Wednesday, November 7, 2018

What #BelieveWomen Means, and Doesn't Mean

Sherry Colb, What Does #BelieveWomen Mean?, Verdict, Justia

As the #MeToo movement gathered steam, exposing many long-ignored instances of sexual misconduct, other hashtags followed in its wake. One of these is #BelieveWomen. In this column, I will analyze some ways of understanding #BelieveWomen and suggest that properly understood, it can provide us with a better way to approach not only women but anyone who brings disfavored messages to our doorstep.

What Does “Believe Women” Mean?

The #BelieveWomen hashtag responds to a very old and longstanding prejudice. The prejudice held (and, to some extent, still holds) that when women say that they were raped, there is a good chance that they are lying. Seventeenth century English jurist Lord Chief Justice Matthew Hale said “[rape] is an accusation easily to be made and hard to be proved, and harder to be defended by the party accused, tho never so innocent.” Well into the second half of the twentieth century, Hale’s concern about women’s false rape accusations distorted the process of adjudicating rape claims in criminal courts.

Judges, for instance, gave juries special instructions cautioning them about the danger of lying rape victims and the need to be extra skeptical of their testimony. Courts often required corroborating evidence as well, even though witnesses who testified about other crimes required no similar corroboration. As Susan Estrich put it in her 1988 book, Real Rape, the law had difficulty believing women who came forward to complain of rape. The law accordingly placed stumbling blocks in the path of prosecution and conviction, including the special cautionary instruction and the need for corroboration.

. . .

So What Would It Mean to Believe All Women?

If we acknowledge that women sometimes bring false accusations, does that mean we should believe only some women but not all women? We can still believe all women, so long as we make sure to follow up with other potential evidence sources before convicting the defendant of rape.

November 7, 2018 in Gender, Media, Pop Culture | Permalink | Comments (0)

Tuesday, November 6, 2018

Legal History: The Importance of the Vote and Property for Women's Citizenship

Excerpt from my book:  Tracy A. Thomas, chp. 2, "What Do You Women Want?", Elizabeth Cady Stanton and the Feminist Foundations of Family Law (NYU Press 2016)

Nineteenth-century women's rights leader Elizabeth Cady Stanton on the economic, political, and constitutional import of the vote and property ownership for women.

Property as Citizenship

 This connection between taxation, property, and political rights was part of Stanton’s initial philosophy articulated in the Declaration of Sentiments. In the Declaration, she identified the abuse of power from taxation of single women and widows without a voice in governance. “If single and the owner of property, he has taxed her to support a government which recognizes her only when her property can be made profitable to it.” The Declaration made a broad demand for women’s status as “citizens” and full members of the community with all civil, economic, and political rights.[i] For citizens, unlike the more general category of “persons,” have power and participatory rights in the governance through political action. She challenged the deprivation of “the first right of a citizen, the elective franchise,” and demanded women’s “immediate admission to all the rights and privileges which belong to them as citizens.” These rights included “the right to protect one’s person and property; to govern one’s self; to have a voice in the law and rulers; to enjoy all the advantages and opportunities of life of which one is capable. This is citizenship in a republic. The natural right to life, liberty, and happiness.”[ii]

 “The Declaration of Sentiments ushered in a new conception of citizenship, for its crucial themes included natural and inalienable rights, suffrage and national citizenship, and legal protection derived from right of contract.”[iii] Stanton utilized liberal political theories of natural, individual rights, arguing that women, the same as men, were entitled to participation in the public sphere in accordance with rights of self-government.[iv] She also appealed to republican political theories of the virtuous citizen working for the collective common good, arguing that women had abilities, as property holders, taxpayers, and morally superior people meriting citizenship.[v]

 Women’s point of entry into this citizen class, though, was not clear. Citizens were defined by their privileges and obligations of voting, jury service, and military service, all of which excluded women.[vi] Women’s obligations of citizenship had instead been defined in terms of their family. “From the era of the American Revolution until deep into the present, the substitution of married women’s obligations to their husbands and families for their obligations to the state has been a central element in the way Americans have thought about the relation of all women, including unmarried women, to state power.”[vii] Republican values of political citizenship after the Revolutionary War created the cultural ideology of Republican motherhood, which held that women contributed their civic duty through their obligation to their families and in educating and raising citizen sons.[viii] This ideology valued women’s caregiving, even while it confined women to the private family sphere. Stanton attacked this notion of a “woman-citizen” as something supernatural, a “monster, half-human, half-beast,” derived from man’s false creation of the image of womanhood sentimentally worshipping her superior virtue yet fearing her emotional and religious nature in the public sphere.[ix] Understanding the reciprocal nature of citizenship, Stanton argued that women were ready to assume the duties of citizenship, like jury duty and liability for debts, if only granted the benefits.[x]

