Gender and the Law Prof Blog

Editor: Tracy A. Thomas
University of Akron School of Law

Thursday, August 29, 2019

How the Equal Rights Amendment would Affect Women's Rights

 I'm quoted in this article in Time on the history and future of the ERA.

Tara Law, Time, The U.S. Constitution Doesn't Guarantee Equal Rights for Women. Here's Why.

When American women won the right to vote — a milestone commemorated on Women’s Equality Day, which marks the anniversary of the Aug. 26, 1920 certification that the 19th Amendment had been ratified — it was just one part of an even larger fight for equality. From Mary Church Terrell’s endeavors to make sure African-American women were included in the fight for suffrage, to Margaret Sanger’s work to promote access to birth control, to Ruth Bader Ginsburg’s efforts to eliminate sex discrimination in the law, women before and after that day in 1920 have fought for wider rights.

 

And yet, the U.S. Constitution does not say that people are equal regardless of their sex.

 

This fact came close to changing in 1972, when the U.S. legislature passed the Equal Rights Amendment (ERA), which stated that rights cannot be denied “on account of sex.” But after conservatives mobilized opposition to the ratification of the proposal, the amendment fell short of the three-quarters majority needed to add the ERA to the Constitution. Now, as the Equal Rights Amendment has regained momentum — with two more states, Illinois and Nevada, recently ratifying it — advocates say that there’s a new opportunity for the ERA to move ahead. ***

How would an Equal Rights Amendment affect women’s rights?

Although American women have made significant gains in equality since the 1970s — and certainly since the 1920s — advocates say that an Equal Rights Amendment could still have a profound effect on the law and on American society.

 

Advocates say that the amendment is help back by the sense among some people that it’s not necessary, but proponents argue that it could strengthen the legal basis for combating violence against women, pay inequality and maternity leave.***

 

Professor Tracy Thomas of The University of Akron School of Law tells TIME that the law would prevent women’s rights from sliding back, and eliminate some “wiggle room” that leaves space in the law for stereotypes to affect civil rights. She also argues that protecting women’s rights in the Constitution would have a major cultural impact.

 

There’s this overriding structure of the highest law in the land that has this absolute command, and so that has to trickle down,” says Thomas. She says that recent events such as the rise of the #MeToo movement reveal how quickly society can change. “Once you start changing the culture and the dialogue, things that were acceptable become unacceptable really quickly.”

August 29, 2019 in Constitutional, Equal Employment, Legal History | Permalink | Comments (0)

Awareness Can Help Hiring Committees Ensure that Implicit Gender Biases Don't Impact Decisions

Hiring Committees that Don't Believe in Gender Bias Promote Fewer Women

Our evidence suggests that when people recognize  might face barriers, they are more able to put aside their own biases," said Toni Schmader, a UBC psychology professor and Canada Research Chair in social psychology. "We don't see any favourability for or against male or  among those committees who believe they need to be vigilant to the possibility that biases could be creeping in to their decision-making."

 

The study was unique in that findings were based on actual decisions made by 40 hiring committees in France, charged with filling elite research positions with the National Committee for Scientific Research (CNRS) for two consecutive years. Past research in this area has relied mostly on hypothetical scenarios, such as presenting a large sample of participants with identical resumés bearing either male or female names and asking who they would hire. By contrast, the decisions made during this study had real impact on scientists' careers.

 

With cooperation from the CNRS, the researchers were able to first measure how strongly hiring  members associated men with . They did this using an "" that flashes words on a computer screen and measures how quickly participants are able to assign those words to a particular category. People who make a strong association between men and science have to think a bit longer, and react more slowly, when challenged to pair female-related words with ....

 

When the researchers compared these implicit and explicit beliefs with the actual hiring outcomes, they learned that committees attuned to the barriers women face were more likely to overcome their implicit science/male associations when selecting candidates for the job. Among committees that believed "science isn't sexist," those which implicitly associated science more with men promoted fewer women. The difference was especially pronounced in Year 2 of the study, when committee members would have been less conscious of the fact that their selections were being studied.

 

The findings show that awareness and acknowledgement of the barriers women face might be key to making sure implicit biases don't affect hiring decisions. They also point to the importance of educating hiring committees about  and how to guard against it, Schmader said.

