Amicus Curiae Brief — Lewis v. United States

+ supreme Court, U.S,

4) FILE Dp

4 6 5 FEB 239 1996

No. 95-6564 CLERK

In the

SUPREME COURT OF THE UNITED STATES

October Term, 1996

Ray A. Lewis, Petitioner

v.

The United States of America, Respondent.

On Writ of Certiorari to the

United States Court of Appeals

for the Second Circuit

BRIEF OF AMICUS CURIAE,

THE JURY TRIAL GROUP,

IN SUPPORT OF PETITIONER

Colin Dunham Christopher Warnock

President, Staff Attorney, Jury Trial Group

District of Columbia Counsel of Record

Superior Court Trial 2900 Adams Mill Rd, N.W.

rs’ Association Washington, D.C. 20009

600 F Street, N.W. (202) 234-6756

Washington, D.C. 20004

(202) 393-0123

TABLE OF CONTENTS

Table of Authorities

Statement of Interest and Summary of Argument

Argument

I. Transcending the Aggregation Problem

Il. Inherent Nature versus Penalty

Ill. Blanton and Plain Language

IV. Conclusion

TABLE OF AUTHORITIES

A inger v. Hamlin,

907 US. 25 (1972)

Baldwin v. New York,

399 U.S. 66 (1969)

Blanton v. City of North Las Vegas,

489 U.S. 538 (1989)

Blockburger v. U.S.,

284 U.S. 299 (1932)

Callan v. Wilson,

127 U.S. 540 (1888)

neff Schnac

384 U.S. 373 (196

Codispoti v. Pennsylvania,

418 U.S. 506 (1973)

District of Columbia v. Clawans,

300 U.S. 617 (1937)

Duncan v. Louisiana,

391 U.S. 145 (1967)

Ex Milligan,

FUS. 115 (1866)

Frank v. U.S.,

395 US. 147 (1969)

In re David Thornwell,

95-5184

Lewis v. U.S.,

65 F.3rd 257 (2nd Cir. 1995)

Maryland v. Crai

4

7 US. 836 (1990) (Scalia,J., dissenting)

ii

12

7, 8,11

2-8, 11

5, 7, 8-10

24, 8

Missouri v. 1

459 U.S. 359 (1983) 3

Schick v. U.S.,

195 U.S. 65 (1904) (Harlan, J., dissenting) 10

U.S. v. !

113 Prong = (1993) 12

United States Constitution

Article Three, Section Two 2, 5-7,9

Sixth Amendment 2, 5-7, 9, 11

Seventh Amendment 8,9

Miscellaneous Constitutions, Statutes and Rules

Indiana Constitution of 1818 9

D.C. Code §6-2361 4

Criminal Justice Act of 1974,

Pub. L. 93-412 1

Fed. R. Crim. P. 8(a) 3

SCR-Crim 8(a) 3

Periodicals and Treatises

4 BLACKSTONE, COMMENTARIES 10, 11

F, Frankfurter, Petty Federal Offenses and the

Constitutional Guaranty of Trial by Jury,

39 HAR. LAW REV. (1926) 9, 10

S. Kaye, Petty Offenders Have No Peers,

26 CHI. LAW REV. (1959) 9

iil

T. Lynch, Rethinking the Petry Offense Doctrine,

4 KAN. J. LAW PUB. POL’Y (Fall 1994) 8, 11, 12 No. 95-6564

T. PLUCKNETT, CONCISE HISTORY OF

THE COMMON LAW (Sth ed. 1956) 10 In the

SUPREME COURT OF THE UNITED STATES

October Term, 1996

Ray A. Lewis, Petitioner

v.

The United States of America, Respondent.

On Writ of Certiorari to the

United States Court of Appeals

for the Second Circuit

BRIEF OF AMICUS CURIAE,

THE JURY TRIAL GROUP,

IN SUPPORT OF PETITIONER

STATEMENT OF INTEREST

AND SUMMARY OF ARGUMENT

The District of Columbia Superior Court Trial Lawyers’

Association ("SCTLA") is composed primarily of private

criminal attorneys defending indigent clients under the

Criminal Justice Act of 1974 (Pub. L. 93-412) in the District

of Columbia courts. The Jury Trial Group ("JTG") is an

independent affiliate of the SCTLA formed in 1994 to defend

the right to jury trial in the District of Columbia. The JTG

has appeared as amicus curiae before the District of Columbia

Superior Court, as well as the District of Columbia Court of

Appeals. The JTG filed a petition for writ of mandamus in

iv 1

this Court, Jn re David Thornwell, 95-5184, denied October 2,

1996.