 Stanton tried to break into this closed circle of citizenship by first latching onto the traditional American basis for granting citizenship rights, property holding.[xi] “In the eighteenth century, the liberal individual (male) was defined by owning property, voting, participating in the public sphere.”[xii] Many states inherited the traditional English system requiring property ownership for voting.[xiii] Property qualifications were viewed as properly extending suffrage to those “seen as having a vested stake in society” and excluding those “too poor to have a will of their own” and too easily coerced by those who controlled their livelihoods.[xiv] These property qualifications allowed women, briefly, in New Jersey to vote between 1776 and 1807, because, as the Supreme Court held, for single, propertied women, “the law supposes them to have wills of their own.”[xv]

Relying on this historical precedent, Stanton argued that women’s ownership of property entitled women to the vote, and thus citizenship.[xvi] “A citizen, says Webster, in the United States is a person native or naturalized who has the privilege of exercising the elective franchise in the qualifications which enable him to vote for senators and to purchase, hold real estate.”[xvii] She endorsed the property connection, arguing “There is no principle of equity more universally admitted than that the owner of property shall have a word to say in its use.”[xviii] Quoting Benjamin Franklin, she said: “If a man’s property can be taken from him without his consent, he is a slave.”[xix]

Stanton also tried to break into citizenship by linking suffrage to taxation.[xx] Echoing the American sentiment from the Revolutionary War, she decried the “tyranny of taxation without representation.” Stanton later developed this theme in an 1873 speech delivered to the Rochester Women Taxpayers’ Association and a later draft lecture, “Taxation,” focusing on the basic idea that “Webster’s defines ‘tax’ as a “sum of money assessed on the person or property of a citizen.” [xxi] She emphasized the citizenship link: “Thus in taxing women the state pays them the compliment of recognizing in them the dignity of citizenship.”

On what principles of justice are there large numbers of men allowed to vote without paying taxes, while the women are compelled to pay taxes without voting? Whatever property the state protects should I think contribute its proportion to the state’s support. Hence as loyal law-abiding citizens we are willing to pay our share for the support of the state. But as our taxes are increased in proportion as many other classes and many kinds of property are exempt. We have a reason to complain of this injustice and to insist that women as large property holders throughout the United States should have a vote on this question.[xxii]

Stanton’s taxation arguments had popular appeal and were easily adopted by women’s rights advocates.[xxiii] Several famous protests by women refusing to pay their taxes were “frequently and widely recounted” by the women’s movement.[xxiv] These protestors included eighty-year old sisters, Julia and Abby Smith, who had their cows seized and sold at auction to pay the taxes, and abolitionist Abby Kelley Foster and her husband Stephen Foster who refused to pay taxes until Abby, and all women, could vote.[xxv] “Popular narratives, valuing as they did the Boston Tea Party, continued to convey that civic authority was related to democratic control of taxation.”[xxvi] These connections between property and taxation voting were partially successful in obtaining women’s right to vote in school or municipal elections, though they enfranchised only relatively well-to-do women.[xxvii] But the arguments failed to achieve Stanton’s greater purpose of establishing women’s full status of citizenship.

After the Civil War, the resulting constitutionalism of the Civil Rights Amendments provided alternative legal arguments to add to these political rationales for voting. Stanton returned to one of the demands from the Declaration of Sentiments insisting that women be given “immediate admission to all the rights and privileges which belong to them as citizens of the United States.”[xxviii] The Fourteenth Amendment, enacted in 1868, seemed to grant exactly this by guaranteeing that “all persons” are “citizens” against whom states cannot abridge “the privileges and immunities of citizenship.” In 1869, Missouri reformer Virginia Minor and her attorney husband, Francis Minor, devised an argument for woman’s suffrage based on the plain language of the newly-enacted privileges and immunities clause.[xxix] Stanton quickly adopted Minor’s argument, appreciating that the Fourteenth Amendment provided the textual hook women needed. She called it the “title deed” to woman suffrage for “without or without intent, a law stands as it is written.”[xxx] This textual argument became the foundation of Stanton’s NWSA legislative and judicial campaigns of “the New Departure” as hundreds of women, including Susan B. Anthony, civilly disobeyed the law by voting under the claimed authority of the privileges and immunities clause.[xxxi]

