All the "protect the children" stuff is just anti-gay rhetoric that doesn't survive any rational scrutiny. There is no actual evidence behind it.
And when a law singles out a group of citizens and disadvantages them or stigmatizes them, there has to be a valid reason for doing this. The law must be necessary to prevent some real harm from happening to other citizens which can outweigh the harm done to the targeted group (for example, like laws preventing legally blind people from having access to a drivers license, which can be argued as being necessary to support the states interest in public safety). But the court found that the only thing Prop 8 does is harm gay couples. It does nothing to prevent any harm to anyone else and does not support any valid states interest.
21.
SoCal_Dave | December 10, 2012 at 4:32 pm
It blows my mind that we are back to discussing standing again.
On the other hand, I have to agree with the argument that NO ONE was or will be harmed by same-sex marriages.
And even though standing is sort of a technical issue, and maybe less satisfying than winning the full legal argument, wouldn't it still be a pretty powerful statement, if SCOTUS said "You can't step in here because you were not harmed, and in fact NOBODY was harmed" ?
or maybe they'd say it like this…
You have no power here, now begone, before somebody drops a house on *you*.
22.
Reformed | December 10, 2012 at 6:46 pm
What I meant was, could the state at this point, if they chose to, step in and "technically" fill the role of "representing" the state, and then just support the a declaration of unconstitutional. Why did the state make room for the stand ins by declining to defend prop 8. Would they have been doing something wrong by not disclosing their intent not to defend and then just supporting a finding of unconsitutional in the end?
23.
Josh | December 10, 2012 at 6:48 pm
Haha, good one
If the court says they don't have standing since they are not harmed, then that should make it much harder for anyone to have standing against our equality, would it not?
24.
Bob | December 10, 2012 at 7:08 pm
@Straight Dave
Not only that but California allows for backers to have standing *IF* they write it into the original proposition that they have standing in court. If what your saying is correct (as I'm sure it is), it sounds like the California Supreme Court effed up by giving the Prop 8 backers standing.
25.
MNBob | December 10, 2012 at 7:13 pm
Just another reason to scrap propositions altogether in California or severely limit their scope to not include civil rights issues. With the exceptions of medical marijuana and prop 30 I can't remember a proposition that did any good.
26.
SoCal_Dave | December 10, 2012 at 7:17 pm
That's what I'm thinking. Also, even though the immediate question is about standing, I would think the bigger point would be that if the courts (including SCOTUS) make a legal finding that no one is harmed, then all the anti-gay arguments about "defending" marriage fall apart. Defending against what? The courts said no one was harmed.
So I'm thinking even a win on standing would be a pretty good win.
(then again, I have no legal background so I could be way off base).
27.
Mike in Baltimore | December 10, 2012 at 7:18 pm
What the California Supreme Court ruled was that IF it were a state case, not a Federal case, the proponents would have standing to argue the case.
The Ninth Circuit Court took that reasoning to extend standing to the proponents. Maybe that is also why they narrowed the ruling to apply only to California?
28.
Paul | December 10, 2012 at 9:43 pm
They didn't give proponents standing. In fact, in their opinion, they specifically said that it was up to the 9th district to interpret the law to determine if the Proponents had standing.
29.
Paul | December 10, 2012 at 9:46 pm
No, the CASC said that the proponents would have been permitted to defend the law in state courts as the courts were lenient on this issue. They said nothing about whether proponents had standing.
30.
Paul | December 10, 2012 at 9:50 pm
No, the state chose not to appeal to the 9th circuit, so they never did. They only had a certain time period to make that appeal, so they forfeited it. If the only people to appeal that decision don't have standing, then it's over.
31.
Paul | December 10, 2012 at 9:54 pm
What? Prop 13 made it so that one person pays $300 in property taxes and the person next to them pays $3,000, even if their houses are worth the same amount. You can't tell me that isn't a phenomenal law!
32.
Mike in Baltimore | December 10, 2012 at 10:49 pm
"permitted to defend"
Aka standing to defend.
Even in state courts, everyone to the dispute MUST have standing. I can't stand in for my neighbor if the tree that fell on my neighbor's house, causing damage to the house and property, caused zero damage to my house and/or property.
33.
Mike in Baltimore | December 10, 2012 at 10:55 pm
And you think "ballot material or the campaign" MUST contain only factual material?
Any lies, stretching the truth, falsehoods, etc. are automatically thrown out?
Then why did ALL the anti-gay campaigns leading up to the November election have an ad (slightly tailored to fit each state) that stated 'if you allow gay marriage, gay marriage will be taught in school, forced onto the schools by the law under consideration'? Even though it was a falsehood?
34.
Marek | December 11, 2012 at 3:23 am
Hmm. I'm not sure, but I think proponents are _not_ claiming that they have suffered direct harm. What they say is:
* state does have interest in defending laws (state would have standing);
* proponents claim to represent the state (this is where the question of the 9th Circuit to SC of CA went -> "can proponents represent the state if elected officials don't").
