Animal Welfare: U.S. Supreme Court Petitioned to Accept Appeal Challenging Constitutionality of California’s Proposition 12
On September 27, 2021, the National Pork Producers Council (NPPC) and American Farm Bureau Federation (AFBF) filed a petition for writ of certiorari in the U.S. Supreme Court seeking to have California’s Proposition 12 declared unconstitutional as a violation of the U.S. Constitution’s Commerce Clause. Proposition 12 in pertinent part prohibits the in-state sale of pork products from animals raised in a manner not compliant with California’s in-state swine confinement standards. National Pork Producers Council, et al. v. Karen Ross, No. 21-468. The law was upheld as constitutional by the U.S. Court of Appeals for the Ninth Circuit in July 2021. NPPC and AFBF’s announcement states that the Court is being asked to determine whether a state law that “requires pervasive changes to an integrated nationwide industry” and thus imposes “dramatic economic effects largely outside of the state” is a dormant Commerce Clause violation, i.e. it unreasonably burdens interstate commerce. If the U.S. Supreme Court agrees to hear the appeal, its decision on the constitutionality of the law will likely be rendered in mid-2022, six months or more after Proposition 12’s effective date of January 1, 2022. If the U.S. Supreme Court declines to hear the case, that is likely to be well before January 1, 2022. For background, see ALWR—July 30, 2021, “Federal Appeals Court Upholds California’s Proposition 12 With Five Months Until Its Effective Date.”
WOTUS: New Mexico District Court Vacates Navigable Waters Protection Rule
On September 27, 2021, the U.S. District Court for the District of New Mexico issued an opinion vacating and remanding the Navigable Waters Protection Rule (NWPR) back to the U.S. Environmental Protection Agency (EPA) and the U.S. Army Corps of Engineers (agencies). Navajo Nation v. Wheeler, No. 2:20-cv-00602. Citing the U.S. District Court for the District of Arizona’s August 2021 decision also vacating the NWPR, the court determined that both factors — “the seriousness of the [rule’s] deficiencies (and thus the extent of doubt whether the agency chose correctly) and the disruptive consequences of an interim change that may itself be changed” — weighed in favor of vacating the NWPR. Additionally, the court noted the agencies’ own observation that, although the NWPR “categorically exclude[d] all ephemeral waters,” they “did not look closely enough at the effect ephemeral waters have on traditional navigable waters” in making that decision and that “of over 1,500 streams assessed under the NWPR” in Arizona and New Mexico, “nearly every one has been found to be a non-jurisdictional ephemeral resource.” According to EPA’s webpage, Current Implementation of Waters of the United States,” in response to the Arizona district court’s August 2021 decision, EPA has “halted implementation of the Navigable Waters Protection Rule and are interpreting ‘waters of the United States’ consistent with the pre-2015 regulatory regime until further notice.” For background, see ALWR—September 3, 2021, “Arizona Federal Court Vacates 2020 Navigable Waters Protection Rule”
COVID-19: Federal Court Dismisses COVID-19 Negligence Suit Filed Against Tyson Foods
On September 22, 2021, the U.S. District Court for the Eastern District of Texas issued an opinion and order dismissing a negligence claim against Tyson Foods, Inc. filed by four workers from Tyson’s Carthage, Texas production facility who contracted COVID-19 and alleged that the company “failed to take adequate precautions to protect workers.” Fields et al v. Brown et al, No. 6:20-cv-00475. The court held that the claim was preempted by both the federal Poultry Products Inspection Act (PPIA) and Texas’s Pandemic Liability Protection Act (PLPA), which was enacted June 14, 2021, and retroactively protects Texas businesses against COVID-19 damage claims. Additionally, the court found that the plaintiffs’ complaint failed to allege sufficient facts, stating that “[p]laintiffs make only conclusory statements that they contracted COVID-19 because of unsafe working conditions, without alleging how, when, or why they contracted COVID-19 or accounting for other possible sources of infection.”
