Archive for the 'Discrimination' Category

Not a Hate Crime, WV Supreme Court Determines about Attack on Gay Men

In April 2015, Steward Butler was in his car at a stoplight when he saw two men kissing on the sidewalk. He directed homophobic comments toward them, then exited his car and punched both men in the face. He was charged with battery, as well as violations of an individual’s civil rights under West Virginia Code Section 61-6-21(b), which makes it unlawful to injure a person because of that person’s “sex.” Though Butler was found guilty of battery, the lower court ruled he had not committed a civil rights violation under Section 61-6-21(b) because his assault on the men was not based on their “sex,” a term the court asserted was unambiguous and could not be expanded to include “sexual orientation.” The West Virginia Supreme Court upheld the ruling.

Sex v. Sexual Orientation

In reaching its decision, the Court explained that because use of the word “sex” in the statute was unambiguous, it should not be subject to interpretation and its plain meaning should be applied. Further, a word used in a statute is not deemed ambiguous merely because the parties in the case do not agree on its meaning.

The Court asserted that because the word “sex” was not defined in the statute, it was required to apply the “common, ordinary and accepted meaning.” In this case, it argued, “sex” and “sexual orientation” have different meanings. Referencing dictionaries to explain the difference, the Court explained that “sex” involves the physical structures such as genitalia and functions that separate males and females. By contrast, “sexual orientation” is about an individual’s sexuality or predisposition when it comes to sexual behavior and activity with other males or females.

Other States Have Included “Sexual Orientation” in Their Statutes

The Court went on to say that most of the states have enacted hate crime statutes, and there is an irrefutable distinction between “sex” and “sexual orientation” among the states. Six states, including West Virginia, use the term “sex” or “gender.” With respect to 20 of the states, the legislature used the term “sex” or “gender” in addition to the term “sexual orientation.” Six other states mention only “sexual orientation.” Some states use the terms “sexual orientation” in addition to “gender expression” or “gender identity.” Finally, certain states do not use any of these terms. Moreover, the Court pointed out that there have been prior court decisions on the matter involving states that use only the word “sex” in their hate crime statutes, and in these cases the courts did not define it to include or exclude “sexual orientation.”

Hate Crime

West Virginia’s Legislature Has Indisputably Left Out “Sexual Orientation”

According to the Court’s analysis of the legislature’s intent, it is undeniable that the term “sexual orientation” has been purposefully left out of the state’s hate crime statute. Since the statute’s enactment in 1987, the legislature has failed to add the term “sexual orientation.” Thus, the Court asserted, it must recognize the legislature’s intent to not include “sexual orientation” in the statute.

Dissenting Justices: Majority’s Take on the Law is Wrong

Justice Workman and Justice Davis wrote a dissenting opinion, arguing the majority opinion showed a detrimental misunderstanding of the phrase “because of . . . sex” in the statute. The Court is required to look at the entire language of a statute, and in this case, the dissenting Justices assert, the victims were assaulted because of their sex. In a hate crime situation, it is the bias and motivation for the crime that are ultimately punished, and the victims were clearly attacked because they were not behaving in a manner their assailant perceived men should behave with other men.

Justices Workman and Davis supported their argument with a case that came under Title VII of the Civil Rights Act of 1964. There, a female manager was denied partnership at her accounting firm and told she should act and appear more feminine. The case came before the U.S. Supreme Court, which concluded the phrase “because of . . . sex” in the federal statute included mistreatment due to gender stereotypes. According to Justices Workman and Davis, the woman was discriminated against not just because she had the anatomical parts of a female, but because she did not conform and act in the manner she was expected to as a woman in a corporate setting. But for her sex, Justices Workman and Davis argue, the woman in the accounting firm would not have been discriminated against. Likewise, but for their sex, the two male victims in this case would not have been attacked by the defendant.

That Victims Suffered “No Injustice” Is Highly Questionable

The Court stated in its opinion that, despite the dismissal of the hate crime charges, there was no injustice because the two counts of battery against Butler were upheld. This remark is undoubtedly an oversimplification of the meaning of hate crimes and what justice means for its victims.

Religious Liberty Executive Order, Is It Something to Fear?

