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July 31, 2007
Justice Department Tips Off Senator Stevens Before Searching His Home!
What's striking is this tidbit in today's WaPo:
Stevens said in a statement that his attorneys were advised of the impending search yesterday morning.I spent nearly 9 years as a federal prosecutor. I'm not aware of a single instance when any prosecutor or agent told anyone outside the Justice Department that a search warrant was going to be executed later in the day. Telling outsiders -- especially lawyers for the person whose property will be searched -- defeats one of the principal purposes of a search warrant: SURPRISE to ensure the integrity of the evidence field.
If you're going to tell the target of the search in advance, then why not just serve a subpoena and trust in compliance?
Now Stevens' reported comment may have been a spin on a phone call from someone at DOJ when the agents were at the front door or the agents themselves calling Stevens' attorneys to ask for the key. But those seem more than a stretch considering that Stevens says the tip came in the a.m., and the search was executed in the p.m.
Maybe it's spin. Or maybe someone at DOJ broke a cardinal principle. Certainly, only a few people would have known about the impending search: the prosecutors conducting the investigation, the team of agents preparing to execute the search . . . and high-level DOJ officials who, considering that Stevens is a U.S. Senator, would have had to approve the search.
Regardless, one thing is clear about Stevens' status from the use of a search warrant. He is now squarely in the cross-hairs of a federal criminal investigation.
According to the Justice Department's Criminal Resource Manual Sec. 659:
A search warrant should not be used to obtain documentary materials believed to be in the private possession of a disinterested third party unless it appears that the use of a subpoena, summons, request, or other less intrusive alternative means of obtaining the materials would substantially jeopardize the availability or usefulness of the materials sought, and the application for the warrant has been authorized as provided in paragraph (a)(2) of this section.
Ted Stevens, clearly, is no "disinterested third party." More likely, given the hoopla a search warrant's execution creates, Stevens is a target -- defined by the U.S. Attorney's Manual Sec. 9-11.151 this way:
"A 'target' is a person as to whom the prosecutor or the grand jury has substantial evidence linking him or her to the commission of a crime and who, in the judgment of the prosecutor, is a putative defendant."In any case, while on the one hand, it's just this sort of event -- a federal search warrant executed against a powerful politician of the same party as the administration -- that suggests the professionals in the Justice Department are doing their job, the remark WaPo attributed to Stevens -- that his attorneys were given a heads-up -- reminds that this Justice Department works very differently at the top than on the line.
If it's true that Stevens' lawyers had a heads-up about the search, I think it's more than fair to ask questions -- and to get answers -- about exactly who told Stevens' lawyers about the afternoon's planned search, who approved the disclosure, and what was the purpose of the tip-off.
Posted by shertaugh at 8:43 AM
July 30, 2007
Meet the Beetles
Posted by Eric at 10:33 AM
July 26, 2007
Getsy v. Mitchell Was Rightly Decided En Banc
I suspect I may be more of a fan than Orin of the so-called "rule of consistency" in single trials. (That's the rule, now largely defunct, that forbids a single jury from convicting one of two alleged co-conspirators while acquitting the other.)
But where two people alleged to have acted jointly are tried by separate juries, as was the case in Getsy v. Mitchell, the rule should not apply. There's just no way on earth to infer, from the fact of one jury's acquittal, that the other jury erred in any way by convicting.
I hope that the Supreme Court will not grant cert in this case; as I argued in my Harvard Law Review article on inconsistent criminal jury verdicts (111 Harvard Law Review 771), I'd like to see the Court revisit and reform its approach to logically inconsistent verdicts -- and Getsy v. Mitchell strikes me as a case that would just lead the Court to dig its heels in deeper rather than presenting an opportunity for helpful reform.
Posted by Eric at 11:44 AM
July 25, 2007
Alberto "Fredo" Gonzales -- So What is Bush Saying?
So just exactly what is the president saying when he calls the Attorney General "Fredo"?
Well, in "The Godfather - Part II", here's how Michael Corleone described his brother Fredo:
Fredo? Well, he's got a good heart but he's weak, and he's stupid. And this is life and death.
All right then. Fredo, though good hearted, is "weak" and "stupid". Nice.
