Archive for the ‘Washington State Constitution’ Category

Jim Johnson is a Candidate for Injustice: Part 5

August 13, 2010

You’ve seen one post today on how Jim Johnson will put profits over people. Courtesy of the Stan Rumbaugh campaign, here’s another example of Jim Johnson’s skewed view and his take on whether same-sex couples should be allowed to marry. The Defense of Marriage Act is a sore subject for me, as the scare-mongering that went into this campaign really hurt, when some of the more stable couples I know are same-sex couples. In kudos to Justice Fairhurst, while I don’t agree with every opinion she had written, she had the courage to write a wonderful dissent on this case. It is one of the reasons I can say I was proud to have worked for her.  The junk science cited by the majority was especially problematic for me, and I’m sure for anyone who has read, and disagreed with, the opinion. Anyhow, here you go:

Contact: Brendan Williams, (360) 791-3979

 

A year ago today should have been the date that legislation finally giving domestic partners in Washington equal rights to married persons took effect. That date was of course delayed when activists forced the issue to a referendum before voters—ultimately celebrated on Election Day 2009 when Referendum 71 was approved by 53.15% of the electorate.

 

Of course, none of that would have been necessary had not exactly two years prior, on this day in 2006, the Washington State Supreme Court handed down a shockingly backwards decision in Andersen v. King County, the Defense of Marriage Act (DOMA) case.

 

The decision was devastating and infuriating for the families represented in the case, not to mention their loved ones and allies across the state, nation, and world.

But no one expected the ugliness that flowed from Justice Jim Johnson’s pen. Unsatisfied with the blockade, the Court’s opinion threw up against the basic rights of Washington’s LGBT community, Johnson wrote a separate concurring opinion that was an unadulterated distortion of our Constitution, science, and even established law. In his close-minded abuse of power he chided the minority’s defense of fundamental fairness as mere “political correctness”.

 

Johnson found that there was no unconstitutional infringement in the exclusive preference of heterosexual couples, and further found that the state had a compelling interest in regulating marriage to the limited definition. This was because of the “unique and binary biological nature of marriage and its exclusive link with procreation and responsible child rearing.” The dissent pointed out that this made no sense whatsoever taken in light of all the childless straight couples and presented a problem for any barren or sterile straights who might want to marry, but Johnson paid no attention to the inconsistencies of his position.

 

Instead he repeatedly promoted the shocking procreation-centric position, and threw in some shop worn homophobic arguments for good measure:

  • He compared laws against gay marriage to laws against polygamy, and in fact posited that polygamists would be better positioned for recognition under the law because their relationship was based upon religion.
  • He suggested that finding statutes like DOMA an unconstitutional infringement would also make all marriages unconstitutional.
  • He found that same-sex parents were scientifically recognized as less-suitable parents.
  • He argued that DOMA was not a violation of constitutional rights because it didn’t prevent equal opportunity for heterosexual marriages for everyone—regardless of interest.

Underscoring the historical importance of the judicial branch in addressing individual and institutional discrimination in society, Johnson compares DOMA to the laws barring interracial marriage just a few generations ago. However, he attempted to draw a clear distinction between the two and calls the dissent “disturbing” for trying to link the two.

 

But make no mistake about it, they are cut out of the same legal cloth. Johnson writing, “The complementary nature of the sexes and the unique procreative capacity of one man and one woman as a reproductive unit provide one obvious and nonarbitrary basis for recognizing such marriage. The binary character of marriage exists first because there are two sexes,” is the same brand of poison dressed up as science as Judge Brazile’s “Almighty God created the races white, black, yellow, Malay and red, and he placed them on separate continents. The fact that he separated the races shows that he did not intend for the races to mix,” in Loving v. Virginia in the sixties.

 

Indeed, this reminds that judicial decisions are inextricably linked to the key moments in society’s advancements. They can delay such moments and cling to regressive standards, or they can highlight the ways our Constitution and laws can drive communities forward into more inclusive and equal chapters.

 

Justice Johnson not only failed to seize his responsibility in that moment, but he led the charge in the opposite direction. His voice on the bench helped make Washington an argument for continuing the abuse of the personal liberty and legal protection of citizens when it is his very job to do the exact opposite.

