For the second time in a span of five days the Supreme Court left me with a bitter taste in my mouth and a burning disgust in my being- so much so that it may take several days for me to finish this post. As I begin it's Tuesday July 1st. As I sit down now to finish it is Saturday July 5th.
Yes, the SCOTUS came down with the ruling Monday that it would exempt some closely held, for-profit firms from covering contraception in workers' health plans. Read the full ruling in this PDF link *HERE- or spare yourself and don't. Let me provide a summary in terms that many more individuals will be able to wrap their heads around.
The question poised to the Justices was if the contraceptive mandate in the Affordable Care Act violated the 1993 Religious Freedom Restoration (RFRA) in that it required that closely held for-profit companies had to provide contraceptive coverage in the health plans they offered to their employees or pay a fine for failing to do so. The RFRA needs a quick bit of explaining. The RFRA was passed by the SCOTUS and signed in to law by Bill Clinton. Its aim was at preventing laws that substantially burdened a persons free exercise of their religion. In order for a "religious freedom" to be considered unprotected under the RFRA the court has to come to a decision that it meet two requirements. First, the burden must be necessary for the “furtherance of a compelling government interest." Secondly, it must be proven that the rule is the least restrictive way in which to further the government interest. So if whatever (X) burdens a person's religion it can only do so if it meets the rubric of a "compelling argument" and the implementation by the government(of X) has to be the least restrictive way the government can carry out that law (X). The RFRA was initially intended to protect Native Americans belief that their land was sacred. The Religious Freedom Restoration Act applies to all religions, but at the time of its passing it was most pertinent to Native American religions that are burdened by increasing expansion of government projects onto sacred land. ~Wikipedia RFRA~ It should be noted that the RFRA has been rejected in the application that citizens holding that military ventures violate their religious non-violent beliefs and therefore should be allowed to refrain from paying taxes some of which go towards military operations. In all of these cases the court has found that the RFRA does not apply because "the Supreme Court has established that uniform, mandatory participation in the Federal income tax system, irrespective of religious belief, is a compelling governmental interest." (see above link)
There are inherent issues with this act, not to mention the fact that its very existence is questionable regarding the whole separation of church and state. The Establishment Clause for one.
Also, what the history of the RFRA act has demonstrated is that all religions are not held equal. The "sincerely held beliefs" of one religion can supersede the "sincerely held belief" of another.
In the instance of Burwell v.Hobby Lobby the RFRA act was used to justify that closely held public for profit companies cannot be forced to cover contraceptives that "violate the sincerely held religious beliefs of the companies owners." (*See PDF link)
Churches are tax exempt as well as many religious institutions. These religious entities are given exceptions to rules which have traditionally been mandatory for others. For profit corporations and companies, even those which are operated by people of faith have not been allowed to play by a different set of rules. Well, until now. The ruling by the SCOTUS talks about "closely held public for profit companies"- so how many closely held for profit companies are there that can now use this ruling to refuse contraceptive coverage (and who knows what else)?
"Over 90% of all corporations, commercial enterprises, partnerships, and sole proprietorships are “closely held corporations” that employ over 52% of the American workforce. A closely held corporation is one in which 5 people or less hold more than 50% of the control of an enterprise. This list of closely held corporations includes very, very large corporations that include, besides the Christian Dominionist’s Hobby Lobby, 71 “religious corporations” that enjoined the lawsuit, Cargill, Dell, and the fascist Koch Industries among many, many others." Yes. PoliticaUSA.
The 5-4 vote for Hobby Lobby and thus for granting religious freedoms to businesses went down as one would expect. Conservatives Antonin Scalia (arguably the most partisan justice), Clarence Thomas, Samuel Alito, Anthony Kennedy and John Roberts sided as the majority. Scalia penned the courts decision which ruled in favor of Hobby Lobby. Ruth Bader Ginsberg penned what has been referred to a "scathing" 35 page dissent which included the statement: "The exercise of religion is characteristic of natural persons; not of artificial legal entities." -Ruth Bader Ginsberg
"In the Court’s view, [the Religious Freedom Restoration Act of 1993 (RFRA)] demands accommodation of a for-profit corporation’s religious beliefs no matter the impact that accommodation may have on third parties who do not share the corporation owners’ religious faith—in these cases, thousands of women employed by Hobby Lobby and Conestoga or dependents of persons those corporations employ. Persuaded that Congress enacted RFRA to serve a far less radical purpose, and mindful of the havoc the Court’s judgment can introduce, I dissent."
— Burwell v. Hobby Lobby Stores, Inc., 573 U.S. ___ (2014) (Ginsburg, J., dissenting).
To summarize, the SCOTUS,using a 20 year old statute said that religious freedoms and the freedom to be "exempt from government mandates" can be extended to private companies and corporations. A company can object to the rules because the rules don't match their religious beliefs.
I contend that the entire sentiment that contraceptives are not health care is incorrect. When the courts declared the Affordable Care Act constitutional the issue of contraceptives as health care should have been solidified within those rulings instead of the contraceptive mandate becoming a separate issue for courts to rule on. Once religious institutions were allowed to opt out of the contraceptive mandate it absolutely should have stopped there, but of course it didn't.
Contraceptives are health care. Human beings require health care. Women are human beings (in case the memo didn't get to you). Women's bodies include reproductive organs such as the uterus as well as other important things like fallopian tubes, the cervix and the vagina. These body parts exist in women regardless of whether she has willing or unwilling sexual intercourse. The reproductive system is not currently optional in human biology. Birth control is used for a variety of conditions, not just to prevent pregnancy and that is fact.
There are those that contest that health care is not a right. There are those who hold the belief that health care is a right but that health care dealing with the (at least female) reproductive systems is not included in those rights. This is claim that I find to be absolutely false. When it comes to the laws of the world I don't see how anyone can argue that men aren't the primary- if not the exclusive writers of such laws. Therefore it is not a stretch to think that perhaps these basic factors about women and the bodies of women have escaped the discussion. It's simple though, women are people and people have reproductive systems that require treatment. Whether it is treatment that controls reproduction or treatment that deals with disorders, diseases such as cancer or symptoms of other problems the need for health care is the need for health care.
This is how the SCOTUS ruling is unfair and discriminatory towards women. It penalized women for being women. Women want and deserve health insurance and that health insurance needs to provide coverage for ALL health care.
