Amicus Curiae Brief — Stroud v. Shaw

} Bupreme Court, U.S.

ry FILED

JUN .2 7 1994

No. 93-1893

GFHCE-GEHE CLERK

In the

Supreme Court of the United States

October Term, 1993

*

C. 1. STROUD,

Fetitioner,

ws

DEBORAH SHAW, ef al.,

Respondents.

¢

On Petition For A Writ Of Certiorari

To The United States Court Of Appeals

For The Fourth Circuit

?

BRIEF OF THE STATES OF MARYLAND

ALABAMA, ALASKA, ARKANSAS, CALIFORNIA,

COLORADO, FLORIDA HAWAII, INDIANA,

KANSAS, KENTUCKY, LOUISIANA, MAINE

MINNESOTA, MISSISSIPPI, MONTANA

NEBRASKA, NEVADA, NEW HAMPSHIRE, NEW

JERSEY, NORTH DAKOTA, OHIO, PENNSYLVANIA,

SOUTH CAROLINA, SOUTH DAKOTA, UTAH,

VERMONT, VIRGINIA, WYOMING AND THE

COMMONWEALTH OF THE NORTHERN MARIANA

ISLANDS AS AMICI CURIAE IN SUPPORT OF

PETITIONER

*

9

J. JOSEPH CURRAN, JR.

Attorney General of Maryland

ANDREW H. BAIDA*

Assistant Attorney General

200 St. Paul Place, 20th Floor

Baltimore, Maryland 21202

(410) 576-6318

*Counsel of Record

[additional counsel] listed on inside cover]

JAMES H. EVANS

Attorney General of Alabama

State House

11 South Union Street

Montgomery, AL 36130

BRUCE M. BOTELHO

Attorney General of Alaska

P.O. Box 110300

Juneau, AK 99801-0300

WINSTON BRYANT

Attorney General of Arkansas

323 Center Street

Little Rock, AR 72001-2610

DANIEL E. LUNGREN

Attorney General of California

1515 K Street, Suite 1511

Sacramento, CA 95814

GALE A. NORTON

Attorney General of Colorado

1525 Sherman Street

Denver, CO 80203

ROBERT A. BUTTERWORTH

Attorney General of Florida

The Capitol, PL 01

Tallahassee, FL 32399-1050

ROBERT A. MARKS

Attorney General of Hawaii

425 Queen Street

Honolulu, HI 96813

PAMELA CARTER

Attorney General of Indiana

402 W. Washington Street

Fifth Floor

Indianapolis, IN 46204

ROBERT T. STEPHAN

Attorney General of Kansas

301 West Tenth Street

Judicial Center, 2nd Floor

Topeka, KS 66612-1597

CHRIS GORMAN

Attorney General of Kentucky

State Capitol

Room 116

Frankfort, KY 40601

RICHARD P. IEYOUB

Attorney General of Louisiana

Department of Justice

P. O. Box 94095

Baton Rouge, LA 70804-4095

MICHAEL E. CARPENTER

Attorney General of Maine

State House nate

Augusta, ME 0433

HUBERT H. HUMPHREY, III

Attorney General of Minnesota

State Capitol, Suite 102

St. Paul, MN 55155

MIKE MOORE ;

Attorney General of Mississippi

P.O. Box 220

Jackson, MS 39205

JOSEPH P. MAZUREK

Attorney General of Montana

215 North Sanders

Helena, MT 59620-1401

DON STENBERG

Attorney General of Nebraska

State Capitol

P.O. Box 98920

Lincoln, NE 68509-8920

FRANKIE SUE DEL PAPA

Attorney General of Nevada

198 South Carson

Carson City, NV 89710

JEFFREY R. HOWARD

Attorney General of New Hampshire

State House Annex

25 Capitol Street

Concord, NH 03301-6397

DEBORAH T. PORITZ

poss General of New Jersey

25 Market Street, CNO80

Trenton, NJ 08625

HEIDI HEITKAMP

Attorney General of North Dakota

State Capitol, 1st Floor

600 East Boulevard Avenue

Bismark, ND 58505-0040

RICHARD WEIL

Acting Attorney General of

the Northern Mariana Islands

2nd Floor, Administration Bldg.

Capito] Hill

Saipan, MP 96950

LEE FISHER

Attorney General of Ohio

30 East Broad Street

Columbus, OH 43266-0410

ERNEST D. PREATE, JR.