And here's how Fredo described himself in a passionate exchange with Michael, who at this point in "The Godfather- Part II" had testified before a Senate committee and was facing possible perjury charges, and Fredo's role in taking sides against the Family comes out:
* Fredo: "Taken care of me?! You're my kid brother! You take care of me? Did you ever think about that? Did you ever once think about that? 'Send Fredo off to do this, send Fredo off to do that! Let Fredo take care of some Mickey Mouse nightclub somewhere! Send Fredo to pick somebody up at the airport!' I'm your older brother, Mike, and I was stepped over!"
* Michael: "It's the way Pop wanted it."
* Fredo: "It ain't the way I wanted it! I can handle things, I'm smart! Not like everybody says. Like dumb. I'm smart and I want respect!"
So there it is. Fredo is "weak", "stupid", everyone thinks he's "dumb", and he's only qualified enough to handle a Mickey Mouse nightclub or pick up someone at the airport. Super.
And Bush has someone whom he thinks of as "Fredo" running the Justice Department. Great. Just great
Posted by shertaugh at 8:39 AM
July 24, 2007
"How Many Gun Barrels Have You Looked Down?"
Black don't wash off. Put us in a nice suit, nice wheels, nice zip code and membership to the right club and some fool with a badge is going to shake us down to see what falls out.My junior year at Brown, I ran down the hill to catch a Bonanza Bus to Boston. Black man wearing jeans and a red t shirt in the summer of 80. We all know how deserted downtown Providence use to be on a Saturday morning. A police officer, drove his car out of nowhere in front of me as I was running across the last street before the bus station. I literally fell onto the hood of the car and when I push myself back, my mother's oldest son was looking down the barrel of a revolver. My crime, I fit the description of a bank robber. Here we go again, I was only 20, but this was the third time, I fit the description of a bank robber. The first time, I was 16 on my bicycle coming from the dentist in Hempstead, NY. Do you know how your face looks when you just had a cavity filled. Cop didn't care that I had a bill and swollen face. They sent (4) cars to arrest one of me that time. The bank robber who was on a motorcycle got away.
Anyway, back in 1980, I don't recall banks being open on Saturday in Providence and it was 8am. I definitely don't believe that showing a Brown ID immediately clears a bank robber of all wrong doings. But that was sufficient for him to speed off without even an apology. I was milliseconds from reaching for my wallet and ID because, I was only thinking about catching the bus. Wonder how the story would have ended if I had been faster.
I'll be honest, I am boring. I have never had a criminal incident, no troubled teenage years, no dreadlocks, tattoos, gang affiliation, alcohol or drug abuse, domestic violence or any issues that would profile me as a trouble maker. I had a DOD security clearance for (5) years. At one time, Uncle Sam knew more about me than my mother, they researched my background all the way back to high school across (4) states and (3) countries and still gave me clearance to look at security stuff. Can't get more squeaky clean, but to guys with the badge, I must be up to something.
I have been harassed my whole life for being a black man in the wrong place, i.e. living in a white world. I have been harassed for going for a walk in downtown Boston, for sitting in my car in San Jose Hills waiting for a real estate agent. Israeli Security refused to believe I was not a basketball player or I must be a spy because no one sends a black man to Israel on business.
I cycle over a 100 miles a week all over San Fransisco Bay area. I will not leave the house without ID, because, I know, there are nervous house wives looking out their windows as I ride my bike through their neighborhoods at 18 miles a hour. The only reason he's riding through here is, he's looking to steal something and hide it in his tight biker shorts.
If a sound a bit sensitive, ask yourself, how many gun barrels have you looked down with a police or some officer of the state at the other end. Me, about a dozen. How many times have you been arrested for making an illegal U turn, 1 mile from your house? I drive a nice sports car. I would never make a quick run to the grocery store in bummy house clothes. If I don't look like I own it, somebody is going to check to see if it is mine. I had a friend that kept a diary and wrote a letter to the local Walnut Creek newspaper and the chief of Police. He listed the dates, badge numbers and outcome of all the police stops over a period of time. He included a copy of his mortgage, job id and other information to show, he lives and works here and will the stop harassing him. Never got stopped again.
Posted by Eric at 1:40 PM
July 22, 2007
The President's Power To Ignore Judicial Orders
The question begging to be asked -- and answered -- is whether, under the OLC memo and the administration's view of executive power, the president can direct all executive branch appointees to refuse to enforce a judgment of the Supreme Court?
Perhaps Eugene Volokh or Marty Lederman at Balkinization will address this question.
