Reproductive Rights Prof Blog

Editor: Caitlin E. Borgmann
CUNY School of Law

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Wednesday, July 16, 2014

Jon Stewart and Stephen Colbert on Hobby Lobby Decision

Wednesday, July 9, 2014

Supreme Court Will Review Pregnancy Discrimination Case

Bloomberg BNA:  Justices Will Review Accommodation Issue Arising Under Pregnancy Discrimination Act, by Kevin P. McGowan:

Granting a United Parcel Service Inc. driver's petition, the U.S. Supreme Court July 1 agreed to review whether the Pregnancy Discrimination Act requires an employer to accommodate the work restrictions of pregnant employees when it does so for some non-pregnant employees with temporary impairments.

On the final day of its term, the court granted Peggy Young's request to review a U.S. Court of Appeals for the Fourth Circuit decision that the PDA didn't require UPS to accommodate Young's pregnancy-related lifting restriction even though the company offered light duty to workers injured on the job, those disabled within the meaning of the Americans with Disabilities Act and drivers who temporarily lost their federal certification (707 F.3d 737, 116 FEP Cases 1569 (4th Cir. 2013). . . .

July 9, 2014 in Pregnancy & Childbirth, Supreme Court | Permalink | Comments (0) | TrackBack (0)

Friday, July 4, 2014

Court Issues Order on Contraception Mandate that Reinforces Female Justices' Concerns About Hobby Lobby Ruling's Scope

The New York Times:  Birth Control Order Deepens Divide Among Justices, by Adam Liptak:

In a decision that drew an unusually fierce dissent from the three female justices, the Supreme Court sided Thursday with religiously affiliated nonprofit groups in a clash between religious freedom and women’s rights.

The decision temporarily exempts a Christian college from part of the regulations that provide contraception coverage under the Affordable Care Act. . . .

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The reason this order  is so frustrating is that Justice Alito's opinion in Hobby Lobby emphasized that its ruling was justified in large measure because the accommodation already provided to certain non-profits could simply be extended to closely held for-profits.  In relying on the existing accommodation, the Court implied that the accommodation was constitutionally acceptable.  Indeed, the Court dismissed Justice Ginsburg's concerns about the opinion's scope, referring to the existing accommodation for non-profits and saying, "[O]ur holding is very specific."  Justice Kennedy in concurrence even felt obliged to issue a separate reassurance: "[I]t should be said that the Court’s opinion does not have the breadth and sweep ascribed to it by the respectful and powerful dissent."  Justice Kennedy pointed out that "there is an existing, recognized, workable, and already-implemented framework to provide coverage" and "[t]hat accommodation equally furthers the Government’s interest but does not impinge on the plaintiffs’ religious beliefs" (emphasis added).  The majority itself assured that the goverment's accommodation "does not impinge on the plaintiffs’ religious belief that providing insurance coverage for the contraceptives at issue here violates their religion."

There was a clue, however, in the majority's opinion, that left Justice Ginsburg and others concerned as to whether the Court was sincere in suggesting it would ultimately find the existing accommodation adequate.  The Court noted, "We do not decide today whether an approach of this type complies with RFRA for purposes of all religious claims," referring to Little Sisters of the Poor, a case in which the Court  issued a previous order addressing the accommodation as applied to a non-profit entity.  This caveat, buried in an opinion full of reassurances about the decision's narrow scope, coupled with today's order supports Justice Ginsburg's concern that the true implications of Hobby Lobby are broad and as yet unclear.

-CEB

July 4, 2014 in Contraception, Religion, Religion and Reproductive Rights, Supreme Court | Permalink | Comments (0) | TrackBack (0)

Monday, June 30, 2014

Hobby Lobby Majority, in Contrast to Justice Ginsburg, Largely Ignores Women and Their Well-Being

The Washington Post - WonkBlog: The 49-page Supreme Court Hobby Lobby ruling mentioned women just 13 times, by Emily Badger:

. . . Th[e] idea — that women's reproductive well-being is vital to both their personal prospects and the country's fortunes — runs throughout Ginsburg's dissent. It is notably absent from Justice Samuel Alito's majority opinion. . . .

