Why ‘Crime’ Isn’t the Question and Police Aren’t the Answer

Moderates often suggest that “police reduce crime.” But the framing of this statement is much more flawed than it may appear.

A few weeks after the murder of George Floyd, the commentator Matthew Yglesias announced to his four hundred thousand Twitter followers that he was about to deliver (through a now-deleted Twitter thread and a Vox article): “Some thoughts on police.”      

When a person like Yglesias, with no expertise in prison and police abolition, offers his general wisdom during a revolutionary political moment that threatens racial and economic privileges from which he benefits—on a website run for profit—it raises questions about what interests the analysis will serve.

Revolutionary moments like this one are exciting because they explode previous conceptions of what is possible and produce new consciousness. But these are also situations in which status-quo moderates burst into action, telling us that the demands of marginalized people seeking change are “too much, too soon,” radical, infeasible, and unsafe.      

As if on cue, in the weeks following nationwide uprisings against racist policing, an army of moderates have attempted to make the idea of defunding and abolishing the police seem like a dangerously naïve fantasy rather than a natural rejection of a discriminatory, expensive, and catastrophic bureaucracy that serves the class of people who own things.      

The claim made by Yglesias—and the claim often made by moderates—is that “police reduce crime.” In this article, I want to explain why this premise is mistaken and how it is designed to distract us from having the conversation that really matters.

We Have Bad Data

It is important to note up front that the data available about the punishment bureaucracy is terrible. Scientifically determining causal inferences for complex social phenomena is inherently difficult, but one of the scandals of mass criminalization in the United States since 1975 is that politicians have cared so little about whether the bureaucracy actually serves its stated goals that they have not invested in collecting data or studying it. Think of it like this: every few years, we are told that a new study says that drinking coffee is bad, but then we’re told that another study says coffee is good. Same with eggs. Or coconut. The social science around the effects of police on heavily politicized concepts like “crime” is far less studied than food. Anyone like Yglesias who tells you confidently that “more police = less crime” should be viewed with skepticism. 

As with Nathan Robinson’s excellent recent critique of the lack of rigor in drawing conclusions from social science generally, my goal here is not to nitpick the studies that Yglesias relies on, or cite the research that says the opposite—although I do find it odd that Yglesias doesn’t acknowledge that contrary research, or even note that the studies he cites explain their conclusions as a debatable part of a contradictory literature. I have read the studies on both sides of the debate about “crime” and find many of them to be methodologically questionable and of almost no use in answering the most relevant questions. 

Here, I’m interested instead in looking at what moderates are doing when they invoke this research. For even if one accepts the findings Yglesias cites about “crime,” they say almost nothing about the ultimate question of whether to significantly defund or abolish the police. Yglesias is simply having the wrong conversation.

Reducing “Crime” Misses the Point

Writing in a format he calls “explanatory journalism,” Yglesias frames his Vox article as a challenge to abolitionists who call for the end of policing as we know it and who advocate for a society that doesn’t need what we now think of as the police. In reality, he offers neither a critique of abolition nor a defense of contemporary policing. Rather than addressing abolitionist arguments head-on, he merely criticizes several supposed factual claims and omissions in a single book, The End of Policing by the professor Alex Vitale. Yglesias’s thinks research shows that deploying more police reduces what Yglesias calls “crime.” He claims this research rebuts Vitale’s conclusions about whether police have positive effects overall.       

So, the heart of Yglesias’s argument is “police reduce crime.” Vitale is not primarily concerned with that question. Vitale argues that the most important function of police has never been to reduce “crime” but instead to enforce white supremacy and preserve wealth. For Vitale, the social costs associated with the real functions of police outweigh any benefit they provide. More police might reduce what they call “crime,” but how much violence and misery do they preserve and create? 

To understand why Yglesias’s argument is weak and mostly irrelevant to the question of defunding police, let’s look at its main flaws.

First, Yglesias’s piece is all about “crime,” but he never explores what that word means. The concept of “crime” is constructed by people who have power. Throughout history, powerful people have defined “crime” in ways that benefit wealthy people and white people. For example, cocaine, marijuana, and opium were made illegal to target specific racial minorities. And even within categories of acts that are classified as “crimes,” powerful people decide where to look for those acts, when to look for them, and which ones to ignore and which to document. Students at universities, for example, frequently violate underage drinking, drug, and sexual assault laws without carceral punishment while Black people who live down the street are surveilled, searched, arrested, beaten, jailed, and rendered homeless, jobless, and traumatized for similar behavior. A schoolyard fight at a wealthy private school may mean a call to parents but the same fight at a school filled with poor children is recorded as a “crime” and prosecuted, ending with a child kept in a cage away from her family. The entire system is filled with such examples. 