Both counsel for petitioner Lewis and the Solicitor General

have consented to the filing of a brief amicus curiae by the

JTG. Copies of written consents were filed with this Court

on February 23, 1996 and original consents will be sent

directly to the Clerk of the Court by the parties themselves.

In this brief amicus curiae will argue that the aggregation

problem cannot be resolved within the parameters of the

“petty” offense exception to the Article III and Sixth

Amendment right to jury trial. Aggregation exposes a

number of dilemmas, inherent in the "petty" offense

exception, that can only be rationally resolved by returning

the plain language of the Constitution.

ARGUMENT

I. Transcending the Aggregation Problem

When considering the question of the Sixth Amendment

and Article Three right to jury trial, conventional wisdom

views the issue of aggregation of "petty" offenses as the

primary question still to be resolved. In Blanton v. City of

North Las Vegas, 489 U.S. 538 (1989), this Court established

the six month penalty test as, in reality, an automatic rule of

law, departing from the usual precedent governing legal

presumptions and allowing only collateral punishment to

establish the rare exception to an otherwise inflexible denial

of the constitutional right to jury trial for criminal offenses

punishable by six months imprisonment or less. Blanton, 489

U.S. at 543. Thus, under Blanton, a defendant charged with a

single offense punishable only by six months imprisonment is

not constitutionally entitled to trial by jury. The primary

question presented by Lewis v. U.S., 65 F.3rd 257 (2nd Cir.

1995), and thus the instant appeal, is that of aggregation,

which asks whether a defendasit is entitled to trial by jury

when charged in a single proceeding with multiple offenses,

each of which is punishable by no more than six months

imprisonment, but for which the aggregate sentence could

exceed six months. Additionally, the Court has requested

that parties brief the question of whether or not a judge, by

2

promising not to give more than a six months aggregate

sentence, can deny jury trial for otherwise jury-demandable

offenses.

The Second Circuit in Lewis initially answers the

aggregation question by holding, without benefit of a citation

or other support, that it is obvious that Blanton focuses on

the seriousness of each individual offense. Lewis, 65 F.3rd 254.

This is a circular argument because the focus of the inquiry as

to seriousness is determinative of the result. The second

answer given by the Lewis Court to the aggregation question

is that, as the government could have tried each offense

seriatim, aggregation in a single proceeding "provides no

greater justification for a jury trial than if the charges were

tried separately." Lewis, 65 F.3rd at 255. In order fora

defendant to raise the aggregation argument, he must accept

that some crimes are not triable by jury, i.e., those criminal

offenses carrying a penalty of six months or less. Having

accepted this initial premise, the seriatim argument is logically

unanswerable as the inherent non-jury character of these

offenses is not essentially altered by their aggregation in a

single proceeding.

The suggestion by the Court that would allow a bench trial

if the trial judge makes a pretrial commitment of a six month

aggregate sentence, also violates the logic of the seriatim

argument. Why should the government be forced to forego

the punishment authorized for each offense, merely because

they are aggregated? This is particularly true for offenses that

may be of a similar character, but do not arise out of the same

act or occurrence. F.R.Crim.P. 8(a); SCR-Criminal 8(a).

However, despite the logic of the seriatim argument, its

necessary consequences cannot be constitutionally accepted.

Lewis and other decisions denying jury trial for aggregated

offenses have focused on the seriousness of each individual

offense charged. Under the precedent of Blockburger v. U.S.,

284 U.S. 299 (1932), and its progeny, it is not a violation of

double jeopardy for the legislature to establish multiple

criminal offenses and multiple punishments for a single act.

The State may even constitutionally charge and punish for

both a greater and lesser included offense. Missouri v. Hunter,

459 U.S. 359 (1983). It is the legislature that determines the

3

unit of prosecution and therefore defines the offense. The

convergence of Blockburger and the denial of aggregation

allow for some startling results once we focus not on single,

statutorily separate offenses, but on the total sentence at issue

for all offenses in a single proceeding. This approach was

followed in Codispoti v. Pennsylvania, 418 U.S. 506, 517

(1973), the primary precedent used to support jury trial for

aggregated offenses.