Recently, President Trump signed a new executive order titled “Presidential Order Promoting Free Speech and Religious Liberty.” While the order is not a surprise, what came out of the White House was very different from expected. Early drafts of the order, leaked by White House aides, included sections which permitted discrimination based on faith. These provisions would have almost been unconstitutional, and several organizations promised lawsuits if the order takes effect.

However, while Trump is no stranger to signing overreaching orders into effect which are later found unconstitutional, this most recent order is different. Instead, this order fits into another common theme for Trump executive orders: symbolic orders that basically do nothing on a legal level. After the order was published, the ACLU said that they didn’t think it was worth the time or resources of challenging the order. They described it as “an elaborate photo-op with no discernible policy outcome…[which] does not meaningfully alter the ability of religious institutions or individuals to intervene in the political process.”

The order has three parts that could have some effect: 1) the government will enforce existing laws protecting religious freedom; 2) the agencies of the executive branch will temporarily not enforce a law preventing churches from participating in political campaigns–as much as is allowed by law; and 3) in the future the Secretary of Health and Human services will introduce regulations on already existing law regarding the contraceptive mandate of the Affordable Care Act (ACA). That may sound like an order that stands to substantially alter the face of the law. But a closer look will show that is not the case.

Vigorous Enforcement of What’s Already There

The first section of this new order promises that “the executive branch [will] vigorously enforce Federal law’s robust protections for religious freedom.” So basically, the executive branch promises to enforce the laws that are already in effect.

So what does this section accomplish or mean? Effectively nothing. It does not guarantee protection to federal employees who want accommodations over religious beliefs. It changes no laws or approaches. It promises no concrete changes. It does actually nothing. So, with that out of the way, let’s move on to sections that have marginally more impact on the state of the law.

Religious LibertyRelaxing the Johnson Amendment

The next section of the order promises that “all executive departments and agencies (agencies) shall, to the greatest extent practicable and to the extent permitted by law, respect and protect the freedom of persons and organizations to engage in religious and political speech.” This by itself is so vague, it can’t be relevant. But, the section goes on to specifically target the Johnson Amendment.

The Johnson Amendment is an element of the code used by the Internal Revenue Service. It says that a 503(c) tax-exempt company–basically any non-profit whether secular or non-secular–may not “directly or indirectly [participate] in, or [intervene] in, any political campaign on behalf of (or in opposition to) any candidate for elective public office.”

The law itself already saw very infrequent application. But, the order states that the Department of the Treasury will take adverse action under the Johnson Amendment against religious organization for talking about politics from a religious perspective as little as possibly permitted while still following the law. This could mean anything from a relaxed standard about prosecution to nothing as the Johnson Amendment itself is law. It is most likely meant to imply that the IRS will be less likely to penalize of revoke 503(c) status for religious organizations or persons who are openly involved in politics. Including speeches or monetary contributions.

No matter what the order says, it’s actual effect has limits. No executive order can overcome or repeal an act of congress such as the Johnson Amendment. Nor can it repeal any existing regulations. The most it can do is relax the approach to this law temporarily. But doing so provides no benefit to organizations normally covered by the Johnson Amendment. This is because any religious organization which takes advantage of the relaxed enforcement–despite the uncertain level of protection the order provides–will just find itself in hot water in a few years upon the inevitable repeal under a new president.

But what exactly does this section of the order do? Pretty much nothing. It doesn’t have an effect, relaxing the enforcement of the Johnson Amendment is an actual change in approach if the Department of the Treasury changes how it handles Johnson situations. However, no lawyer could recommend taking advantage of such tenuous promises without an actual repeal of the law.

Targeting Women’s Access to Contraceptives

The final relevant section of the new order states that “the Secretary of the Treasury, the Secretary of Labor, and the Secretary of Health and Human Services will consider issuing amended regulations, consistent with applicable law, to address conscience-based objections to the preventive-care mandate promulgated under” the ACA. So sometime in the future, agencies working under Trump could possibly add regulations dealing with the provisions of law that already exists. Like the ACA which needs employers with more than a certain number of employees to provide insurance plans offering no-cost birth control to their female employees.

To understand exactly what this part of the order does, it’s important to first understand the famous Hobby Lobby case of recent years and it’s history. In 1990, the Supreme Court ruled that you cannot break a law that applies the same to everybody as an expression of your religious beliefs. In response, Congress passed the Religious Freedom Restoration Act (RFRA). Under RFRA, practice is any exercise of religion whether compelled by, or central to, a system of religious belief or not. The RFRA is still in force and, although it is unconstitutional to apply it to state laws, it still applies to laws passed by the federal government.