August 29, 2019 in Equal Employment, Gender | Permalink | Comments (0)

New York Legislation Allows Domestic Violence Victims to Terminate Telephone and Cable Contracts

Governor Cuomo Signs Legislation Requiring Companies to Allow Victims of Domestic Violence to Terminate Contracts Without Penalty

Legislation Allows Victims of Domestic Violence, Who Are Under a Multi-year or Bundled Contract with a Telephone, Cable, or Satellite Company, to Terminate Their Contract Without Penalty

Builds on New York State's Nation-Leading Protections for Victims of Domestic Violence and Sexual Assault

Governor Andrew M. Cuomo today signed legislation (A.5318/S.2356) requiring companies to allow victims of domestic violence, who are fleeing their batterers and have received an order of protection, to terminate their multi-year or bundled contract with a telephone or cable or satellite company at a location they have fled without penalty.

"Survivors of domestic violence should not have to handle the added stress and red tape that comes with contract termination penalties," Governor Cuomo said. "When leaving an abusive environment, a clean break is critical and in New York we will give survivors the resources they need to move onto the next chapter of their lives."

While multi-year contracts with telephone or cable companies offer consumers better price-saving options, the fees to cancel such contracts vary across providers and can be charged to victims of domestic violence who are fleeing their abusers. In many cases of domestic violence, it is necessary for victims to leave behind items of intrinsic and financial value and sever all ties with their offender. By allowing victims, who submit a written claim, to terminate their contracts at a location they have fled without penalty, we are strengthening protections for victims and providing tools to potentially ease the stress and trauma often associated with domestic violence.

August 29, 2019 in Legislation, Violence Against Women | Permalink | Comments (0)

CFP AALS Women in Legal Education Section "A Century Since Suffrage"

Call for Presentations and Papers – Monday, September 23 Deadline


The Women in Legal Education (WILE) Section of the American Association of Law Schools Seeks submissions for the American Association of Law Schools Annual Meeting January 2-5, 2020 in Washington, D.C.

The Section on Women in Legal Education is pleased to announce a Call for Papers from which presenters will be selected to participate in the Section’s main program at the AALS 2020 Annual Meeting in Washington, D.C. The program, A Century Since Suffrage: How Did We Get Here? Where Will We Go? How Will We Get There?, will explore the legal accomplishments and failures of the women’s movement since 1920. A century ago, women won the right to vote. Since then, women garnered additional rights in virtually every legal area, including in the realms of employment, property, reproduction, education, caretaking, sexual freedom, and protection from violence. Despite significant success, much work remains.

This session will consider the future of the women’s movement through a critical examination of our past as guided by three multi-faceted inquiries:
(1) How did we get here?
Topics can include, for example: Who shaped the movement’s path? What were the movement’s guiding ideologies, practices, and priorities? Where did the movement fail? How did the exclusion of African American and other minority women shape the movement’s trajectory and goals? How did the prioritization of some issues over others impact women’s lives and the reality of sex equality?
(2) Where will we go?
Topics can include, for example: What are or should be our priorities as we move forward? How do we continue our work given the current political climate, assault on women’s rights, and status of our world? How will our understandings of gender shift the goals of the women’s movement? What impact will intersectionality have on the movement?
(3) How will we get there?

Topics can include, for example: Who will shape our actions and goals as we move forward? Which philosophies will guide us? What are the obstacles in our path? What have we learned from our past and how will that knowledge guide us into the future?
Submission guidelines: We welcome proposals for 30-minute presentations on these topics. Proposals for presentations should be sent as an e-mail file attachment in MS Word to

Professor Rona Kaufman at kitchenr@duq.edu by Monday, September 23, 2019. She will confirm receipt of all submissions. Proposals for presentations should be 500-1500 words long, and should denote the topic to be addressed, any special technological needs for the session, the presenter’s background, years of teaching, institutional affiliation, and contact information. All abstracts will be reviewed by members of the WILE Program Committee. Selected professors will present their work at the 2020 AALS Annual Meeting. Full drafts of articles based on conference presentations will be due by July 1, 2020. Final versions of the articles will be due by August 19, 2020. Accepted articles will be published in the Winter 2021 issue of the Duquesne Law

August 29, 2019 in Call for Papers, Conferences, Legal History | Permalink | Comments (0)

Thursday, August 15, 2019

New Book by Attorney, "Nobody's Victim" on Cases Challenging Title IX Sexual Violence and Revenge Porn

The Lily, Wash. Post, Carrie Goldberg's New Memoir "Nobody's Victim": How Schools Fail Black Girls

The following is an excerpt from attorney Carrie Goldberg’s memoir, “Nobody’s Victim: Fighting Psychos, Stalkers, Pervs, and Trolls,” which comes out Aug. 13. In 2014, Goldberg made a name for herself representing victims of sexual violence — specifically in cases of revenge porn. Her law firm, C.A. Goldberg, PLLC, specializes in handling cases of sexual harassment, sexual assault and blackmail.