Stanton however extended the legal argument beyond mere textualism. She “proposed a dynamic model of constitutional interpretation designed to keep the principles of the text current with present social conditions and needs.” Adam Winkler has argued that Stanton theorized in what was then a “radically different way of understanding constitutional interpretation,” by arguing that the constitution should develop in a dynamic way to meet the ever-changing understanding of society. This idea of a changing, dynamic “living constitution” would become “the dominant mode of constitutional construction in the twentieth century.” Stanton’s use of the method not only foreshadowed modern critiques of originalism, but according to Winkler, secured her place as “its most important innovator.”[xxxii] Stanton described the fundamental law as “the organic law of the land” that should be “so framed and construed” to emphasize the progressive development of individual rights.[xxxiii] She argued in her speech to the Joint Committees of the District of Columbia, considering women’s suffrage in D.C., that “As history shows . . . each step in civilization has been a steady approximation to our democratic theory, securing larger liberties to the people.”[xxxiv] She gave the example of men’s suffrage, which had evolved from rights only for propertied white men, then expanded to universal white male suffrage including laborers, and then extended to black men. In another example, she cited the legal developments of the married women’s property acts that evolved from a new understanding of women’s civil rights departing from coverture. “Woman has not been standing still, but has been gradually advancing to an equal place with the man by her side.”[xxxv]

In January 1872, appearing before the Senate Judiciary Committee in support of woman’s suffrage, Stanton “added a stinging condemnation of the dominant method of constitutional interpretation, originalism, which was proving to be the primary stumbling block for suffrage reform.” “Though the world has been steadily advancing in political science, and step by step in recognizing the rights of new classes, yet we stand to-day talking of precedents, authorities, laws, and constitutions, as if each generation were not better able to judge of its wants than the one that preceded it. If we are to be governed in all things by the men of the eighteenth century, and the twentieth by the nineteenth, and so on, the world will be always governed by dead men.[xxxvi] Stanton argued for an evolutionary understanding of the entire Constitution from 1789 to 1870, arguing that the meaning of the privileges and immunities clause, contained originally in Article IV, had changed.[xxxvii]

Stanton needed to depart from the traditional legal constitutional interpretation of originalism because the framers of the Fourteenth Amendment clearly did not intend to include the right to vote in its guarantees. This legislative intent was recent history and familiar to all, especially Stanton’s congressional audience, many of whom were the framers themselves.[xxxviii] Their primary intent had been to grant civil, legal rights to freed slaves; they explicitly did not include the right to vote, which was envisioned separately as a political compromise in the Fifteenth Amendment granting suffrage to black men.[xxxix] The national citizenship of the Fourteenth Amendment was defined not by the vote, but as the reciprocal obligation of allegiance by the individual to the nation in exchange for protection by the state.[xl]

The U.S. Supreme Court agreed, rejecting Stanton and Minor’s claim of a constitutional right to vote. In Minor v. Happersett, the Court easily recognized women as citizens.[xli] As John Bingham, the primary drafter of the Fourteenth Amendment had explained in a Senate Report several years before, there was “no longer any reason to doubt that all persons” born or naturalized in the United States were citizens as declared by the amendment.[xlii] But that was a conclusion without significance, for the catch was that citizens did not automatically have the right to vote. That had been the feminists’ assumption: that voting was the distinguishing privilege of a citizen, and why they focused their goal on establishing women as full citizens.[xliii] Stanton attacked Bingham’s report and its implication that “women are not ‘citizens,’ but ‘members’ of the nation!—mere appendages to the State, the Church and the home.” She snarked, “If this, indeed, be woman’s normal condition, may God grant us a wiser, nobler type of manhood as our prefix than John Bingham, of Ohio.”[xliv]

The Court Supreme Court in Minor agreed that voting was not a privilege of national citizenship protected by the Fourteenth Amendment, but was instead a political right discretionarily granted by the state.[xlv] The Court defined “privileges and immunities” by reference to its antecedent in Article IV of the Constitution and the intent of the founders which did not include the vote as a privilege of citizenship. The republicanism of the founders believed in virtual representation by which only an elite few property owners were qualified to govern with political rights of voting. The Court applied the traditional originalist interpretation of the intent of the framers, both constitutional and amendment, refusing to engage Stanton’s dynamic interpretation.