Water Quality: Water Advocacy Group Files Federal Civil Suit Against Hanover Foods Alleging Clean Water Act Violations at Pennsylvania Plant
On September 24, 2021, the Lower Susquehanna Riverkeeper Association filed a complaint in the U.S. District Court for the Middle District of Pennsylvania against Hanover Foods Corporation, alleging violations of the Clean Water Act and Pennsylvania’s Clean Streams Law at its Hanover, Pennsylvania plant. Lower Susquehanna Riverkeeper Association v. Hanover Foods Corporation, No. 1:21-cv-01600. Hanover’s NPDES permits for several discharges at issue expired in 2020 but have been administratively continued by the Pennsylvania Department of Environmental Protection (DEP). Hanover also possesses a pretreatment permit from the local wastewater treatment plant for a portion of its wastewater discharge from the plant. The complaint contains an accounting of monthly test results for Carbonaceous Biochemical Oxygen Demand (CBOD5), Total Suspended Solids (TSS), Fecal Coliforms, Ammonia-Nitrogen, Dissolved Oxygen and alleges that between 2016 and 2021 Hanover has violated its permits and state and federal law and “has discharged, and continues to discharge . . . industrial wastewater containing pollutants at levels that exceed effluent limitations” applicable under state and federal law. The discharges at issue are into Oil Creek, which flows into the Codorus Creek, the Susquehanna River and ultimately the Chesapeake Bay. Hanover has not yet filed any response to the lawsuit. The Complaint does not allege that DEP has taken any action regarding the claimed discharges.
Animal Welfare: Fish and Wildlife Service to Initiate Endangered Species Status Review of American Bumble Bee
On September 29, 2021, the U.S. Fish and Wildlife Service (FWS) posted in the Federal Register its “90-Day Findings for Five Species” for which petitions gave been filed seeking endangered or threatened status under the Endangered Species Act of 1973 (ESA) (86 FR 53937). FWS also announced its determination that a petition to list the American bumble bee (Bombus pensylvanicus) as endangered under the ESA contained “substantial information” warranting such a listing and FWS will commence a twelve month status review during which the public may submit comments and relevant information (FWS-R3-ES-2021-0063). FWS stated that the American bumble bee is “potentially threatened by disease, habitat destruction, livestock grazing, pesticide use, loss of genetic diversity, climate change, and competition from non-native honeybees.”
CENTER FOR AGRICULTURAL AND SHALE LAW PROGRAMS & RESOURCES
Agricultural Law Podcast:
Special Episode #11. Bioengineered Food & Genetically Modified Salmon (Oct. 1, 2021).
Weekly Episode #195. Federal Court Denies Dismissal of Beef Antitrust Litigation & EPA Rescinds WOTUS Maui Guidance (Sept. 27, 2021).
Special Episode #10. Glyphosate Litigation (Sept. 24, 2021).
Weekly Episode #194. White House Addresses Meat Industry Consolidation & USDA Announces $1.4 Billion in Grants for Food Workers and Small Businesses (Sept. 10, 2021).
PA Farm Bureau’s Farm Focus podcast, New Agritourism Law – What you need to know (Sept. 30, 2021). Brook Duer is a guest.
NALC Webinar Recording, Overview of Federal and State Purchase of Agricultural Conservation Easement (PACE) Programs, presented by Ross Pifer for the National Agricultural Law Center (Sept. 15, 2021).
Agricultural Law/Policy Resources of Interest:
Ohio Ag Law Blog, OSU Income Tax Schools: 2021 Two-Day Tax Schools for Tax Practitioners & Agricultural & Natural Resources Income Tax Issues Webinar (Oct. 1, 2021)
Ohio Ag Law Blog, Ohio Crop Enterprise Budgets—Projected Returns for 2022 (Sept. 28, 2021).
DTN/Progressive Farmer, Cybersecurity and Ag Series:
- Part 3—Is Uncle Sam Asleep on the Cybersecurity Job? (Sept. 27, 2021).
- Part 4—Precision Ag Companies Strive for Cybersecurity, but Hacking Threat Remains (Sept. 29, 2021).
- Part 5- Five Tools Pros Use to Protect Data and Systems (Oct. 1, 2021)
Vox, How 4 Companies Control the Beef Industry (video) (Sept. 29,2021).
IDFA Webinar Series: Introduction to Dairy Product Labeling (Oct. 20 & 21, 2021).
DTN Ag Policy Blog/Jerry Hagstrom, Stabenow, Boozman Offer Different Takes on USDA Climate Initiative (Sept. 30, 2021).
NALC/Micah Brown, Considering Carbon: Overview of Existing Market Structures (Sept. 28, 2021).
