# Petition for Writ of Certiorari — Bostic v. Ohio > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40385601_0948%3A2 ## Record - **Collection:** Supreme Court brief - **Document type:** Petition for Writ of Certiorari - **Published:** January 1, 1963 - **Citation:** 373 U.S. 932 ## Text IN THE e Supreme Court of the United States — Geasins Term, 1962, . 1012 i FRANK E. LIPP and BETTY FRIEDMAN, Executrix , of the Estate of Josepn Friepman, Deceased, .Petitioners, See . THE UNITED STATES. | ; } % aE = Petition for a Writ of Certiorari to the United States * Court of Claims April 11, 1968. .* Pd | - , Guy Emery ® Attorney for Petitioner’ P One Farragut Square South * Washington 6, D. C. ‘ Emery AND Woop Of Counsel : ¢ Washington, D. C.: @ ante THE REPORTER Company, INc., Walton, N. Y —UN 5-4131—1963 4 ~ mo, : ~ > Index. . c 5 . Page UI Bice ree et roche ins, Deeb deaat os aac 92 i ee ; NPA TIO on ncs ccs caso oonsnctene ene snease sSicatedatmae caer’ 2 Jurisdictional Statement. ' es ihe. : iil. nae Pree @ . DB - Kirtley wv. United States? C. Cis. No. 98-55 0006 ye oN Sisie Knight ve. United States, C. Cis.c No. 64-60, le- . cided January 18, 19617 ..02..\ oe... 6, 8, 21 Levadi v. United ee, aay, ' Cls. No. 260-60) ty ee Se q: . Lipp v. United States s, 301 F.-2d. 684 22... ER AAR . 222 * MacFarlane v. United States, 134 C. Cls. 755. 16 ~ Marshall vw. The Baltimore and Ohio. failroad ('o.., 16 How. 314, RR St Ree aaa csaantipbechgtqinnsseZtnten’ ‘S. Odell v. ae te 134 Cte Gee: ih Patterson v. United “ates, 141 0°. C's. 435 ._6,7,16, 18 Proper e. United States, IO CecCts. 511 : 6, 7. 16-18 Robinson v. United States, C. Cls. No. 433-59 2 s Rosnick v. United States, 132 €. Cis. 1 SO Tah a3 A, i) : _ San WNlan v. United States, 139 C, Cle 485. 6,16, 17, 1S Soukaras uv. United States, 135 C. Cl. 88. Sea an 16 Suter vv. United States, 1W39.C. Cls. 466 00. 6, 16-18, 20 Uhlen +. United States, 128 C. Cls. GOS 6, 14, 16, 17, 18 Wales rt ited States, 132 C. CY, THD : bi, 1 Walters vr. United States. C. Cls. aoe ee S cindy r. United States, 148 ©. Cls, 445 re Woodard v. United States, CCls, No. 190-60 . ; ‘. . e, STATUTES “ Administrative Proce@ure Act. 60 Stat. 245, 0 fe RE Renee encuemcaeen area, Rules 23(5), Revised Rules of Supreme Court of the United Stafes, 28 U. S. C. followin 69680... eek PC ete bese 2 Legislative Reorganization Act of 1946, 60 Stat.’ ee et ed Oe as 9,11, 19 28 U; S.C. §1DB5 (1) onan ecceeccseccideeeneeeeees fen Sep SENT aie 28 U. S. C. §2501 ............ eR Vee Act of October 25, 1951, 65 Stat. 699. 10 Us , : | SE Cae eee irtew 3, 10, 12, 5 19, 20 ' OTHER % Re 27 Comp. Gen. 709 (1948) ee at ome i 42 Washington Post, April 17, 1962, p. A16- EE “World Almanac, 1963 0... Jeet events oe 9 10 y H. R. 1181, House of Representatives, Committee ~ con Armed Services, May 15, 1951 [No. 21] ib | Sf UNARMED PCS Ae os i Gree, A ‘ A vi” Senate Report No? 788, p. 1, S2nd Congress, Session ..%....... Reet faltee Bee ret aT aee ee ae Bovep of tig STRODE NG se No. 449, S2nd Congress, Ist Session™: Tan ene me er ae ? ° “a € ® - 2 e s @ - & . : ° . & ° . = : a : s => We i a Ix THE aa oan Conrt of the Hnited States ctober Term. 1962 _ .® _ ' -. Frank FE. Lipp, and Berry | Executrix of the Estate of Jdseph Friedman, Deceased, Petrone wie cs) iP 74% 4 4rsz ; = . ‘ ° Your petitioners, Frank E’ Lipp and Betty Friedman, pray that a writ of certiorari issue to review the jude ements of the Pnited States Court of Claims, Washington, / * . D.-€.. in the. above-entitled aetions. : ~ * . | o « .% a s . ‘ 3 sg + » c e e — , = « ° e * ? b 8 \ > Opinions Below The opinions ef the Court below (Appendices A and B, infra, A1, A51) are reported, respectively, Lipp v. United _ States, at 30] F. 2d 684 (1962), and Friedman v. United States, at 310 F. 2d 381 (1962). Jurisdiction —,. The opinion of the court below dismissing the petition in Lipp v. United States, supra, was entered April ‘4, 1962 (A1); the order of thd burt overruling plaintiff's mo- tion for rehearing was entered on November 7, 1962 (A 50); and the order of the court: overruling . plaintiff's motion for reconsideration ‘was entered on, January 11, 1963 (A950). In. Friedman rv. United States, supra, the opinion of the court ee ae the petition was entered on November 7, 1962 (A951), and the order of the court overruling nlaintift’ motion for — Was entered. on January 11, 1963 (Appendix B, infra, A 92). Under tie practice of the United States’ Court of tain, there is no formal judgment ade litional to an opinion dis- missing a petition. The jurisdiction of this Court to re- view: decisions of the Court of Claims is invoked under 28. U. S.C. §1255(1). The review of these CASES OD CRY -tiorari to the United States Court’of Claims is sought in ° a single petition pursuant to Rule’ 23(5), Revised Rules . of the Supreme Court ‘of the Tnited States, 28 UL So. following 42680. Question Presented Whether an action in the United States Court of Claims begun well within the six years following an allegedly arbitrary, caprigious and unlawful denial of a claim timely” made to % ite for the Correetion of Military Records, a&. 3° ‘ - , . + =” . ee ts *e S 3 ee, a. established in a service department Miystaiit to at uA of Congress, WU. S.C. $1552 0495), and over which claim the said Correction Board has ckercised jnvisdi tion, is barred by limitations, 28 FL S.C. 2501 (AS), simply Because more than six years bate elapsed between the initial occurrence of the events with which the elais is concerned and the’ commencement of the onit in th Court. of Claims. . * - Statutes Involved & \ ™ The statutes imvolved, 5 UL S.-€. 1009, To ES. s1oo2 and 28 U.S.C. $2501, are set forth in Appendix ©, jufra (N 94). or . - ‘Statement of the Case a > Ph doth. petitioner Lipp and Josept Mriedman, decoasecd husband of petitioner Betty) Ayiedman, were non Reena: medical officers of the Army 2ghe United) State. who served on extended: active duty with thee \rmy dare: World War Hl. Both were in good health® when they entered upon ‘such duty. Both incurred disabiing physi al defects while serving, and incident to their extend active service, Both were relieved from active: duty. ne! for physical disability. and neither of them: has received any retirement: pay oy benefits as proyided by law fey service members who be®ome incapagitated for aetive diity in line-of duty, and incident to theif active duty, Joseph Friedman, prior to his relief from: active duty. met a number of medical boards and retiring boards, all of which found him untit: for weber al se vig and ore of which recommended , his retirement. The jst votirine board, however, found him “not permanently incapacitated for active duty at’ l that! time” and rocommended his Ve bb 4 ld s ° : re Be De sie - examination and revaluation after six months (451). For reasons which eannot now he established, this was not done (A 52). 2 ; ; In Lipp’s case, the petitioner suffered from multiple sclerosis, an incurable disease of the nervous system which is characterizes] by periods of exacerbation and remission, He exhibited symptoms while.on active’ duty whieh, in retrospec*, Were attributable to muitiple sclerosis but at the time were not correctly diagnosed, His tronble wa- not definitely identified until some two years after his relief from duty (A 15,25). When his: infirmit® Was dis- covered, he requested, but wasyrefused, permission to aj, pear before an Army Retiri fx* Boards to determine his entitlement fo retired pay (A 18. ak ; Applications were nile on behalf f both men, Lipp by himself and Joseph, Pigedman ly his widow and exee v trix, “Betty Priedman, io the Army Board for Correction of Military Records asking for correction of” their re spective records to. reflect: their retirement for’ physical disability and consequent entitlement to retirement pay and benefits. The Board denied both applications. Fach petitioner thereupon filed suit in the United States"Cour: of Claims claiming the retirement? pay whigh they had heen denied, alleging that such denial, on the part of the Atorrection Board, was arbitrary, capricious and nnlaytnal. Kaich suit was filed @ithin Six vears after the aitteei serhi trary and capricions action on the part of the: Correction Board, pursuant to the statute limiting actions in the Court of ¢ ‘laims to those filed within six vears after the claim has acerued, 28 U.S.C. 62501. The court below hoPever, held that hoth were time-barred, petitioner Fried- tnan’s having acerued in 1946 or 1947 (A. S8), and petitioner Lipp’s upon the refusal of the Department of the paged to grantshim an appearance hefore a Retiring Board i 1950 (XN 5). Both petitions in the comt helow were thére. a7 ra ie eee | ‘ _fore dismissed orm the ground that the aleged arbitrary, capricious