 

This excerpt appears in Chapter 4, “Girls’ Lives Matter,” in which Goldberg describes her work with three clients — all middle-school-aged girls of color from New York City. In the chapter, she describes the Title IX complaint she filed with the U.S. Department of Education Office for Civil Rights on behalf of Vanessa, who alleged a classmate sexually assaulted her when she was 13.

 

“When I opened my firm, the idea of representing clients who were still in middle school wasn’t even on my radar,” Goldberg writes. “But by 2018, I’d filed seven Title IX complaints with the U.S. Department of Education Office for Civil Rights, including five on behalf of middle and high school students who were sexually violated by their peers, then shamed and blamed by the school officials who were supposed to be protecting them.”

 

In this excerpt, Goldberg outlines the stories of two other clients and discusses a larger system of bias against black girls and women who report sexual assault.

August 15, 2019 in Books, Education, Media, Violence Against Women | Permalink | Comments (0)

CFP Feminist Legal Theory CRN Law and Society 2020

Call for Papers – Friday, September 20 Deadline

The Feminist Legal Theory Collaborative Research Network

Seeks submissions for the

Law and Society Association Annual Meeting

May 28-31, 2020 in Denver, Colorado

Submission link: https://form.jotform.com/91827795835172

Dear friends and colleagues:

We invite you to submit a paper for a panel to be sponsored by the Feminist Legal Theory Collaborative Research Network at the 2020 Law and Society Annual Meeting in Denver. The Feminist Legal Theory CRN brings together law and society scholars across a range of fields who are interested in feminist legal theory. Information about the Law and Society meeting is available at https://www.lawandsociety.org/index.html

We will give preference to individual paper proposals over proposals for panels that are pre-formed.  One of the goals of the Feminist Legal Theory CRN is to encourage scholars to engage with the diverse work of others across the academy. Any proposals for a fully-formed panel should address specifically the efforts that the panel organizers have made to ensure diversity among presenters, including race, gender, sexual orientation and gender identity; diversity in the institutions of presenters’ affiliation and/or primary training; diversity among positions in the academy such as senior vs. junior scholars, tenured vs. non-tenured participants, doctrinal vs. non-doctrinal faculty. 

This year’s meeting invites us to explore “Rule and Resistance.”  We are especially interested in proposals that explore the application of feminist legal theory to this theme, broadly construed. We are also interested in papers that will permit us to collaborate with other CRNs, such as the Critical Research on Race and the Law CRN. We welcome multidisciplinary paper proposals and proposals from scholars from all parts of the world.

Our goal is to stimulate focused discussion of papers on which scholars are currently working rather than to seek fully-formed panels.  Thus, while you may submit papers that are closer to publication, we are particularly eager to receive proposals for works-in-progress that are at an earlier stage and will benefit from the discussion that the panels will provide. We strongly encourage applications from junior scholars and graduate students – as well as people who are new to feminist legal theory.

 

The Planning Committee will assign individual papers to panels of four presenters, based on subject matter. Each paper presentation should run roughly 10 to 15 minutes to allow ample time for discussion. We will also assign a chair, and one or two commentators/discussants for each panel, to provide feedback on the papers and promote discussion.

 

In addition to traditional panels, we are open to proposals in the other formats that the LSA allows, including Author Meets Reader, Salon, or Roundtable sessions. If you have an idea that you think would work well in one of these formats, please also use the submission form above.  Organizers of these types of sessions should address in their proposal the same diversity criteria listed above.

 

Finally–and new this year–the FLT CRN welcomes submissions for roundtables on how to incorporate feminist principles into both teaching methods (pedagogical strategies as well as classroom practices) and course coverage across subject areas. Sessions could potentially address topics such as: (1) what feminist teaching can look like and (2) how to deal with the unique challenges of teaching in a hostile or indifferent environment to feminism. Preference will be given to proposals that involve materials or demonstrations.