To address a factor brought up by the naysayers who say that Hobby Lobby still offered birth control- Yes, it is true that Hobby Lobby provides some forms of birth control in their health plans. However, the specific forms that they object to are not SCIENTIFICALLY different in their function or intention of preventing pregnancy from the forms that they cover. No, really. I've seen the internet trolls comment again and again that there are all these lies being told by whoever or whatever and that Hobby Lobby provides contraceptives (pregnancy preventing drugs) just not abortifiacients (drugs which induce miscarriages/abortions). Okay, yes, Hobby Lobby does not object to some methods of contraceptives but the ones they do object to are not abortifacients. Fact. "What?" you say. "Obviously if it wasn't true than the court could have brought that up and shown that the forms of birth control that Hobby Lobby objects to are really no different then the forms they do not object to, right?"
Wrong.
The case was not about whether or not the owners of Hobby Lobby were accurate in their opinions- just the fact that they BELIEVED that these types of contraceptives caused abortions was enough.
So, based on feelings, opinions and beliefs Hobby Lobby won the right to deny certain kinds of contraceptive coverage because they BELIEVE that they cause abortions even though they do not?
Yes.
IUD's (Intrauterine Devices) do not prevent fertilization if it has already occurred. There are two types of IUD's available, one with hormones and one made of copper. The morning after pill- plan b and ella do not prevent fertilization if it has already occurred. Think of women who become pregnant while on birth control, if they are on birth control they will still be taking it when fertilization occurs until they become aware of their pregnancy. Plan B contains hormones found in birth control pills at a higher level. If fertilization has occurred then it simply doesn't do anything. IUD's diminish sperm and make the uterus or womb inhospitable to implantation/fertilization and even at their extremely high rate of effectiveness it is possible to get pregnant with the IUD inserted.~The Craziest Thing About Hobby Lobby Decision~
In addition, Hobby Lobby's retirement plan funds offers eight (out of twelve)investment options for firms which manufacturer not only Plan B (the emergency contraceptives they so strongly object to), but the actual abortion pill, yes, the one (unlike the four they are objecting) that induces abortions. Mother Jones broke THIS story as well as the one revealing that Hobby Lobby covered emergency contraceptives in their health care plan until they were approached by The Becket Fund and encouraged to file suit.IS IT TRUE?
At some point the question may have entered your mind about what this ruling says about contraception that isn't included directly in Hobby Lobby's "sincerely held beliefs." Just in case you were wondering, the SCOTUS clarified a day after their initial ruling that while Hobby Lobby was suing over the four kinds of contraceptives that they incorrectly believe to be abortifacients, the ruling will apply to all contraceptives. Yes, ALL CONTRACEPTIVES. The progesterone only pills (the mini-pill), the hormonal pill, the patch, the nuva ring, the depo shot, the diaphragm, the progestin IUD, the copper IUD, the implant and all emergency contraceptives including Ella, Plan B and Next choice. I assume male and female condoms are also included in this bill but perhaps just the female condom. Hobby Lobby now doesn't have to cover any form of birth control and even if they do there are a number of other companies who filed similar objections to the coverage of any and all contraception and the court has just given them the go ahead regardless of what lower courts have already decided. Those cases have automatically been sent down to be re-ruled upon as the law has been decided by the higher court.
The public response has, in some instances, been so asinine that I find myself tempted to engage in every uninformed commenter on every website and every message board. Those who hail this as a win for religious freedoms are woefully inaccurate. How can the religious beliefs of a non-religious institution trump the right for women's access to medications? Religious freedoms have not been solidified by the ruling that companies can refuse to cover a very specific, very gendered type of health care. This case is about more than the women employees who can now legally be discriminated agaisnt based on their reproductive organs. Those companies who claimed their rights were being violated by having to provide health care were unsuccessful in overturning the Affordable Care Act. Once it was solidified that they would be unable to avoid extending coverage the next step was to get out of the contraceptive mandate and now the SCOTUS has given them the tools to do so. This is not a women agaisnt men battle or a government versus business battle. This is a human rights issue.
In conclusion, the extension of "religious freedoms" to owners of closely held for profit companies asserts some simple facts about what the highest court of the land deems to be constitutional. As it did in the Citizens United case, the SCOTUS said that corporations are people, have people like beliefs and don't have to play by the rules if they don't want to. The SCOTUS says that you as an individual cannot have your beliefs or rights unless the "company" says you can. What this does is bring subjective religious beliefs to the forefront of womens health. I've read over and over again in comment sections online that "birth control" is a choice therefore if you choose to take it you should be forced to pay for it. Again, no ones personal health decisions should be subject to the type of scrutiny that contraceptives are. Who is anyone to tell me that I should or should not use a medication that has various uses besides preventing pregnancy? It's disappointing albeit not surprising that individuals are so quick to attack another persons private health care decisions. There is nothing so private and personal about someones right to bodily autonomy.
I have chosen not to venture into some further issues related to the Burwell v. Hobby Lobby ruling in this entry for a couple reasons, mostly because I would like to publish this post before the end of July. One being that health insurance coverage for the entirely recreation based medication called Viagra has not been called into question. Another being that the people clamoring about the ruling and the great things it does to ensure religious freedoms may be in for a shock when the full ramifications and scope of this ruling has played out further. There is also the boycott Hobby Lobby movement uprising, the many other companies which will be able to get a pass on the contraceptive mandate and perhaps most importantly the epic Ruth Bader Ginsburg dissent and the calls that her retirement is imperative to maintain the 5-4 conservative/liberal split on the SCOTUS. More to come on those issues at a later date.
I encourage you to find out as much as you can about the ruling in Burwell v. Hobby Lobby because it is crucial that you have the correct information before deciding how you feel about it. Are you angry and or invested enough to call out the individuals who don't have their facts straight? Are you effected to the point that you want to boycott Hobby Lobby and other companies who will use this ruling to not pay for contraceptive coverage for their employees? Does this move you to vote in future elections for candidates that hold the same beliefs that you do? Are you happy to have just made it through this long and at times boring (I know and it's okay) blog entry from a concerned women from Massachusetts? Do you hope to never hear the company name Hobby Lobby again?