and unlawful actions on the part of the Any Board for Correction of Military Records did iiet give rise to a cause Of action cognizable by the Court of Claims and that any cause’ of action petitioners §night have was barred by limitations (A 5753). . s ‘ - . Reasons for Granting the Writ : 7 1. The decisions of the court. helow. holding the peti tioners’ claims to be barred by limitations, are not’ only in direct conflict with a doctrine long established by. this Court, but with a multitude of 4t + In Eicks rv. United States, supra. at p. 926, Mr. Justice Reed (Ret.), sitting by designatior@ in holding that the action was not baryed by limitations, sdid, “This suit seeks recovery of salary for periods more than ‘six years prior to its institution” but the right: to recover is not. set up as a salary debt but arises, it is claimed. from the arbi- trary and capricious action of the Secretary of the Navy in refusing correction of plaintiff's record.” In Knight v. United States, C. Cls. No. 64-60, January 18, 1961, Madden, J... speaking Yor the unanimous court, denied: . . % : * 7 Ss le” the government's motion to digmiss the petition as bgrtred ° » ° ° _ e ° Ps by limitations, by reference to the court's earlier décision in a similar case in these terms: t Tn Furlong e, luited States, iss Crt. Cl. S45, S45, the court cited seven cases and then said; The principle of these @ases is first, jJurisdic- fet is canferred by Congress, not’ on this court, hutoon retiring boards and the Pecretaries of the three armed services, to decide ‘an officer's right to retirement for physical disability, and his con Jsequent right) to retires pay; second, it follows therefrom that we cannot acquire jurisdiction of such ‘a claim un@il after the Board and the Sec retary have acta. or failed or refused to act. and not then unless the board and the Secretary acted arbitrarily or capriciously or contrary to law: - third, sinee our jurisdiction could not B® invoked 2] until after the retiring board and the Secretary had acted, the statute of limitations on a suit: in this court did not ‘begin to run until they had ‘ aed, tourth, on a finding of arbitrary or other. wise unlawful action by the retiring board and Secretary, it is our duty to act in the place of the wiring hoard and? on a finding of disability. at the time f discharge, tothold an officer is entitled -to retired pay from: the date of his discharge. Since the deeRion of Furlong, the case of Proper vt. Uneted States. 139 Ct: Cl. 51: Friedman rv. United States, 141 Ct. Ci. 289: Patterson. Unitey States, 141.0%. Cl. doo >and Allin v. Casited Stake 5 No. 004.95, decided November 4, 1959, havet heen decided by this court. They all are in aceord with What was said in Perlova, supra.” Cleariy, petitioners submit, the decisions of the court below of which certiorari is sought herein are in conflict with the whole bodysof law heretofore established. not only by the decisions of this, court, but by those of the -court below. In fhese premises, petitioners respectfully submit that this court should resolve the conflict. : sd *s . a _— 8 e ‘ . ’ . The decis ions forswhich packs usutd is Hitste. inal if ree . jist aria. to thie plaintiffs - thea of (aims whi have filed their petitions and, in pomne instances, assumed the expensive burden of teial in relianceauh the series ‘of 4 contrary holdings, by that court. As this eaurt said ovey a century ago, there are no cases where an adhe rence to the - maxim’ of stare a ix so absolutery es: on al to the peace of .s0c iety is \Lhose . whic A afte vet retroae tive! thie jurisdiction of conits ag a The RBaltime San at Ohio Railrs oad ('v., 16 rOW, 4c 320 ( BSary, Petitions ~ submit that to deny he varihg of thetr efises to these | gants below on the grounds of a suddenly raised bar of limitations. which did not éxist before and ‘is unjustified At new, is equally tireenscionable,————___. Yet At least 25 plaintiff's who are, iv respect of limitations? — : ‘situated -simgglarly to _ titioners herelu-here het wetlons in the cour . “To go aground on the new barrier reef erectéd by the Pa ‘isions below ino these petitioners’ x eases.” Six of them have already borne the costs of trial ‘ a Court. Watters tint States, C. Cls. No. 315-59; Robmson r. Lnited States: 4 Cls. No. 435-59; "Heller ve United States, C. Cls. No. 15-60; Levadi v. United States, \. Cis, No. 