This means that the ACA, in particular its provisions regarding contraception, were subject to the RFRA. This was the central argument in Hobby Lobby. The company was saying that providing contraceptives to its employees violated their RFRA rights as their religion didn’t support contraception. The Supreme Court decided that, in the case of closely held corporations (corporations owned by a small number of people with no public stock) RFRA meant that the ACA couldn’t require them to provide coverage with contraception. After this, the Obama administration added rules which allowed insurance companies to pay for contraceptives instead of the companies.

That’s the current state of the law already, the order is basically saying that it will try and make sure the law is properly enforced through new regulations. That being said, the Secretary of Health and Human Services has already announced quick follow up on this part of the order. It’ll be important to keep an eye on exactly what regulations spring forth from this section as they could easily make the jump from following the state of the law–no matter how unfortunate that state is–to improperly barring women from access to health services above and beyond what the law allows.

What it Does vs. What it Implies

In general, the right to free practice of religious or any other right is not supposed to limit others, but protect yourself. But this order does not offer protection to federal employees, even when they claim religious objection. Like the West Virginia County Clerk currently being sued for a practice of verbally assaulting homosexual applicants for marriage licenses. However, it has the potential to embolden such abusive actions. This order accomplishes as close to nothing for the cause it claims to champion that it can without being pure grandstanding. But at the same time has the potential to endanger the rights of women and the LGBT community through its implications. In the end, this is an order where everybody loses.

Survivor Contestant Publicly “Outed” Highlights the Mistreatment of Transgender Community

The reality competition show Survivor has been running strong for seventeen years and is on its thirty-fourth season. But in all their seasons, never had they had a transgender contestant. And never has someone been “outed” on their show. Both happened recently.

Background

Survivor contestant Zeke Smith was outed by a fellow contestant as being transgender in an attempt to show that Zeke had the capability of being “deceptive”. Zeke’s tribemates/fellow contestants quickly came to his aid, arguing his transgender status had nothing to do with the game and was a personal aspect of his life. Although Survivor is just a reality TV show, it highlighted a genuine issue in today’s society – the misconception of transgender people and the discrimination they face.

Survivor ContestantWhat is Transgender?

A transgender person is a person whose internal sense of him or herself is different than the gender assigned at birth. It is different than one’s sexual orientation, or who a person is attracted to. In that regard, sexual orientation relates to whether a person is gay, lesbian, heterosexual, or bisexual. Just because a person is transgender does not also mean that he or she is gay or lesbian.

Approximately seven-hundred thousand people identify as transgender in the United States. A recent study showed that a staggering 41% of transgender people in the United States have attempted to commit suicide, compared with 4.6% of the general public.

Transgender Laws in the U.S.

Eighteen states and the District of Columbia have protections for transgender people, but their protections vary. For instance, Colorado, Illinois, and Minnesota ban discrimination based on sexual orientation, and defines “sexual orientation” to include gender identity. A number of states protect transgender students from discrimination or harassment in public schools. Nevada bans discrimination in employment, housing, and public accommodations such as retail stores, restaurants, and hospitals.

Additionally, there are federal laws which protect transgender people against housing and employment discrimination. In 2012, the U.S. Equal Employment Opportunity Commission ruled that discriminating against someone because that person is transgender is a Title VII violation. Similarly, the U.S. Department of Housing and Urban Development finds discrimination against transgender tenants or home buyers illegal sex discrimination under the Fair Housing Act.

Despite the laws in place to protect the transgender community, they still are bullied, fired from their jobs, passed up for raises, and discriminated against simply for being transgender.

Transgender Rights and the Bathroom

During his last term in office, President Obama issued a directive to all public schools in the country allowing transgender students to use bathrooms matching their gender identity. The declaration was signed by the Justice and Education department officials and described what schools can do if any of their transgender students were discriminated against. While it did not carry the force of law, it did impose a threat for any school that did not abide by the law as they may face lawsuits or loss in federal aid.

Consistent with his hateful propaganda and lack of support for the LGBT community, President Trump rescinded the protections for these students that President Obama created.

