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Presidential Signing Statements -- The More Things Change:

I'm sure it's only a matter of time until the ABA denounces as "contrary to the rule of law and our constitutional system of separation of powers" President Obama's use of signing statements to voice constitutional concerns about legislation he signs into law. See ABA Task Force on Presidential Signing Statements and the Separation of Powers Doctrine, Report at 5 (July 24, 2006) ("ABA Task Force Report"). The President quietly issued another such signing statement on Tuesday, the fourth constitutional signing statement of his young presidency.

The signing statement notes that six Members of Congress to be appointed to the newly created Ronald Reagan Centennial Commission may serve in an advisory or ceremonial capacity only and may not administer the act, consistent with separation of powers doctrine, the Appointments Clause, and the Ineligibility Clause. It read:

I wholeheartedly welcome the participation of members of Congress in the activities of the Commission. In accord with President Reagan's Signing Statement made upon signing similar commemorative legislation in 1983, I understand, and my Administration has so advised the Congress, that the members of Congress "will be able to participate only in ceremonial or advisory functions of [such a] Commission, and not in matters involving the administration of the act" in light of the separation of powers and the Appointments and Ineligibility Clauses of the Constitution (Public Papers of the President, Ronald Reagan, Vol. II, 1983, page 1390).

President Bush issued a remarkably similar statement in 2001:

Consistent with the requirements of the Appointments Clause of the Constitution, I welcome the participation, in an advisory capacity on the commission, of representatives of the Judiciary; the Brown Foundation for Education Equity, Excellence, and Research; the NAACP Legal Defense and Education Fund; and the Brown v. Board of Education National Historic Site in the activities of the commission. While the Constitution does not permit them to participate in the performance of executive functions, their advice will be crucial to the effective functioning of the commission. As I exercise my constitutional power of appointment to name 11 members of the commission, under the Appointments Clause and the enabling legislation, I welcome, as a matter of comity, the suggestions of the congressional leadership for those positions.

Signing Statement for H.R. 2133, creating the "Brown v. Board of Education 50th Anniversary Commission" (P.L. 107-41) (Sept. 18, 2001). As a Deputy in the Office of Legal Counsel, I testified on Presidential Signing Statements before the House Judiciary Committee, and so I am fairly familiar with their past use. As President Obama's signing statement itself suggests, similar concerns have routinely been expressed by Presidents of both parties for the past quarter century.

President Obama's most recent signing statement is novel not for its substance so much as for the layers of political cover the Administration has provided itself, by (1) explicitly mentioning a forebear who expressed a similar concern; and (2) explicitly noting that the Administration "has so advised the Congress" before enactment. Noting that the Administration has advised Congress of its objections addresses one of the recommendations of the ABA Signing Statement Task Force, that the President "communicate such concerns to Congress prior to passage." ABA Task Force Report at 5. Confirming that such notice was given in the signing statement itself seems prudent as a matter of congressional relations, but it is more a matter of style than substance. Although there have certainly been exceptions, administrations of both parties (including the Bush Administration) have routinely advised Congress of their constitutional objections through informal contacts and formal bill comment letters. The Obama Administration has now taken an additional step to "paper the record" by noting that fact at the time of the signing statement.

For those of you keeping score at home, based on the listing of signing statements on coherentbabble.com (which includes both constitutional signing statements and uncontroversial rhetorical or laudatory signing statements), President Obama has issued more constitutional signing statements than President Bush had at this point in his presidency (by my count, four versus one).

Related Posts (on one page):

  1. A Belated Presidential Signing Statement:
  2. Presidential Signing Statements -- Comment Thread:
  3. Presidential Signing Statements -- The More Things Change:
levisbaby:
Were you concerned by Bush's use of signing statements as well?

Or are you just trying to score some political points?
6.5.2009 7:44pm
ruuffles (mail) (www):

President Obama has issued more constitutional signing statements than President Bush had at this point in his presidency (by my count, four versus one)

First, that's not statistically significant.

Second, do you really think Bush signed more legislation than Obama at this point?

Third, the signing statement you highlight is Ronald Reagan Centennial Commission??
6.5.2009 7:46pm
MarkField (mail):
I've never thought the number of signing statements was important, but what they said. Bush's contained vague assertions of presidential power without detailing the specific passages of the statutes or the precise powers he claimed. If you want to criticize Obama, you're going to need more substance.
6.5.2009 7:53pm
ChrisTS (mail):
MarkField:
I've never thought the number of signing statements was important, but what they said. ...... If you want to criticize Obama, you're going to need more substance.