And I assume the answer requires something more than a reference to Marbury v. Madison or the mention of "judicial review" or even the president's Art. II obligation to see that the laws -- including judge-made laws -- are faithfully executed.
Art. II of the Constitution, or Articles I and III, say nothing about judicial review and, certainly, nothing about a president's duty to abide by a federal-court constitutional ruling. The Supreme Court has been the final arbitor because the other two branches have allowed it to be (although some say that Andrew Jackson refused to enforce the Supreme Court's ruling in the Indian-Removal cases).
And, sure, SCOTUS rejected the Nixonian argument that each branch gets to make the final call on the constitutionality of its own actions. But that takes us right back to the unstated principle in the Constitution of judicial review.
Finally, the president's constitutional duty to execute the laws proves nothing here. This administration -- and the Reagan OLC memo -- already believe that, regardless of a duly enacted law requiring the U.S. Attorney in D.C. to prosecute alleged congressional contemnors, the president can ignore that law when the contempt arises out of an assertion of executive privilege.
Not to overstate things, but the Constitution is hanging by a thread here.
Posted by shertaugh at 8:34 AM
July 20, 2007
The Ninth Amendment, Dog Fighting, Gambling, and Constitutional Originalism
When the Constitution was adopted, dog fighting was, it seems, legal in all 13 states.
Should those who believe in the interpretive doctrine of originalism be arguing that under the Constitution, the criminalization of conduct that was legal in all 13 states from the founding of our country until the late Nineteenth Century involving the use one's property that in no way injures another person violates the Ninth Amendment because the right to gamble on dog fighting was not only well recognized, but involves the use of one's own property in a manner that harms no other person. Is this not one of those unenumerated "rights" enshrined in the Ninth Amendment to be free for all time from federal government elimination -- as Vick faces no "time, place, or manner" problem, to borrow a 1st Amendment phrase.
How 'bout the due process clause -- as understood in 1789 -- because gambling on dog fights was perfectly legal? Does not the criminalization of behavior seen as legal since not long after the Jamestown settlement until William McKinley's presidency establish reasonable expectations in the limits of the federal criminal laws? And I'll toss in the Fifth Amendment's Taking's clause, as obviously, the criminalization of dog fighting takes -- to use a law school metaphor -- one of the sticks from the bundle of rights recognized at the founding as essential to ownership of a dog.
[To be clear, I'm no gambler. And I'm definitely no proponent of dog fighting.]
I'm also struck by the almost 'round-the-clock coverage of Vick's alleged participation in a dog-fighting conspiracy as proof of his, well, pathological badness . . . only a bad person would so mistreat a dog.
What Vick's case is really about, though barely audible above the current din, is his involvement -- allegedly -- in a gambling enterprise. Vick is an NFL quarterback. Quarterbacks handle the ball on nearly every every offensive play. No player is better positioned to change the outcome of a game than a quarterback.
The NFL seems happy to let the media make this case all about Vick's inhumane treatment of dogs. And the media seems pleased to treat the story as having nothing to do with gambling.
Why? Because otherwise the NFL would have to start explaining why a player as talented as Vick is basically a substandard passer with a .500 record. And the media might have to do some real investigative fact gathering (and let's not forget, we're talking about sports reporters here, not vintage Woodward & Bernstein).
That is, the NFL and media would have to deal with questions about whether, given the allegations, Vick's been throwing games (aargh . . . no pun here) to settle gambling debts.
Far fetched? Hardly. An NBA referee is under investigation by the FBI for point shaving.
Posted by shertaugh at 6:46 PM
July 16, 2007
Fortune Cookies Meet Stand-Up Comedy
This was the fortune in my fortune cookie:
"In order to discover who you are, first learn who everybody else is. You're what's left."On the flip side was the Chinese word for "rimshot."
Well, OK, "rimshot" wasn't the word on the flip side. But that really was my fortune.
Posted by Eric at 8:45 PM
July 12, 2007
The FoxNews President
Posted by Eric at 12:26 PM
July 11, 2007
The Bad Idea In Katyal's and Goldsmith's Otherwise Intriguing Proposal
Preventive detention of U.S. citizens on the basis of nothing more than membership in a group is a really, really bad idea. It was a bad idea when the group was a Shinto sect, and it was a bad idea when the group was the Communist Party. It's a bad idea now.