Second, the data and reporting about “crime” that Yglesias cites comes from police themselves. Police are not some objective body neutrally “enforcing the law.” Not only do they choose to look for some crimes, committed by some people, in some neighborhoods, some of the time, but they have political incentives to manipulate the data they collect, and not to collect other data at all. To take one example, depending on the political winds, police have an incentive to either under or over report the number of various types of crimes in order to promote particular campaigns or narratives. To take another example, police do not record as crimes all of the illegal stops, searches, and assaults that they themselves commit, even though counting these would likely increase overall “crime” dramatically by adding thousands of additional physical assaults to the record books in every major U.S. city each year.

Third, and perhaps most importantly, what constitutes a “crime” in the United States is divorced from what causes harm. The standard narrative of police as central to “public safety” rings hollow when one considers actual causes of injury and death. For example, tobacco kills 480,000 people every year in the United States, including 41,000 from second-hand smoke alone. This dwarfs police-reported data on deaths from the drugs that police call “crimes.” The same is true of water pollution, air pollution, and fraudulent home foreclosures, all of which are linked to astronomical mortality rates, and are perpetrated by large corporations and the wealthy people who own them. Wage theft by employers is almost never investigated by police or prosecuted, and yet it costs low-wage workers an estimated $50 billion per year, dwarfing the cost of all police-reported robberies, burglaries, larcenies, and motor vehicle thefts combined. But this narrative of what constitutes “crime” is how local news can declare that crime is “soaring” after a month with a few dozen more car burglaries and how a newspaper can declare that a city became “safer” because there were 34 fewer homicides one year without considering how many people there died preventable deaths due to unstable housing, lack of access to health insurance, race-based pollution, or malnutrition. 

Not all human tragedy is preventable, but quite a lot of it is, and accepting conceptions of “crime” and police data about that concept as a proxy for holistic public safety is the original sin of most writing in this topic.

What About “Violence”?

But what about what Yglesias calls “violent crime,” a concept one might initially believe less susceptible to social construction? On this point, it’s interesting that Yglesias does not engage with the historical literature demonstrating that the rise of modern U.S. policing had little to do with “violent crime” and more to do with catching enslaved people who had liberated themsleves and crushing organized labor actions by low-wage workers. For present purposes, I’ll ignore that Yglesias mixes research on generic “crime” to make his argument about “violent crime” because the “violent crime” argument is so pervasive in moderate commentary and should be addressed head-on.

Here too Yglesias never explores the basic concept he’s discussing. What constitutes violence? True violence is more than physical assault and murder: there’s the everyday violence of structural poverty, lack of access to health care, forced homelessness, children forced to drink water poisoned with lead, a pregnant woman unable to afford proper nutrition, or a family (often illegally) evicted from their home.

And there is another glaring flaw in Yglesias’ argument: the pro-police studies he cites make no attempt to count the “violent crimes” committed by the police and prison bureaucracy itself, or the other deaths in custody like the death of Sandra Bland. They leave out millions of illegal police assaults each year[1], and hundreds of thousands of sexual and physical assaults in jails and prisons alone[2]. Given the small margins of the supposed reductions that Yglesias cites, the results of the studies would likely be reversed completely if they included crimes and physical violence committed by police and prison guards.

Not only do police not report their own crimes, but the vast majority of sexual assault and violent incidents are never reported to police at all. This is a profound problem for Yglesias and the studies he relies on, because one of the central features of abolitionist theory and practice is creating a society where harm rarely occurs because we are devoting resources to tackling its actual causes, like cycles of trauma, mental illness, lack of deep relationships with one another, lack of investment in children, environmental pollution, and toxic masculinity. Abolitionists seek structural solutions that, by building something in place of punishment bureaucracies that actually meets people’s needs and helps them flourish, end all of that unreported crime as well.