Substance is important only if one has a point to make. Otherwise, blather does very nicely.
6.5.2009 7:57pm
one of many:
M. Field you mean more substance like this or more like Bush's signing statements likethis ? The first is a pretty broad one there don't you think? Admittedly the first is more in line with what you object to in Bush's signing statements but the latter is more typical of Bush's signing statements.
6.5.2009 8:00pm
Steve:
I had plenty of problems with Bush's use of signing statements but I always felt the critics tended to overstate the case. I have no problem with a signing statement that clearly says what the President will do or not do and frames the issue in such a way that Congress can push back if it wants to - either by passing further legislation or by bringing a lawsuit.

My problem with Bush's signing statements was that many of them were written in pure legalese that gave no notice to anyone of how exactly the law might be disregarded. "The President will construe this section in accordance with his authority to oversee the unitary executive branch," full stop, end of signing statement. You're left with no idea whether the President intends to disregard substantive requirements of the legislation or if he's simply noting a routine objection for the record.

I don't agree with the formalist view that says if there's a paragraph buried somewhere in the legislation that the President believes to be unconstitutional, he has to veto the whole thing. That seems unproductive to me.
6.5.2009 8:09pm
DidTheResearch:
MarkField:

Bush's contained vague assertions of presidential power without detailing the specific passages of the statutes or the precise powers he claimed.

Actually, President Bush's DID cite specific statutory provisions to which he objected; it was telling people exactly which provisions he objected to that enabled pointed criticism. President Clinton, on the other hand, would frequently object to "several provisions of the bill" or the like.

As to the "precise powers" asserted, they were usually phrased in pretty much the same way as other Presidents had phrased them.

None of this diminishes in any way your implied criticism of the substance of the powers asserted, but it does suggest that maybe you don't really know much about what you're talking about.
6.5.2009 8:10pm
wm13:
Wow, I must be really superficial, because I can't see the difference between Obama signing statements and the ones the totally non-partisan ABA objected to. Maybe Mr. Field can enlighten us with some of the detailed analysis that John Yoo is incapable of.
6.5.2009 8:17pm
ShelbyC:

Were you concerned by Bush's use of signing statements as well?

Or are you just trying to score some political points?



Yeah?!? Why didn't I see John Elwood on the VC criticizing Bush's signing statements?

Welcome, BTW.
6.5.2009 8:19pm
levisbaby:
ShelbyC - you know he blogged for years before VC, right?

Or are you, too, just trying to score some cheap points?
6.5.2009 8:23pm
ShelbyC:

ShelbyC - you know he blogged for years before VC, right?

Or are you, too, just trying to score some cheap points?


#2.
6.5.2009 8:28pm
Steve:
So let's see, Elwood links to his Congressional testimony where he defends Bush's signing statements, and the question is whether he was concerned by Bush's use of signing statements as well? Hmm, let's think about that one for a moment.

Is it really that hard to understand the point of this post? I don't particularly agree but I certainly think I get it.
6.5.2009 8:31pm
innocent bystander (mail):
Is that the best you've got? Great start.
6.5.2009 8:34pm
Sarcastro (www):
hypocrisy is the lubrication that keeps society from grinding to a halt.
6.5.2009 8:46pm
dmv (www):
As much as I tend to disagree with Kenneth Anderson on the merits of things, at least he (usually) provides thoughtful, substantive posts when he blogs, rather than ridiculous and transparently partisan babble.

Just saying.
6.5.2009 9:02pm
dirc:
Sarcastro is the lubrication that keeps VC readers from grinding to a halt.

levisbaby is the grit that grinds the wheels of blogging.

Oh, no! I'm a hypocrite! I neither praised Sarcastro's comments nor complained about levisbaby's comments during the Bush Administration.

Will someone please help me out and make a complete list of everything I praised or criticized between 2001 and 2009, so that I may know which topics I am permitted to address?
6.5.2009 9:16pm
frankcross (mail):
Welcome to the commenters, Mr. Elwood.

I don't believe he was criticizing Obama's signing statements, just saying that Obama was the same as Bush and should be received likewise.