Attorney General of

Pennsylvania

Strawberry Square, 16th Floor

Harrisburg, PA 17120

T. TRAVIS MEDLOCK

Attorney General of

South Carolina

P.O. Box 11549

Columbia, SC 29211-1549

MARK BARNETT

Attorney General of

South Dakota

500 East Capitol

Pierre, SD 57501-5070

JAN GRAHAM

Attorney General of Utah

236 State Capitol

Salt Lake City, UT 84114

JEFFREY L. AMESTOY

Attorney General of Vermont

109 State Street

Montpelier, VT 05609-1001

JAMES S. GILMORE, III

Attorney General of Virginia

101 N. Eighth Street, 5th Floor

Richmond, VA 23219

JOSEPH B. MEYER

Attorney General of Wyoming

123 Capitol Buildin

Cheyenne, WY 82002

es

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i

QUESTION PRESENTED

Can an individual’s failure to supervise a subordinate

"cause" the deprivation of a right protected under 42 U.S.C.

§ 1983 when (a) the supervisory relationship terminated fifteen

months prior to the subordinate’s actions inflicting the

plaintiff’s injuries, and (b) the subordinate’s current supervisor

is found not liable under § 1983?

ii

TABLE OF CONTENTS

QUES IIe PRED 6 6 6 6 ee sae ne ee am

INTEREST OF AMICI CURIAE

AND INTRODUCTORY STATEMENT ..........

REASONS FOR GRANTING REVIEW ..........

THE DECISION BELOW CONFLICTS WITH

APPLICABLE DECISIONS OF THIS COURT

IN IMPOSING SUPERVISORY LIABILITY

DESPITE THE LACK OF ANY

AFFIRMATIVE LINK BETWEEN’ THE

SUPERVISOR’S ACTIONS AND THE

ae rere ee eee

eee ee Cee ee Cee eee eS

CASES:

ili

TABLE OF AUTHORITIES

Page

Bivens v. Six Unknown Named Agents

of Federal Bureau of Narcotics,

GBS U.S ee a ow 6 ees 4,7

Canton v. Harris, 489 U.S. 378 (1989) .. 5,8,9,10

Carlson v. Green, 446 U.S. 14 (1980) ....... 7

Collins v. Harker Heights,

TAS BA. Fe ce eee es 5

Farmer v. Brennan, 62 U.S.L.W. 4446

(OR Re eer ee ee ere ae 7,9,11

Haynesworth v. Miller, 820 F.2d 1245

Oe ie os Se ce ee ke O 3,11

Jett v. Dallas Independent School District,

Ore TEs ee a 6 ae ee 8 6

Martinez v. California,

O06 TER. Br ee 8 ew eee es 3,6,10

Monell v. New York City Dept. of Social

Services, 436 U.S. 658 (1978) ........ 4,5,11

Oklahoma City v. Tuttle,

ig Q's & 2°. : Sanaa amar aree 5,8

Palsgraf v. Long Island Railroad Co.,

248 N.Y. 339, 162 N.E. 99.0928) ...... . «0 8

iv

Pembaur v. Cincinnati, 475 U.S. 469 (1986) .. 5,8

Polk County v. Dodson, 454 U.S. 312 (1981) .. 5

Rizzo v. Goode, 423 U.S. 362 (1976) ... 6,10,11

Springfield v. Kibbe,

ke ok er er ey ee 5,8,9

St. Louis v. Praprotnik,

Cae Uae ERe CUR eo ee dis eeu hoe 4,9

CONSTITUTIONAL PROVISIONS, STATUTES, AND RULES:

U.S. CONST.

Pe ec. 4 0 6% 6h ale Det eee 5

Se WE 8 0.2 os sea ee eee 79,11

GS Wide eS ee so 6 8 ie oe Ce passim

Sas SOE cc ka cutetew mars 2,3

ak eer ee rer recy Ee eo ee 1

MISCELLANEOUS:

Restatement (Second) of Torts (1965) ..... 9,10

In the

Suprenie Court of the United States

October Term, 1993

«

No. 93-1893

s

C. I. STROUD,

Petitioner,

Vv.

DEBORAH SHAW, et al.,

Respondents.

.