Thus, the things police and Yglesias call “violent crime” cause significantly less injury and death than structural violence in our society. So if our concern is overall safety, life, and well-being, a focus on “violent crime” in the narrow sense that the police calculate it is inadequate, as well as a political and rhetorical choice designed to get you to focus on some harms and not others. 

Moderates Don’t Want You To Think About The Alternatives

On top of these core flaws, the research moderates usually cite does not support their conclusions. Yglesias’s studies, for example, do not support larger police budgets in the aggregate: they only purport to speak to particular police strategies at particular moments in particular places.  Most of what police do is respond to non-criminal calls—“violent crime” amounts to only about 4 percent of their time. And even when they do deal with criminal incidents, only 5 percent of all police arrests are for what the FBI considers serious “violent crime.” The vast bulk of what police do is execute physical violence and surveillance against disproportionately poor and Black individuals for low level offenses like driving on a suspended license (11 million people have suspended licenses because of unpaid debts), trespassing, “disorderly” behavior caused by mental illness, technical probation violations, and owing debts. Tens of millions of people have been caged and separated from families for drug possession—in 2015, more people were handcuffed and caged for marijuana offenses than for all “violent crimes” combined. All of this forcible arresting would itself be seen as the “violent crime” of “kidnapping” if people who own things in our society had not given police permission and money to do it. 

In a single throw-away sentence, Yglesias praises what is actually the bulk of Vitale’s argument. He notes that the book “contains some good ideas about the potential to use housing and mental health policy to address certain classes of problems that are now largely dumped on the criminal justice system.” Yglesias doesn’t acknowledge that these “certain classes of problems” are mostly what police spend their time on! Far from agreeing that police budgets are largely wasted on unnecessary surveillance, military weaponry, criminalization of poverty, low-level arrests, arresting the mentally ill, and the waste, fraud, and abuse of the police overtime system, Yglesias never even contemplates that police might need less funding. This is despite the fact that reducing budgets and redirecting police priorities toward high priority geographic and subject matter areas is a clear implication if one takes his studies seriously. Yglesias never acknowledges that he could largely maintain his faith in those studies while also dramatically reducing much of the rest of what police do.

Most importantly, though, none of the studies Yglesias cites examines what kind of “violent crime” would happen in a society that was properly investing in communities. In other words, they do not ask whether other interventions (i.e. not police, guns, tasers, handcuffs, prosecutors, lawyers, jails, judges, probation officers, prisons, prison guards, parole officers, etc…) would be more effective than police in reducing “violent crime.” There is a body of research on how other alternatives reduce even what police call “crime,” and the studies cited by Yglesias do not control for those interventions when they study the supposed effects of more police. Yglesias’s studies basically take as a given the current structural systems and cultural attitudes and examine police data about what happens in the short term when fewer or more police arrive in a particular geographic area subject to all of those larger forces and in a community already used to being forced to use police to manage conflict. That flaw makes them useless as a rebuttal to abolitionists.  

I therefore suspect that not even several of the pro-police researchers Yglesias cites would agree that their research supports his generalization (in a section heading no less!) that “police officers reduce crime.” The short-term studies themselves say nothing about the complex generational effects of policing and imprisonment on even the police-controlled “crime” data they use. They do not study long term “crime” effects of heavy policing given the trauma and mental health of residents, the criminogenic effects of arresting and jailing people who later then lose their housing or their jobs and become more likely to commit “crime,” the effects on Black children growing up with an incarcerated parent, and so on. These studies, whatever their value, are operating with limited, distorted variables and in a different universe from the social and economic changes that abolitionists envision. 

The Costs of Police

The existence of this different universe is clearest in Yglesias’s failure to mention the costs of policing. To his credit, Yglesias acknowledges inequality.  But it is revealing that Yglesias uses the metaphor of the police as a “Band-Aid” to mitigate the harms of social inequalities. This metaphor subtly suggests that policing is actually an attempt to alleviate the damage caused by harmful systems rather than working in tandem with them to accomplish their unequal goals. Band-Aids aren’t typically one of the causes of a wound.

One of the most important moments of Yglesias’s article is therefore when he argues that the reason we should not pursue defunding or abolition is that we have not yet tried “reforms” that would hold violent “bad apple” cops accountable. This argument is predicated on a claim that the only significant cost of police is what Yglesias calls the “excessive force” caught on video in the George Floyd murder. But none of the abolitionists I know are concerned only about overt physical violence by police that is already nominally illegal. The abolitionists I know are more focused on what the “good cops” are doing every day. It’s those “good cops” who enforce the massive punishment bureaucracy.      