 

Please also note that LSA rules limit each participant to a single conference appearance as a paper panelist or as a roundtable participant.


As a condition of participating as part of a program sponsored by the CRN, we also ask that you agree to serve as a chair and/or commentator/discussant for another panel or participant
. We will of course take into account expertise and topic preferences to the degree possible.

 

Chairs are responsible for the primary organization of the panel. Chairs will develop a 100 to 250 word description for the session and submit the session proposal to LSA before the November 6 LSA deadline.  This will ensure that other participants accepted by the CRN can submit their proposal to LSA, using the panel number assigned by the CRN. The Chair may also serve as the Discussant for the panel, or there may be a separate Discussant.  Where possible, we will attempt to assign two Discussants to each paper panel. Discussants read the two to three papers assigned to them and prepare a short commentary to offer feedback and serve as a basis for discussion among the panelist and audience members as well as (to the extent relevant) identify ways that the papers relate to one another.

If you would like to present a paper as part of a CRN panel, please make your submission here https://form.jotform.com/91827795835172. The submission form will ask you to provide:

  • A 500 word abstract or summary of your paper;
  • Your paper’s title
  • Your name and institutional affiliation;
  • Number of years you have been in teaching/working as a grad student; and
  • A list of your areas of interest and expertise within feminist legal theory.

Please note that for Author Meets Reader, Salon, or Roundtable sessions, organizers should provide a 500-word summary of the topic and the contributions they expect the proposed participants to make.

If you need to contact the CRN Planning Committee, please do so via  feministlegaltheory@gmail.com. (Please do not send submissions to individual committee members.) 

Please submit all proposals by Friday, September 20, 2019. Late proposals may not be considered for inclusion. This schedule will permit us to organize panels and submit them prior to the LSA’s deadline of November 6. In the past, we have accommodated as many panelists as possible, but have been unable to accept all proposals. If we are unable to accept your proposal for the CRN, we will notify you by early November so that you can submit an independent proposal to LSA.

We hope you’ll join us in Denver to share and discuss the scholarship in which we are all engaged and connect with others doing work on feminist legal theory.

Finally, please make sure to sign up for the Feminist Legal Theory Collaborative Research page on TWEN, as that is our primary platform for communication about the CRN’s activities.  If your primary academic affiliation is outside a U.S.-based law school, please contact Bridget Crawford (bcrawford@law.pace.edu), and she will arrange for you to have access to TWEN, if you provide your institutional email account.  The CRN welcomes participants from all parts of the academy.

 

 

2020 LSA Feminist Legal Theory CRN Planning Committee

 

Naomi Cahn (co-chair)

Bridget Crawford (co-chair)

David Cohen

Tugce Ellialti

Jessica Feinberg

Jessica Knouse

Shruti Rana

Jordan Woods

 

August 15, 2019 in Call for Papers, Conferences | Permalink | Comments (0)

New NY Domestic Violence Law Includes Economic Abuse and the Right to Vote by Mail

Governor Cuomo Signs Legislation Expanding Protections for Victims of Domestic Violence

Governor Andrew M. Cuomo today signed three pieces of legislation expanding protections for victims of domestic violence. These measures broaden the definition of the crime of domestic violence to include forms of economic abuse such as identity theft, grand larceny and coercion (S.2625/ A.5608); give victims the choice to vote by mail-in ballot, even if they remain within the county where they are registered to vote (S.3232-A/A.219); and allow victims to report abuse to any law enforcement agency in New York State, regardless of where the violence originally took place (S.1243/A.4467A).

 

"Domestic violence is a quiet scourge that has the potential to leave lasting trauma on victims," Governor Cuomo said. "By signing these measures into law, we will broaden the legal definition of domestic violence so more abusers are held accountable as well as empower victims to get help faster and provide them a measure of protection from their abuser when they vote."  