In the District of Columbia, possession of unauthorized

ammunition is a misdemeanor. D.C. Code §6-2361. The

City Council could make this offense punishable by six

months imprisonment, rendering it non-jury demandable

under Blanton, and establish a single bullet as the unit of

prosecution. Thus a defendant found in unlawful possession

of a handgun with a twenty round magazine, a single act,

could be charged with twenty counts of possession of

unauthorized ammunition and convicted in a single bench

trial and be sentenced to ten years imprisonment. Any

discrete criminal act can result in an infinite number of

criminal offenses. Thus under Blanton, Blockburger and the

aggregation precedent articulated in Lewis, the legislature can

amend the criminal code and totally eliminate jury trial for

offenses punishable by imprisonment.

The Court has suggested that as a possible solution to this

problem, a judge could make a pretrial commitment to give

no more than six months imprisonment and still have a

bench trial for aggregated proceedings. This is not a logical

solution. It fails to address the seriatim argument. It does

look to the total imprisonment imposed, but fails to consider

the consequences of multiple convictions. It forces the trial

judge to determine the maximum sentence before hearing the

evidence in the case. The pretrial commitment rule would

also be fairly simple for the government to avoid. Rather

than formally aggregating cases they could be proceeded

against separately, but on the same day and in front of the

same judge, thus gaining much of the benefit of aggregation.

The offenses would be non-jury demandable and sentences

longer than six months could still be imposed for a single act.

The most serious danger in allowing a pretrial

commitment of no more than six months imprisonment is

4

that this precedent, like failing to aggregate, can be used to

eliminate trial by jury. There appears to be no reason why

this same rationale would not apply to all offenses. If the

trial judge promised to impose no more than six months

imprisonment, why should he not be able to deny jury trial

for a misdemeanor carrying a one year sentence or for a

felony for which the maximum punishment is ten or twenty

years imprisonment?

The dangers of refusing to aggregate offenses or permitting

a pretrial commitment are obvious and a statutory

interpretation that condones this precedent is obviously

flawed. The Constitution does not, and cannot, contain the

seeds of its own destruction; an interpretation of a

constitutional provision that destroys the constitutional right

embodied therein cannot be maintained. Yet the seriatim

argument is logically unanswerable. This seeming paradox

can only be resolved by transcending the aggregation

argument. The logical and practical difficulties revealed by

the aggregation problem can only be truly resolved by

returning to the plain language of the Constitution and

overruling the line of precedent that began with Callan v.

Wilson, 127 U.S. 540 (1888), and had its logical culmination

in Blanton. As this Court held in Duncan v. Louisiana,

",..our decisions interpreting the Sixth Amendment are

always subject to reconsideration.” Duncan v. Louisiana, 391

US. 145, 158 (1967).

Il. Inherent Nature versus Penalty

For the first century after the adoption of the

Constitution, this Court strictly interpreted the language of

the Sixth Amendment and Article Three requiring trial by

jury even in wartime. See Ex parte Milligan, 71 U.S. 115, 120

(1866) ("The Constitution of the United States is a is a law for

rulers and people, equally in war and peace, and covers with

the shield of its protection all classes of men, at all times and

under all circumstances.”) In Callan v. Wilson, 127 U.S. 540

(1888), this Court first articulated the concepts of "petty

offenses", i.e., non-jury demandable crimes, versus "serious

offenses”, i.e., jury demandable crimes, creating the "petty

offense exception" to the constitutional guarantees of jury

5

trial. The requirement that an jury demandable offense be

"serious" rather than a crime created an immediate conflict

between the plain language of the Constitution and Supreme

Court precedent. U.S. Const. amend VL; U.S. Const. art. I;

see also District of Columbia v. Clawans, 300 U.S. 617, 634

(1937) (MacReynolds & Butler, JJ., dissenting). The inquiry

into seriousness, however, still depended in the inherent

nature of the offense. Callan, 127 U.S. at 556. This Court’s

holding in Blanton v. City of North Las Vegas that it would no

longer inquire into the inherent nature of an offense very

clearly breaks with previous Sixth Amendment

jurisprudence. "...[O]Jur earlier decisions focused on the

nature of the offense and whether it was triable by jury at

common law." Blanton, 489 U.S. at 541. The statement that

"{iJn more recent years, however, we have sought more

‘objective indications of the seriousness with which society

regards the offense,” Blanton, 489 U.S. 541, and the citation

to Frank v. U.S., 395 U.S. 147, 148 (1969) are misleading.