But of course the true issue is not the signing statement itself, but the content of its, typically constitutional, claims. Explaining the President's position in a signing statement is an unqualified good, but the constitutional claims made in such statements may be dubious. Though the ABA and others didn't always appreciate this critical difference.
6.5.2009 9:38pm
MarkField (mail):

M. Field you mean more substance like this or more like Bush's signing statements likethis ? The first is a pretty broad one there don't you think? Admittedly the first is more in line with what you object to in Bush's signing statements but the latter is more typical of Bush's signing statements.


What I meant by "substance" was that Mr. Elwood needs to give examples from specific statements and explain what it is that's wrong with them. The reason he needs to do that is that most people acknowledge that signing statements are an accepted presidential practice, so any abuses have to be defined in the details, not in the number (and especially not in the number based on an unrepresentative sample).

I'd agree that the first one is pretty vague, especially in the Foreign Affairs section. Other sections strike me as mis-readings of the Constitution, though at least it's possible to understand where he thinks the problem lies. With Bush's, it was often impossible to know that. Steve's post sets that out pretty well.


Actually, President Bush's DID cite specific statutory provisions to which he objected; it was telling people exactly which provisions he objected to that enabled pointed criticism.


Sometimes he did, often he didn't. But a good signing statement -- assuming there is such a thing -- should do two things IMO:

1. It should identify specific language in a statute which is problematic; and

2. It should state precisely the other provision of law (statute, case, or constitution) which is violated and why.

In general, I'd say most presidents fail to provide this detail. However, just to take an example from Obama, this passage seems pretty clear (and probably correct):

"Section 8203 of the Act provides that the Secretary of the Interior shall appoint certain members of the Erie Canalway National Heritage Corridor Commission "based on
recommendations from each member of the House of Representatives, the district of which encompasses the Corridor." Because it would be an impermissible restriction on the appointment power to condition the Secretary's appointments on the recommendations of members of the House, I will construe these provisions to require the Secretary to consider such congressional recommendations, but not to be bound by them in making appointments to
the Commission."


Maybe Mr. Field can enlighten us with some of the detailed analysis that John Yoo is incapable of.


Talk about the soft tyranny of low expectations...
6.5.2009 10:30pm
David M. Nieporent (www):
What I meant by "substance" was that Mr. Elwood needs to give examples from specific statements and explain what it is that's wrong with them. The reason he needs to do that is that most people acknowledge that signing statements are an accepted presidential practice, so any abuses have to be defined in the details, not in the number (and especially not in the number based on an unrepresentative sample).
In fact, most people don't know anything about signing statements, and first heard of them when the liberal media started criticizing Bush for them, and don't think they're an accepted presidential practice at all. In my experience.
6.5.2009 10:55pm
Justin (mail):
I suspect that Mr. Elwood has no problem with signing statements, and the purpose of this post is to criticize CRITICS of signing statements.
6.5.2009 11:04pm
MarkField (mail):

In fact, most people don't know anything about signing statements, and first heard of them when the liberal media started criticizing Bush for them, and don't think they're an accepted presidential practice at all. In my experience.


Well, you're probably right to some extent. "Most people" should have been "most people who've studied the issue". Marty Lederman once did a post on them (he thinks they're proper if done correctly) and gave lots of examples from many presidents. Personally, I think they're just an attempt to influence the courts, which should be focusing on the intent of the legislature and should pay no attention to them. As far as I know, they never have (I stand to be corrected on this, since I'm not that knowledgeable).
6.5.2009 11:49pm
Constantin:
Question Barack? How dare you, sir. Have you no shame?

P.S. How dare you.
6.6.2009 1:59am
tank treads and ooloong tea:
First two comments are inanely substance-free, and miss the point completely: Elwood is highlighting the hypocrisy of those who criticized signing statements before, but who are conspicuously quiet now; not himself criticizing signing statements, which he has defended before Congress. It's so obvious it shouldn't even need pointing out. Oh well, another 2 minutes of my life wasted on correcting the obtuse.
6.6.2009 5:49am
Brett Bellmore:

I don't agree with the formalist view that says if there's a paragraph buried somewhere in the legislation that the President believes to be unconstitutional, he has to veto the whole thing. That seems unproductive to me.