August 15, 2019 in Legislation, Violence Against Women | Permalink | Comments (0)

Most States Prohibit Blending Surnames at Marriage

Hannah Haksgaard, Blending Surnames at Marriage, 30 Stanford L. & Policy Rev. 307 (2019)

In most states, marrying couples are severely limited in their surname choices at the time of marriage. While recent scholarship has focused on men’s limited surname choices, other important problems with the marital surname process exist. For example, the increasingly popular decision to blend surnames — taking parts of both current surnames to create an entirely new surname — is generally not allowed. Four states explicitly allow for surname blending on the marriage license, and three more allow for any surname to be adopted. This article argues the remaining states should follow suit by allowing surname blending and other surname options. In addition to providing too few surname options, in most states the current system creates ambiguities and problems because marriage licenses fail to reflect the married surname of either spouse. This article argues that states should update marriage licenses to include the surname a marrying couple chooses to adopt as the marital name.

Listen to Hannah discuss her work on the Ipse Dixit Podcast

August 15, 2019 in Family, Gender, Pop Culture | Permalink | Comments (0)

Tuesday, August 13, 2019

Central Park's First Statute of Real (rather than Fictional) Women Redesigned to Include Sojourner Truth with Women's Suffrage Leaders Elizabeth Cady Stanton and Susan B. Anthony

From Press Release:

Today, Monumental Women’s Statue Fund announced a redesigned statue that will honor pioneering women’s rights advocates and will be the first statue depicting real women in the 165-year history of New York City’s Central Park.

The amended design includes Susan B. Anthony, Elizabeth Cady Stanton, and Sojourner Truth.  All three are remarkable and monumental women’s rights pioneers who were New Yorkers and contemporaries. In the amended design, nationally-recognized sculptor Meredith Bergmann shows Anthony, Stanton, and Truth working together in Stanton's home, where it is historically documented they met and spent time together.

The NYC Public Design Commission must review the amended design of the statue, which will be unveiled on The Mall in Central Park on August 26, 2020, the 100th anniversary of the ratification of the 19th amendment, when women constitutionally won the right to vote. Next year is also the 200th anniversary of Susan B. Anthony’s birth.

“Our goal has always been to honor the diverse women in history who fought for equality and justice and who dedicated their lives to the fight for Women's Rights. We want to tell their stories and help create a full and fair historical record of their vast and varied contributions. When the Public Design Commission unanimously approved our previous design with Anthony and Stanton, but required that a scroll with names and quotes of 22 diverse women’s suffrage leaders be removed, we knew we needed to go back to the drawing board and create a new design.  It is fitting that Anthony, Stanton, and Truth stand together in this statue as they often did in life.” said Pam Elam, President of Monumental Women.

Central Park's First Statute of Real Women Redesigned to Include Sojourner Truth

Last year’s unveiling of designs for the first statue in Central Park’s 165-year history that depicts real historic women–a sculpture of Elizabeth Cady Stanton and Susan B. Anthony–was met with mixed reviews: Why didn’t the statue, set to be dedicated in August of 2020, marking the 100th anniversary of nationwide women’s suffrage, include any of the many African-American women who aided in the cause? Today it was announced that a redesigned statue honoring pioneering women’s rights advocates will include Susan B. Anthony, Elizabeth Cady Stanton, and Sojourner Truth, an escaped slave and abolitionist who joined the fight for women’s rights.

August 13, 2019 in Legal History, Pop Culture | Permalink | Comments (0)

ABA Postpones Contentious Debate Over Affirmative Consent Law

Contentious Resolution Seeking to Redefine Consent in Sexual Assault Cases is Postponed

The ABA House of Delegates has postponed indefinitely a resolution that would call on legislatures and courts to redefine the consent standard in sexual assault cases, after contentious debate Monday at the ABA Annual Meeting in San Francisco.

 

Resolution 114 was sponsored by the Commission on Domestic and Sexual Violence and Civil Rights and Social Justice Section and asked legislatures and courts “to define consent in sexual assault cases as the consent of a person who is competent to give consent to engage in a specific act of sexual penetration, oral sex, or sexual contact, to provide that consent is expressed by words or action in the context of all the circumstances, provided that nothing herein changes the Constitutionally-guaranteed presumption of innocence, or the burden of proof, which at all times remains on the prosecution to prove every element of an offense, including without limitation lack of consent, beyond a reasonable doubt.”

 

The resolution built on an earlier Resolution 115, which was adopted at the ABA Midyear Meeting in January to oppose placing upon victims of sexual assault the legal burden of demonstrating resistance to the assault.

 

The Criminal Justice Section was originally a sponsor of the resolution, but withdrew its co-sponsorship and filed the motion to postpone the resolution indefinitely.