NALC/Samantha Mikolajczyk, International Agricultural Trade Update: The United States-Mexico-Canada Agreement (Sept. 30, 2021).
Tiffany Lashmet, 2021 USDA NASS Cash Rent Report Available (Sept. 27, 2021).
Successful Farming, Burst of USDA Top-Up Pandemic Payments to Farmers (Sept. 28, 2021).
Roger A. McEowen, Extended Livestock Replacement Period Applies in Areas of Extended Drought – IRS Updated Drought Areas (Sept. 30, 2021).
Roger A. McEowen, Tax Happenings – Present Status of Proposed Legislation (and What You Might Do About It) (Sept. 24, 2021).
Paul Goeringer, Idaho CAFO Permit Sent Back to EPA for Lack of Monitoring (Sept. 28, 2021).
WeConservePA, Understanding Funding Opportunities Available Through the American Rescue Plan (webinar) (Sept. 28, 2021)
Relevant Legislative Hearings:
U.S. Senate Agriculture Committee, Milk Pricing: Areas for Improvement and Reform (recorded Sept. 15, 2021).
Alert: U.S. House Agriculture Committee, A Hearing to Review the State of the Livestock Industry (Oct. 7, 2021, noon) Witnesses: Sen Chuck Grassley; USDA Secretary Vilsack;
Todd Wilkinson, National Cattlemen’s Beef Association; Francois Leger, on behalf of the North American Meat Institute; Scott Blubaugh, Oklahoma Farmers Union, on behalf of the National Farmers Union; Scott Hays, National Pork Producers Council; Brad Boner, American Sheep Industry Association.
U.S. House Agriculture Committee, Voluntary Carbon Markets in Agriculture and Forestry (recorded Sept. 23, 2021)
Pennsylvania Senate Agriculture and Rural Affairs Committee, Hearing on Utility Scale Solar Development and Agricultural Land in Pennsylvania, hearing recording and written testimony from nine witnesses, including Brook Duer (Sept. 21, 2021).
Weekly Featured Graphics:
Agricultural Economic Insights, Four Key Insights from the USDA’s Farm Income Estimates (Oct. 1, 2021)
The Counter, Meat prices increasing faster than other goods, government data shows (Sept. 24, 2021)
Penn State News, Research, & Resources:
State-Driven Emissions Controls Only Slightly More Expensive (Sept. 14, 2021).
Mitigating Carbon May Have Unintended Consequences (Sept. 27, 2021).
USDA Grant Supports Penn State Research on Mushroom Industry Automation (Sept. 28, 2021).
AGENCY PRESS RELEASES—STATE/FEDERAL
PENNSYLVANIA DEPARTMENT OF AGRICULTURE PRESS RELEASES:
U.S. DEPARTMENT OF AGRICULTURE (USDA) PRESS RELEASES:
U.S. Department of Agriculture Announces Key Staff (Sept. 30, 2021).
USDA AGENCY PRESS RELEASES:
Agricultural Marketing Service
USDA Opens Annual U.S. Grain Exporter Registration for 2022 (Oct. 1, 2021).
Agricultural Research Service
Animal and Plant Health Inspection Service
Farm Service Agency
Food and Nutrition Service
USDA Takes Action Against Detroit SNAP Retailers for Rules Violations (Sept. 29, 2021).
Food Safety and Inspection Service
Foreign Agricultural Service
Private Exporters Report Sales Activity for China (Sept. 27, 2021).
Private Exporters Report Sales Activity for Mexico (Sept. 28, 2021).
U.S. Specialty Crops Trade Issues—2020 Report to Congress (Oct. 4, 2021).
National Agricultural Statistics Service
Agricultural Statistics Board Briefing—Small Grains Summary Grain Stocks (Sept. 30, 2021).
National Institute of Food and Agriculture
NIFA Invests $5 Million in Community Foods Projects Awards (Sept. 28, 2021).
PENNSYLVANIA EXECUTIVE AGENCIES (Pa. Bulletin Vol. 51, No. 40—Oct. 2, 2021):
Department of Conservation and Natural Resources
51 Pa.B. 6257 Notice: “Proposed Exchange of Property [Greene Township, Clinton County and Spring Township, Centre County].”