 

For more information visit: www.johnsonsinjustice.com

 

For more information on Stan Rumbaugh visit: www.rumbaughforjustice.com

 

Jim Johnson is a Candidate for Injustice: Part 4

August 13, 2010

In our continuing coverage of the ill-conceived opinions of Justice Jim Johnson, we bring you not one, not two, but four opinions. Why four? Because The Prof is taking a much-deserved vacation in the Methow Valley. This of course meant a day of just relaxing in Leavenworth, whereby I discovered the joy that is the Big Boy Brat. Throw some stone ground mustard and some sauerkraut on that bad boy and call it good.

Anyhow, here’s a few opinion for your perusal:

The first of the day: Davis v. Baugh, where, according to Jim, even though outdated precedent had run its course, had grown out of line with the statutory scheme, and shielded subcontractors no matter how badly they were negligent:

 

Date: July 23, 2010

 

Contact: Brendan Williams, (360) 791-3979

 

In 2007′s Davis v. Baugh, the Court got right to the heart of the matter: a man was killed due to the negligence of a company. Our judicial system is based upon the idea that punishing that kind of wrongdoing is not only fair, it is the only way to create a deterrent that helps prevent future criminal behavior. This point—that the court has a purpose in crafting strong language in the public interest—is critical to understanding the lengths Johnson was willing to go in his dissent, using dense legal language in an attempt to keep the company off the hook.

 

Baugh was a subcontractor who completed a subterranean pipe network for Glacier Northwest on a larger project. Glacier employed Alan Davis, who was sent to inspect the pipes when it was noticed, after installation, that they were leaking. As he was doing this, two ton-and-a-half portions of the pipe fell on him, crushing and killing him.

 

The portion of the pipes that failed was found to be structurally unsound. But for Baugh’s failure to recognize this before providing the pipes for installation, resulting in the predictable failure, Davis would still be alive.

 

His tragedy is easy enough to understand. What is not as easy to understand is the conflict that was created in the law when Alan Davis’s family sought justice in the courts.  Most perplexing of all was Johnsons’ refusal to help clarify the law in a way that gives working people like Alan Davis the protections they are entitled to in a situation like this.

 

The laws protecting victims from injury caused by another party’s negligence come to us from England centuries ago. They are called ‘common law’, and which is refined and updated by judges over the years. One such common law element at play in this case was the doctrine of completion and acceptance.

 

Completion and acceptance meant that once an independent contractor finished their work and it was accepted by the owner, liability for injuries ends.  This cutoff occurs no matter how negligently the work was performed. The court rejected this doctrine as “outmoded, incorrect, and harmful.”

 

Prior to this case, the Court hadn’t addressed the completion and acceptance issue for 40 years. In that 40 years our Legislature passed statutes which govern construction liability and created workplace safety regulations for the benefit of all working people. The very common law foundations of the completion and acceptance doctrine had been abandoned by the court, and the doctrine itself was rejected in 37 other states.  With the range of materials used and complexity of construction projects greatly expanded, the number and importance of subcontractors had steadily increased over the years. The very nature of the construction industry had changed.

 

That is why under modern law construction contractors are liable for injury or damage due to negligence after acceptance as long as it is reasonably foreseeable that the injury could occur.

 

Washington’s Supreme Court agreed, saying, “We have put the source of the obligation where it ought to be.”

 

It was necessary to place the obligation of responsibility for injury on negligent subcontractors to protect injured workers, bystanders, and other construction companies. The ancient legal scheme had run its course, and was superceded by new statutes and the development of the common law. But Johnson, per usual, sides with the negligent wrongdoers, not the victims or good public policy.

 

That part is expected. What is ironic is his sudden (misguided) concern about judicial activism. In his defense of keeping the company unaccountable for the death of Davis, Johnson argues that “without the stabilizing effect of stare decisis, “law could become subject to … the whims of current holders of judicial office.”

 

True, except for the fact that this decision moves Washington law in line with common sense, public interest, already changed legal precedent, and legislative updates. And unlike the manytimes Johnson has been accused of judicial activism, the Court here is advancing its own common law, not manipulating the intent of statutes created by the Legislature.

 

In an effort to fairly portray his position, it should be clear that Johnson also tries to make this case about “allow[ing] private contracting parties to continue to craft mutually beneficial and voluntary contract agreements for construction.” Of course, the majority takes the time to remind him this case is about tort law, not contract law, writing, “Thus, we respectfully disagree with the dissent that this case implicates any questions regarding contract interpretation in any way.”