The only other point at which Yglesias quantifies social costs is when he mentions a study that purported to find that every $1 spent on police brings $1.63 in “social benefits.” Yglesias’s conclusion from the study is, apparently, that we should hire infinitely more police officers because every additional cop adds marginal value to society. Setting aside that this study shares the fatal conceptual problems I have previously described, notice two aspects of it: first, the study decided that every murdered life was worth $7 million and that every sexual assault caused $142,020 in damage. The absurdity of Yglesias passing off judgments like this as science is self-evident, and different estimates of the relative financial value of rape and murder could have just as easily yielded a conclusion that police cost more money than they are worth. Second, as with the other studies, this one does not include violence by police or prison guards. Using the study’s own numbers, if there are 1,000 deaths from police shootings every year and 95,000 yearly sexual assaults against people arrested by police, that would be more than an additional $20 billion in social costs—reversing the finding of the study. More broadly, the study does not include the costs of other police harm: millions of stops, searches, arrests, beatings, chokeholds, and taserings; interference with community-based efforts to combat violence; lost jobs, homes, and separated families; interrupted medical and mental health care; spreading of infectious disease in jails; deportations; and harder-to-quantify effects of things like widespread surveillance on human relationships and privacy. Presenting the supposed benefits of something without counting its harms is not objective science.

Thus, even if one believed that police marginally reduce “crime” such that we should hire enough police to station one officer inside every person’s bedroom and outside every person’s home, one might still conclude that the costs of living in such a police state would make that undesirable. It is astonishing that a public figure would argue for more police based on a few flawed studies less rigorous than studies about whether olive oil is good for your skin without attempting to confront these costs.

Yglesias and other moderates also ignore alternative less costly ways that we might obtain the benefits they tout. To take one blatant example, none of Yglesias’s studies control for unique features of police—as far as the studies are concerned, we don’t know whether the same results could have been obtained by flooding “high crime” areas with priests or poets. Or Black Panthers.

One of the academics Yglesias (mis)cites, sociologist Patrick Sharkey, explains the even more robust empirical literature showing that community-based investments have dramatically beneficial effects on “violence.” (I suspect Yglesias read Sharkey’s widely-shared recent Washington Post op-ed, which he linked to, but not Sharkey’s academic work.) Unfortunately, although Sharkey is a more rigorous thinker than Yglesias and comes to some better conclusions about alternatives to police, his work on this issue is pervaded by nearly all of the flaws I discuss with Yglesias. The key paragraph on police and “crime” in Sharkey’s op-ed relies on the same flawed studies as Yglesias. It also contains several bizarre moments that reflect biases toward power and a lack of interest in focusing on the important structural questions. For example, when talking about the supposed benefits of police on “violent crime,” Sharkey says without explanation that “violence is the most damaging feature of urban inequality.” This claim strikes me as unfounded: many people I know and work with in those communities think that more harm is caused by the far greater number of deaths associated with other features of “urban inequality”: eviction; lack of medical care, nutritious food, living wages, physical exercise, and stimulating education; lead poisoning; air pollution; mental health disorders and lack of treatment; predatory financial practices that trap people in cycles of debt and poverty; drug use; disproportionate infant mortality and cancer rates; mass family separation caused by the criminal and child welfare bureaucracies, etc. And even though Sharkey makes statements of disputable fact favorable to police narratives with confidence, he is only willing to say on the other side that “one can argue” that police are an “authoritarian institution” that has historically targeted Black people. This equivocation correlates with his calls to maintain police funding while only “piloting” investments in alternatives using non-government funds. Like Yglesias, Sharkey appears to be unwilling to confront, at a structural level, the symbiotic relationship between policing and racial capitalism or to understand “violence” in a holistic way that would challenge the existing racial and economic order.

Yglesias’s interventions on this point since his Vox article are just as puzzling. Although Yglesias deleted his original tweet thread introducing his “thoughts on police,” he keeps tweeting about the issue in even less justifiable ways: his latest tweet proclaims that he is “very skeptical” about calls to reduce police budgets, but cites only his Vox piece. He never publicly acknowledges that he has not weighed the costs of the “crime” reduction he touts or empirical analysis of whether investments other than police could lead to greater reductions in what he calls “crime.” Thus, although Yglesias says that the United States needs more police instead of their defunding, he does not ever even try to make the case for that view. 