Department of Environmental Protection
51 Pa.B. 6259 Notice: “Applications For NPDES and WQM Permits Under The Clean Streams Law And Federal Clean Water Act.”
51 Pa.B. 6320 Notice: “Citizens Advisory Council Meeting [Tuesday, October 19, 2021].”
51 Pa.B. 6320 Notice: “Stream Redesignation Evaluation of Chester Creek and Reynolds Run; Water Quality Standards Review”
Environmental Quality Board
51 Pa.B. 6336 Notice: “October Meeting [Tuesday, October 19, 2021].”
The General Assembly
51 Pa.B. 6253 “A Concurrent Resolution [Hurricane Ida].”
Susquehanna River Basin Commission
51 Pa.B. 6343 Notice: “Actions Taken at September Meeting.”
Signed into Law
HB 1591 “An Act amending . . . The County Code, in names and corporate powers, classification of counties, further providing for ascertainment, certification and effect of change of class; and making related repeals.” Act. No. 74 (Oct. 1, 2021).
Presented to Governor
HB 523 “An Act amending . . . the General Road Law, further providing for repair of private roads and providing for definitions.” Presented to the Governor (Sept. 29, 2021).
Legislation in Second Chamber
HB 1919 “An Act amending Title 3 (Agriculture) of the Pennsylvania Consolidated Statutes, providing for extensive amendments to the very small meat processor Federal inspection reimbursement grant program.” Referred to AGRICULTURE AND RURAL AFFAIRS [House] (Sept. 27, 2021).
HB 1658 “An Act amending Title 74 (Transportation) of the Pennsylvania Consolidated Statutes, in public utility facilities, further providing for adjustment [‘Financial Relief for Rural Landlines’].” Referred to TRANSPORTATION [Senate] (Sept. 28, 2021).
HB 591 “An Act amending . . . The Clean Streams Law, in other pollutions and potential pollution, further providing for potential pollution [NPDES Program].” Referred to ENVIRONMENTAL RESOURCES AND ENERGY [Senate] (Sept. 28, 2021).
SB 725 “An Act amending Title 75 (Vehicles) of the Pennsylvania Consolidated Statutes, in licensing of drivers, further providing for classes of licenses; and in commercial drivers, further providing for requirement for commercial driver’s license [Clarification of Legislative Intent – Exemption for Farmers from CDL Requirements].” Referred to TRANSPORTATION [House] (Sept. 29, 2021).
SB 736 “An Act amending Title 75 (Vehicles) of the Pennsylvania Consolidated Statutes, in registration of vehicles, further providing for use of farm vehicle plates [Streamlining the Home Delivery of Agricultural Products].” Referred to TRANSPORTATION [House] (Sept. 29, 2021).
SB 832 “An Act amending Titles 3 (Agriculture) and 27 (Environmental Resources) of the Pennsylvania Consolidated Statutes, in Conservation Excellence Grant Program, further providing for criteria for evaluation of applications; providing for nonpoint source pollution reduction and establishing the Agriculture Conservation Assistance Program, the Pennsylvania Clean Water Procurement Program and the Municipal Storm Water Assistance Program.” First consideration [Senate] (Sept. 28, 2021).
SB 525 “An Act amending Title 27 (Environmental Resources) of the Pennsylvania Consolidated Statutes, in environmental stewardship and watershed protection, further providing for legislative findings, for fund and for agencies.” First consideration [Senate] (Sept. 28, 2021).
SB 284 “An Act amending Title 27 (Environmental Resources) of the Pennsylvania Consolidated Statutes, in environmental protection, providing for bonding for alternative energy production projects; and, in special programs, providing for solar forced labor prevention [Bonding of Solar and Wind Installations].” Removed from table [Senate] (Sept. 28, 2021).
FEDERAL EXECUTIVE AGENCIES (Federal Register Sept. 27–Oct. 1, 2021):
86 FR 53265 Notice—Comment Period: “Intent To Establish an Equity Commission and Solicitation of Nominations for Membership on the Equity Commission Advisory Committee and Equity Commission Subcommittee on Agriculture” (Sept. 27, 2021).
86 FR 53628 Notice, comments accepted: “Submission for OMB Review; Comment Request [Food and Nutrition Service: Food Delivery Portal (FDP) Data Collection]” (Sept. 28, 2021).
86 FR 53942 Notice: “Submission for OMB Review; Comment Request [Forest Service
Title: Timber Sale Contract Operations and Administration]” (Sept. 29, 2021).