Undeterred, Stanton continued to press for what she thought was self-evident, even as she simultaneously pursued alternative political strategies like a new Sixteenth Amendment for women’s suffrage. “By every principle of fair interpretation we need no amendment, no new definitions of the terms ‘people,’ ‘persons,’ ‘citizens,’ no additional power conferred on Congress” to enable Congress to grant women suffrage.[xlvi] She continued to believe that the text of the Fourteenth Amendment, properly interpreted, should grant women the right to vote. Her argument, however, “was still too radical for its time.”[xlvii]

 

[i]  Declaration, 3; McClain and Grossman, 1, 8.

[ii] ECS, “Women Do Not Wish to Vote,” National Bulletin, Apr. 1894.

[iii] Isenberg, 32.

[iv] ECS to SBA, July 4, 1858; ECS, “The Power of the Statute Legislature,” Woman’s Tribune, Mar. 1, 1885.

[v] ECS, “A Household of Women,” Woman’s Tribune, Oct. 6, 1900; Mrs. Stanton’s Suffrage Convention Letter, Washington Chronicle¸ Jan. 28, 1883; Davis, 2, 19-20.

[vi] Kerber, Ladies, 94; Isenberg, 13.

[vii] Kerber, Ladies, 11.

[viii] Kerber, Republic, 283; Norton, Liberty’s, 247-49.

[ix] Isenberg, 198; ECS, 1860 NY Address; ECS, “The Degradation of Woman,” Rev., Jan. 15, 1868; Miller, 173.

[x] ECS, “Editorial Correspondence,” Rev., Mar. 17, 1870; “Rev. Thompson.”

[xi] ECS, Bible and the Church Degrade Woman.

[xii] Clark, “Self-Ownership,” 905.

[xiii] Isenberg, 26.

[xiv] Kerber, Ladies, 94.

[xv] Isenberg, 24

[xvi] ECS, Speech to the Women Taxpayers’ Association in Rochester, New York, Oct. 31, 1873.

[xvii] ECS, Taxation Lecture, 15-16 (1877).

[xviii] Taxation Lecture, 23h.

[xix] “Household.”

[xx]  Declaration; Bible and Church, 1-12.

[xxi] Taxpayers’ Speech.

[xxii] Taxation Lecture, 23e-g.

[xxiii] Rochester Proceedings, 15.

[xxiv] Kerber, Ladies, 100-04; Jones, 265, 269.

[xxv] Jones, 269.

[xxvi] Kerber, Ladies, 113.

[xxvii] Jones, 272-73.

[xxviii] Declaration, 4.

[xxix] “Francis Minor,” Rev., Oct. 21, 1869; “Mrs. Francis Minor,” Rev., Oct. 28, 1869; “Fundamental Rights,” Rev., Jan. 20, 1870.

[xxx] Argument of Mrs. Stanton Before the Judiciary Committee, reprinted as “Woman Suffrage,” Daily Morning Chronicle, Jan. 13, 1872.

[xxxi] Winkler, 1456, 1475-77, 1483; DuBois, “Taking the Law,” 23-34.

[xxxii] Winkler, 1456-59, 1468, 1480, 1515.

[xxxiii] ECS, Speech to Joint Committees of D.C., in “The Women in Washington,” Rev., Jan. 27, 1870.

[xxxiv] Id.; HWS, v.II, 411-16.

[xxxv] HWS, v.II, 510.

[xxxvi] “Woman Suffrage; HWS, v.II, 510.

[xxxvii] Winkler, 1482-83.

[xxxviii] Id. 1472-74.

[xxxix] Jack M. Balkin, “How Social Movements Change (or Fail to Change) the Constitution: The Case of the New Departure,” 39 Suffolk University Law Review 27, 46 (2005); John Bingham, H.R. Rep. No. 41-22, Report, Committee on the Judiciary, 41st Cong., House of Rep., Jan. 30, 1871.

[xl] Bingham Report.

[xli] 88 U.S. 162 (1875).