On Petition For A Writ Of Certiorari

To The United States Court Of Appeals

For The Fourth Circuit

«

BRIEF OF THE STATES OF MARYLAND

ALABAMA, ALASKA, ARKANSAS, CALIFORNIA,

COLORADO, FLORIDA, HAWAII, IND :

KANSAS, KENTUCKY, LOUISIANA, MAINE,

MINNESOTA, MISSISSIPPI, MONTANA

NEBRASKA, NEVADA, NEW HAMPSHIRE, NEW

JERSEY, NORTH DAKOTA, OHIO, PENNSYLVANIA,

SOUTH CAROLINA, SOUTH DAKOTA, UTAH

VERMONT, VIRGINIA, WYOMING AND THE

COMMONWEALTH OF THE NORTHERN MARIANA

ISLANDS AS AMICI CURIAE IN SUPPORT OF

PETITIONER

S

Pursuant to Sup.Ct.R. 37, the twenty-nine (29)

signatory States and the Commonwealth of the Northern

Mariana Islands respectfully submit this brief as amici

curiae in support of petitioner.

2

INTEREST OF AMICI CURIAE

AND INTRODUCTORY STATEMENT

This case presents important questions concerning

the continuing liability of government officials for civil

rights violations that former subordinates commit long

after the termination of the supervisory relationship.

Review is warranted to clarify the circumstances in which

individual government officials may be held liable in

damages for the acts of their supervisees.

In holding that a supervisor may be responsible

under 42 U.S.C. § 1983 for a former subordinate’s

actions that occur fifteen months after the supervisor’s

transfer, the Fourth Circuit applied a tort theory of

causation that imposes substantial social costs at the

expense of effective and efficient government. That

decision is of major significance to the states because it

represents an unprecedented expansion of civil rights

liability for state and local government officials, threatens

the core of the states’ ability to dispatch their own

internal affairs, and implicates fundamental principles of

federalism.

The civil rights claim in this case hinges on

whether a supervisor can "cause" an individual to be

deprived of his rights protected under § 1983 solely by

failing to supervise a subordinate whose actions fifteen

months after the superviser’s departure form the basis of

the § 1983 claim. That issue involves "an important

question of federal law which has not been, but should

be, settled by this Court," Sup.Ct.R. 10.1(c), as this

Court has never directly addressed the scope of individual

supervisory liability under § 1983. Moreover, the Fourth

Circuit has decided this federal question "in a way that

conflicts with applicable decisions of this Court,"

3

Sup.Ct.R. 10.1(c), as this Court’s rulings in the related

contexts of municipal liability and Bivens actions suggest

strongly that there must be a direct affirmative link

between a supervisor’s inactions and the injury

complained of for liability to attach. No such causal

connection can exist when, as in this case, the ability to

supervise the acts of another ends months before the

conduct giving rise to the claim. Indeed, this Court has

previously recognized that the passage of an even shorter

period of time than the fifteen month lapse in this case

rendered an injury too remote with respect to the previous

actions of state officials for purposes of imposing § 1983

liability. See Martinez v. California, 444 U.S. 277, 284-

85 (1980). No constitutionally sound reason exists for

applying a different theory of causation when addressing

the connection between the alleged inactions of

supervisory state officials and a plaintiff's injury.

In the absence of any controlling Supreme Court

case, the federal appellate courts have adopted a variety

of approaches, which are not altogether consistent, in

attempting to resolve the issue of individual supervisory

liability under § 1983. See, e.g., Haynesworth v. Miller,

820 F.2d 1245, 1260-62 and notes 123-133 (D.C. Cir.

1987) (citing cases). One of those courts -- the Fourth

Circuit in this case -- has now decided that issue in a way

that seriously tests this Court’s past observation that "it is

perfectly clear that not every injury in which a state

official has played some part is actionable under that

statute." Martinez v. California, 444 U.S. at 285. This

Court should grant review to address the circumstances in

which individual government officials are to be held

responsible for the injuries that their subordinates inflict.

4

REASONS FOR GRANTING REVIEW

THE DECISION BELOW CONFLICTS

WITH APPLICABLE DECISIONS OF

THIS COURT IN IMPOSING

SUPERVISORY LIABILITY DESPITE

THE LACK OF ANY AFFIRMATIVE

LINK BETWEEN THE SUPERVISOR’S

ACTIONS AND THE PLAINTIFF’S

INJURY.