86 FR 54420 “Submission for OMB Review; Comment Request [Animal and Plant Health Inspection Service: Endangered Species Regulations and Forfeiture Procedures]” (Oct. 1, 2021).
Agricultural Marketing Service
86 FR 53863 Rule: “Walnuts Grown in California; Notification of Moratorium” (Sept. 29, 2021).
86 FR 54339 Final Rule: “Reorganization and Transfer of Regulations [Economic Adjustment Assistance for Textile Manufacturers]” (Oct. 1, 2021).
86 FR 54419 Notice—Comment Period: “Seafood Processors Pandemic Response and Safety Block Grant Program; Request for Emergency Approval of a New Information Collection” (Oct. 1, 2021).
86 FR 54420 Notice—Comment Period: “Local Food Purchase Assistance Cooperative Agreement Program” (Oct. 1, 2021).
Commodity Credit Corporation
86 FR 54149 Notice—Comment Period: “Climate-Smart Agriculture and Forestry Partnership Program” (Sept. 30, 2021).
Environmental Protection Agency
86 FR 53653 Notice: “Applying the Supreme Court’s County of Maui v. Hawaii Wildlife Fund Decision in the Clean Water Act Section 402 National Pollutant Discharge Elimination System Permit Program” (Sept. 28, 2021).
86 FR 53960 Notice—Comment Period: “Proposed Information Collection Request; Comment Request; Estimating Benefits of Surface Water Quality Improvements” (Sept. 29, 2021).
Farm Credit Administration
86 FR 54347 Final Rule: “Regulatory Capital Rules: Tier 1/Tier 2 Framework” (Oct. 1, 2021).
Fish and Wildlife Service
86 FR 53255 Proposed Rule: “Endangered and Threatened Wildlife and Plants; 17 Species Not Warranted for Listing as Endangered or Threatened Species” (Sept. 27, 2021).
86 FR 53337 Notice—Comment Period: “Agency Information Collection Activities; Federal Fish and Wildlife Applications and Reports-Law Enforcement” (Sept. 27, 2021).
86 FR 53609 Proposed Rule—Comment Period: “Endangered and Threatened Wildlife and Plants; Endangered Status for South Llano Springs Moss and Designation of Critical Habitat” (Sept. 28, 2021).
86 FR 53583 Proposed Rule—Comment Period: “Endangered and Threatened Wildlife and Plants; Endangered Species Status for the Peñasco Least Chipmunk and Designation of Critical Habitat” (Sept. 28, 2021).
86 FR 53937 Proposed Rule: “Endangered and Threatened Wildlife and Plants; 90-Day Findings for Five Species” (Sept. 29, 2021).
86 FR 53933 Proposed Rule: “Endangered and Threatened Wildlife and Plants; Two Species Not Warranted for Listing as Endangered or Threatened Species [Black Creek crayfish and Hairy-peduncled beakrush]” (Sept. 29, 2021).
86 FR 54298 Proposed Rule—Comment Period: “Endangered and Threatened Wildlife and Plants; Removal of 23 Extinct Species From the Lists of Endangered and Threatened Wildlife and Plants” (Sept. 30, 2021).
86 FR 54145 Proposed Rule—Comment Period: “Endangered and Threatened Wildlife and Plants; Removing the Braken Bat Cave Meshweaver From the List of Endangered and Threatened Wildlife” (Sept. 30, 2021).
86 FR 54230 Notice—Comment Period: “Agency Information Collection Activities; U.S. Fish and Wildlife Service ArcGIS Online (AGOL) Platform” (Sept. 30, 2021).
Food and Drug Administration
86 FR 54454 Notice—Comment Period: “Agency Information Collection Activities; Submission for Office of Management and Budget Review; Comment Request; Food Safety; Federal-State Food Regulatory Program Standards” (Oct. 1, 2021).
International Trade Administration
86 FR 54424 Notice: “Agreement Suspending the Antidumping Duty Investigation on Fresh Tomatoes From Mexico; Preliminary Results of 2019-2020 Administrative Review” (Oct. 1, 2021).
National Agricultural Statistics Service
86 FR 53269 Notice—Comment Period: “Notice of Intent To Request Revision and Extension of a Currently Approved Information Collection” (Sept. 27, 2021).