Continued Discrimination

The transgender community is still sadly misunderstood. During March Madness, North Carolina (the eventual winners of the tournament) was scheduled to host championship games. They were stripped of the honor by the National Collegiate Athletic Association (NCAA) because the state of North Carolina bans individuals from using public bathrooms that do not correspond with their biological sex. In other words, in North Carolina, transgender individuals cannot use the restroom of the gender they identify as, but as the gender they were born as. Eventually, the NCAA reversed course and scheduled championship games in North Carolina, but received harsh criticism for doing so.

The significance of Survivor highlighting a transgender player and the type of discrimination he faced shows that we are nowhere near inclusive civil rights for the transgender community. But at least it brought about discussion, which can hopefully lead to change.

It’s Official: Texas Voter ID Law Violates the Voting Rights Act

On Monday April 17th,  a Federal Judge ruled that the voter ID laws enacted in Texas were enacted with not only the intent to discriminate against minorities but with the purpose of discriminating against those minorities.  This is a huge ruling with implications for both the law, S.B. 14, and the state of Texas as a whole.  This ruling has the potential to leave any law related to voting coming out of Texas subject to federal approval in the future.

However, this ruling is far from out of the blue.  The story of S.B 14 has been a back and forth saga through the courts since 2011.  Let’s take a look at the history of this bill, this most recent ruling, and what that ruling means.

Texas Voter IDThe History of S.B. 14

S.B. 14 is a law which substantially limits the acceptable types of voter IDs in Texas, often in particularly odd ways.  For instance, a hunting license is acceptable ID to vote but a student ID would not.  This is just the tip of the iceberg to what represented an enormous amount of limitations on what was acceptable identification to allow somebody to vote.  While there were suggestions to make funds available to educate the public on the details of the new restrictions and assist poorer voters to obtain sufficient identification, these suggestions were shot down at every turn and nothing of the sort made it into the final law.

When this law was initially passed in Texas in 2011, the Voting Rights Act (VRA) gave the Attorney General (AG) the power to review and shut down voting laws coming out states which had historically had discriminatory voting practices–think Jim Crow and the South.  With the effect the limitations would have and the lack of education on these effects in mind, the Attorney General at the time-Eric Holder-exercised this power and shut down the law.  While challenged this in the courts, AG Holder’s decision was upheld.

However, in 2013, a Supreme court ruling known as Shelby substantially limited the powers of the VRA.  Section 5 of the VRA allowed the federal government to pre-clear any voting laws coming out of states that previously had issues, as discussed above.  In Shelby, the Supreme Court analyzed the constitutionality of the VRA and Section 5 in particular.  They ultimately determined that, while Section 5 itself was constitutional, Section 4 was not.  Section 4 was the part of the VRA that allowed enforcement of Section 5.  Without this section, the pre-clearance requirements of the VRA were rendered essentially toothless.  The reasoning behind the Supreme Court’s decision was that justifications for the VRA’s restrictions-the history of discriminatory voting practices-was not the same concern it was when the VRA was enacted in the 60s.  Whether this is true or not, the Supreme Court decided that the provisions of the VRA needed to be reviewed by Congress if they were to remain in effect.

In the wake of this decision, many states-Texas, Mississippi, North and South Carolina-passed voting laws which had previously been shut down as potentially discriminatory by the federal government.  Among these was S.B. 14.  However, the law was immediately challenged in court.  In 2014, the law was determined to have discriminatory intent and purpose and struck down.  It was then appealed to the 5th Circuit Court of Appeals, which upheld the ruling in part, but asked the lower court to revisit the matter of discriminatory intent.

This brings us to ruling of last week.  However, as opposed to the initial ruling, there was one huge difference–AG Jeff Sessions.  Jeff Sessions has made it clear that the potential for discriminatory voting laws is not a priority under his watch, and told his attorneys at the Department of Justice to drop this case altogether.  Despite this, and a request from the DoJ plaintiffs to drop the case, Judge Ramos-the judge handling this case-looked to the facts already submitted in coming to a resounding yes on the discriminatory intent and purpose behind S.B. 14.

Discriminatory Intent and Discriminatory Purpose

Discriminatory intent is shown where racial discrimination is a-although not necessarily the only-motivation behind a governing body’s decision.  Discriminatory purpose goes a little further than intent, implying that the law was enacted because of the adverse effects on an identifiable group.  A law demonstrating discriminatory purpose or effect is unconstitutional. A discriminatory impact is not enough on its own for a law to be unconstitutional on its face, there needs to be at least a partial discriminatory motive.