 

But in the end, despite all the legal posturing, this case is very simply about preventing companies from negligently killing people with no accountability. The Supreme Court stood up and said it was wrong. Justice Johnson dissented.

 

His reason? “This rewriting of our law will cost consumers in the long run.” This is debatable, but before this, companies were allowed to kill people like Alan Davis for free.

 

For the opinions in this case, visit http://scholar.google.com/scholar_case?case=11653189741185350761&hl=en&as_sdt=2&as_vis=1&oi=scholarr

 

Jim Johnson is a Candidate for Injustice: Part 3

August 11, 2010

We’ll keep them coming, up through election day. You deserve to know how Jim Johnson gets things wrong. From the Rumbaugh campaign, the ill-reasoned dissent in Ferry County, whereby [soon to be Ret.] Justice Jim Johnson poo-poos science:

Date: July 22, 2010

Contact: Brendan Williams, (360) 791-3979

In 2005’s Ferry County v. Friends of Ferry County, the County was updating its comprehensive plan. The Growth Management Hearings Board, trial court, appellate court, and Supreme Court all agreed “that Ferry County failed to demonstrate inclusion of best available science (BAS) in listing only two species as endangered, threatened, or sensitive (ETS) in its critical areas ordinance.” The County ignored the recommendations of other authorities, like the State Department of Fish and Wildlife which “recommended that Ferry County list 12 species as ETS.”

The Court found that the County’s decision-making process failed to incorporate “a sound, reasoned process which includes best available science.” Rather than using the State guidelines or other authority, the County exclusively relied on a local retired biologist. Before retiring he had spent his career out of state and for this project he  did not consult with local experts, employ on-site observations in data gathering, provide explanation of methodology or submit his findings to peer review.

The majority of the Supreme Court correctly stood up for Washington’s law, impartiality, and transparency.

Justice Johnson, however, could not support such a position.

Instead, Johnson authored a sarcastic dissent designed to undermine Washington’s important science-based environmental protections.

Despite the well-documented positions of the State’s Department of Fish and Wildlife, Johnson tries to spin the debate by claiming the majority’s “concern [with] the “environmental” groups” relies upon “undocumented species concerns” and reframes endangered species laws as an impossible requirement to “prove a negative”.

But Johnson doesn’t stop there:

“The result is analogous to requiring designation of critical habitat for the sasquatch, a species which the county and its biologist expert could not prove is not present. Repeated reports of sasquatch sightings do not, in my view, constitute “best available science” nor require counties to hire expensive experts to disprove its presence. As further noted below, this case is more extreme. Unlike the sasquatch, several of these supposed endangered species have no reported sightings in Ferry County.” [Emphasis added.]

Justice Chambers was so taken aback by Johnson’s dissent as to craft a majority concurrence specifically addressing the flaws:

“I am bemused by my learned colleague’s knowledge of “[r]epeated reports of sasquatch sightings”… [but]adopting the dissent’s position would require us to consistently substitute our judgment for the county and the growth management hearings board. That is not appropriate within our system of divided government.” [Emphasis added.]

Once again, Johnson’s toxic judicial activism prompted rebuke from his benchmates.

But neither the legislating from the bench nor the attack on science should come as a surprise to those familiar with his private practice work, where Johnson has history undermining endangered species protections.

Just the year before, Johnson had served as the attorney for big business—including campaign contributors the BIAW—in the Common Sense Salmon Recovery case, where he argued in federal court against the government in the matter inclusion of the Chinook Salmon on the Endangered Species List.

The June 2000 Fishermen’s News described opposition to the listing as spearheaded by “an extremist property rights legal defense group” and “a front for many of the industries who have profited handsomely from salmon habitat destruction over the years.”

In 2005 the U.S. District Court judge found attorney Johnson had failed to even state a valid claim worth trial—and simply dismissed the case on summary judgment.

The addition of a judicial robe obviously did not change Johnson’s views a year later.

Luckily in both cases Johnson was unsuccessful. But whether it be salmon, sasquatch or sprawl, environmental protections must rely on the most rigorous science in order to protect our resource economies, recreation, and health now and in the future. Our Supreme Court must join in this line of protection by impartially enforcing the laws as they come to them, not promoting personal ideological agendas at every turn.