However this makes you feel or whatever you have taken away from this post, I hope that I've offered you an explanation that shows what this case has stood for and what its ruling means. I hope that you will take the time to check the facts and become informed about how laws like these effect not only you but those around you that you care about. Most of all, I hope that when it comes time to do your craft supply shopping you take a few moments and consider how you feel about spending your money at Hobby Lobby. This company has been allowed to follow a different set of rules because though some of their beliefs are scientifically inaccurate, the fact that they believe them so strongly is enough to give them a pass on including a basic and necessary medication in their health plan that negatively effects half the countries population. Who is going to say that women are not humans and not entitled to quality and inclusive health care? Who is going to say that for-profit companies should be considered to have the legal right to impose their beliefs on those who do not share those beliefs? I guess the individuals who are for their own religious freedoms over those of others and I suppose only those who already believed health care should not be compulsory or universal but with that in mind I ask those people not to separate health care and contraceptives. They are without a doubt one in the same.
Saturday, July 5, 2014
Sunday, June 29, 2014
Breaking Down the Buffer Zone Ruling
On Thursday the United States Supreme Court handed down the ruling that the 35 foot buffer zone outside abortion clinic entrances in Massachusetts is unconstitutional. I was in the lovely Registry of Motor Vehicles when I saw the news- as if being in the RMV isn't enough to ruin ones day, I was heavily disappointed but not as surprised as I thought I would be. Once I saw that the decision was unanimous I was a bit more upset and it wasn't until later on when I had the time to really look at the ruling that I understood why and began to further comprehend what the court was saying. Should you be interested in reading the ruling yourself, all 52 pages of it, you can find it HERE.
Though it is never easy to read legal text or briefings or even summaries of theses things, I read through enough of the ruling to actually understand what it was saying for those of us without degrees in constitutional law. Don't get me wrong, I am furious and disappointed that the SCOTUS failed to see the need for the buffer zone around abortion clinics and why there should be SOME exceptions to where people may physically exercise their right to free speech. However, it could have been worse.
Mind you, the actual Supreme court building has its own buffer zone. Yes, you read that right- the Supreme court has a buffer zone much larger than 35 feet buffer zone at question and they ruled that the 35 foot abortion clinics buffer zone was unconstitutional. Isn't it IRONIC?
The majority ruling in this case was written by Chief Justice John Roberts, also signing on to the majority opinion was Stephen Breyer, Ruth Bader Ginsberg, Elana Kagan and Sonya Sotomayor. While the ruling was unanimous in deciding that the zones were unconstitutional the reasoning behind this decision was split. The five previously mentioned judges held the majority, Anthony Kennedy, Clarence Thomas and Antonin Scalia held the opposing opinion and Samuel Alito was the lone opinion in his own dissent from the other judges.
The Court determined that the Massachusetts law violates the First Amendment, mostly because the buffer zones include public areas like sidewalks. The Court calls for more targeted responses to specific incidents (of harassment, stalking and or threatening behavior) and is stating that the buffer zone law is not "narrowly tailored," the burden the state government must meet when dealing with laws that encroach upon first amendment rights. States can address specific cases of obstruction but broader restrictions are not permitted National Journal. The majority opinion decided that the buffer zone law was content neutral because while it did limit where the protestors could exercise their right to free speech it did not encroach upon what it is that the protestors were saying. Scalia ardently opposed that decision.
While it may seem that the liberal judges sided with the conservatives in the ruling, when considering the breakdown of the majority and minority opinions it looks more like a standard 5-4 decision with the twist being that Roberts joined the liberals. The judges all agreed that the law as written is unconstitutional but the majority opinion leaves room for the State to take other actions. The practical result is Massachusetts state officials still have some room to write laws designed to shelter abortion clinic workers and patients from protest without the strict scrutiny incurred by the First Amendment. What those laws will be and how they will be enforced remains to be seen.
The minority opinion basically stated that the buffer zone law was unconstitutional AND the very core of the law was not content neutral because they believe it unfairly gives an advantage to abortion supporters. There were four exemptions included in the buffer zone law as to who could physically be in the 35 foot space without violating the law. One was for people who were entering and exiting the facility itself, the second exemption included clinic employees and the third exemption was for law enforcement, ambulance, firefighting,construction, utilities, public works and other municipal employees. The fourth exemption was for individuals who were walking through the zone to get to another location. In the case of the last instance clinic protestors have been known to walk up and down the sidewalk thus evading breaking the law as long as they kept moving.
Scalia, of the minority opinion stated that Roberts preserved “the ability of jurisdictions across the country to restrict antiabortion speech without fear of rigorous constitutional review." Scalia also stated that "The provision is thus unconstitutional root and branch and cannot be saved, as the majority suggests, by limiting its application to the single facility that has experienced the safety and access problems to which it is quite obviously not addressed."FORBES.
As of right now there is a big question as to what Massachusetts state officials will be able to do now that the law has been ruled unconstitutional. In Worcester and Springfield the Planned Parenthood buildings have private parking lots which protestors will still not be able to enter for the purpose of protesting. The 35 foot buffer zone at the entrances to those parking lots are a different story. It is still a crime to prevent anyone from entering a reproductive health clinic as the Freedom to Access of Clinic Entrances Act is still applicable (FACE ACT).
The location in Boston unfortunately, does not have a private lot and the entrance is right on the sidewalk. Protestors will no longer be forced back 35 feet from the entrance. This is where the law being overturned will have the most direct effect on patients. Boston has been recruiting extra clinic escorts in the past several weeks and will most likely have them out during the week now as opposed to just on Saturdays. I encourage anyone who may be interested in volunteering to visit the website. PPLM
Thursday, June 26, 2014
Buffer Zone Law overturned in Massachusetts
While the Massachusetts state buffer zone law was unanimously ruled unconstitutional today by the SCOTUS, the outcome was not shocking and could have been worse. Chief John Robert's wrote the majority decision that the buffer zone violated the first amendment but left open the possibility for States to utilize other means in order to protect patients and clinic employees from harassment. While the decision was unanimous the majority opinion (5-2-1) held that other avenues could be explored.
Court Rejects Zone to Buffer Abortion Clinics
It is incredibly disappointing to hear the ruling come down from the Supreme Court where they themselves have a protected buffer zone of 100 feet.
Court Rejects Zone to Buffer Abortion Clinics
It is incredibly disappointing to hear the ruling come down from the Supreme Court where they themselves have a protected buffer zone of 100 feet.
Monday, June 23, 2014
Waiting with Baited Breath
Any day now the SCOTUS (Supreme Court of the United States) is going to be handing down its rulings on two cases that are especially important to women and reproductive freedom. The first is what has become known as The Hobby Lobby case. This is huge because a ruling in favor of Hobby Lobby would allow for profit corporations to refuse to cover birth control in there insurance plans and not pay for it under the guise of religious freedom. Original Post HERE.