Introducing People to Abolition

Yglesias mentions abolitionists Ruth Wilson Gilmore, Angela Davis, and Mariame Kaba up front as if he is familiar with their work, but he does not discuss their ideas. And he doesn’t mention the other abolitionist theories, principles, or empirical evidence that I have engaged with for the past 12 years working in and studying the punishment bureaucracy.

To me, the crux of the abolitionist body of literature, thinking, and revolutionary struggle which those three Black women and many others (check out Derecka Purnell’s brilliant recent essay on police abolition here) have given us is that the main function of police and prisons in a society of pervasive racism and hoarding of wealth is to serve the interests of the white owning class. 

In any modern capitalist society, police are what protects the private property of people who own it. In the United States, this means something specific: white elites stole the labor and land of Black and indigenous people for centuries and then continued to break their own laws (with the help of police) to extract more of their wealth once formal law supposedly ended legally sanctioned atrocities. They did this through the state violence of enforcing slavery, racial terrorism and lynching, busting organized labor actions, race-based lending and foreclosures, and widespread academic and employment discrimination. One of the main functions of police is to preserve that distribution of wealth, land, and resources that resulted from that pillage.      

To take one example linked to this history, police are the reason that people who now own all of the extra vacant houses and apartments in every U.S. city can call upon the force and violence of the state to prevent people who have no place to live from taking shelter. 

And today, police are the reason wealthy moderates can afford to not treat homelessness as a crisis: it may be killing people, but it won’t affect them much. Police are the mechanism by which some people can live comfortably with a spare bedroom or three, knowing that if a houseless person showed up at their door, they could bring down metal handcuffs and a jail cell on that person if the person refused to leave. The threat of police intervention is the reason Jared Kushner can forcibly evict people from properties he owns.   

One of the most important functions police serve is enforcing who can be where and with what—if police were not willing to enforce wealth hoarding, people who own things could not maintain their claims to land. Restaurants and grocery stores who sell food could not deny it to the hungry, and our society would be forced into a different set of relationships. This is a violence of a kind, and it is the constant threat of this state-sanctioned violence that allows for so much more structural violence associated with poverty and inequality to exist. But this isn’t what moderates notice about police.

Most of the writing and organizing around abolition is thus about something broader than Yglesias’s conception of “crime”: it’s about how the U.S. has caged people in numbers unprecedented in history, surveillance that has changed how we interact with each other, and the separation of tens of millions of families. It’s about the trillions of dollars that have been spent constructing new “crimes” in the “war on drugs,” and billions of dollars in poor people’s property have been taken by the police through “civil forfeiture.” It’s about the cash bail system and the privatization of nearly every component of the punishment bureaucracy, including how all of these systems fit together; for example, in thousands of jails across the country, people who are confined solely because they cannot pay cash bail are now prohibited from seeing or hugging their children because police have signed contracts with multi-billion dollar corporations to require them to pay for phone and video calls with loved ones instead. Those who cannot pay cannot speak to the people they love. And it’s of course about racial disparities—by 2002, the police bureaucracy caged Black people at a rate six times that of South Africa at the height of apartheid, and those disparities haven’t changed in the decades we have been talking about “reform.” 

Most fundamentally, abolition is about transforming a mindset of individualized blame and punishment into a society that invests in the kinds of bonds and relationships that not only effectively prevent harm but that also enable meaningful accountability when harm does occur.      It’s about whether to accept structural violence or to create truly safe places to live, learn, and love.

Why Focus On the Bad Arguments of Moderates?

It is hard to overstate the urgency of this moment for the people whose bodies and minds are on the line. Police surveil, harass, brutalize, and kill Black people. The things happening to human beings in our jails and prisons are unspeakable. And police are about to enforce millions of evictions, disproportionately of Black families. Police and prison abolition has been around for some time, but this is the first time in decades that there has been a widespread movement dedicated to actually reducing the size of this bureaucracy because of the threat that it poses to Black people.