 

June 30, 2014 in Contraception, Supreme Court, Women, General | Permalink | Comments (0) | TrackBack (0)

Concurring Opinions Offers a Round-Up of Comments on McCullen

Concurring Opinions: Nine Comments on McCullen, the Abortion Buffer Zone Case, by Ronald K.L. Collins:

I thought it might be interesting to share excerpts from some of the commentary on McCullen v. Coakley. Here are 9 views on the case. . . .

June 30, 2014 in Abortion, Anti-Choice Movement, Supreme Court | Permalink | Comments (0) | TrackBack (0)

Q&A on Hobby Lobby

Here is the link to UltraViolet's Twitter Q&A  on Hobby Lobby, which I participated in this morning.

The effects of Hobby Lobby decision are already being felt in the non-profit context, with the 11th Circuit enjoining the government, pending appeal, from enforcing the contraception rule against Eternal Word Television Network, a tax-exempt non-profit organization, "[i]n light of the Supreme Court's decision today" in Hobby Lobby.  Also, via Lyle Denniston at SCOTUSblog:  "Over the dissents of two Justices, the Supreme Court on Monday evening temporarily barred enforcement of the birth-control mandate against Wheaton College, a non-profit religious institution in Illinois."

June 30, 2014 in Contraception, Religion and Reproductive Rights, Supreme Court | Permalink | Comments (0) | TrackBack (0)

Supreme Court Rules in Favor of Hobby Lobby

Justice Alito wrote the opinion. There are qualifications to the Court's ruling. It appears to be limited to closely held corporations and to contraception, for example. SCOTUSblog is live blogging the decision here. The opinion is available here.  I will be participating in a Twitter chat hosted by UltraViolet to answer questions about the opinion.

June 30, 2014 in Contraception, Religion, Religion and Reproductive Rights, Supreme Court | Permalink | Comments (0) | TrackBack (0)

Thursday, June 26, 2014

Supreme Court Reverses First Circuit in McCullen v. Coakley

Massachusetts buffer zone is invalid.  SCOTUSblog is live-blogging the decision here.  The opinion is available here.

June 26, 2014 in Abortion, Supreme Court | Permalink | Comments (0) | TrackBack (0)

Tuesday, June 24, 2014

The Supreme Court Will Decide Hobby Lobby, but the Public Favors the Contraception Rule

The Washington Post: Awaiting Supreme Court’s Hobby Lobby ruling, public favors contraception mandate, by Cathy Lynn Grossman:

The U.S. Supreme Court is expected to finally issue its ruling this week in the highly anticipated case of the craft companies vs. Obamacare. . . .

But to the general public, this is seen as a showdown between employers — the evangelical Green family behind Hobby Lobby and the Mennonite Hahn family that owns the Conestoga cabinet company — and the employees’ personal reproductive choices under their insurance. . . .

June 24, 2014 in Contraception, Public Opinion, Religion and Reproductive Rights, Supreme Court | Permalink | Comments (0) | TrackBack (0)

Monday, June 23, 2014

U.S. Supreme Court Declines To Review Preliminary Injunction of Wisconsin Admitting Privileges Law

The Huffington Post/Reuters: U.S. Supreme Court Rejects Wisconsin Abortion Case, by Lawrence Hurley:

The U.S. Supreme Court on Monday declined to intervene in the legal fight over a new Wisconsin law that requires any doctor performing an abortion to have privileges to admit patients to a nearby hospital.

The justices turned away the state's appeal of a December 2013 ruling by the 7th U.S. Circuit Court of Appeals that upheld a federal judge's decision to block the law temporarily. . . .

June 23, 2014 in In the Courts, Supreme Court, Targeted Regulation of Abortion Providers (TRAP) | Permalink | Comments (0) | TrackBack (0)

Tuesday, June 17, 2014

NPR Answers Questions About the Federal Contraception Rule

NPR: 6 Questions About Contraception Coverage And The Supreme Court, by Julie Rovner:

One of the most watched issues before the Supreme Court this term may turn on the question of religious freedom. But it will also likely determine how women will be able to access a key provision of the Affordable Care Act – one seeking to guarantee no-cost prescription contraception in most health insurance plans.

The justices' ruling on Sebelius v. Hobby Lobby Stores and Conestoga Wood Specialties Corp v. Sebelius, two cases that are being considered together, is expected by the end of this month. The court will decide whether those companies, and potentially all other for-profit companies, must abide by the so-called contraceptive mandate. It's a complicated legal thicket, so here is some background. . . .