Rural Business-Cooperative Service
86 FR 53270 Notice—Comment Period: “Notice of Solicitation of Applications for Inviting Applications for the Rural Business Development Grant Programs for Fiscal Year 2022” (Sept. 27, 2021).
Small Business Administration
86 FR 54006 Notice: “Administrative Declaration Amendment of a Disaster for the Commonwealth of Pennsylvania” (Sept. 29, 2021).
86 FR 54006 Notice—Comment Period: “Reporting and Recordkeeping Requirements Under OMB Review [Paycheck Protection Loan Program—Second Draw]” (Sept. 29, 2021).
U.S. HOUSE AGRICULTURE COMMITTEE:
- Rept. 117-129 “Agricultural Fairs Rescue Act [Committee Report].”
H.R.2424 “Agricultural Fairs Rescue Act” Placed on the Union Calendar, Calendar No. 93 (Sept. 27, 2021).
H.R.5399 “National Security and Federal Lands Protection Act” Referred to the Committees on Natural Resources, Agriculture, and Homeland Security (Sept. 28, 2021).
H.R.5406 “Biological Intelligence Organization and Attribution Act” Referred to the Committees on Energy and Commerce, Armed Services, Homeland Security, Natural Resources, Foreign Affairs, Financial Services, Ways and Means, Veterans’ Affairs, the Judiciary, Intelligence, and Agriculture (Sept. 28, 2021).
H.R.5421 “To amend the Food, Agriculture, Conservation, and Trade Act of 1990 to provide research and extension grants to combat plant pests and noxious weeds that impact coffee plants, and for other purposes.” Referred to the House Committee on Agriculture (Sept. 29, 2021).
H.R.5422 “To amend the Food, Agriculture, Conservation, and Trade Act of 1990 to modify the macadamia tree health initiative, and for other purposes.” Referred to the House Committee on Agriculture (Sept. 29, 2021).
H.R.3617 “Marijuana Opportunity Reinvestment and Expungement Act of 2021” or the “MORE Act of 2021” Ordered to be Reported in the Nature of a Substitute by the Yeas and Nays: 26 – 15 (Sept. 30, 2021).
U.S. SENATE COMMITTEE AGRICULTURE, NUTRITION, AND FORESTRY:
S.2855 “A bill to extend authorization for livestock mandatory reporting.” Read twice and referred to the Committee on Agriculture, Nutrition, and Forestry (Sept. 27, 2021).
S.2860 “A bill to prohibit mandatory or compulsory checkoff programs.” Read twice and referred to the Committee on Agriculture, Nutrition, and Forestry (Sept. 27, 2021).
S.2861 “A bill to prohibit certain practices relating to certain commodity promotion programs, to require greater transparency by those programs, and for other purposes.” Read twice and referred to the Committee on Agriculture, Nutrition, and Forestry (Sept. 27, 2021).
S.2884 “A bill to amend the Food, Agriculture, Conservation, and Trade Act of 1990 to provide research and extension grants to combat plant pests and noxious weeds that impact coffee plants, and for other purposes.” Read twice and referred to the Committee on Agriculture, Nutrition, and Forestry (Sept. 29, 2021).
S.2885 “A bill to amend the Food, Agriculture, Conservation, and Trade Act of 1990 to modify the macadamia tree health initiative, and for other purposes.” Read twice and referred to the Committee on Agriculture, Nutrition, and Forestry (Sept. 29, 2021).
Top #AgLaw HotLinks Sept. 27–Oct. 1, 2021
Biden Administration Considers Biofuel Blending Cuts, According to Reports, Univ. of Ill. Farm Policy News
Global Corn Production Higher, but Farmers Face Ida-Related Input Supply Disruptions- Increased Fertilizer Costs, Univ. of Ill. Farm Policy News
Germany Retooling Pork Industry as ASF Spreads, Brownfield
Ida Agriculture Damage at Least $584m in Louisiana, Morning Ag Clips
Hackers Target Another U.S. Grain Co-op, Farms.com
Wayne Farms Selling Newly Upgraded Laurel Operation, Meat+Poultry
Subscribe to the Pennsylvania Farm Employers’ Listserv (PFEL), an email networking and resource-sharing group about human resources topics exclusively for agricultural operations and producers, by sending an email with “subscribe” in the subject line to [email protected].
Audry Thompson—Research Assistant
Brook Duer—Staff Attorney