Frank was a contempt case and contempts were not triable by

jury at common law. Cheff v. Schnackenberg, 384 U.S. 373,

380 (1965) (criminal contempts by nature not jury-

demandable). The reliance of the Frank Court on the

"objective indications” precedent cited in District of Columbia

v. Clawans, 300 U.S. 617 (1936) is also misleading. While

precedent is occasionally obscure, Clawans is an example of

pre-Blanton precedent that held that the inquiry into the

objective indications of seriousness, predominately the

penalty authorized or imposed, did not take place until a

court determined that an offense was inherently petty and

not of a criminal nature. In Clawans, which concerned the

offense of selling second hand property without a license, this

Court noted that this offense was not indictable at common

law and held that its moral quality was inoffensive. Clawans,

300 U.S. at 625. But the Clawans Court refused

...to foreclose consideration of the severity of the

penalty as an element to be considered in determining

whether a statutory offense, in other respects trivial and

not a crime at common law, must be deemed so serious as

to be comparable with common law crimes, and thus to

6

entitle the accused to the benefit of a jury trial

prescribed by the Constitution.

(emphasis supplied) Clawans, 300 U.S. at 625. This principle

was affirmed in Duncan v. Louisiana, 391 U.S. 145 (1967),

where this Court held that "[cJrimes carrying possible

penalties up to six months do not require jury trial if they

otherwise qualify as petty offenses." (emphasis supplied)

Duncan, 391 U.S. at 159.

Thus, the unanimous decision in Blanton represents not an

adherence to or logical extension of previous precedent, but a

revolutionary departure. The use of the six month test in

Baldwin v. New York was a compromise, as several justices

were willing to agree that more than six months

imprisonment merited jury trial, but would not agree that

less than six months imprisonment meant that there was no

constitutional right to a jury. Baldwin v. New York, 399 U.S.

66, 74 (1969). Before Blanton and Baldwin, an inquiry as to

the maximum penalty imposed was a secondary test, only

resorted to for inherently petty offenses. This subsidiary test

has swallowed the primary criterion, the inherent criminality

or seriousness of an offense, just as the petty versus serious

distinction restricted the constitutional guarantee of trial by

jury for all crimes and the petty offense doctrine itself now

threatens the constitutional right to jury trial. Thus over a

century of Supreme Court jurisprudence addressing jury trial

for “petty” offenses has shown the natural tendency for any

exceptions to constitutional guarantees to grow and eliminate

the rights they ostensibly qualify.

Ill. Blanton and Plain Language

The confusion evident in petty offense jurisprudence was

and is necessary because Blanton is not just a departure from

precedent, but contrary to the plain language of the

Constitution. The Sixth Amendment provides that "[iJn all

criminal prosecutions, the accused shall enjoy the right to a

speedy and public trial, by an impartial jury..." U.S. Const.

amend VI. Article Three provides that "[t)he trial of all

crimes, except in cases of impeachment, shall be by jury...”

U.S. Const. art. III § 2. The Sixth Amendment and Article

7

Three are unequivocal, unlike the Seventh Amendment, these

provisions provide no exception to their clear commands.

Some jurists have acknowledged the truly revolutionary

nature of the Blanton six month penalty test. The Second

Circuit in Lewis stated that "[dJespite the absolute language of

the Sixth Amendment, the Supreme Court has made clear that

a jury trial is required only for those offenses that are

‘serious’ in nature; bench trials are sufficient for ‘petty’

offenses.” (emphasis supplied) Lewis, 65 F.3rd at 253-4. In his

dissent in Baldwin v. New York, Justice Black rejected the

“petty” or “serious” distinction,

The Constitution guarantees a right of trial by jury in

two separate places but in neither does it hint of any

difference between ‘petty’ offenses and ‘serious’

offenses... Thus the Constitution itself guarantees a jury

trial ‘{iJn all criminal prosecutions’ and for ‘all crimes.’