June 17, 2014 in Contraception, Religion and Reproductive Rights, Supreme Court | Permalink | Comments (0) | TrackBack (0)

Tuesday, June 10, 2014

49 Years After Griswold, Access to Contraception Still Under Attack

RH Reality Check:  49 Years After Griswold: A Splintering Legacy

This month marks the 49th anniversary of Griswold v. Connecticut, the landmark Supreme Court decision that ruled states could not criminalize contraception use between married couples.

In a Washington Post article published this March, Walter Dellinger noted that the oral arguments in the 1965 case suggested that, by 21st-century standards, the justices were “either uninformed about contraceptive methods or uncomfortable discussing them.” . . .

Fast forward nearly 50 years and the Supreme Court is once again considering the question of birth control, this time in the Hobby Lobby case . . . .

June 10, 2014 in Contraception, Supreme Court | Permalink | Comments (0) | TrackBack (0)

Friday, March 28, 2014

Commentary on Hobby Lobby

Balkinization: Religious Accommodations Cost More than Money, by Kara Loewentheil: 

Yesterday the Supreme Court heard arguments in the consolidated cases ofHobby Lobby and Conestoga Wood. With the publication of the full argument transcript online, it became clear that even the experienced lawyers arguing these cases – along with the Supreme Court Justices themselves – were struggling to understand how to think about the relationship between religious accommodations and third party rights. In this context, that means the impacts that accommodations granted to religious employers would have on their female employees who would otherwise have access to contraception without cost-sharing under the Affordable Care Act’s contraceptive coverage requirement (and indirectly on their partners and children). 
 
This came as no surprise to me. In When Free Exercise Is A Burden: Protecting “Third Parties” In Religious Accommodation Law, a paper I authored that is shortly forthcoming in the Drake Law Review, I argue that neither scholars nor courts have thus far provided a satisfying account of how to balance free exercise rights against the impact of those rights on “third parties.” . . .
 
In my paper I argue that the contraceptive coverage requirement has an enormously important expressive element – it signifies a social and political commitment to women’s social and economic equality, and symbolizes an acceptance of social and shared responsibility for gender equality. . . .
 
 
Hobby Lobby is shaping up to be the most important free exercise of religion case the Supreme Court has heard in a very long time.    It’s also emerging as a key test for Justice Anthony Kennedy and his vision of individual liberty.  Will Justice Kennedy recognize that Hobby Lobby’s employees, who seek to protect their health and control their reproductive lives, are entitled to enjoy federal guarantees that safeguard women’s liberty and personal dignity by ensuring access to the full range of contraceptives? . . .

March 28, 2014 in Contraception, Religion, Religion and Reproductive Rights, Supreme Court | Permalink | Comments (1) | TrackBack (0)

Tuesday, March 25, 2014

Round-Up on Today's Oral Arguments in Hobby Lobby

SCOTUSblog: Birth Control, Business, and Religious Beliefs: In Plain English, by Amy Howe:

Almost two years ago to the day, the Supreme Court heard oral arguments in a challenge to the Affordable Care Act’s individual mandate, which requires virtually everyone in the United States to buy health insurance or pay a penalty.  This morning, it heard a new and different challenge arising out of the Affordable Care Act:  can a business be required to provide its female employees with health insurance that includes access to free birth control, even if doing so would violate the strong religious beliefs of the family that owns the business?  After the oral argument today, it looked like the Court’s answer may well be no, although the decision may not prove as sweeping as some of the challengers might prefer.  And as is so often the case, it looks like Justice Anthony Kennedy may hold the key vote in the case.  Let’s talk about the proceedings at the Court today in Plain English. . . .

Balkinization: Today's Oral Arguments in Hobby Lobby, by Nelson Tebbe:

The oral argument in Hobby Lobby and Conestoga Wood, which I attended today, provided some slight cause for optimism for those of us who have been arguing that accommodating the companies would raise serious concerns because it would mean shifting the cost of that accommodation onto third parties (the affected women employees). Not only did Solicitor General Verrilli open and close with the argument, but Justice Kennedy arguably displayed some sympathy for the point. First, Justice Kennedy asked Paul Clement (who was arguing for the companies) whether there are rules of statutory construction that should guide the Court in this case, such as the canon of constitutional avoidance. Later, Justice Kennedy asked directly what should happen when granting an accommodation for the companies would shift costs onto employees. Justice Kennedy asked whether the employer's interests should simply trump in such situations. . . .