I'm surprised to see lawyers and scholars of their abilities promoting it.
Posted by Eric at 9:06 PM
Nothing New Under The Sun
"The System to Assess Risk, or STAR, assigns risk scores to possible suspects based on a variety of information, similar to the way a credit bureau assigns a rating based on a consumer's spending behavior and debt. The program focuses on foreign suspects but also includes data about some U.S. residents. A prototype is expected to be tested this year."From chapter 9 of my forthcoming book "American Inquisition: The Hunt for Japanese American Disloyalty in World War II":
"Yet at the same time as the Western Defense Command ("WDC") was scaling back its proposed criteria for gauging Japanese American disloyalty, it was also ramping up a new plan to compile and process vast amounts of intelligence data about the entire Japanese American population in the United States. Under the plan, WDC technicians would key every known piece of biographical information onto IBM punch cards for every Japanese American in the United States – age, sex, citizenship, last known address, residency in a relocation center, and so on. This biographical information would take up half the card; the other half would be reserved for codes reflecting every piece of derogatory intelligence information about the person that was to be found in the files of every military and civilian investigative agency in the country. A processing machine would then allow the Western Defense Command to sort Japanese Americans' punch cards for any type of biographical data and any type of derogatory intelligence information. This punch-card system was to be the "total information awareness" program of its day – a massive, mechanized system for keeping tabs on an entire American ethnic group. If, for example, the WDC wanted a list of all Buddhist Nisei from Los Angeles who belonged to the Japanese American Citizens League and competed in judo, the system was designed to produce that list."
Posted by Eric at 8:52 PM
Profiling Terrorists
That would be a profiling system put together 24 years after the terrorist attack on the Marine barracks in Lebanon. One created 14 years since the first attack on the World Trade Center. 10 years since the American embassy bombings in Tanziania and Kenya. A system offered 6 years after 9/11. And after the Madrid, London and Indonesia terrorist attacks.
That covers 6 presidential elections and 7 FBI directors. Wow.
Posted by shertaugh at 5:45 PM
July 10, 2007
Why The Federalist Society Is Indeed "Particularly Unusual" On Matters Of Race And Gender Diversity
But Eugene does more; he is (among other things) defending the Federalist Society here, and from the data he has compiled, he says the following:
"I also want to suggest that one set of answers, or at least reactions, is misguided: If we're going to wonder about demographic disproportions in reputation-based legal academic contexts — such as conference invitations — it's a mistake to see the Federalist Society as particularly unusual. Our own profession's citation patterns show stunning disproportions that can't be put off to any Federalist-Society-specific practices."Perhaps Eugene has misunderstood the criticism of the Federalist Society. The criticism is of the overwhelming maleness of its invitees and management structure.
If we were to examine not citation rates but the makeup of panels and the management structures of other legal scholars' organizations, we would find something quite different from what Eugene has found. Take two examples: the American Society for Legal History and the American Law and Economics Association. (I chose these two more or less at random, after excluding an organization like the Association of American Law Schools, which articulates diversity as a core goal.) Take a look at the programs of the most recent ASLH and ALEA meetings. Take a look at the management structures of the two organizations -- ASLH and ALEA.
Isn't it interesting how different these are from the invitation and management patterns of the Federalist Society? ASLH and ALEA are, it seems to me, working to counter the very patterns of gender disparity that Eugene's citation study reveals.
What distinguishes the Federalist Society, I suggest, is that it, alone among legal scholars' groups, is not uncomfortable with the patterns of gender disparity that Eugene has identified, and is therefore not interested in working against them in its speaker choices and management structure. (I note that scholars who wish to present at ASLH and ALEA must apply to do so, and that their programs therefore do not directly reflect those organizations' invitation strategies. However, the organizations do screen the applications, approving some and declining others. I know from experience that gender and racial diversity are among the important criteria for ASLH; I suspect (but don't know for sure) that something similar is at least in the mix for ALEA too.)
This difference between the Federalists and these other organizations should not be controversial or surprising. Declining to work against broad cultural patterns of bias against traditional American targets (racial minorities and women) is, as I have always understood it, a matter of ideological commitment for the Federalists, who view goals such as racial or gender balance as the "political correctness" of affirmative action. As Eugene, presumably speaking for the Federalist Society, rather derisively put it in the title of his opening comment in this discussion, "Here We Thought That Ideological Diversity Is Good Enough." Gender and racial diversity are among the goals worth seeking for groups like ASLH and ALEA. For the Federalists, those goals are often matters of derision. They are instances of unfairness -- a visiting on today's white men of what they view as some prior generation's sins against non-whites and women. They are unjust deviations from a color-blind and gender-blind system of pure "merit."