Many years ago this Court, without the necessity of

amendment pursuant to Article V, decided that ‘all

crimes’ did not mean ‘all crimes’ but meant only ‘all

serious crimes.” Today three members of the Court

would judicially amend that judicial amendment and

substitute the phrase ‘all crimes in which punishment

for more than six months is authorized’...Such

constitutional adjudication, whether framed in terms of

‘fundamental fairness’, ‘balancing’, or ‘shocking the

conscience’ amounts in every case to little more than

judicial mutilation of our written Constitution.

Baldwin, 399 U.S. at 74-5. This is the rule in the majority of

jurisdictions. Cato Institute lawyer Timothy Lynch notes

that "[a]pproximately thirty states already recognize the right

to jury trial in petty criminal cases." T. Lynch, Rethinking the

Petty Offense Doctrine, 4 KAN. J. LAW PUB. POL’Y 16 (Fall

1994).

Attempts have been made to justify the petty offense

exception. In Duncan v. Louisiana, this Court notes correctly

that some "petty" offenses were among those offenses tried

summarily under colonial and English practice before the

enactment of the Constitution. Duncan, 391 U.S. at 160.

The Court then holds,

So-called petty offenses were tried without juries both in

England and the Colonies and have always been held to

be exempt from the otherwise comprehensive language

of the Sixth Amendment’s jury trial provisions. There

is no substantial evidence that the Framers intended to

depart from this established common law practice.

Duncan, 391 U.S. at 160. This holding is the so called

"codification" argument and is erroneous. The codification

argument was first raised in Justice Frankfurter’s 1926

Harvard Law Review Article which asserts that the Sixth

Amendment cannot be taken literally and that the Founders

meant only to codify the existing practices of the colonies. F.

Frankfurter, Petty Federal Offenses and and the Constitutional

Guaranty of Trial by Jury, 39 HAR. LAW REV. 917-1015

(1926). The most substantial evidence that the Founders

intended to depart from English and colonial practice before

the Constitution is the clear language of the Sixth

Amendment and Article Three which make no distinction

between petty and serious offenses, but speak only of

criminal offenses and crimes. U.S. Const. amend. VI; U.S.

Const. art. III. It is notable that some state constitutions did

make explicit exceptions to the right to trial by jury. The

Indiana Constitution of 1818 states that, "in all criminal cases

except in petit misdemeanors, which shall be punished by

fine only, not exceeding three dollars...the right of trial by

jury shall remain inviolate.” S. Kaye, Petty Offenders Have No

Peers, 26 CHI. LAW REV. 257-8 (1959) . Similarly, the

Seventh Amendment makes an explicit exception to the right

to jury trial for civil cases. U.S. Const. amend. VII.

Because Callan focuses on the inherent nature of an

offense, its holding is not that all offenses tried without a jury

previous to the Constitution may now be summarily tried,

but that if an offense was tried summarily, this fact is simply

one indication that the offense may be "petty". English and

colonial practice was not based on the inherent nature of the

offense: "There was no unifying consideration as to the type

of criminal offense subjected to summary trial..."

9

Frankfurter, supra at 927. Despite the fact that some so-called

"petty” offenses continued to be tried summarily, previously

summary offenses were among those tried by jury after the

adoption of the Constitution. Tax frauds and excise offenses,

for example, were tried summarily by commissioners of

excise and revenue and justices of the peace. 4

BLACKSTONE, COMMENTARIES * 278. Summary

proceedings were appropriate, says Blackstone, because of the

necessity of collecting revenue and the convenience for the

Crown and defendants. 4 BLACKSTONE, COMMENTARIES

*278 These reasons, rather than assertions that tax fraud

was not a crime or was somehow "petty", account for the fact

that it was triable summarily.

Another error of the Duncan Court was the assertion that

summary trials were part of the common law. All English

summary trials occurred as a result of explicit parliamentary

authorization. See Schick v. U.S., 195 U.S. 65, 80 (1904)

(Harlan, J., dissenting). "Very gradually the legislature

ventured to make some offenses triable ‘upon examination’

by justices of the peace, that is to say, without a jury. This

was a serious break with common law tradition at several

points." T. PLUCKNETT, CONCISE HISTORY OF THE

COMMON LAW (5th ed. 1956) at 438. The most

authoritative statement of the status of summary trials at

common law is made by William Blackstone,

By a summary proceeding I mean principally such as is

directed by several acts of parliament (for the common

law is a stranger to it, unless in the case of

contempts)...But it has of late been so far extended, as if

a check be not timely given to threaten the disuse of our

admirable and truly English trial by jury, unless only in

capital cases... This change in the administration of

justice hath some mischievous effects...the extensive

power of a justice of the peace, which even in the hands

of a man of honour is highly formidable, will be

prostituted to mean and scandalous purposes...and from

these ill consequences we may collect the prudent

foresight of our ancient lawgivers who suffered neither

the property nor punishment of the subject to be

10

a ee REE ee ee ee ee ch ee ee ee eee RSE

determined by the opinion of any one or two men; and

we may also observe the necessity of not deviating any

further from our ancient constitution...