NPR:  Justices Divide By Gender In Hobby Lobby Contraception Case, by Nina Totenberg:

There was a clear difference of opinion between male and female justices at the U.S. Supreme Court on Tuesday. The issue was whether for-profit corporations, citing religious objections, may refuse to include contraception coverage in the basic health plan now mandated under the Affordable Care Act.

The female justices were clearly supportive of the contraception mandate, while a majority of the male justices were more skeptical. . . .

 

March 25, 2014 in Contraception, Religion and Reproductive Rights, Supreme Court | Permalink | Comments (0) | TrackBack (0)

Monday, March 24, 2014

Important but Little-Discussed Fact -- How Plan B Actually Works -- Undermines Hobby Lobby's Claims

The Wall Street Journal - Law Blog: In Contraceptives Case, Court May Run Into Plan B, by Joe Palazzolo:

As the Supreme Court weighs whether for-profit companies have the religious right to refuse to provide contraceptives, it may also run into another question: Whether the Plan B drug is a contraceptive or a form of abortion. . . .

When the Food and Drug Administration approved a drug known as Plan B One-Step in 1999, it wasn’t entirely clear how the drug worked. So the agency required that the label mention the possibility that the drug affected implantation. . . .

Abortion-rights advocates and medical groups, including the American College of Obstetricians and Gynecologists, say heaps of research since the late 1990s has produced no scientific evidence showing that Plan B inhibits implantation. There are fewer studies on ella, because it is a newer drug, but they have reached the same conclusion, they say.

“FDA labeling has not caught up with the recent research,” said Caitlin E. Borgmann a law professor at City University of New York Law School and former lawyer for the American Civil Liberties Union’s Reproductive Freedom Project. . . .

___________________________________

See also Caroline Corbin's article on this issue.

March 24, 2014 in Contraception, Religion and Reproductive Rights, Supreme Court | Permalink | Comments (0) | TrackBack (0)

Opinion on Hobby Lobby

The Washington Post - op-ed:  Contraception as a test of equality, by Walter Dellinger:

Walter Dellinger is an attorney in Washington. He co-authored, with Dawn Johnsen of the Indiana Maurer School of Law, a brief for the Guttmacher Institute and professor Sara Rosenbaum of George Washington University supporting contraception coverage.

Forty-nine years ago this week , the nine men on the Supreme Court heard arguments that would profoundly affect women’s access to birth control. By 21st-century standards, the oral arguments in the 1965 case Griswold v. Connecticut suggest that most of the justices were either uninformed about contraceptive methods or uncomfortable discussing them. When the court returns to the subject of birth control this week, it is critical that the justices understand the complexity of contraception and its role in women’s lives. . . .

The New York Times editorial: Crying Wolf on Religious Liberty:

This week, the owners of two secular, for-profit corporations will ask the Supreme Court to take a radical turn and allow them to impose their religious views on their employees — by refusing to permit them contraceptive coverage as required under the Affordable Care Act.

The Supreme Court has consistently resisted claims for religious exemptions from laws that are neutral and apply broadly when the exemptions would significantly harm other people, as this one would. To approve it would flout the First Amendment, which forbids government from favoring one religion over another — or over nonbelievers. . . .

Balkinization: Whose Faith Does RFRA Protect?  Everyone's, No One's, or Not Mine?, by Priscilla Smith:

One outcome of tomorrow's Hobby Lobby case that this reproductive rights supporter might be able to get behind involves granting the Hobby Lobby Executives an accommodation from the Affordable Care Act’s contraceptive coverage requirements under an expansive view of the Religious Freedom Restoration Act (RFRA).  I’ve written about this possibility in a forthcoming article here.  Under this view, it is the RFRA claimant, not the court, who decides if something is a “substantial burden” on “religious exercise” under RFRA.  Counsel for the University of Notre Dame promoted this view of RFRA in a recent Seventh Circuit oral argument in a related case, stating “[i]t is up to the believer to draw the line.”  As Marty Lederman's excellent posts here revealing the lack of burden on Hobby Lobby Executives religious exercise should establish, in order to find for Hobby Lobby the Court needs to adopt this broad view of RFRA's protections. . . .