Stated a bit differently, the Federalist Society is comfortable piggybacking on, rather than countering, whatever the American cultural dynamics are that have produced and continue to produce the citation patterns that Eugene so helpfully identifies.
To sum up: the Federalist Society's invitation patterns and management structure do roughly parallel the gender disparity in law review citation patterns. But they do not parallel the invitation patterns and management structure of other societies of legal scholarship. In that important sense -- contra Eugene's assertion -- the Federalist Society does indeed seem "particularly unusual."
UPDATE: Some data from Ann Bartow.
Posted by Eric at 8:06 AM
July 9, 2007
Of Foxes and Hedgehogs
I posted a reply which awaits moderation and hasn't appeared yet. But in a nutshell, my answer was this: it depends on your goals in life. If what you're looking to do is do be noticed -- to be deemed a new "player" in your "field" -- then the hedgehog strategy is the way to go. I don't think academics really know what to do with foxes, unless they are extraordinarily good. (I'm thinking of people like Ian Ayres and Mitu Gulati and Jerry Kang here.)
It's also worth noting, I think, that factors other than fox-vs.-hedgehog can be quite important in the trajectory of an academic's career and reputation. I take myself as an example: I have had two distinct hedgehog phases. In my first 4 years in academia, I (without any reflection on the matter) went the hedgehog route in the area of constitutional criminal procedure, writing a couple of articles that placed really well (Yale Law Journal and Harvard Law Review), developing a rigorous analytical angle on criminal juries through an appellate lens. (The articles are described here and here.)
Then, all of a sudden, I shed the hedgehog fur and went all "fox" on everybody, veering to work on the legal history of the Japanese American internment and more generally on questions of civil liberties and national security in wartime. Though nobody has ever told me this, I'm quite sure that I left the crim pro folks scratching their heads, wondering where the hell I had gone just as I was making a name for myself.
In the years since that shift, I've resumed the hedgehog life in the new area. But this has posed challenges of its own: I'm a person doing what might be characterized as ethnic legal history about an ethnicity that is not my own. (This would be just one of several possible characterizations, but it is perhaps the most obvious one.) So this too is, I think, a bit confusing to people, and may leave people in my "new" area (I place "new" in quotation marks because I've been doing it for more than 10 years now) scratching their heads a little bit about who I am and why I do what I do.
So I think these questions of career development and focus are rather complex. The "fox-vs-hedgehog" dichotomy is a very important distinction, but it's just one of (at least) several.
Great question that Belle has raised. My comments are still broken, but if you email me (isthatlegal - "at" sign - bellsouth - dot - net), I'll update this post with your comments.
Posted by Eric at 11:36 AM
July 7, 2007
Father of the Bride
Posted by Eric at 6:29 AM
"Memories My Parents Never Had"
Posted by Eric at 6:11 AM
Is This An Image of "Approachable Perfection?" Or "Unapproachable Imperfection?" Discuss.
I am the type of girl who, instead of trying to cultivate an image of unapproachable perfection (she of Breck hair and glossy lips), freely admits within the first 10 minutes of meeting someone that I bought my label maker because it looks like a Star Trek phaser. And then admits that I label everything, even the unsalted/salted butter containers in my refrigerator. You heard me.
Posted by Eric at 5:59 AM
July 6, 2007
I'm A Federalist And I'm O.K.! I Sleep All Night And I Work All Day!
UPDATE: Welcome, Volokh Conspiracy readers! While you're here, check out the Federalist Society's all-male Board of Directors and Business Advisory Council. Or its male President, Senior Vice President, and Executive Vice President.
I'm a big fan of the Federalist Society here at UNC-Chapel Hill, and, although I'm a registered Democrat, have served as faculty adviser for the Law School Republicans, a group whose membership overlaps significantly with the Federalists. Both groups are great contributors to the intellectual and political atmosphere here at UNC -- and both have management structures with more women than the national organization.
FURTHER UPDATE: I am informed that Lee Liberman Otis, the Federalist Society's Senior Vice President since May 27 of this year, is a woman. My error ... and my apologies to Ms. Otis.