Judge Ramos found such an intent and purpose behind S.B. 14.  In determining to this, she looked to a number of things.  She noted not only the disproportionate impact that the carefully chosen ID limitations had on minorities, she also pointed to racist remarks made by legislators during deliberations on the law, the bypassing of usual procedures in passing the law, and the outright refusal to include anything which would help the public understand the laws.  Additionally, any amendment proposed to make the provisions less harsh–easing registration procedures, reducing costs to purchase the IDs necessary to vote, expanding the acceptable types of identification-were all rejected with essentially no consideration.  In fact, the Texas Congress was specifically advised of the disproportionate impact that the law would have and advised on a number of ways to lessen this disproportionate impact on minorities-they rejected all of them.

The stated goal of the bill was to avoid voter fraud.  However, despite the Texas Legislature being shown evidence that in person voting happened in about two out of every twenty million cases in the last decade and provided evidence that mail-in voting was much more commonly vulnerable to fraud, the Legislature didn’t feel the need to include any provisions on mail-in voting and focused exclusively on in-person voting.

With all this in mind, Judge Ramos ruled that she could find no non-discriminatory purpose for how Texas had approached S.B. 14.

What Will This Ultimately Mean

Unfortunately, despite years of rulings saying this law was intended to prevent minority voters from being represented at the polls, there’s a good chance this law will win out in the end.  Jeff Sessions has, as Attorney General, told the attorneys of the DoJ to cease litigating the case completely.  While Judge Ramos followed through with the case, Texas will certainly appeal her decision.  This appeal will probably have no lawyers opposing Texas, unless an outside group steps in to handle the litigation.  If this is the case, the chances of beating this law drop precipitously.  However, should somebody step in to help fight the law this is a case that has a good chance to make its way to the Supreme Court.  As it stands, even with the addition of Justice Gorsuch, the makeup of the court makes it likely that this law would be struck down and Texas would continue to require preclearance from the federal government for any new law effecting voters.

This hasn’t been a particularly good year for Texas when it comes to their voting process being ruled racially discriminatory.  Two separate courts have already ruled, this year alone, that Texas’ district maps are gerrymandered to “pack and dilute” minority votes.  The determination of Shelby limited the VRA on the premise that discriminatory voting practices were a thing of past generations.  However, this ruling and many other rulings this year have shown the opposite.  It is unlikely that congress, in its current state, will pass any legislation giving teeth back to the VRA.  However, as cases like this are appealed to the Supreme Court, they have the potential to create precedent for a future court ruling reevaluating Shelby.  However, it seems unlikely in the near the future.  Only time will tell how momentous this ruling may be, for now Judge Ramos’ ruling will serve to protect voting rights for minorities in Texas.

Travel Ban 2.0: Trump’s Second Attempt to Ban Immigration

The initial executive order out of President Trump’s White House regarding limiting immigration to the U.S, widely known as the “Muslim Ban,” was an unmitigated disaster.  Rolled out overnight, the order caused chaos across the country as agencies tried to put the order’s new rule into force.  It also drew immediate legal challenges from numerous states, all challenging the order-in whole or in part-as unconstitutional.  Several of these legal challenges succeeded; most notably a challenge out of the state of Washington which culminated in a preliminary injunction–an order preventing the “Muslim Ban” from taking effect whatsoever until the Washington case is fully litigated.  In the face of court order saying that the order was most likely unconstitutional, and the fallout of the original implementation of the order, President Trump did something we perhaps should all have expected-he signed and put into force a nearly identical order.  On Monday, March 6th, President Trump issued an executive order titled “Executive Order Protecting The Nation From Foreign Terrorist Entry Into the United States.”

In the past we’ve already covered the effects of the ban, the constitutional problems intrinsic to the ban, the many lawsuits brought after the ban was passed, and the injunction which ultimately put an end to it.  So with that in mind, you’ve got to know that we’ve got some thoughts about Trump’s second iteration of the ban.  So without further ado, lets dive into it–the changes between this new order and the original order courts ruled to be likely unconstitutional, the chances that this order will stand, and the legal challenges the order already faces.