260-60. Wood- ‘8ard v. United Sigtés, C. Cls. No. 190-60; Knight v. United States, C..Cls. No. 64,60. Petitioners submit thaf this Ts an intolerable injury to be inflicted .on litigants whose only lapse hes be®n that they relied on the law as the cou®t below had heretofore clearly and gmphatically stated it to be. ¢ 2 See Appendix D, infra. The office of the Clerk of®the Court has informally indicated that ali of the cases listed in Appendix |) - are-presently suspended, until 30 days “after final action on the instant petition. Many other, such cages, petitioners are advised and believe, ie he i formally or formally, before various Commissioners te) e > than 16,000,000 of our citizens served in our last major War, between 1941 and 1946. Prior to 1946. corrections in military and naval records could Ve made only wher authorized by a jprivate bill enacted by Congress.) tu order to obviate ‘the consice ration of a substantial number of such bills subsequent to World War Hl, Section 207 of. the Legislative Reorganization Act of 1946 (60 Stat. Siz, S37) provided for the correction of military and naval! records by board= of civilian officers or emiplovees of thie respective service departments. By 1951, stich boards yore) ~ guet. Act of Aurust J. 1946, 60 Stat sv, Os7 lhid é a ’ ; | ; e a ‘ . . % The effort on Congress’ part was well-intentioned but did not prove very. fruitful. Shortly after the Board- were established the Comptroller General rendered at épiniow to the effect that “neither Section 207 nor othe? legislation vests in the hedds of the specified, department- or in this Office-any authority to * °° funds to pay any-ciaim for money, based on corre tian made in the military or naval records of an. individual nunc appropriated under the authority of that section.” Congress thereupon proceeded; in 1951, to amend the Act to provide the needed autbority."” During the hearings on the proposeds amend. “ ment, it was brought clear!y and unmistakably to the at- tention of the subcommittee of the House of, Representa- _ tives that certain agencies of the government, the Genera! Accounting Office as well as the service departments. would have preferred that the act, as amended, should specifically preclude review of Correction Board dec: sions by the .courts. The committee’ rejection of the suggestion was emphatic. dhe following is atypical passage :" “Mr. Deyle: I never like to see the right of the court to review any board abrogated. whatever the board is. Mr. Baier [representing the Department of De- fense|: I think that provision is to prevent a lot of these little cases from going to court and wasting the court’s time where the Department has the rec- ord and they try to dssemble the data. ° Mr. Clemente: Unfortunately the word was ‘wast- ing a court’s time.” | don’t think it ix properly put because the courts are there for that specific reason. Mr. Baier: I will take that back. It will save «27 Comp, Gen. 709 (SEF. > i Act of October 25, 1951, 65 Stat. 655, 10 U.S.C. $1552. ‘© Hearings Before a Subcommittee of the House Committee on Armed Services on H.R. 1181, 82d Cong., ist Session, pp. 376, 392. 8? : yd Ibid, p. 392. ‘ a—— He Pay % : : 13 ; >. 2 Mr. Doyle: IT may observe from a quarter of ¢ century, of a law practice before the court that fread. is pretty diffe te-prove atid seten-you say, except when procured: by means of fraud, you are” prac- ticaliy eliminating an applicant making a meritori- otis ‘showing’ before a Federal court. If there is going to fe any wording, I certainly favor the in- clusion of ‘mistake’ on a broader ground, so that at all times the applicants have the right, if they have the money, to go fore a court and protect their rights. ; ° And the fact that vou have reconsidered case- where there has been supplementary, evidence in itself shows that there might well) be many cases . which might well go before the courts.” If its ee the full Coyunfitter ou Armed Services merely stated : “On page 3, lines 11 and 12, the committee has deleted the words ‘including a review by the courts te of the U nitedg States ~ since it is of Phe opinion that the courts of the United States.should not be pre- cluded from review?tg such cases under appropriate circumstances.” ; It would scarcely seem necessary to belabor this point to such an extent since the court below, in jt comprehen- sive and thoroughly well-reasoned nei in Friedman e. United States, 14mC. Cle. 289, 259 41958), seemed to have setfled the question, if atv existed, as to the intent” et Congres~ in these Terms: ; e "We conclude that Congres- had no intention, in enacting the correction board legislation, of with- holding from this court jurisdiction to render a mogey judgment for pay of which a claimant. is deprived by reason of the arbitrary or illegal action of a correction board *°* *" ~» Notwithstanding, the court, below, in ap appendix at- iached to itfrom service not for physical disability. 