[xlii] Bingham Report.

[xliii] “Rev. Thompson”; HWS, v.I, 412; see 41st Cong., 3d Session, H.R. Rep. 22, Jan. 30, 1871, by Reps. Loughridge and Butler (pt. 2, minority) (Judiciary Committee) (Minority Report, 9); HWS, v. II, 594.

[xliv] ECS, Letter to Editor, Woodhull and Claflin’s Weekly, Mar. 11, 1871.

[xlv] 88 U.S. 162 (1875); Slaughter-House Cases, 83 U.S. (16 Wall.) 36 (1872).

[xlvi] ECS, “Statement of Mrs. Elizabeth Cady Stanton,” Woman Suffrage, to the Senate Select Committee on Woman Suffrage, Apr. 2, 1888.

[xlvii] Winkler, 1465.

November 6, 2018 in Books, Constitutional, Legal History | Permalink | Comments (0)

The Trial of Susan B. Anthony

Ann D. Gordon, The Trial of Susan B. Anthony, Federal Judicial Center (2005)

United States v. Susan B. Anthony was a criminal trial in the federal courts. In the federal election in November 1872, Anthony, the best-known advocate of woman suffrage, registered to vote and then voted. The government charged her with the crime of voting without “the legal right to vote in said election district”—she, in the words of the indictment, “being then and there a person of the female sex.” Her trial revealed the complexity of federalism in the post-Civil War years. She was convicted in federal court under federal law for violating state law about who was eligible to vote. New York state law prohibited women from voting, and a recent federal law provided for the criminal prosecution of anyone who voted in congressional elections “without having a lawful right to vote.”

 

Primarily a case about woman suffrage and sexual discrimination, United States v. Susan B. Anthony is also a case about Reconstruction and the balance of federal and state authority. Prior to the Civil War, the demand for woman suffrage was directed to state governments, each of which set the qualifications of voters in the respective states. Reconstruction redirected the demand. The federal government assumed some authority over the voting qualifications enacted by the states, and woman suffragists saw in that change an opportunity to extend voting rights not only to black men but also to black and white women. They called for universal suffrage.

 

Anthony and the members of the National Woman Suffrage Association, after failing to gain explicit reference to the voting rights of women in the Fourteenth and Fifteenth Amendments, set about testing the meaning of what those amendments did say and how the amendments might have changed the rights of women. Anthony was among a group of women in the country trying to establish, through test cases in the federal courts, that the amendments had so redefined citizenship and rights that women were protected by the federal government in their right to vote. 

November 6, 2018 in Constitutional, Courts, Legal History | Permalink | Comments (0)

Support for the Term "Feminist" on the Campaign Trail

Surprising Support for the Term "Feminist" on the Campaign Trail

Asked whether she was a feminist, Amy McGrath, the former Marine fighter pilot running for Congress in Kentucky, was emphatic: “Hell yeah, I’m a feminist.” Her opponent, Representative Andy Barr, turned her words into an attack ad.

 

Many politicians have considered the word “feminist” toxic. But that might be changing. In 11 battleground districts nationwide, including Kentucky’s Sixth, about half of voters said they supported electing feminists, compared with roughly a third who opposed it, according to Upshot/Siena House polls this fall. About a fifth said they didn’t know.

 

We don’t have past surveys asking the same question to compare with these results, and support of feminist candidates is still not a majority opinion — more Republicans opposed electing them than supported it. But the overall support our polls found would have been unthinkable in even recent elections, scholars say. Some compare this moment to the feminist political movements of the 1920s and 1970s.

 

The spark, people across the political spectrum said, was the MeToo movement, after the misogyny seen in the 2016 presidential campaign.

 

“An embrace of the term in political candidates? That’s news,” said Estelle Freedman, a professor at Stanford who specializes in women’s history. “We know that women have been really politicized by the perceived assault on women’s rights writ large. The kindling was there, and it got ignited by the misogyny.”

 

One reason that voters’ support for feminist candidates is surprising is that in a variety of surveysonly a fifth or fewer identify as feminists themselves. (The share goes up when the word is defined as equal rights for men and women, or when specific feminist policies are mentioned.) Our polling question, asked in 14 districts, was whether respondents supported or opposed electing more people who describe themselves as feminists. It did not define the term.