How is This Order Different From the One Courts Already Stopped?

travel banThe short answer, it isn’t very different.  The order still targets specific Muslim majority countries, barring immigration from those countries for 90 days. It also still cuts the number of refugees allowed to be admitted to the U.S. per year by more than half.  However, with this being said, there are some important changes in effect from the initial order–mostly designed to make the order appear more kosher to the courts.

The new version of the order has removed the indefinite ban on the U.S. taking in any refugees out of Syria.  Instead, the order includes a 120-day freeze on taking in those refugees.  However, the order also includes the ability to renew the ban for a longer period of time upon review.  It also doesn’t include any limits on the number of times the ban can be renewed, so in effect the ban could very well be indefinite.

The order also has removed Iraq from the original list of countries slapped with a 90-day immigration ban, leaving only the other 6 original countries.  The reason for this change is a request from the Defense Secretary, fearing that such a ban would injure the U.S.’ ongoing efforts to fight ISIS in Iraq.  The order doesn’t take a ban on immigration out of Iraq off the table though, threatening to put the country back on the list if Iraq’s  leaders don’t increase their amount of intelligence they share with the U.S.

The new crack at the ban also has eliminated language specifically offering preferential immigration status to “persecuted religious minorities.”  This was one of the most widely criticized elements of the order, both by the public and in legal challenges to the order.  The thought being that the provision was designed to favor other religious groups over Muslims.

As opposed to the frenetic same-day introduction of the last immigration ban, the Trump administration has allowed for a slower implementation and time to prepare for implementation.  The ban only goes into effect ten days after its signing–March 16.

The order has a number of other changes.  The order includes specific details about why the six countries hit with the 90-day ban were selected; presumably to strengthen the order against the many legal challenges saying the order was targeting countries based on their Muslim majority.  The order focuses its details sections on the statistics regarding terrorism for each country selected.  The order also no longer affects current visa holders or refugees already granted asylum.

So you’ve likely noticed that these changes are, intentionally, targeted at trying to make the order stand up to the scrutiny of the courts.  In order to determine whether it has succeeded, let’s look at why the last order got hit with an injunction.

Why Was the Last Order Blocked?

Since we’ve covered this issue in previous articles, we’ll keep the discussion of why the last order couldn’t pass constitutional muster on the short side.

A preliminary injunction is granted where the party seeking it can show that they are likely to succeed in their arguments, there would be irreparable harm if the thing they seek to stop isn’t stopped immediately, there isn’t a public interest against granting an injunction, and the party seeking the injunction will be more harmed by what they seek to stop than the party you’re bringing the injunction against will be harmed by the injunction itself.  In the case brought by Washington, the court ruled that they were likely to succeed in their arguments that the immigration ban unconstitutionally singled out targets based on religion or national origin–in other words the order discriminated likely discriminated against protected classes.

Will the New Order Stand Up in Court?

The White House certainly believes its changes, although extremely minor in practice, are enough to allow the order to pass muster.  In fact, the Department of Justice has already filed briefs saying that the revisions have rendered all the legal cases regarding the first order moot.  In other words, the injunction has no further effect and the new order must be challenged or not on its own merits.

However, as of March 9th, Washington state lawyers have taken the stance that the changes are so minor as to amount to essentially putting lipstick on a pig.  They argue that the prejudicial purpose behind the order remains and its most offensive portions are essentially untouched.  For this reason, they’ve asked the federal judge who placed the preliminary injunction on the original order to expand his order to cover the “Muslim Ban 2.0.”  A similar attempt to challenge the ban has been brought by Minnesota and Hawaii.  The Attorney Generals for Massachusetts, New York, and Oregon have all made it known that they intend to join in on the challenges brought by Hawaii, Minnesota and Washington.

So will the new and improved “Muslim Ban” stand up?  We’ll have to see how the courts rule.  However, the order has changed very little in actual effect.  It still targets specific nationalities in almost exactly the same manner and it still exclusively targets Muslim majority countries.  The same reasons it was likely unconstitutional before are all still there.  Even if the order itself has removed some of the language making obvious attempts to target Muslims and provided an alternate explanation, Trump’s own statements on immigration and the previous order still can be used as evidence of the discriminatory purpose to the new order.

Nothing in law is ever truly certain, but the definition of insanity is doing the same thing and expecting different results.  The new ban is very similar to the previous order, it seems unlikely that it will pass constitutional muster with such minimal changes.

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