 

Mark Schickman, chair of the Commission on Domestic and Sexual Violence, spoke in support of the resolution. He said his commission first proposed the resolution at the Midyear Meeting in Las Vegas in January, but agreed to spend more time working on its language with the Criminal Justice Section. The two groups worked together on the resolution and the accompanying report over the past few months.

 

However, Schickman said, in recent weeks, criminal defense lawyers criticized the resolution, saying it attempted to eliminate defendants’ presumption of innocence in sexual assault cases and move the burden of proof to the defense.

 

The resolution was amended to address these concerns the day before the House of Delegates meeting, Schickman said.

 

“I am asking of you today that you not focus simply on the human experience that you see today, which doesn’t stop to ask for consent, which doesn’t wait to see if there is consent,” he said. “I ask you to do what is right.”

 

Neal Sonnett, a past chair of the Criminal Justice Section, told the House of Delegates that his section agreed to work with the Commission on Domestic and Sexual Violence on the resolution. Even though there was some dissent, its council voted to approve and co-sponsor the resolution.

 

It wasn’t until later that Criminal Justice Section leadership realized they hadn’t paid enough attention to the “far-reaching implications of this resolution,” Sonnett said.

 

“This is a new paradigm,” he said. “This changes the law entirely with respect to sexual behavior.”

August 13, 2019 in Legislation, Violence Against Women | Permalink | Comments (0)

New Progressive Oregon Family Leave Law First in Nation to Cover Minimum-Wage Workers

Oregon Paid Leave Law is Nation's First to Fully Cover Lowest Wages

Oregon Gov. Kate Brown on Friday signed what advocates are calling the nation’s most progressive paid family and medical leave measure, making the state the first in the country to offer 100% wage replacement for minimum-wage workers.

 

The law, which will pay out benefits beginning in 2023, gives 12 weeks paid time off to new parents, victims of domestic violence and those who become ill or need to care for a sick family member. It also includes people who may be in the country illegally and those working part time. Residents need to work 1,000 hours a year to qualify.

 

The state joins eight others and the District of Columbia in offering paid family leave.

 

“This is one of the most inclusive and equitable paid leave laws in the country,” said Andrea Paluso, executive director of Family Forward, the advocacy group who helped craft the bill. “It’s accessible to nearly every worker and provides enough benefits so people can just focus on taking care of themselves or their families when they need to.”

 

The law allows workers to take time off not only to care for blood relatives, but also for significant others, friends and other close associates that are the “equivalent of a family relationship.”

 

Workers will also be able to take paid leave in non-consecutive increments, allowing those with chronic illnesses to take time off when needed.

August 13, 2019 in Equal Employment, Family, Legislation | Permalink | Comments (0)

Feminist Law Professors Critique Title IX and Domestic Violence Law

Chronicle, The Revolt of the Feminist Law Professors

 In the fall of 2011, the Department of Education’s Office for Civil Rights issued informal, non-binding guidance on how colleges should treat claims of sexual assault and harassment in a document now referred to as the Dear Colleague letter. It was accompanied by public claims of an ongoing crisis of sexual violence on universities made by President Barack Obama and Vice President Joe Biden. In 2014, Gersen and three of her colleagues — Elizabeth Bartholet, Janet Halley, and Nancy Gertner — led a contingent of their peers in calling out the system of investigation and adjudication that emerged during the Obama years as “so unfair as to be truly shocking.” The four were joined by 24 of their Harvard Law colleagues in an open letter published in The Boston Globe decrying Obama’s Title IX recommendations as “overwhelmingly stacked against the accused.”

 

In a statement called “Fairness for All Students Under Title IX,”  jointly authored with Halley, Bartholet, and Gertner, Gersen noted that at many colleges, investigators are trained to start by believing the complainant. Many schools would “improperly house the functions of investigation and adjudication” in the same office, with “strong incentives” to keep the schools in the Office for Civil Rights’ “good graces.” “Some schools,” they wrote, “allow appeals only on very narrow grounds such as new evidence or procedural error, providing no meaningful check on the initial decisionmaker.” The evidentiary threshold required was the lowest one, the “preponderance of the evidence” standard, meaning anything greater than 50 percent certainty should yield a finding of wrongdoing. 

August 13, 2019 in Courts, Education, Violence Against Women | Permalink | Comments (0)