And so the political and media establishment has mobilized against serious change with misinformation and misdirection. Among the most dangerous of these counter-revolutionary interventions are a wave of articles like last month’s “news” report in the New York Times praising the “reforms” of the Camden, New Jersey police department. The celebrated “reformsresulted in more police, more low-level arrests of poor Black people, and more Black children being separated from their parents. The role of such articles (and a similar New York Times story about Seattle published while this article was being finalized) is to narrow the conception of what is possible—to re-calibrate public expectations about which kinds of changes are appropriate and which are out of bounds. While the Camden story included evidence-free empirical assertions about the Camden police department’s effects on “crime,” cherry-picked quotes from supportive residents (but none from those organizing against the police in Camden), and cute anecdotes of police leaders marching with protesters and watching children play basketball, it did not contain a single word implying that some people have a structural critique of police in an unequal capitalist society built on white supremacy. Rather than informing its audience about that issue, the article’s denouement was a scene seemingly out of an Onion article in which a cop let kids stay on a playground past curfew and agreed with the happy children that “Black lives matter.” Such “news” articles (part of a long history by the New York Times and other moderate media) share the biases, lack of rigor, and flaws of Yglesias’s piece but parade as objective journalism. The media’s scrutiny of factual claims and the assumptions underlying those claims, and its willingness to contextualize claims in a broader truth, is inversely proportional to how much those claims and assumptions adhere to the interests and preconceived beliefs of people who own things.

Moderate arguments in favor of the status quo are popular: the hagiography of the Camden police department was featured on page A1 of the New York Times Sunday edition. And none other than Barack Obama—whose “Department of Justice” funded the hiring of 7,000 new police officers in 2009 with over $1 billion—tweeted Yglesias’s article to his 120.7 million Twitter followers. Famous moderate Steve Pinker sent out Sharkey’s article to his 655,000 twitter followers, ironically (mis)using a careless paragraph by Sharkey to quip that we should not abolish the police. Moderates with reputations to bolster, institutes to run, and money to make in corporate-owned media who tell you that more funding for police reduces “crime” are like the factory farming corporations touting the benefits of pork.

More deeply, the people in corporate media who claim that “police reduce crime” are generally not among the several billion people forced by profit-protecting state and corporate violence to starve each day around the world and not among the tens of millions of people in the United States forced by elite-controlled state violence to barely meet the basic necessities of life. As people who don’t experience police lynching and don’t worry each day about whether their children will have enough food or will be jailed by police because they cannot pay cash bail, it makes sense that they are largely comfortable with the way the world looks.

And so people talking to you about police-reported “crime” focus on the wrong conversation for a reason. Moderates don’t actually want to attack what police call “violence” if that would mean housing, healthcare, food, and theater classes for everyone’s children; they want to attack “violence” only if it means brutalizing, surveilling, and controlling powerless people. Most journalists and academics understand that Barack Obama and Steve Pinker won’t retweet you for making those points, and you won’t be able to brag about getting onto page A1. The incentives for career advancement, prestige, and profit are linked to not upsetting people who own things.

The flaws and timing of these arguments reflect the moderate groupthink that Dr. Martin Luther King, Jr. warned about in his “Letter from a Birmingham Jail”: 

“I have almost reached the regrettable conclusion that the Negro’s great stumbling block in his stride toward freedom is not the White Citizen’s Counciler or the Ku Klux Klanner, but the white moderate, who is more devoted to ‘order’ than to justice; … who paternalistically believes he can set the timetable for another man’s freedom; who lives by a mythical concept of time and who constantly advises the Negro to wait for a ‘more convenient season.’ Shallow understanding from people of good will is more frustrating than absolute misunderstanding from people of ill will.”

Unfortunately for the most vulnerable people in our society, moments like this activate a lot of these moderate counter-revolutionaries, and they are in a battle for our hearts and minds.

[1] Take the City of Newark, New Jersey alone: the DOJ found that 93 percent of the tens of thousands of police-pedestrian stops lacked justification—every unjustified police stop, search, and arrest is a legal assault.
[2] The Department of Justice estimates that about 4 percent of prisoners are sexually assaulted each year (excluding all other physical assaults), meaning about 95,000 individuals—the majority of sexual assaults by government officials.   

Alec Karakatsanis is the founder of Civil Rights Corps and the author of Usual Cruelty.  Sam Rosen, a third-year student at Harvard Law School, and Medha Swaminathan, a second-year student at Yale Law School, contributed exceptional research assistance.

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