This Court has aever squarely decided the scope of

individual supervisory liability in the context of a civil

rights claim that is based on a government official’s

alleged deliberate indifference to a _ plaintiff's

constitutional rights. Nevertheless, the rationale of this

Court’s prior decisions in § 1983 municipal liability cases

and actions brought under Bivens v. Six Unknown Named

Agents of Federal Bureau of Narcotics, 403 U.S. 388

(1971), makes clear that an individual cannot be held

civilly liable for the injuries that a former supervisee

inflicts months after the supervisory relationship ends.

Section 1983 imposes liability if a person

"subjects, or causes to be subjected," another person to

the deprivation of a federally protected right. This Court

in Monell v. New York City Dept. of Social Services, 436

U.S. 658 (1978), held that this language does not "impose

liability vicariously on governing bodies solely on the

basis of the existence of an employer-employee

relationship with a tortfeasor." Jd. at 692. Indeed,

"vicarious liability would be incompatible with the

causation requirement set out on the face of § 1983." St.

Louis v. Praprotnik, 485 U.S. 112, 122 (1988). Rather,

liability attaches only when the conduct or policy

complained of is "the moving force of the constitutional

> thee Teele

5

violation. . . .". Monell, 436 U.S. at 694.

Consistent with its recognition that respondeat

superior liability is inapplicable in actions brought under

§ 1983, "the Court repeatedly has stressed the need to

find a direct causal connection between municipal conduct

and the constitutional deprivation." Springfield v. Kibbe,

480 U.S. 257, 267 (1987) (O’Connor, J., dissenting),

citing Oklahoma City v. Tuttle, 471 U.S. 808, 824-25,

n.8 (1985); Polk County v. Dodson, 454 U.S. 312 (1981).

In Pembaur v. Cincinnati, 475 U.S. 469 (1986), for

example, the plurality held that the municipal defendant

could be held liable for the policymaking decision of the

county prosecutor because that decision "directly caused

the violation of petitioner’s Fourth Amendment rights."

Id. at 484. Similarly, in determining whether a

municipality may be held liable for deficiencies in the

training of its personnel, this Court has insisted that

"(t]here must at least be an affirmative link between the

training inadequacies alleged, and the particular

constitutional violation at issue," Oklahoma City v. Tuttle,

471 U.S. at 824 n.8, and emphasized that "the identified

deficiency in a city’s training program must be closely

related to the ultimate injury." Canton v. Harris, 489

U.S. 378, 391 (1989) (emphasis added).

In subsequently explaining its rationale in these

decisions, this Court stated that "[i]t was necessary to

analyze whether execution of a municipal! policy inflicted

the injury in these cases because, unlike ordinary tort

litigation, the doctrine of respondeat superior was

inapplicable. The city . . . is only liable when it can be

fairly said that the city itself is the wrongdoer." Collins

v. Harker Heights, 112 S.Ct. 1061, 1067 (1992). The

common thread found throughout this Court’s municipal

liability decisions, therefore, rests on the notion that

6

liability under § 1983 does not attach unless a clear causal

connection exists between particular policies or actions of

a governmental body and the constitutional injury at

issue.

While these cases each addressed the circumstances

in which a local governmental body may be held

responsible for civil rights violations that one of its

employees commits, the same causation principles would

seem to apply when a plaintiff seeks to impose civil rights

liability on individual government officials sued for

injuries that their subordinates directly inflict, particularly

since, as this Court has observed, "we have rejected

respondeat superior as a basis for holding a state actor

liable under § 1983... ." Jett v. Dallas Independent

School District, 491 U.S. 701, 736 (1989) (emphasis

added). Past decisions of this Court in analogous settings

suggest as much.

In Rizzo v. Goode, 423. U.S. 362 (1976), for

example, this Couft reversed the award of § 1983 relief

against supervisory officials when "no affirmative link"

was made connecting any specified policies or acts of

those officials to the police misconduct that directly

caused the plaintiffs’ injuries. See 423 U.S. at 371.