(emphasis supplied) 4 BLACKSTONE, COMMENTARIES *

277-9. Additionally, summary proceedings were most often

used to "...inflict divers petty pecuniary mulcts and corporal

punishment...for many disorderly offenses; such as common

swearing, drunkenness, vagrancy, idleness...” 4

BLACKSTONE, COMMENTARIES * 278. Precedent which

allowed a magistrate to order an offender whipped for

vagrancy, swearing or drunkenness is rather disreputable, and

is not persuasive precedent to support a modern denial of

jury trial.

Finally, the codification argument is flawed because it

ignores the fact that the Sixth Amendment does clearly

depart from colonial practice and gives greater protections

than were available under colonial practice and even under

common law. For example, under the common law, the

accused was not entitled to compulsory process for the

production of witnesses. T. Lynch, Rethinking the Petty

Doctrine, 4 KAN. J. LAW PUB. POL’Y 14 (Fall 1994).

The Sixth Amendment clearly makes compulsory process a

required constitutional right explicitly departing from

common law and colonial practice. U.S. Const. amend. VI.

The codification argument would render the Constitution a

nullity, as any provision that differed from the common law

or colonial practice would be eliminated despite the plain

language of the Constitution. The codification argument fails

because a constitutional interpretation that eliminates the

right it is meant to elucidate cannot be maintained. The

relentless logic of Justice Black’s dissent in Baldwin cannot be

overcome.

IV. Conclusion

Part of the rationale of Blanton appears to have been a

hope that a six month penalty standard would be simpler to

apply than the inherent nature test. Blanton, 489 U.S. 541-2.

Instead this Court is faced with the difficulties presented by

the aggregation problem and in addition, it appears that this

11

Court will be faced with numerous cases raising claims of

"serious" collateral consequences, e.g., U.S. v. Nachtigal, 113

S.Ct. 1072 (1993), due to the wide variety of non-

imprisonment penalties. It has not proven difficult to

approximate the standards imposed by the plain language of

the Constitution to Sixth Amendment rights other than jury

trial. See Argersinger v. Hamlin, 407 U.S. 25 (1972). As noted

earlier a majority of jurisdiction provide for jury trial for

petty criminal offenses, "In fact, of the ten most populous

cities in the United States, seven are currently operating

under a rule that gives the right to a jury trial in any case

where imprisonment is a possible penalty.” (emphasis supplied)

T. Lynch, Rethinking the Petty Offense Doctrine, 4 KAN. J.

LAW PUB. POL’Y 14 (Fall 1994). Certainly it is difficult to

accept a radical change in precedent that has the effect of

reducing such a vital constitutional right.

Amicus curiae would urge this Court to re-examine the

petty offense exception. To paraphrase Justice Scalia, for

good or for bad, the Sixth Amendment requires jury trial,

" and we are not at liberty to ignore it. To quote the

document one last time (for it plainly says all that need be

said): ‘in all criminal prosecutions; the accused shall enjoy the

right [to a speedy and public trial by jury].’" Maryland v.

Craig, 497 U.S. 836, 870 (1990) (Scalia, J., dissenting). Rather

than viewing jury trial as an impediment to the smooth

functioning of justice, amicus curiae urges this Court to

restore the jury to its proper function as the pre-eminent

guarantor of due process in the American judicial system for

*all crimes” and "in all criminal prosecutions".

Respectfully submitted,

THE JURY TRIAL GROUP

Colin Dunham Christopher Warnock

President, Staff Attorney, Jury Trial Group

District of Columbia Counsel of Record

Superior Court Trial 2900 Adams Mill Rd, N.W.

Lawyers’ Association Washington, D.C. 20009

600 F Street, N.W. (202) 234-6756

Washington, D.C. 20004

(202) 393-0123