March 24, 2014 in Contraception, Religion and Reproductive Rights, Supreme Court | Permalink | Comments (0) | TrackBack (0)

Hobby Lobby Round-Up

Supreme CourtSCOTUSblog: Argument Preview: Religion, Rights, and the Workplace, by Lyle Denniston:

At 10 a.m. next Tuesday, the Supreme Court will hold ninety minutes of oral argument on the government’s authority to require private businesses to provide birth control and other pregnancy-related services to their employees under the Affordable Care Act.  Arguing for the challengers to the so-called “contraceptive mandate” will be Paul D. Clement, of the Washington, D.C., law firm of Bancroft PLLC.  Defending the mandate will be U.S. Solicitor General Donald B. Verrilli, Jr.   Each will have forty-five minutes of time, under an order issued Thursday expanding the time beyond the normal amount.  The consolidated cases are Sebelius v. Hobby Lobby Stores and Conestoga Wood Specialties Corp. v. Sebelius. . . .

Newsweek: It's About Birth Control, Stupid, by Pema Levy:

For two years, Republicans have rallied against the Affordable Care Act's (ACA) provision that health insurance plans cover the full range of contraceptives approved by the Food and Drug Administration, charging that the rule is an assault on religious liberty.

Next week, when the Supreme Court hears oral arguments in two legal challenges to the contraception requirement, the issue of religious freedom will be front and center. . . .

But for political activists on both sides -- and perhaps for the justices themselves -- it all comes down to the decades-old left-right battle over birth control. . . .

ThinkProgress: If Hobby Lobby Wins, It Will Be Even Worse For Birth Control Access Than You Think, by Tara Culp-Ressler:

Next week, the Supreme Court will take up the issue of contraceptive coverage, hearing arguments in a closely-watched lawsuit against the Affordable Care Act. Two for-profit companies — the craft chain Hobby Lobby and the furniture-making company Conestoga Wood Specialties — are fighting for their right to withhold insurance coverage for certain types of contraceptive methods based on their religious beliefs. But there’s actually much more at stake than prescription drug coverage.

The two plaintiffs in these cases object not just to covering specific types of birth control, but also to providing counseling about that birth control. In Hobby Lobby’s lawsuit, for instance, the company states that it does not want to follow the Obamacare provision that forces employers to “provide health insurance coverage for abortion-inducing drugs and devices, as well as related education and counseling.”  . . .

The New York Times: Ruling Could Have Reach Beyond Issue Of Insurance, by Adam Liptak:

The Supreme Court on Tuesday will hear arguments in a case that pits religious liberty against women’s rights.

That issue is momentous enough. But it only begins to touch on the potential consequences of the court’s ruling in the case, notably for laws banning discrimination against gay men and lesbians. . . .

 

March 24, 2014 in Contraception, Religion and Reproductive Rights, Supreme Court | Permalink | Comments (0) | TrackBack (0)

Monday, March 3, 2014

SCOTUSblog's Contraceptive Mandate Symposium Addresses Hobby Lobby and Corporate Religious Refusals

SCOTUSblog: Accomodations, Religious Freedom, and the Hobby Lobby Case, by Rick Garnett:

Every law student learns and every lawyer knows that there is more to “doing law” than simply looking up or even arguing for the right answers.  It also involves identifying the questions that need answering.  This is one reason why law-school examinations so often ask students to “spot the issues” that are presented, or hidden, in complicated and sometimes bizarre hypotheticals, stories, and narratives. . . .

SCOTUSblog: Under a Straight-forward Reading of Constitutional Text and History and Fundamentals of Corportate Law, Hobby Lobby's Claims Fails, by Elizabeth Wydra:

Superstar Supreme Court lawyer Paul Clement starts his brief on behalf of Hobby Lobby Stores, Inc., and its individual owners, the Green family, with a rather remarkable assertion: that this case “is one of the most straight-forward violations of the Religious Freedom Restoration Act.”  Someone like Clement can get away with breaking one of the basic rules of legal advocacy – one is generally not supposed to tell the Court that it is reviewing “an easy case,” since such a legal cakewalk probably wouldn’t require the rare attention of the High Court.  But Clement’s assertion is nonetheless wrong.  To the contrary, it’s — dare I say — easy to show that this case is far from easy for Hobby Lobby to win. . . . 