I think that would be very productive: It would produce an incentive for Congress to actually give a damn whether or not it's bills were constitutional. Or at least to break up omnibus bills into a number of smaller, single purpose bills. Both of which are unambiguous goods.

The problem with the opposite view is that the Constitution provides neither for a line item veto, nor a Presidential right to ignore portions of laws he has actually signed.
6.6.2009 6:35am
Owen Hutchins (mail):

First two comments are inanely substance-free, and miss the point completely: Elwood is highlighting the hypocrisy of those who criticized signing statements before, but who are conspicuously quiet now; not himself criticizing signing statements, which he has defended before Congress. It's so obvious it shouldn't even need pointing out. Oh well, another 2 minutes of my life wasted on correcting the obtuse.



That is a straw man argument; the issue was not the existence of signing statements, but rather what was said in them. It is also rather dubious to use the statistics from this early in Bush's term as if it were indicative of his whole Presidency.
6.6.2009 7:23am
bikeguy (mail):
Obama infatuation is fundamentally similar to a teenage boy's crush on a high school cheerleader. Same embarrassing squirming. It is uncomfortable to watch.
6.6.2009 7:51am
Letalis Maximus, Esq. (mail):
No Owen, tank treads is right. The point is that for the umpteenth time President Obama does something that someone in the Democrat Amen Corner, in this case the ABA, pilloried President Bush for doing. And yet, as in so many of these cases, the only response you hear now is the crickets.

Glenn Reynolds is dead right with his Pete Townsend/Jerry Seinfeld riff: "Meet the new boss yada yada yada."
6.6.2009 8:30am
Blue Neposnet (mail) (www):
The diarist needs to learn to use google. After an exhaustive 3 minute search I found an article in the March 12, 2009 version of the ABA journal calling out President Obama for his signing statements. I look forward to an update.

FTA:

The ABA adopted a policy in August 2006 objecting to "misuse" of signing statements. ABA President H. Thomas Wells Jr. had this advice for the new president in a November 2008 column of the ABA Journal: "If you believe that any provision of a bill pending before Congress would be unconstitutional if enacted, you should communicate those concerns to Congress before passage and use your veto power if you conclude that all or part of a bill is unconstitutional."
6.6.2009 8:39am
Blue Neposnet (mail) (www):
The good readers of the Volokh Conspiracy might also be interested in knowing that President Obama issued a memo regarding signing statements on March 9, 2009. The subject of the memo was "Presidential Signing Statements" if you want to do a google search and find the memo.

The ABA responded to this memo by restating their position on the matter. I posted part of one of their responses above. The President of the ABA, H. Thomas Wells Jr. also responded to President Obama's March 9th memo by restating the ABA's position on signing statements.

If your true motivation was to inform your readers, you have failed Mr. Elwood. The documents I noted are central to this discussion and the fact that you were unaware of them makes your claim of expertise in this area suspect.
6.6.2009 9:01am
rosetta's stones:
BN,

The ABA evidently wants bills vetoed if they're unconstitutional, per your quote above. Like Bush, Obama is ignoring the ABA's wants, and signing such bills, accompanied by a signing statement. Thus, the 2 administrations appear to be acting similarly, is the point of Elwood's post, I believe.

Meet the new boss... indeed.
6.6.2009 9:36am
dmv (www):
I think it's funny that pointing out how a "criticism" of Obama misses the mark, or isn't very thoughtful, or is mainly just partisan hackery, instantly becomes in the minds of some, "Obama infatuation," or idolatry of Obama.

There's a vasty difference between objecting to baseless, or just plain silly, criticisms of Obama and apologizing for everything he does. No doubt, there are some who think Obama can do no wrong, but no doubt, there are those who as a general matter support Obama but who are critical of him where they think he's gone wrong (me, for instance). So yeah, some of us will defend the man against substanceless, rhetorical sniping, but that doesn't mean we think he's perfect.

Just flip the coin, if this point isn't sinking in. How would you like it if, any time you criticize anything Obama does, everyone immediately accuses you of racism? Obviously, that would be stupid.

Same coin, guys.
6.6.2009 9:58am
wolfefan (mail):
So in his very first post on this blog, our new Conspirator a) chooses that old, worn-out bugaboo of "hypocrisy" and b) is waiting for the ABA to do something it already did.