November 6, 2018 in Gender, Pop Culture, Theory | Permalink | Comments (0)

Monday, November 5, 2018

Implicit Bias in the Law School Dean Search Process

Michelle Benedetto Neitz, Pulling Back the Curtain: Implicit Bias in the Law School Dean Search Process, Seton Hall L. Rev. (forthcoming) 

The dean search process can be viewed as a bellwether for the health of a law school. Within the microcosm of a civilized “dean search committee” can lie the tensions of rival factions attempting to impose their visions for the next chapter of the law school enterprise. If law school revenue is down, the factions may be fighting for their own survival.

Not surprisingly, therefore, the dean search process is a lightning rod for the stresses facing law school faculty and staff and university administrators. As a result, the implicit biases of individuals and institutions can play a major (if unseen) role in the selection of a dean. Despite the regularity of dean searches in American law schools, no scholar to date has fully examined the ramifications of implicit bias in the dean search process.

This article stems from my experience chairing multiple dean searches and my research interest in the causes and effects of implicit bias. Part II reviews the role of a law school dean, with special consideration of the ways the Great Recession and its effects transformed the role of the dean. Part III describes the typical dean search process and evaluates dean diversity statistics to determine which candidates are selected for these powerful roles in today’s law schools. Part IV introduces the concept of implicit bias, specifically focusing on in-group favoritism. Part IV also analyzes the ways implicit biases can manifest in the dean search process, focusing on racial, gender, socioeconomic, and sexual orientation biases. Finally, Part V suggests recommendations to minimize implicit bias on the part of dean search committees, and offers new and creative ways to change the traditional dean search process.

November 5, 2018 in Equal Employment, Law schools | Permalink | Comments (0)

The Inevitable Failure of California's Law Mandating Gender Diversity in the Corporate Boardroom

Joseph Grundfest, Mandating Gender Diversity in the Corporate Boardroom: The Inevitable Failure of California’s SB 826

America's corporate boards are insufficiently diverse. Too few women and ethnic minorities are at the table. California's SB 826 seeks to remedy this situation by imposing penalties on publicly traded corporations with headquarters in California, regardless of where they are chartered, if their boards have fewer than a legislatively mandated number of self-identified women directors. While well intentioned, this legislation will not achieve its intended effect because it is unconstitutional as applied to the vast majority, if not all, of publicly held corporations headquartered in California. The internal affairs doctrine will limit the law’s application to only 72 corporations headquartered and chartered in California, or 1.59 percent of all publicly traded corporations. The bill will increase the number of board seats occupied by women by trivial amounts, if at all. These trivial changes will, however, come at great risk to the evolution of affirmative action jurisprudence. California's own legislative analysis concludes that "the use of a quota-like system, as proposed by this bill … may be difficult to defend." A successful equal rights challenge means that SB 826 will have no effect at all. The legislation thus offers a poor bargain for diversity advocates: gain a trivial number of board seats, if any, but increase the risk of judicial rulings inimical to broader affirmative action initiatives. There is a better way. California can use its significant capital market influence to induce major institutional investors to mount more aggressive activist campaigns that can rapidly and materially increase boardroom diversity. These campaigns have a demonstrated history of success. They will not generate years of litigation, will not be limited to California-chartered corporations, and will pose no risk to affirmative action jurisprudence. Properly structured shareholder activism is the better, smarter way to proceed.

November 5, 2018 in Business, Constitutional | Permalink | Comments (0)

Using Laws in the UK to Ensure Gender Equality in Digital Spaces

Guardian, Far From Empowering Young Women, the Internet Silences Their Voices

If you walked past a craft beer store regularly, and subsequently received obscene messages on Facebook from the store account, what would you do?

 

Former Austrian Green party MP Sigrid Maurer wanted to sue a beer shop owner in Vienna after receiving a series of abusive online messages.

 

But Maurer wasn’t able to sue for public sexual assault, because the messages were private. Instead, she reposted the messages online, including the name of the store and its owner – who then sued her, successfully, for libel. She is now appealing against the ruling in Vienna that would mean her having to pay more than €4,000 in damages, because she couldn’t prove he personally posted the obscene messages. He argued that anyone in the store could have accessed his account and sent the message.

 

The case is just one example of the chilling impact of online abuse and sexual harassment of women, particularly those prominent in public life.

November 5, 2018 in Media | Permalink | Comments (0)