Similarly, in Martinez v. California, this Court held that

state officials did not "deprive" a 15-year-old girl of her

life when she was murdered by a parolee five months

after his release, because her death was "too remote a

consequence of the parole officers’ action to hold them

responsible under the federal civil rights law." 444 U.S.

at 285. These cases, particularly when they are

considered against the backdrop of this Court’s municipal

liability decisions, reflect the understanding that a state or

local government official cannot be held liable for the

constitutional torts of a subordinate in the absence of a

—————

——————E———— rer errr _

7

strong connection between the official’s action (or

inaction) and the plaintiff's injury.

This Court’s decisions in damages actions alleging

unconstitutional conduct by federal officials, see, ¢.g.,

Bivens v. Six Unknown Named Agents of Federal Bureau

of Narcotics, 403 U.S. 388 (1971); Carlson v. Green,

446 U.S. 14 (1980), demonstrate that, if anything, the

standard of liability is higher when suit is brought against

individual officials as opposed to a governmental body.

Indeed, this Court just held that the objective deliberate

indifference standard set forth in Canton v. Harris, while

appropriate "for the quite different purpose of identifying

the threshold for holding a city responsible for the

constitutional torts committed by its inadequately trained

agents," does not apply when determining the liability of

individual prison officials under the Eighth Amendment.

Farmer v. Brennan, 62 U.S.L.W. 4446, 4450 (U.S. June

6, 1994) (quotations and citation omitted). Rejecting the

argument "that a prison official who was unaware of a

substantial risk of harm to an inmate may nevertheless be

held liable under the Eighth Amendment if the risk was

obvious and a reasonable prison official would have

noticed it," id. at 4450, the Court instead stated that no

such liability exists "unless the official knows of and

disregards an excessive risk to inmate health or safety;

the official must both be aware of facts from which the

inference could be drawn that a substantial risk of serious

harm exists, and he must also draw the inference." Jd. at

4449.

The Farmer decision, while postdating the Fourth

Circuit’s decision in this case, is the latest in the long line

of cases discussed above in which this Court has

recognized -- tacitly or explicitly -- the high threshold that

a plaintiff must meet in order to obtain monetary relief

8

against a government official. The court of appeals in

this case, however, rejected the dominant theme of these

cases by applying a substantially more relaxed theory of

"but for" causation and holding that despite petitioner’s

transfer fifteen months before respondents’ decedent’s

injury, that injury "was a natural and foreseeable

consequence of [petitioner’s] failure to investigate, or

even to address, the pervasive violent propensities of one

of his officers." App. at 16. That tort theory of

causation is in conflict with this Court’s decisions and is

inapplicable in a federal civil rights action.

"The ‘causation’ requirement of § 1983 is a matter

of statutory interpretation rather than of common tort

law." Springfield v. Kibbe, 480 U.S. at 269 (O’Connor,

J., dissenting). While the liability theory that the

majority opinion below applied may suffice under state

tort law principles, see, e.g., Palsgraf v. Long Island

Railroad Co. , 248 N.Y. 339, 162 N.E. 99 (1928), it falls

far short of what the federal civil rights statute requires

because establishing that a failure to supervise "was the

‘cause’ of constitutional injury at issue . . . entails more

than simply showing ‘but for’ causation." Canton v.

Harris, 489 U.S. at 393 (O’Connor, J., concurring and

dissenting in part). See also Pembaur v. Cincinnati, 475

U.S. at 482 n.11 ("Although [in Oklahoma City v. Tuttle]

there was no opinion for the Court on this question, both

the plurality and the opinion concurring in the judgment

found plaintiff's submission inadequate because she failed

to establish that the unconstitutional act was taken

pursuant to a municipal policy rather than simply

resulting from such a policy in a ‘but for’ sense.")

(emphasis in original).

At a minimum, a government official’s inaction in

the face of a subordinate’s wrongful acts "subjects, or

9

causes to be subjected," a plaintiff to the deprivation of a

right under § 1983 only when it is "so obvious" and "so

likely" that the inaction will "result in the violation of

constitutional rights. . . .". Canton v. Harris, 489 U.S.

at 390. See also Farmer v. Brennan, 62 U.S.L.W. at

4450 (holding in the Eighth Amendment context that

liability exists only when the official has "failed to act

despite his knowledge of a substantial risk of serious

harm."). But in light of the fifteen month gap between

petitioner’s transfer and his former subordinate’s actions,

to hold that petitioner’s past omissions "constituted the

‘moving force’ in bringing about the [subordinate]

officer’s unconstitutional conduct, notwithstanding the

large number of intervening causes also at work up to the

time of the constitutional harm, appears to be largely a

matter of speculation and conjecture." Springfield v.