SCOTUSblog: Mandates Make Martyrs Out of Corporate Owners, by Ilya Shapiro:

Should some people be exempt from laws that generally apply to everyone but infringe on sincerely held religious beliefs? If so, doesn’t that privilege believers over nonbelievers, and indeed pick and choose among religious tenets to determine which merit accommodation? Does it matter if the religious belief in question relates strictly to worship or is tied to an otherwise secular mission, such as the provision of education or social-welfare services? What about commercial activity, and do the legal forms in which that activity is pursued matter? These are some of the thorny questions that arise when a pluralistic society tries to reconcile the rule of law with religious liberty. . . .

_______________________________

Other pieces in the symposium can be accessed here.

March 3, 2014 in Contraception, Religion and Reproductive Rights, Supreme Court | Permalink | Comments (0) | TrackBack (0)

Thursday, February 6, 2014

A Missing Argument in Hobby Lobby

The New York Times editorial: A Missing Argument on Contraceptives:

One of the most anticipated showdowns of the Supreme Court’s current term will take place March 25, when the justices are scheduled to hear two cases brought by secular, for-profit corporations whose owners want an exemption, based on their religious beliefs, from the requirement that employers’ health plans cover the full range of contraceptive services without a co-payment. . . .

Oddly, the Justice Department has relegated to a footnote what may be the strongest single argument against allowing the two companies to deny their workers contraceptive coverage that they would otherwise be entitled to under the health care law. . . .

February 6, 2014 in Contraception, Supreme Court | Permalink | Comments (0) | TrackBack (0)

Saturday, February 1, 2014

Caroline Corbin on Corporate Exemptions from the Contraceptive Coverage Rule

Caroline Mala Corbin (Univ. of Miami Law School) has posted the following articles on SSRN:

Caroline CorbinCorporate Religious Liberty: Why Corporations Are Not Entitled to Religious Exemptions:

One of the main questions before the Supreme Court in Sebelius v. Hobby Lobby Stores, Inc. and Conestoga Wood Specialties Corp. v. Sebelius is whether large for-profit corporations are entitled to religious exemptions under the Free Exercise Clause or the Religious Freedom Restoration Act. In particular, the plaintiffs seek religious exemptions from the Affordable Care Act’s so-called “contraception mandate.”

This is an entirely novel claim. It is also without merit. The Free Exercise Clause and the Religious Freedom Restoration Act protect the religious practices of individuals and churches. They do not, and should not, extend to the for-profit corporate form for at least three reasons. First, corporate religious liberty makes no sense as free exercise is understood to (a) protect an individual’s relationship with the divine and (b) respect the inherent dignity of the individual. Furthermore, Citizens United v. Federal Election Commission provides no theoretical foundation for corporate religious liberty: The justifications for extending free speech protection to for-profit corporations do not translate into the free exercise context. Second, there is no precedent for the claim that for-profit corporations are entitled to religious liberty exemptions; on the contrary, precedent points in the other direction. Third, recognizing corporate religious liberty will benefit employers at the expense of their employees, who risk losing protection of the employment laws as well as their own free exercise rights.
 
 
Do for-profit corporations have a right to religious liberty? This question is front and center in two cases before the Supreme Court challenging the Affordable Care Act’s “contraception mandate.” Whether for-profit corporations are entitled to religious exemptions is a question of first impression. Most scholars writing on this issue argue that for-profit corporations do have the right to religious liberty, especially after the Supreme Court recognized that for-profit corporations have the right to free speech in Citizens United. 

This essay argues that for-profit corporations should not – and do not – have religious liberty rights. First, there is no principled basis for granting religious liberty exemptions to for-profit corporations. For-profit corporations do not possess the inherently human characteristics that justify religious exemptions for individuals. For-profit corporations also lack the unique qualities that justify exemptions for churches. Citizens United fails to provide a justification as its protection for corporate speech is based on the rights of audiences and not the rights of corporate speakers. Second, as a matter of current law, neither the Free Exercise Clause nor the Religious Freedom Restoration Act recognizes the religious rights of for-profit corporations. Finally, corporate religious liberty risks trampling on the employment rights and religious liberty of individual employees.

February 1, 2014 in Contraception, Religion and Reproductive Rights, Supreme Court | Permalink | Comments (0) | TrackBack (0)