The second case has to do with the constitutionality of the Massachusetts Buffer Zone law. Will the courts uphold that protestors must stay at least 35 feet away from clinic entrances? More information on the case can be found at McCullen v. Coakley.
I am optimistic that the rulings will come down the against Hobby Lobby and for Massachusetts. This wait has been intense and it's time for it to be over.
The second case has to do with the constitutionality of the Massachusetts Buffer Zone law. Will the courts uphold that protestors must stay at least 35 feet away from clinic entrances? More information on the case can be found at McCullen v. Coakley.
I am optimistic that the rulings will come down the against Hobby Lobby and for Massachusetts. This wait has been intense and it's time for it to be over.
Sunday, June 15, 2014
Louisiana Signs off on Admitting Privileges
Bobby Jindal, Republican Governor of Louisiana signed into law on Thursday an admitting privileges bill that could leave the whole state of Louisiana with one or two abortion clinics. Louisiana is the latest state to fall prey to the unnecessary and politically motivation admitting privileges laws. In order for clinics to operate under the new law, a Doctor from each clinic needs to obtain admitting privileges at a hospital within 30 miles from the clinic. Sure, you may say, that sounds reasonable...right? Well, it isn't. Primarily the problem starts with the fact that a women who needs to be transferred to an emergency room or hospital with abortion complications has nothing to gain by having the doctor who performed the abortion having admitting privileges. All admitting privileges mean are that the Doctor has a "relationship" to the hospital. The patient will not be turned away or disadvantaged in anyway if her Doctor doesn't have a relationship with the hospital. Consider then that even if a Doctor applies for admitting privileges to a hospital the hospital can deny the request for any reason. Recently a hospital in Texas tried to revoke the admitting privileges they granted to two Doctors after being pressured by anti-abortion individuals who threatened to stage protests at the hospital. The Doctors won the right to maintain their admitting privileges after suing the hospital.
The five clinics in Louisiana have approximately two months to comply with these requirements being having to close.
The five clinics in Louisiana have approximately two months to comply with these requirements being having to close.
Saturday, May 24, 2014
Buffer Zone Disconnect
As we in Massachusetts await the decision from the Supreme Court on the fate of our buffer zone laws, our neighboring state of New Hampshire can celebrate the passing of its own 25 foot buffer zone law.
Governor Maggie Hassan has indicated that she will sign the bill into law which passed with bi-partisan support. The bill requires that protestors stay at least 25-feet from the entrance to the clinics in order to allow patients some degree of privacy. Once signed, the bill will go into effect 30 days after. Though the Senate Judiciary committee recommended waiting for the Massachusetts ruling to go come down, the senate rejected that recommendation and passed the bill by a 13-10 vote in favor of the creation of the buffer zone.
As usual the anti-choice population completely misses the point. “They will place us at a distance where we would not be able to speak to people without raising our voice,” said Susan Clifton, and we are a very gentle, peaceful group that comes here.”(CBSLOCAL)Gentle or not what seems to be lacking from the protestors logic is the right to privacy. These individuals think that they have information that women seeking abortions are unaware of. From both an ethical and religious perspective the protestors use the "freedom of speech" argument to justify that they should be able to approach strangers on the street and begin telling them how they should live their lives. In some cases the protestors don't want to "counsel" women as some claim their intentions and merely shout and mock the patients entering clinics (some entering for an abortion and some not).
The Massachusetts buffer zone requires protestors to stay at least 35-feet from the entrance to clinics or in the case of Springfield's clinic, 35-feet from the entrance to the private parking lot. If the protestors do enter the buffer zone they have to be walking through it and not come to a halt. If the law was to be overturned there would be no safe space between where the protestors are allowed and where the entrances to the clinics are. It would be naive not to expect a higher level of confrontation between protestors and patients as well as any non affiliated civilians in the area.
The challenge for courts comes from the fact that abortion is a unique issue with no other situation setting precedent for how to handle legal challenges. In the early days after abortion became legal, protestors went to such extremes that violence and chaos were often the result. From infiltrating clinics as pretend patients to gluing clinic door locks and then in 1993 murdering abortion providers (David Gunn) and in 1994 Planned Parenthood employee's (John Salvi), it isn't hard to understand why a buffer zone law is a good compromise between the right to free speech and the right to privacy. It is my sincere hope that the Supreme Court upholds the Massachusetts buffer zone law to in order to protect women and maintain a level of public safety that could otherwise lead us back into the violence and tragedy of the past.
Governor Maggie Hassan has indicated that she will sign the bill into law which passed with bi-partisan support. The bill requires that protestors stay at least 25-feet from the entrance to the clinics in order to allow patients some degree of privacy. Once signed, the bill will go into effect 30 days after. Though the Senate Judiciary committee recommended waiting for the Massachusetts ruling to go come down, the senate rejected that recommendation and passed the bill by a 13-10 vote in favor of the creation of the buffer zone.
As usual the anti-choice population completely misses the point. “They will place us at a distance where we would not be able to speak to people without raising our voice,” said Susan Clifton, and we are a very gentle, peaceful group that comes here.”(CBSLOCAL)Gentle or not what seems to be lacking from the protestors logic is the right to privacy. These individuals think that they have information that women seeking abortions are unaware of. From both an ethical and religious perspective the protestors use the "freedom of speech" argument to justify that they should be able to approach strangers on the street and begin telling them how they should live their lives. In some cases the protestors don't want to "counsel" women as some claim their intentions and merely shout and mock the patients entering clinics (some entering for an abortion and some not).
The Massachusetts buffer zone requires protestors to stay at least 35-feet from the entrance to clinics or in the case of Springfield's clinic, 35-feet from the entrance to the private parking lot. If the protestors do enter the buffer zone they have to be walking through it and not come to a halt. If the law was to be overturned there would be no safe space between where the protestors are allowed and where the entrances to the clinics are. It would be naive not to expect a higher level of confrontation between protestors and patients as well as any non affiliated civilians in the area.