See the Ferry County opinions here http://caselaw.findlaw.com/wa-supreme-court/1029981.html

See the Common Sense Salmon opinion here http://scholar.google.com/scholar_case?case=10824665907697403157&hl=en&as_sdt=2&as_vis=1&oi=scholarr

For more information, please visit http://www.rumbaughforjustice.com

I urge you all to donate if you can. Even if its only a couple dollars, now is the time that Stan has to push to get his message heard!

Richard Sanders: Not Exactly a Model of Integrity

August 11, 2010

Those of you who read The Prof know that I often take issue with Sanders’ opinions. I also take issue with his apparent pre-judgment of issues, his lack of belief in a system to govern lawyers and judges, and his general view that anything goes in this society. Yes, he’s a true libertarian. But his version of libertarianism would equate to a legal system that does not have the support, respect, or trust required of such a system in order for it to function. We may live in a post-modern society, but there is no such ability to have a post-modern legal system.

Some helpful examples are provided by way of the Charlie Wiggins campaign:

• In 2005 Justice Sanders was disciplined by the Washington State Commission on Judicial Conduct for improperly personally interviewing sexually violent predators with cases pending before the Supreme Court. Nine judges unanimously agreed that Sanders’ conduct created an improper appearance that he might favor the sexually violent predators [In re Disciplinary Proceedings Against Sanders, 159 Wn.2d 517, 145 P.3d 1208 (2006)].

• Judges cannot decide a case in which they have an interest in the outcome, but in 2009, Justice Sanders wrote a majority opinion for the Court that directly benefited him, since he was a party in a very similar case on appeal. The Court was forced to withdraw the decision and hear argument again without Sanders [Yousoufian v. King County, 165 Wn.2d 439, 200 P.3d 232 (2009), on reconsideration, ___ Wn.2d ___ (3/25/10)].

• The justices of the Supreme Court make the final decision for all violations of lawyer ethics.  In 2007 Justice Sanders dissented from the decision of the 8 other justices to disbar a lawyer who sexually molested an 11 year old former client. Justice Sanders thought the lawyer should not be disbarred, but only suspended temporarily. [In re Disciplinary Proceeding Against Day, 162 Wn.2d 527, 173 P.3d 915 (2007].

I take special issue with Day, as I worked on this case. The lawyer’s conduct was a violation of the trust that is inherent with clients. Using the profession as a gateway to molestation is absolutely abhorrent.
Let’s not forget, Sanders was the candidate who, immediately after being sworn in, went to the steps of the legislature to deliver a speech to pro-lifers. For a libertarian, he sure has a funny way of involving himself in a woman’s right to choose.
Please vote for Charlie Wiggins in the upcoming election for Washington State Supreme Court. I’ve worked on cases where Charlie has handled the appeals. He is, arguably, the best appellate trial lawyer in the state. His analysis is superb. He is the right man for the job and will follow the law, as guided by principles of justice.

WA Supreme Court: Jailhouse Trial for Murder Uncouth (mostly)

May 30, 2010

I apologize for the delay in getting this latest set of supreme court opinions out. I have been in trial in Skagit County. For those who don’t know, Skagit lies just a tad bit north of the Prof’s chosen abode in Seattle. I actually head back up there tuesday for another trial. Nothing like living life out of a suitcase!

State v. Jaime

Jaime was tried for second degree murder. The court held, with Justice Stephens writing for the majority, that holding said trial in the jail courthouse violated his due process rights by “eroding the presumption of innocence.” Can’t say I disagree just based on the smell test, but here’s what the court had to say about it:

Consistent with this analysis, the question here is whether the average juror would take for granted his or her presence in a jail, i.e., whether jurors are so inured to the experience of being in a jail building that it would have no effect on their perspective as jurors.  The answer is self-evident.  ”‘[R]eason, principle, and common human experience’” tell us that the average juror does not take for granted a visit to a jail.  Id. at 569 (quoting Estelle, 425 U.S. at 504).  The average juror does not frequent the jailhouse for the very reason that a jailhouse is not meant to be a public space.  Unlike a courthouse, in which the public is welcome to — and in some instances required to — conduct all manner of business, a jail serves a specific purpose not generally applicable to the public at large.