Sen Cornyn's gain is our loss, in more ways than one.
6.6.2009 10:16am
tarheel:
Ellwood post #1 debunked in less than 30 comments via Google. On the plus side, it held up better than the work of the Bush OLC.
6.6.2009 10:17am
Fugle:
ABA Report approved by the house of delegates = letter from ABA president? At least that appears to be the argument, but I suspect that an approved report carries significantly more weight.

Is it actually better that the signing statements have continued after the ABA letter?

Hypocrisy is only a "worn out bugaboo" when it is your inconsistencies that are being pointed out. In case it has been forgotten, Obama was elected because he was going to bring "Hope &Change." The point being that there has been little change - that is both relevant and significant.
6.6.2009 10:33am
miss p:
As others have pointed out, this post makes sense only if it is a criticism of the ABA (and not Obama), but there are at least four factors (beyond the partisan one Elwood implies in his post) that undermine the allegation that the ABA is hypocritical here. First, as other commenters have noted, the president of the ABA has already formally criticized Obama's use of signing statements. Second, the ABA has already issued a report on its legal opinion of signing statements and there's no reason to issue a new one if nothing has changed. (Thus, the ABA president's criticism should be viewed as a continuing objection.) Third, as Elwood himself pointed out, Obama took steps to address ABA concerns by communicating his objections to congress through official channels and by then noting that communication in the signing statement. Finally, Obama hasn't been in office issuing signing statements for six months yet; it would be difficult for the ABA to issue an updated report on his practice, with full approval by the board, etc., during this period.
6.6.2009 11:01am
mls (www):
In my view the relevant questions are

1. When, if ever, is it permissible for a President to sign (or not veto) a bill that he believes to be unconstitutional (or might reasonably be interpreted in a manner that would make it unconstitutional) in some part?

2. If a President does sign a bill that he believes to be unconstitutional in some part, when, if ever, is it permissible (or mandatory) that he refuse to execute those parts that he believes to be unconstitutional?

3. Assuming that there are some cases that fall within category two, is it appropriate for the President to issue a signing statement announcing his intent (or direction to the executive branch) not to execute those provisions?

4. If the President believes that a provision in a bill can be reasonably interpreted in a manner that would make it constitutional or unconstitutional in his judgment, is it appropriate for him to issue a signing statement announcing his intent (or direction to the executive branch) to interpret in the constitutional manner?

5. When the President does issue a signing statement relating to categories three or four, how specific should he be in identifying the offending provisions and the constitutional basis for his objections/concerns?

6. What should be the legal effect, if any, of signing statements issued pursuant to categories three or four?


I would suggest (assuming that he, as a new conspirator, is open to suggestions from the audience) Mr. Elwood go back a few steps and explain how the executive branch has traditionally approached these questions and the alternative approaches advocated by the legislative branch, the ABA or other critics. This would give us a baseline to evaluate the respective practices of the Bush and Obama administrations and to consider whether there has in fact been any change worthy of note.
6.6.2009 11:24am
therut (mail):
When Democrats do it the MSM is silent and everthing is good. A Republician on the other hand is a blight on the Country and the Constitution itself. Nothing new here. Obama the King has spoken.
6.6.2009 12:04pm
Upend, Coming:
Welcome aboard John Elwood.

Note that this guy's second google hit is his NYTimes marriage notice 13 years ago! I am a fan of appellate practice and so I am interested to see if you blog on that subject.

Now to my own two cents:

As to the question about the ABA brought up mainly in the comments: What's the difference between a Democrat and a tribe of cannibals? The cannibals have the sense not to eat their own.

The change in the text of the signing statement does seem consistent with the oft-stated goal of "increased transparency."

To coin the phrase: a "Hannity edit." Meaning, the out-of-context excerpting of a statement by cutting off either a prefatory remark or context, or by cutting off a subsequent qualification or caveat, with the goal of implicitly misleading an audience to achieve an unstated goal.


Now to use it in a sentence:

I think that this change in the language of a signing statement is exactly the sort of language needed to minimize the possibility of a Hannity edit.
6.6.2009 12:10pm
Cornellian (mail):
The problem with signing statements is not that they are used, it's that they can be used to dodge the President's constitutional obligations.

For example, Congress enacts a bill saying "The President may do X, but only if he notifies Congress whenever he does X." The President then signs the bill into law while saying that he'll interpret the law consistent with his responsibilities as commander in chief, the unitary executive etc.