Kibbe, 480 U.S. at 268 (O’Connor, J., dissenting).

Simply put, if the unlawful acts in this case confer

liability upon petitioner, "the result would be

indistinguishable from respondeat superior liability." St.

Louis v. Praprotnik, 485 U.S. at 126.

Even analogizing to traditional tort principles

shows the lack of any causal connection between

petitioner’s alleged omissions and the death of

respondents’ decedent. The Restatement (Second) of

Torts § 452(2) (1965) provides that "[w]here, because of

lapse of time or otherwise, the duty to prevent harm to

another threatened by the actor’s negligent conduct is

found to have shifted from the actor to a third person, the

failure of the third person to prevent such harm is a

superseding cause." The Fourth Circuit noted that

following petitioner’s transfer, several individuals

informed his successor about his former subordinate’s

past and continuing use of excessive force against

arrestees. App. at 8-9. Under the Restatement, that

10

successor’s failure to act, which the court of appeals held

did not give rise to any § 1983 liability, App. at 17-18,

constitutes "a superseding cause, which will relieve the

original actor of liability." Restatement (Second) of Torts

§ 452, Comment f, p. 490.

Observing that "[p]roximate cause is a regrettably

imprecise concept," Judge Hall in his dissenting opinion

below nevertheless concluded that "§ 1983’s ‘affirmative

causal link’ rapidly deteriorates with passage of time,

especially where a new, self-sufficient impetus for the

eventual injury develops." App. at 29. As in Martinez

v. California, respondents’ decedent’s death, occurring so

many months after petitioner’s transfer and his subsequent

replacement with a new supervisor, was "too remote" a

consequence of petitioner’s prior inactions to hold him

responsible under § 1983. 444 U'S. at 285.

As this Court has aoted, "[t]o adopt lesser

standards of fault and causation would open municipalities

to unprecedented liability under § 1983." Canton v.

Harris, 489 U.S. at 391. The Fourth Circuit’s decision

has equally far-reaching ramifications that "implicate

serious questions of federalism." Jd. at 392. It

significantly broadens the liability exposure of state and

local government officials by holding them accountable,

utilizing a state tort law theory of causation, for actions

that occur long after these officials surrender authority

over the person whose conduct provides the basis of the

§ 1983 claim. That causation analysis greatly erodes "the

well-established rule that tue Government has traditionally

been granted the widest latitude in the dispatch of its own

internal affairs," Rizzo v. Goode, 423 U.S. at 378-79

(quotations omitted), and it does so without advancing any

legitimate purpose. |

11

The reason for holding a government official liable

for constitutional wrongs caused by a failure to supervise

"is bottomed on the principle that in some contexts failure

of an official to safeguard against constitutional

transgressions by those under his control constitutes an

actionable wrong. . . ." Haynesworth v. Miller, 820 F.2d

at 1259-60 (emphasis added). Cf. Monell v. Dept. of

Social Services, 436 U.S. at 694 n.58 ("By our decision

in Rizzo v. Goode, . . . we would appear to have decided

that the mere right to control without any control or

direction having been exercised and without any failure to

supervise is not enough to support § 1983 liability.").

See also Farmer v. Brennan, 62 U.S.L.W. at 4453

(suggesting that individual prison officials may be entitled

to summary judgment on remand if they can show they

had "no direct responsibility" over or "power to control"

conditions giving rise to inmate’s Eighth Amendment

claim). Under the Fourth Circuit’s analysis, however, an

official may be held monetarily liable under § 1983 for

the acts of a former subordinate despite the lack of any

control over that individual.

This case thus presents substantial issues that are

of great importance to state and local governments across

the. country. This Court should review the Fourth

Circuit’s decision, therefore, and establish the standards

that the lower courts are to apply when addressing the

issue of individual supervisory liability.

For the reasons stated, the petition for writ of

certiorari should be

*Counsel of Record

June 27, 1994

12

CONCLUSION

granted.

Respectfully submitted,

J. JOSEPH CURRAN, JR.

Attorney General of Maryland

ANDREW H. BAIDA*

Assistant Attorney General

200 St. Paul Place, 20th Floor

Baltimore, Maryland 21202

(410) 576-6318

Counsel for Amici States