The challenge for courts comes from the fact that abortion is a unique issue with no other situation setting precedent for how to handle legal challenges. In the early days after abortion became legal, protestors went to such extremes that violence and chaos were often the result. From infiltrating clinics as pretend patients to gluing clinic door locks and then in 1993 murdering abortion providers (David Gunn) and in 1994 Planned Parenthood employee's (John Salvi), it isn't hard to understand why a buffer zone law is a good compromise between the right to free speech and the right to privacy. It is my sincere hope that the Supreme Court upholds the Massachusetts buffer zone law to in order to protect women and maintain a level of public safety that could otherwise lead us back into the violence and tragedy of the past.
Tuesday, May 6, 2014
Why I Filmed my Abortion
It was through my facebook feed that I first found the link to this COSMO article. In short, a young woman who works at a women's clinic becomes pregnant and has an abortion. She decides to film part of the actual procedure and make the video public. Internet trolls commence and spew hate on her Vimeo film page and on the comment sections of the Cosmo article. The video is not graphic and it does not show any part of the actual suction process. The video shows Emily Lett talking to the camera giving some brief background information on who she is and what she does. She is an abortion counselor and when she discovers that she is pregnant she decides to film part of the procedure. You can view the video HERE.
If so inclined, I suggest publishing a comment on the Cosmo site or making an account on Vimeo to leave a statement in support. Bravo to this brave young girl who tells the world that she made the right decision for her and she is not going to be shamed for it.
If so inclined, I suggest publishing a comment on the Cosmo site or making an account on Vimeo to leave a statement in support. Bravo to this brave young girl who tells the world that she made the right decision for her and she is not going to be shamed for it.
Tuesday, April 29, 2014
One State down?
You've probably heard it before, politicians declaring that they want to make their state "abortion free."
Governor Phil Bryant of Mississippi has often stated that he wants to end abortion in Mississippi.
Unfortunately for the women of the state, Gov. Bryant and others have made Mississippi dangerously close to becoming the first state post Roe which would have no abortion clinic.
Of course this doesn't mean that Mississippi will be an abortion free state at all- it just means that women in Mississippi will have no place in their state where they can obtain a safe legal procedure. As more and more states look to enact legislation requiring admitting privileges, the number of clinics able to meet this unnecessary and frivolous requirement are minimal at best because hospitals can deny these privileges simply because they want to.
This battle has been going on for over a year in Mississippi. U.S. District Judge Daniel P. Jordan III let the law take effect in July 2012, after the clinic sued the state. Judge Jordan blocked the state from closing the clinic however, while it tried to comply. Now the clinic is back in court fighting to keep its doors open after area hospitals have refused to grant admitting privileges to the clinics doctors. I strongly encourage you to view my post on admitting privileges before continuing (if you haven't already) as it explains what the admitting privilege requirements really mean and why the only purpose for them to exist is to force clinics to close. In short, admitting privileges have nothing to do with the quality of care, competency of the doctor and lack of said privileges does not prevent patients with abortion related complications from receiving care- at all. Patients cannot be turned away if they haven't been sent by a doctor with admitting privileges and there is no added benefit to any patient who has been referred to a hospital by a doctor with admitting privileges.
The court is now faced with the decision of whether or not the admitting privilege requirement can be enforced while simultaneously avoiding creating an "undue burden." Confused? I don't blame you. If the admitting privilege requirement is enforced the only clinic in Mississippi providing abortion services will be forced to shut down. Shutting down the last clinic which provides LEGAL abortions in the state of Mississippi could be construed as an undue burden as it is forcing women to go out of state to obtain abortion services. As far as the undue burden aspect we must look to the case of Planned Parenthood v Casey which was decided in 1992. Though the ruling did hold the basic principle of Roe v Wade- that abortion would remain legal in the United States up to "viability," the ruling also granted states the right to impose restrictions on how and when and under what circumstances women would be allowed to obtain abortions. Since the term "undue burden" is entirely subjective (look HERE to the case in Texas where a Judge stated women would not be inconvenienced by a lack of access to clinics because they could just "drive faster") what can and cannot be considered an undue burden is highly subjective.
Because there are states with pending admitting privileges legislation and states with this legislation that have already been deemed "constitutional" under appeal (ahem, Texas), it is difficult to predict what the outcome will be in Mississippi. If the court upholds the admitting privilege requirements then the last clinic in Mississippi will be forced to close. While Mississippi will be the first state to effectively negate the legality of abortion it will certainly not be the last and as usual the casualties will be women. This is a dangerous road to be going down and as Governor Bryant and other abortion rights foes will find out there is no way to drive the need for abortions out of any state- with or without clinics women will always need abortion services whether or not the state is willing to grant them a safe procedure or not. Mississippi should not be proud to be the first state to deny women that right.
Governor Phil Bryant of Mississippi has often stated that he wants to end abortion in Mississippi.
Unfortunately for the women of the state, Gov. Bryant and others have made Mississippi dangerously close to becoming the first state post Roe which would have no abortion clinic.
Of course this doesn't mean that Mississippi will be an abortion free state at all- it just means that women in Mississippi will have no place in their state where they can obtain a safe legal procedure. As more and more states look to enact legislation requiring admitting privileges, the number of clinics able to meet this unnecessary and frivolous requirement are minimal at best because hospitals can deny these privileges simply because they want to.
This battle has been going on for over a year in Mississippi. U.S. District Judge Daniel P. Jordan III let the law take effect in July 2012, after the clinic sued the state. Judge Jordan blocked the state from closing the clinic however, while it tried to comply. Now the clinic is back in court fighting to keep its doors open after area hospitals have refused to grant admitting privileges to the clinics doctors. I strongly encourage you to view my post on admitting privileges before continuing (if you haven't already) as it explains what the admitting privilege requirements really mean and why the only purpose for them to exist is to force clinics to close. In short, admitting privileges have nothing to do with the quality of care, competency of the doctor and lack of said privileges does not prevent patients with abortion related complications from receiving care- at all. Patients cannot be turned away if they haven't been sent by a doctor with admitting privileges and there is no added benefit to any patient who has been referred to a hospital by a doctor with admitting privileges.
The court is now faced with the decision of whether or not the admitting privilege requirement can be enforced while simultaneously avoiding creating an "undue burden." Confused? I don't blame you. If the admitting privilege requirement is enforced the only clinic in Mississippi providing abortion services will be forced to shut down. Shutting down the last clinic which provides LEGAL abortions in the state of Mississippi could be construed as an undue burden as it is forcing women to go out of state to obtain abortion services. As far as the undue burden aspect we must look to the case of Planned Parenthood v Casey which was decided in 1992. Though the ruling did hold the basic principle of Roe v Wade- that abortion would remain legal in the United States up to "viability," the ruling also granted states the right to impose restrictions on how and when and under what circumstances women would be allowed to obtain abortions. Since the term "undue burden" is entirely subjective (look HERE to the case in Texas where a Judge stated women would not be inconvenienced by a lack of access to clinics because they could just "drive faster") what can and cannot be considered an undue burden is highly subjective.