The difference between jailhouses and courthouses is evident even in their architectural contrast.  Courthouses are often monuments of public life, adorned with architectural flourishes and historical exhibits that make them inviting to members of the public.  Many of our county courthouses are on historical registries and are visited each year by school children, civic groups, and tourists.  A jail, on the other hand, is singularly utilitarian.  Its purpose is to isolate from the public a segment of the population whose actions have been judged grievous enough to warrant confinement.  Jail buildings are typically austere in character, and entrance is subject to heightened security.  Indeed, the Yakima County jail in which Jaime’s trial was held was described by the judge in an unrelated trial as “a monolithic concrete building.”  Br. of Appellant at 111,  State v. Sanchez, No. 26816-1-III (Wash. Ct. App. Jan. 23, 2009) (oral argument stayed pending decision in this case).

Given the character of a jail, a juror would not take a visit to a jailhouse for granted, nor would he or she be inured to the experience.  See Holbrook, 475 U.S. at 569.  A juror’s experience with jail is very likely limited to what our societal discourse tells us of jails:  they are high-security places that house individuals who need to be in custody.  That the average juror would draw a corresponding inference from that experience is reasonable to surmise.

Of course, some jurors’ experience with a jail may be more personal but no less negative.  What if, for example, one of Jaime’s jurors was the victim of domestic violence whose abuser was housed in the jail?  Her visit to the jail would not strike her as unremarkable or routine.  It takes no great logical leap to conclude that such a juror’s heightened awareness of her surroundings could contribute negatively to her view of the defendant.

In short, under the analysis of Holbrook, holding a trial in a jail courtroom is inherently prejudicial for two reasons.  First, the setting is not in a courthouse, a public building whose purpose is to provide a neutral place to conduct the business of the law.  Second, the setting that replaces the courthouse has a purpose and function that is decidedly not neutral, routine, or commonplace.  Holding a criminal trial in a jailhouse building involves such a probability of prejudice that we must conclude it is “‘inherently lacking in due process.’”  Holbrook, 475 U.S. at 570 (quoting Estes, 381 U.S. 542-43).

That said, the court didn’t say that you could never have a jailhouse trial, but there had better be a damned good reason for doing so (articulated safety risks, etc.).

Of particular note, is the court’s calling out of a false statement to the jury by the trial court. I wholeheartedly believe, as does the court, that trust in the jury, and the juries trust in the system are essential for the proper administration of justice. The trial court here misrepresented to the jury why the trial was being held at the jailhouse. While I do not think it was the slightest ill intent by the trial, and do not fault the trial court for wanting to find an explanation that may satisfy the jury, the explanation must be truthful.

Justices Fairhurst, J. Johnson, and Madsen would hold that the prejudice of walking through a jail on the way to a courtroom is less prejudicial than shackles, and that the trial implicated no due process rights. Additionally, Justice J. Johnson would hold that the jury could have followed a curative instruction. I would point out that if this were the case, there would potentially be no due process violations, even for shackles applied inappropriately, as anything could be simply explained away. Some bells cannot be unrung, no matter how well you instruct the jury.

In Memoriam: Sanford “Sam” Kinzer (1947-2010)

May 3, 2010

kinzer.jpg

Both the Yakima Herald and the Washington State Association for Justice are reporting the death of Sanford “Sam” Kinzer, of Liberty, Washington. Sam died after a fall on his property, when he slipped and fell off a cliff, while removing a tree. My apologies if the year of his birth is wrong. Sam was 63 years young at the time of his passing.

Sam is well known in the trial lawyer community, having served as a past-Director of the Washington State Trial Lawyers Association. The following is his biography from Central Washington University’s web page:

Mr. Kinzer was born and raised in La Grande, Oregon where he attended public schools, 4-H clubs, played sports and enjoyed the outdoors. The first member of his family to graduate from college, he attended Eastern Oregon College his freshman year, and graduated with a degree in Political Science from the University of Oregon in 1970. He later graduated from the University of Wisconsin with a Masters Degree in Public Administration, and from Georgetown University Law School in 1977.

Prior to law school Kinzer worked as a lobbyist for the Teamsters Union in Washington, D.C. After graduating he practiced for a year in Seattle, and returned to the other Washington where he worked as staff counsel to the U.S. Senate Judiciary Committee, and as Chief of Staff to U.S. Senator Patrick Leahy (D-Vt.). In 1983 Kinzer moved to Seattle and joined the law firm of Preston Gates and Ellis.