7AIF were suits for ealisability retirement, pay. The court’ pronouncements on the matter of? limitations were these: ad Suter (holding): 4 ae. & © Our decision is that the plaintiff, when he Was released from, the Army in 1946, had a total and permanent service-connected disability, Lf the Physical Evaluatio® Board in 1951, or the Board for the Correction of Military. Records in 1954 thad so decided, and the decision had been * officially approved, the plaintiff would have received his retired pay from the date of his release in 1946. Since his eanse of tion is based upon the failure of the first of those tribunals to decide his case at all, or upon the failure of the second to degide the case upon the evidence, we must decide the ease as we think thee should have decided it, and With like effect.” : San Millan (dicta): oF a it has long been held that. this court: has - jurisdiction to render judgment for the pay which was denied the claimant by the arbitrary or eapri- cious actions of the adininistrative agency of the Government. Dismuke v. Uuited States, 297 U.S. 167; Uhley ve United” States, 137 ©. Cls. 275; Gordon «. United “States, 129 Cr Cis. 270; Suter vr. Conited States, decided this day, ante, p. 466." Proper tholding) : eee * 8 As we said in our recent decision in the ease of John @ Furlong v. United States, 138 ©. (ls. 843, this court acquired jurisdiction of a,elaim for disability retired pay = --* *.* Sifter the * * * Secretary * * * acted, or failed or refused to act * * © arbitrarily or 7 *“* * capri: ously or contrary to law; ts Friedman (holding) : 2 see ay! Nes é. - ak = . ; ‘Accordingly, we hold that plaintiff” s clain® based on the-alleged arlitrary action of the Secretary of the Army is not barred by the statute of’ jimitations.” _ . ‘ mt “In a number of recent decisions by this court it has been held that a cause of action for disability retired pay accrues, when the Secretary or a Cor- rection Board arbitrarily, caprieously and con- trary to law denies such application. Furlong v. Unified States, 138 C. Cls. 843;,.San Millan v. United States, 139 C. Cls. 485; Proper v, United States, 139 C. Cls. o11. This event in plaintiff's case took’ place in 1954.- We are of the opinion that whether plaintiff's cause of action accrued in 1952) when the Air Foreée’ erroneously failed to retire him according to the findings and geo oer age of the Physical Evaluation Board, in 1954 when the (Correction Board denied Sie ‘abn ition, his claim is not barred Wy the statute of limitations. Fi Patterson (holding) : ? “With respect to the defendant's eontentior “that the plaintiff's claim is barred by the six-year Stat- ute of limitations, this court has held that where a plaintiff has received no determination of his eligibility for disability . retirement pay by .any board until the correction board has acted, ‘his cause of action accrues not at the time of his‘separa- tion from the service, but at the time of the al- , leged wrongful action “of the correction. board, ay)- : proved. by .the Secretary, in wrongfully - refusing tor correct the records and grant the plaintiff dis- v ability retirement with pay. Uhlew v. United States, 128 C. Cls. 608: Furlong v. Uniteds States, 138 C. Cls. 843: Proper v. Uhited States, TRY C. _ 511; Friedman v. United States, supra; Suter United States, supra, Accordingly, we conclude that the claim stated herein is not barred by the statute of limitations.” . oe nF tia “419 Finally, in Kicks ¢. United States, 140 C. Cls. a22 (1959), through Mr. Justice ‘Reed, sitting by designation, the court stated the doctrine filly and, it Was thourht, once and for all. Gludge ‘Laramore dissented for other rea- ons.) The court » 1 1946, based Apon an allegation of” arbitrary and) capri- cious action by a Correction Board i 1956, ten years later. In Frederick v. United States, ©. Cls. No. 111-56, decided July 15, tines the Court adhered to the estag- lished doctrine, although recovery was limited. to pay due for the peryod of six years prior to the filing of the petition, Judges Whitaker and Larfimore Flissented Judge Whitaker, hawever, stated’ that “In all of these cases, the question for our determination is whether or not the actfux of the Seeretars is arbitrary or capricions or not suppotted by” substantial evidenee.” ; Finally t) urt below came to Auight ve. United States, . Cls. NoS 64-60, which has been discussed to some ex- tent above.’ In this case, the unanimous court would appear to have stated its position in the clearest, most ainequivocal and definitive terms at its command: 4 _ “The Governnignt’s motion is based entirely upon the statute of limitations. It raises no other issue. The contention is that the piaingiffs cause of action. if he has one, accrued at The time of his release from active duty in TAT: that “that ocenurred more = than six vears before@he filed his petition in this court, erge, the elaim is barred by limitation. This comtention assumes that Congress, in enact- ing in W446 and aamending in 1951 the statute authorizing the establiszhment of boards for the correction of military reeords, intended to create no leval rights but merely to lodve an arbitrary nneontrolled power in the Secretaries to correct records or refnse to correct records iis they hisipy- pened to feel like doing. th The assumption is net sound. That kind of raw nower tmeontroll@l by law conld only be conferred he the most express and emohatie language. We have repeatedt: held that the Seeretaries and their honres for the correction of records must base their: decisio@® unon substantial evidence, and are not privileged. to make arbitrary and capricious deeisjans.” -—-——_— + < ° See p. 7, supra. . ‘ 2 : . Notwithstanding,’ the court below has iow abandoned that position for no apparent reason.» demonstrated above, the attempt by the court in petitioner Friedman's case to rationalize ite @hift does not accord with either the facts or the law. Nn Lipp. supra, the court's holding is that resort to the Correction Boards 1s merely per- missive and such resort does pot tol! the limiting statute, something which was neve in issue. The opinion in Friedman, supra, is squavely to the coutrary, holding, apparently, that resort to some board will activate the’ statute, whether a Correction Board or a Retiring Board. To perplex the situation beyond tepair, the court below, on the same day, allowed recovery in Harper v. United States, ©. Cls. No. 206-59, decided* November 7, 1962, although 15 years had elapsed between the beginning of the period for which he was granted: retirement pay and the institution of his suit, aye only intervening board having been the Correction Board which had denied_his application a year before the filing of his -petition.** Petitioners submit thai, amidst such confusion, all that can he fairly said i is that the real issue upen which this petition turns is simpix whether or not the members of the Armed Forces have the right, upon an arbitrary and capricious action by a Correction Bogrd, to the judicial review of such an action that Congress iitended to pr. vide, and which is in accord with the doctrine long estab- lished, by this court and followed, hitherto, by a multitudg of cases in the same court to which certiorari is sought. Petitioners submit that they, in company with the mil- lions of other men and women in uniform, have the right to such review by gue process of law. Military forces depend upon morale Sy as much as upon equipment and “training. Nothing can Be more destructive of that morale, and more foreign to our concept of justice, than the cee of this fundamental right. 23 See, alsu, the 2pparent holding in Friedman, supra, that resort to the Correction Board is mandator) in some instances. A 68. ; ’ . ; e - » . & Conclusion . or the forecoin’ reasons, this petition for certiorari to the United States Court of Claims should be granted. Respectfully submitted, (ivy Emery ° eas is lttorney for Petitioners One Farragut Sqfiare South . Washington ee | et be f, VERY AND Woop : ig fit (Counsel = . é © % ® o < - 2 2 : 7 Pp ¢ ae 2 & a - Fe ° --- Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40385601_0948%3A2. Public record. Not legal advice.