If I'm right then SCOTUS will not say anything about proponents or anyone else being harmed. The decision will be whether proponents can represent the state in a federal court. Sorry (would have been sweet, I agree)
35.
nicksternet | December 11, 2012 at 6:51 am
"If we cannot have moral feelings against homosexuality, can we have it against murder?–Justice Scalia
Sick!!!!
36.
nicksternet | December 11, 2012 at 6:56 am
Scalia and the dehumanization of gay people!
http://www.queerty.com/scotus-judge-antonin-scali…
37.
Steve | December 11, 2012 at 7:38 am
Scalia is dumb beyond words
Having feelings != enshrining them into law
What an asshole
38.
Straight Dave | December 11, 2012 at 8:20 am
Chief Justice Burger in Palmore v Sidoti (1984):
"Private biases may be outside the reach of the law, but the law cannot, directly or indirectly, give them effect. "
Do a little reading, Tony
39.
MFargo | December 11, 2012 at 8:40 am
Title III Standing isn't just about this case. We saw at the Appellate Court a contorted effort by the panel to justify their ruling on this case (that is, going to the California Supreme Court for their opinion which really has no weight in Federal Court). Title III was established to limit the number of cases before the Court and to keep anyone from joining simply to delay justice (and I think we have a really good example in this case of weak arguments from individuals who have no business joining the case simply to keep it tied up before the court, their endless motions and delays evidence of that). So SCOTUS has more at stake that simply our arguments on Same Sex Marriage; I feel the intervenors have behaved scandalously throughout the whole trial with trivial points (or no points) siimply because they have a moral problem with our cause. They've mocked the whole process throughout.
40.
Straight Dave | December 11, 2012 at 8:44 am
I agreee with your description of the position the proponents took.
The part that tends to get overlooked is that the state didn't abandon their duties by declining to appeal. The AG performed his job exactly the way he was supposed to. He looked at the situation and made a decision that is his alone to make in the best interests of the state. It's not the place of proponents to come along and say "I don't like the choices the AG is making so I'm going to do his job for him, the way I want it done".
I'm still bothered by the fact the CA SC let them get away with this – initiatives rule, power to the people. and all that. Effing wimps if you ask me when it comes to initiatives. (it's because judges can get voted out – another rant). If the people had actually voted for the proponents to act as their legal arm, then the court might have a point. But they didn't. The people voted for the AG to handle that part of the business, so the people's desires are already taken into account and well covered.
I wish our team would hammer this point more in the standing argument. The justifications for proponents' standing felt awful weak to me.
41.
MFargo | December 11, 2012 at 9:27 am
If he's so morally outraged by homosexuality, I would say to him: "Just don't do it." If he thinks he's sitting on some high throne and asking me not to do it, I'd say to him: "Step down."
42.
Mike in Baltimore | December 11, 2012 at 10:36 am
Filing of Federal taxes is done under Federal rules, regulations and laws. If there is no law to support a rule or regulation, then the rule or regulation is not lawful, unless the issuer can use 'logical' reasons for the rule or regulation, and can pass court muster.
The IRS rules and regulations on filing of Federal tax returns were crafted partially under the restrictions of DoMA, Section 3 of which states that the only 'marriages' the Federal government will acknowledge is 'one man and one woman'.
Thus, if Section 3 of DoMA is repealed or found to be UNConstitutional, the rules and regulations of the IRS, if left in place, would not be based on Federal law, and would have to be changed, (or some logical rationale would need to be used to not change them). SCOTUS could force them to change the rules quickly, or not. Since the President is in favor of marriage equality, I think the IRS (which is in the Executive Branch) would quickly change the rules.
As to filing state taxes, those are under the control of state laws and constitution. The Federal government has little to no control over the state laws or constitution.
43.
Mike in Baltimore | December 11, 2012 at 11:08 am
A determination of standing in a state court is under the dictates of the state laws and constitution. A determination of standing in a Federal court is under the dictates of the court rules, Federal laws, and even more importantly, Article III of the US Constitution.
State laws and state constitutions can and do differ on what constitutes standing than Article III of the US Constitution. Thus a party may have standing in a state court, but not in a Federal court, or vice versa.
And the California Supreme Court was not asked if the backers of Prop H8 had standing in Federal court, but rather, if the case went through the California state court system, would they have standing. About a year later, the California Supreme Court came back and said they would have standing in a California state court. They did NOT state that the backers of Prop H8 did or did not have standing in a Federal court. The Ninth Circuit applied the interpretation of the California Supreme Court on the issue, as it applies to the state courts, to the Federal courts.
My opinion? The California Supreme Court may have been correct when it ruled on standing in state courts, but the Ninth Circuit was totally incorrect in relying on that interpretation as it applies to Federal courts. The backers of Prop H8 might have standing in Federal court, but the Ninth Circuit should have made that determination based on the Constitution, Federal laws and court rules ONLY, even if it would have been a tough decision.
44.
Mike in Baltimore | December 11, 2012 at 11:28 am
So Scalia thinks that only Roman Catholics have morals? Those who are not RC do not have morals? And where in the Constitution is that stated?
Remember, SCOTUS's job is to determine if a person violates the law, and/or if the law is Constitutional or not.
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