Because there are states with pending admitting privileges legislation and states with this legislation that have already been deemed "constitutional" under appeal (ahem, Texas), it is difficult to predict what the outcome will be in Mississippi. If the court upholds the admitting privilege requirements then the last clinic in Mississippi will be forced to close. While Mississippi will be the first state to effectively negate the legality of abortion it will certainly not be the last and as usual the casualties will be women. This is a dangerous road to be going down and as Governor Bryant and other abortion rights foes will find out there is no way to drive the need for abortions out of any state- with or without clinics women will always need abortion services whether or not the state is willing to grant them a safe procedure or not. Mississippi should not be proud to be the first state to deny women that right.
Monday, April 21, 2014
Admitting Priviledges
Anti-choice folks cried foul when their motives for requiring doctors who provide abortions to obtain admitting privileges at local hospitals were labeled politically motivated. My what a difference six months makes.
For instance, Executive Director for Wisconsin Right to Life, Barbara Lyons stated: "The 5th Circuit decision matters because the admitting privileges provision is essential to protect a woman’s health. With no admitting privileges, a woman suffering complications from her abortion is placed in an ambulance and taken to a hospital where no one knows her, her medical records are not available, and she is left to explain why she is there."
With that dramatic descriptive imagery one could be led to believe that abortion clinics ship off the few patients with complications to some unknown place under a shroud of secrecy and shame. I can even picture the ambulance pulling up and a patient emerging on a stretcher, eyes down cast, blood pooling around her gurney and being interrogated by medical professionals who apparently have no idea how to recognize or handle abortion complications. Barbara Lyons would have you believe that without admitting privileges doctors are unable to admit patients with complications leaving women vulnerable and helpless should their surgery go awry.
Anti-women Governor Rick Perry signed legislation in Texas requiring clinics to have at least one doctor with admitting privileges to a hospital within 30 miles (the bill is referred to as HB 2). Upon this action the supporters of reproductive rights knew immediately what forces were at work. Hospital admitting privileges can be granted or denied without any logical reasoning behind the decisions. Some hospitals even have a requirement that Doctors must admit a certain amount of patients once granted the admitting privileges in order to keep them. If you understand how abortion services work you might note immediately that abortion providers often work on a part time basis with clinics and do not admit many patients to local hospitals. In fact, at a recent conference I heard an abortion provider declare that if you are admitting more than one patient per year to the hospital due to complications arising from abortion procedures that you are not a very good provider. Due to safety concerns in certain hostile states, doctors are actually flown in to clinics located in places where an abortion provider would likely face harassment and threats of violence should they reside in the community. If a doctor only goes to a clinic once a week, how likely are they to be granted admitting privileges by the local hospital? Not very. To recap, hospital admitting privileges can be granted or denied for any reason. Hospitals are not required to explain why or why not they choose to grant admitting privileges to some doctors and not to others. Legislation requiring abortion clinics to have doctors with admitting privileges is a ploy to close down clinics and absolutely places undue burdens on the women who lose access to clinics because of this policy. It's been about five months since these new requirements took effect and they have caused the closure of about a third of all abortion clinics in Texas.
Here are some facts:
1. Surgical abortions are safer then giving birth and complications are rare. According to the Guttmacher Institute when performed under proper medical conditions by trained personnel in a hygienic setting, abortion is an extremely safe procedure. Fewer than 1% of all U.S. abortion patients experience a major complication and the risk of death associated with abortion is 10 times as low as that associated with childbirth.
2. Under a 1986 federal law known as EMTALA, hospitals are required to provide, admit and treat anyone who needs emergency care. This requirement includes pregnant women who need a life-saving abortion, are in labor, or are suffering the effects of a botched abortion. Hospitals cannot refuse to treat a women with abortion complications just because her abortion provider did not have a prior "relationship" with the hospital which is all admitting privileges mean anyway.
Furthermore, as Barbara Lyons laments that women will be stranded at hospitals where "no one knows her" and "her medical records are not available," the most pressing question I have is how would that change if a doctor had admitting privileges? The quality of care given to these women should not depend on whether or not anyone at the hospital knows her or not. That sentiment is so far from the point that I am surprised she takes herself seriously. In fact, how long a women has to wait and how far she has e to travel for abortion services is directly related to her care. When Texas decided to require this arbitrary admitting privilege regulation it is placing politics so far above the care of women it is baffling that anyone fails to see the thinly veiled attempt at closing clinics in the name of protecting women.
In fact proponents of the admitting privilege legislation stated that hospitals would not be able to discriminate against abortion providers seeking admitting privileges as many opponents claimed. They stated that the law was only intended to make abortion safer for women and any one who thought otherwise didn't truly care about women's health. Take a look at this articlefrom last Fall. Granted it comes from the extreme "lifenews.com", but even still that goes to further to prove the point that admitting privileges are being used to close clinics, not to make them safer. In the instance of the horrible case of Kermit Gosnell especially, I am hard pressed to see how any admitting privileges would have changed this sick and disturbed individual who is the exception and not the rule when it comes to abortion providers. This article also brings up other controversial issues that aren't explained in much depth either but what I want to highlight is the flawed logic used by the writer and how misleading it is. "Admitting privileges should not be a problem for a good physician to come by," says the author, "the criteria hospitals examine when deciding whether or not to grant admitting privileges to a local physician tend to be board certifications, malpractice history and reported complications, level of experience and expertise, and validation of educational credentials. Bottom line: If a doctor cannot get admitting privileges, then maybe women should be protected from receiving any medical treatment (or mistreatment) from him or her." So it IS about women's health and safety right? Not just a ploy to close clinics...if physicians are granted admitting privileges based on all of the described criteria above than there should be no problem for legitimate providers to gain them. Right? Well, no...
Doctor with over 40 years experience has difficulties gaining admitting privileges.