What the President doesn't tell anyone in Congress or outside the White House is that he actually is going to treat the Congressional notification portion of the law as if it doesn't exist because he thinks it's unconstitutional. He thus goes around doing X, doesn't notify Congress, refuses to confirm whether he's doing X and claims to be fully in compliance with the law, but based on his secret reading of it, not on what the law actually says. He also avoids judicial review of the constitutionality of the law because he refuses to tell anyone whether he's doing X, so the issue of the law's constitutionality never gets into court.

That's the kind of signing statement I object to, and the example raised in this post is nothing like that.
6.6.2009 1:31pm
MnZ (mail):
missp, let's talk in a year. My guess is: (i) Obama will continue to make signing statements and (ii) the ABA won't say anything about it. Why? Because the signing statement "controversy" was basically stupid. (See my response to Cornellian.)

Cornellian, you said, "The problem with signing statements is not that they are used, it's that they can be used to dodge the President's constitutional obligations." The problem is President's dodging their Constitutional obligations--not signing statements that indicate that they might dodge their obligations. To use your example, a President could fail to inform Congress whether he issued a signing statement or not. The signing statement does not determine whether the President follows the law or not. I would prefer that the President issue a signing statement that says he was going to ignore the law rather than sign the law and
surreptitiously ignore it when the cameras stopped rolling.
6.6.2009 1:51pm
rrr (mail):
"Were you concerned by Bush's use of signing statements as well?

Or are you just trying to score some political points?"

Are you concerned with Obama's use of signing statements as well?

Or are you just a hypocrite who defends everything that Obama does with "Bush did it!!" after you cried about it then?
6.6.2009 1:51pm
sybilll (mail):
I have sent this to Politifact no less than 10 times. Why they are so vehemently opposed to admitting this was a broken campaign promise is beyond me.
6.6.2009 2:08pm
Owen Hutchins (mail):
Signing statements themselves are not and never were the issue. It was what was said in them. If someone wants to claim "hypocrisy" or "same as Bush", then they must demonstrate that the signing statements (which are not unique to these Presidents) are in fact all the same.
6.6.2009 4:12pm
Andrew J. Lazarus (mail):
Some of Bush's signing statements were intended to cover-up and purport to legalize torture. They were predicated on a controversial (or perhaps I should say, tyrannical) view of Article II and its application to treatment of POWs.

Pretending that the content of the signing statements is irrelevant is a clever rhetorical trick, nothing more.

Overlooking that the ABA has already weighed in critically, that's embarrassing.
6.6.2009 6:05pm
WHOI Jacket:
Yes, well, when you're "sort of like God", all things are possible, I guess.
6.6.2009 6:16pm
M N Ralph:

The diarist needs to learn to use google. After an exhaustive 3 minute search I found an article in the March 12, 2009 version of the ABA journal calling out President Obama for his signing statements. I look forward to an update.


Elwood's face, meet egg.
6.6.2009 7:08pm
Cornellian (mail):

"Pretending that the content of the signing statements is irrelevant is a clever rhetorical trick, nothing more. "

I disagree. It's not all that clever.
6.6.2009 10:30pm
one of many:
Blue Neposnet:

Sorry for not getting back to you sooner, but I was away for the weekend.

The problem with the March 12th article in the ABA Journal is that doesn't call out President Obama for his signing statements, the worst it does is mention the advice to the incoming (at the time) president from last November while noting that ABA policy was directed at 'misuse' of signing statements (quotes in original). It does this right after presenting an argument that Obama's signing statements are not the same type as Bush's. The article is silent on the question of whether or not Obam's signing statement violated the ABA 2006 policy. The article mentions enough information that the reader can conclude the signing statement violated the advice given by H Thomas Wells last November, but that hardly qualifies as "calling out President Obama for his signing statements".

What would be more on point is the March 10th press release from H. Thomas Wells which did call Obama out for his March 9th memo. I could find no stories based upon the press release though, so it seems not to have had an impact and unless you read the release itself you would probably not even be aware of it's existence. The ABA Journal itself makes no mention of it in their March 12th article. If the ABA Journal overlooks one the ABA's press releases 2 days after it was released, we can hardly consider M. Elwood's overlooking almost 3 months later to be a foul.
6.7.2009 4:04pm

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