Posted by Eric at 11:21 PM
July 5, 2007
I Totally Stand By My Robert Redford Claim.
Posted by Eric at 9:22 AM
July 4, 2007
Al Gore, Look On The Bright Side.
Posted by Eric at 12:46 PM
Is A "Libertarian Community" Like A "Jumbo Shrimp?"
And only my land.
If you don't get off,
I'll shoot your head off.
I've got a shotgun,
And you ain't got one.
This land was made for only me.
Posted by Eric at 12:36 PM
July 3, 2007
Presumably There Were Some Female Servers At The Luncheon, Though.
Posted by Eric at 8:39 PM
The PICS Case and the Rhetoric of Conservatism
As I said earlier, I think Justice Kennedy got the case about right. In this I have little company among people with whom I usually agree. But I do think the post to which I link is quite perceptive about the rhetoric of the Roberts-Alito-Scalia-Thomas plurality opinion, with which I do not agree.
Posted by Eric at 3:16 PM
Scooter's Law
A federal grand jury started to investigate. Lawrence testified, and he lied: he said he'd never received the pricing information.
Lawrence was indicted for making false statements to the grand jury, and for conspiring to defraud the United States. A jury convicted him.
The federal sentencing guidelines produced a range of 10 to 16 months for Mr. Lawrence. The judge, however, granted what's called a "downward departure" to Mr. Lawrence, and sentenced him to 6 months' home confinement and probation.
Why did the judge depart downward from the sentencing range? The judge noted that Mr. Lawrence was 52 years old, had no criminal record, had served in the military, and had a superb reputation in the community. He had risen from humble beginnings to success in legitimate business. In the context of this industrious, law-abiding life, the judge found that the offense conduct was aberrational. The judge also took into account that Lawrence's 80 employees would likely lose their jobs if he were jailed and that his business would suffer significant collateral consequences (like debarment from government contracts and civil liability) that mitigated the need for imprisonment.
The government appealed Mr. Lawrence's sentence, arguing -- quite rightly, in my view -- that there was nothing so unusual about the circumstances of Mr. Lawrence and his crimes that the guideline range of 10 to 16 months' incarceration ought not apply.
The U.S. Court of Appeals for the Fourth Circuit agreed with the government and vacated Mr. Lawrence's sentence, directing that the district court resentence Mr. Lawrence to a term of incarceration selected from within the 10-to-16-month range that the sentencing guidelines said was fair and appropriate for people like Mr. Lawrence.
Why do I tell you about this rather ordinary white-collar case? Well, yesterday, as you probably know, President Bush determined that Scooter Libby's prison sentence of thirty months -- a sentence that the trial judge selected from within the range that the sentencing guidelines indicated were appropriate and fair for a case like Libby's. In commuting Libby's sentence to eliminate all incarceration, the President was picking up on the idea proposed by William G. Otis in a much-discussed op/ed a few weeks ago in the Washington Post.
President Bush explained his decision to eliminate jail time as follows:
"Mr. Libby was sentenced to thirty months of prison, two years of probation, and a $250,000 fine. In making the sentencing decision, the district court rejected the advice of the probation office, which recommended a lesser sentence and the consideration of factors that could have led to a sentence of home confinement or probation.The court system got things exactly right in Mr. Lawrence's case; there was nothing so unusual about it as to disengage the sentencing guidelines and counsel no jail time at all for him.I respect the jury’s verdict. But I have concluded that the prison sentence given to Mr. Libby is excessive. Therefore, I am commuting the portion of Mr. Libby’s sentence that required him to spend thirty months in prison."
By the same line of reasoning, the President got things badly wrong in Mr. Libby's case yesterday. There was nothing so unusual about it -- apart from Libby's friendship with the Vice President and his loyalty to the President -- as to disengage the nation's sentencing laws and counsel no jail time at all. It's interesting that the President didn't reduce Libby's term of incarceration, which he had the power to do. He completely eliminated it.
Outrageous.
Oh, and one other interesting little footnote: the government lawyer who successfully argued for the incarceration of Wilbert Lawrence was Willam G. Otis.
Posted by Eric at 10:12 AM
July 1, 2007
Rail to the Chief
We need more of this sort of breaking of the presidential bubble.
Posted by Eric at 6:36 AM