In addition, it was revealed last week that University General Hospital of Dallas revoked admitting privileges which had been granted to two doctors and specifically stated that it was because these doctors provided abortions. The hospital stated:
"It has come to our attention that you perform 'voluntary interruption of pregnancies' as a regular part of your medical practice. As a matter of policy, UGHD does not perform these procedures due to the fact that obstetric procedures are not within UGHD's scope of services and that UGHD does not have the capacity to treat complications that may arise from voluntary interruption of pregnancies."
NATION NOW
A judge has already issued a temporary injunction against the revocation as both doctors have sued the state of Texas citing a law that prohibits discrimination based on a physicians decision to provide abortion services or not. The law was brought up by supporters of HB 2 as a reason why hospitals would not be allowed to refuse admitting privileges solely on the basis of whether they performed abortions or not. In the lifenews.com article our author claims, "admitting privileges should not be hard for a good physician to come by," so why are they? Could it be because they have little to do with protecting women and a lot to do with hindering abortion access for women?
Texas is not the only state that has used admitting privileges legislation to try to close down clinics. Wisconsin and Mississippi are at various stages of enacting and retrying the controversial admitting privileges requirement. Alabama has passed a similar law that would close down three of the five abortion clinics in the State. The constitutionality of that law is being challenged and a federal judge decided to send the case to trial on May 19th which will determine whether or not the law will take effect in yet another state.
"It really is about the health care of women," Alabama State Senator Scott Beason asserted.
Really? Forgive me if I remain skeptical.
For instance, Executive Director for Wisconsin Right to Life, Barbara Lyons stated: "The 5th Circuit decision matters because the admitting privileges provision is essential to protect a woman’s health. With no admitting privileges, a woman suffering complications from her abortion is placed in an ambulance and taken to a hospital where no one knows her, her medical records are not available, and she is left to explain why she is there."
With that dramatic descriptive imagery one could be led to believe that abortion clinics ship off the few patients with complications to some unknown place under a shroud of secrecy and shame. I can even picture the ambulance pulling up and a patient emerging on a stretcher, eyes down cast, blood pooling around her gurney and being interrogated by medical professionals who apparently have no idea how to recognize or handle abortion complications. Barbara Lyons would have you believe that without admitting privileges doctors are unable to admit patients with complications leaving women vulnerable and helpless should their surgery go awry.
Anti-women Governor Rick Perry signed legislation in Texas requiring clinics to have at least one doctor with admitting privileges to a hospital within 30 miles (the bill is referred to as HB 2). Upon this action the supporters of reproductive rights knew immediately what forces were at work. Hospital admitting privileges can be granted or denied without any logical reasoning behind the decisions. Some hospitals even have a requirement that Doctors must admit a certain amount of patients once granted the admitting privileges in order to keep them. If you understand how abortion services work you might note immediately that abortion providers often work on a part time basis with clinics and do not admit many patients to local hospitals. In fact, at a recent conference I heard an abortion provider declare that if you are admitting more than one patient per year to the hospital due to complications arising from abortion procedures that you are not a very good provider. Due to safety concerns in certain hostile states, doctors are actually flown in to clinics located in places where an abortion provider would likely face harassment and threats of violence should they reside in the community. If a doctor only goes to a clinic once a week, how likely are they to be granted admitting privileges by the local hospital? Not very. To recap, hospital admitting privileges can be granted or denied for any reason. Hospitals are not required to explain why or why not they choose to grant admitting privileges to some doctors and not to others. Legislation requiring abortion clinics to have doctors with admitting privileges is a ploy to close down clinics and absolutely places undue burdens on the women who lose access to clinics because of this policy. It's been about five months since these new requirements took effect and they have caused the closure of about a third of all abortion clinics in Texas.
Here are some facts:
1. Surgical abortions are safer then giving birth and complications are rare. According to the Guttmacher Institute when performed under proper medical conditions by trained personnel in a hygienic setting, abortion is an extremely safe procedure. Fewer than 1% of all U.S. abortion patients experience a major complication and the risk of death associated with abortion is 10 times as low as that associated with childbirth.
2. Under a 1986 federal law known as EMTALA, hospitals are required to provide, admit and treat anyone who needs emergency care. This requirement includes pregnant women who need a life-saving abortion, are in labor, or are suffering the effects of a botched abortion. Hospitals cannot refuse to treat a women with abortion complications just because her abortion provider did not have a prior "relationship" with the hospital which is all admitting privileges mean anyway.
Furthermore, as Barbara Lyons laments that women will be stranded at hospitals where "no one knows her" and "her medical records are not available," the most pressing question I have is how would that change if a doctor had admitting privileges? The quality of care given to these women should not depend on whether or not anyone at the hospital knows her or not. That sentiment is so far from the point that I am surprised she takes herself seriously. In fact, how long a women has to wait and how far she has e to travel for abortion services is directly related to her care. When Texas decided to require this arbitrary admitting privilege regulation it is placing politics so far above the care of women it is baffling that anyone fails to see the thinly veiled attempt at closing clinics in the name of protecting women.
In fact proponents of the admitting privilege legislation stated that hospitals would not be able to discriminate against abortion providers seeking admitting privileges as many opponents claimed. They stated that the law was only intended to make abortion safer for women and any one who thought otherwise didn't truly care about women's health. Take a look at this articlefrom last Fall. Granted it comes from the extreme "lifenews.com", but even still that goes to further to prove the point that admitting privileges are being used to close clinics, not to make them safer. In the instance of the horrible case of Kermit Gosnell especially, I am hard pressed to see how any admitting privileges would have changed this sick and disturbed individual who is the exception and not the rule when it comes to abortion providers. This article also brings up other controversial issues that aren't explained in much depth either but what I want to highlight is the flawed logic used by the writer and how misleading it is. "Admitting privileges should not be a problem for a good physician to come by," says the author, "the criteria hospitals examine when deciding whether or not to grant admitting privileges to a local physician tend to be board certifications, malpractice history and reported complications, level of experience and expertise, and validation of educational credentials. Bottom line: If a doctor cannot get admitting privileges, then maybe women should be protected from receiving any medical treatment (or mistreatment) from him or her." So it IS about women's health and safety right? Not just a ploy to close clinics...if physicians are granted admitting privileges based on all of the described criteria above than there should be no problem for legitimate providers to gain them. Right? Well, no...
Doctor with over 40 years experience has difficulties gaining admitting privileges.