Sanford has practiced law as a litigator, and trial lawyer. Between 1989 and 2005 he maintained his office in Everett, Washington representing primarily injured persons. He has been a member and director of many civic organizations, and served as a Trustee at Everett Community College during 2000-05. In July, 2005 he and his wife and two young daughters moved to Ellensburg where they now live and work. Rural dwellers, the Kinzer’s have many animals and raise and show American Quarter Horses.

Sam, a staunch advocate for education, resigned from his post as trustee at Central Washington University over tuition increases in 2009. Sam openly opposed the rate increase, and explained his position in a letter to the Daily Record:

Central Washington University just handed its students a 14 percent increase in tuition, and next year another 14 percent is proposed. The Board of Trustees rubber stamped this year’s increase at the recommendation of the administration without debate.
As a result, the CWU board has one fewer trustee. That would be me. I resigned because I am opposed to the tuition boost, and I detest the board’s habit of automatic, lock-step approvals of whatever the administration wants.

A college education has become too expensive, and we are not doing enough to control costs. The priority of university administrators (at Central and elsewhere) is to preserve the institution as is – maintain the jobs, the programs, the benefits – cuss the legislature for cutting funding, then lobby for authority to raise the kids’ tuition. It’s been going on for years.

Even when we didn’t need the money in flush times, we have had tuition increases. Seven percent increases were passed each year from 2004 to 2008, and in 2002 and 2003, there were 14 percent increases.

A full-time student at Central will now pay tuition and fees of $4,841, additional “mandatory fees” of $882, books and supplies of about $924, room and board of $8,052, transportation costs of $1,098, and estimated miscellaneous expenses of $2,016. Those numbers equal a not insignificant $17,813 for a year at CWU.

Without much help from home, Central graduates can now expect to finish with $20- $30,000 of debt. In this job market, many students will start saying it’s not worth it.

And then you hear: all of the other universities are raising tuition, Central will fall behind if we don’t follow suit. We must maintain the competitive edge, keep pace, preserve the quality of our product.

Central needs to start worrying more about whether it is going to have students around to enjoy the quality of any product. It is time to change CWU. We can no longer afford the old ivy and all of its trappings.

A good start would be for Central to step forward with innovative ideas, and say:

No more damn tuition increases for now. We think too much of our students and their families. We’re going to find another way. Raise more private money, trim the alphabet soup of courses offered, offer fewer majors, quit trying to be all things to all students, cut back on staff and teachers, make do with less.

Like any school, CWU wants a brand. To be known for something special. Here’s a thought: “Join our team at Central where we believe in our students, where we draw the line on tuition gouges, where we might ask you to mow the grass, but we’ll give you a jacket” It says:

“CWU: Where Students Come First.”

The Amateur Law Professor would like to express our condolences to Sam’s family. Our prayers are with you in this tough time.

Court of Appeals: Div I – Police May Not Search Any Vehicle After They’ve Arrested the Driver, Except for Eugene Riley’s

February 10, 2010

State v. Riley

Eugene Riley was pulled over for running a stop light.  After determining that there was an outstanding warrant, police arrested Mr. Riley.  After he had been arrested and was in handcuffs, police searched his car, finding methamphetamine.  At his trial, Mr. Riley claimed that the vehicle belonged to someone else and that he had no knowledge of the drugs being in the car.  He was convicted of possession of methamphetamine.

During the prosecution, the United States Supreme Court issued its opinion in Arizona v. Gant.  In that case, the Supreme Court had held that police may not search a vehicle after an arrest unless they are searching for evidence related to the offense for which the arrest was made.

The Court of Appeals held in this case (2-1), that because the police were operating under a good faith belief that their conduct was constitutional, the evidence they found (methamphetamine) was admissible at trial.  The majority didn’t seem to care that the search was actually unconstitutional, only that the police thought it was at the time.  The majority also declined to state that the search was unconstitutional under article I, section 7 of the Washington Constitution.

The dissent disagreed.  The dissent stated that under controlling Washington Supreme Court precedent, the search was unconstitutional under art. I, sec. 7 of the Washington constitution and should have been suppressed.

Note to Supreme Court: The dissent appears to be interpreting the state constitution according to your recent precedent. 


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