In addition, it was revealed last week that University General Hospital of Dallas revoked admitting privileges which had been granted to two doctors and specifically stated that it was because these doctors provided abortions. The hospital stated:
"It has come to our attention that you perform 'voluntary interruption of pregnancies' as a regular part of your medical practice. As a matter of policy, UGHD does not perform these procedures due to the fact that obstetric procedures are not within UGHD's scope of services and that UGHD does not have the capacity to treat complications that may arise from voluntary interruption of pregnancies."
NATION NOW
A judge has already issued a temporary injunction against the revocation as both doctors have sued the state of Texas citing a law that prohibits discrimination based on a physicians decision to provide abortion services or not. The law was brought up by supporters of HB 2 as a reason why hospitals would not be allowed to refuse admitting privileges solely on the basis of whether they performed abortions or not. In the lifenews.com article our author claims, "admitting privileges should not be hard for a good physician to come by," so why are they? Could it be because they have little to do with protecting women and a lot to do with hindering abortion access for women?
Texas is not the only state that has used admitting privileges legislation to try to close down clinics. Wisconsin and Mississippi are at various stages of enacting and retrying the controversial admitting privileges requirement. Alabama has passed a similar law that would close down three of the five abortion clinics in the State. The constitutionality of that law is being challenged and a federal judge decided to send the case to trial on May 19th which will determine whether or not the law will take effect in yet another state.
"It really is about the health care of women," Alabama State Senator Scott Beason asserted.
Really? Forgive me if I remain skeptical.
Monday, April 14, 2014
#CLPP2014
This weekend I attended the 28th annual conference "From Abortion Right's to Social Justice Building the Movement for Reproductive Freedom." The event is hosted by the Civil Liberties and Public Policy program at Hampshire college.
The experience is described well in the introduction and welcome statement in the conference program. "CLPP is a national reproductive rights and justice organization dedicated to educating, mentoring and inspiring new generations of advocates, leaders and supporters. Combining activism, organizing, leadership training and reproductive rights movement building, CLPP promotes an all inclusive agenda that advances reproductive rights and health and social and economic justice."
A lofty goal no doubt, and one that may have even seemed impossible to me had I not gone and experienced it myself. As challenging as creating an environment of acceptance and education is, the CLPP conference comes the closest I have ever been to experiencing an "all inclusive" agenda.
This annual Spring conference is held at Hampshire College and is put on by Civil Liberties and Public Policy (CLPP). The three day conference starts on Friday night and goes through Sunday afternoon. The conference features an Abortion Speak out as well as workshops on a wide variety of topics. Some examples from this years conference include Creative Solutions to Abortion Restrictions, Queering Reproductive Justice, Invisible: Women in America's Prisons and Jails, Birth Justice, Showing up in Solidarity When Racism and Privileges are the Co-Hosts, Organizing for Reproductive Justice in Religious Communities, The Intersection of Immigrant Rights and Reproductive Justice and MANY MANY MORE...in fact, if I had to criticize the conference structure for anything it would be that their are just too many workshops on the Saturday schedule (three sessions) and not enough on Friday and Sunday (One session each), I would love it if the conference were spread out another day or two just to give participants the opportunity to attend more workshops. I would have loved to have been able to go to another few workshops on topics that weren't my first choice issues but t
Conferences like these are important for both the Reproductive Justice (RJ) field as well as all individuals who want to work towards social justice in any form. There is an incredible amount of topics and resources available at CLPP and it is crucial for discussions to take place around these vital topics. Without the opportunity to be exposed to the experiences and opinions of those unlike ourselves we are unable to grow and thrive as individuals. I appreciated the vast intersectionality that CLPP demonstrated by grouping class, race, gender and gender identity under the large umbrella of Reproductive Rights and Social Justice as a whole.
For me personally, my most memorable experience was having Dr. Susan Robinson (one of only four late term abortion providers in the country) sit next to me during a workshop and chat with her about Crisis Pregnancy Centers. She later gifted me with a necklace made by her husband featuring a tiny copper wire hanger on a black string; reminding us of how far we've come and how much further we have to go in the field of Reproductive Rights.
CLPP 2015 will be held on the Hampshire College campus on April 10-12th. More information can be found here.
The experience is described well in the introduction and welcome statement in the conference program. "CLPP is a national reproductive rights and justice organization dedicated to educating, mentoring and inspiring new generations of advocates, leaders and supporters. Combining activism, organizing, leadership training and reproductive rights movement building, CLPP promotes an all inclusive agenda that advances reproductive rights and health and social and economic justice."
A lofty goal no doubt, and one that may have even seemed impossible to me had I not gone and experienced it myself. As challenging as creating an environment of acceptance and education is, the CLPP conference comes the closest I have ever been to experiencing an "all inclusive" agenda.
This annual Spring conference is held at Hampshire College and is put on by Civil Liberties and Public Policy (CLPP). The three day conference starts on Friday night and goes through Sunday afternoon. The conference features an Abortion Speak out as well as workshops on a wide variety of topics. Some examples from this years conference include Creative Solutions to Abortion Restrictions, Queering Reproductive Justice, Invisible: Women in America's Prisons and Jails, Birth Justice, Showing up in Solidarity When Racism and Privileges are the Co-Hosts, Organizing for Reproductive Justice in Religious Communities, The Intersection of Immigrant Rights and Reproductive Justice and MANY MANY MORE...in fact, if I had to criticize the conference structure for anything it would be that their are just too many workshops on the Saturday schedule (three sessions) and not enough on Friday and Sunday (One session each), I would love it if the conference were spread out another day or two just to give participants the opportunity to attend more workshops. I would have loved to have been able to go to another few workshops on topics that weren't my first choice issues but t
Conferences like these are important for both the Reproductive Justice (RJ) field as well as all individuals who want to work towards social justice in any form. There is an incredible amount of topics and resources available at CLPP and it is crucial for discussions to take place around these vital topics. Without the opportunity to be exposed to the experiences and opinions of those unlike ourselves we are unable to grow and thrive as individuals. I appreciated the vast intersectionality that CLPP demonstrated by grouping class, race, gender and gender identity under the large umbrella of Reproductive Rights and Social Justice as a whole.
For me personally, my most memorable experience was having Dr. Susan Robinson (one of only four late term abortion providers in the country) sit next to me during a workshop and chat with her about Crisis Pregnancy Centers. She later gifted me with a necklace made by her husband featuring a tiny copper wire hanger on a black string; reminding us of how far we've come and how much further we have to go in the field of Reproductive Rights.
CLPP 2015 will be held on the Hampshire College campus on April 10-12th. More information can be found here.
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