# Amicus Curiae Brief — Wilkinson v. Flagner

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URL: https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40386014_2349%3A4

## Record

- **Collection:** Supreme Court brief
- **Document type:** Amicus Curiae Brief
- **Published:** January 1, 2001
- **Citation:** 534 U.S. 1071

## Text

‘ey | Supreme Court, U.S.

FILED
No. 01-324 SEP 24 200!
In the
CLERK

Supreme Court of the United-States—

Reginald A. Wilkinson, et al.,
Petitioners,
v.

Hbrandon Lee Flagner,
Respondent.

On Petition for a Writ of Certiorari to the
United States Court of Appeals for the Sixth Circuit

Brief of the States of New Jersey, Alaska, California,
Colorado, Delaware, Florida, Indiana, Iowa, Kansas,
Louisiana, Michigan, Missouri, Nebraska, Nevada,
Oklahoma, South Carolina, Tenessee, U.S. Virgin
Islands, Utah, Virginia and Wyoming as Amici Curiae
in Support of Petitioners

John J. Farmer, Jr.

Attorney General of New Jersey
R.J. Hughes Justice Complex
PO Box 106

Trenton, New Jersey 08625
(609) 292-8550

Patrick DeAlmeida
Deputy Attorney General
Of Counsel

Victoria L. Kuhn

Deputy Attorney General

Counsel of Record and On the Brief
[Additional Counsel on Inside Cover]

\\ x

BRUCE M. BOTELHO
Attorney General of Alaska
P.O. Box 110300

Juneau, AK 99811-0300

KEN SALAZAR

Attorney General of Colorado
Department of Law

1525 Sherman Street, 7th Floor
Denver, CO 80203

M. JANE BRADY

Attorney General of Delaware
820 N. French Street
Wilmington, DE 19801

ROBERT A. BUTTERWORTH
Attorney General of Florida
The Capitol PL-01 ~
Tallahassee, FL 32399-1050

THOMAS J. MILLER
Attorney General of lowa
Hoover State Office Building
Des Moines, IA 50319

CARLA J. STOVALL
Attorney General of Kansas
Memorial Hall, 2nd Floor
120 S.W. 10th Avenue
Topeka, Kansas 66612-1597

RICHARD P. IEYOUB
Attorney General
State of Louisiana
One American Place
301 Main Street, Suite 600
P.O. Box 94005

\Baton Rouge, LA 70804-9005

JENNIFER M. GRANHOLM
Michigan Attormmey General
P.O. Box 30212

Lansing, MI 48909

JEREMIAH W. (JAY) NIXON
Attorney General of Missouri
Supreme Court Building

207 West High Street
Jefferson City, MO 65101

DON STENBERG
Nebraska Attorney General
2115 State Capitol
Lincoln, NE 68509

FRANKIE SUE DEL PAPA
Attorney General of Nevada
100 N. Carson Street

Carson City, NV 89701-4717

W.A.DREW EDMONDSON
Attorney General of Oklahoma
2300 N. Lincoln Boulevard
Suite 112

Oklahoma City, OK73105-4894

HARDY MYERS
Attorney General of Oregon
1162 Court Street
Salem, OR 97310

CHARLES M. CONDON
Attorney General

State of South Carolina
P.O. Box 11549
Columbia, SC 29211

PAUL G. SUMMERS
Attorney General and Reporter
of Tennessee

P.O. BOX 20207

Nashville, TN 37202

MARK L. SHURTLEFF
Attorney General of Utah
236 State Capital

Salt Lake City, Utah 84114

IVER A. STRIDIRON

Attorney General of the ”

U.S. Virgin Islands

48B-50C Kronprindsens Gade-GERS Bldg.
2nd Floor

St. Thomas, U.S. Virgin Islands 00802

MARK L. EARLEY
Attorney General of Virginia
900 E. Main Street
Richmond, VA 23219

HOKE MACMILLAN
Attorney General of Wyoming
123 State Capitol

Cheyenne, Wyoming 82002 -

STEVE CARTER

Attorney General of Indiana
219 State House
Indianapolis, IN 46204

BILL LOCKYER

Attorney General of California
1300 I Street, 17th Floor
Sacramento, CA 95814

\

TABLE OF CONTENTS

Statement of Amici Interest ................... ]
Summary of Argument ..................... 3
NS aaa 65e dee KA A kb wo 4-0 0-6 we % 4

THE DECISION OF THE SIXTH CIRCUIT TO
ALLOW INDIVIDUAL-INMATE EXEMPTIONS
FROM CONSTITUTIONALLY VALID PRISON
SECURITY REGULATIONS THREATENS THE
ORDERLY OPERATION OF CORRECTIONAL
INSTITUTIONS NATIONWIDE, WARRANTING
oe |, 4

a rr 13

il

TABLE OF AUTHORITIES
Cases Cited:

Bell v. Wolfish,
gi ae OF) ae ere passim

Blyther v. New Jersey Dep't of Corrections,
730 A.2d 396 (N.J. Super. Ct. App. Div. 1999)... . 15

Flagner v. Wilkinson,

241 F.3d 475 (6th Cir. 2001) ............. 3,5,9
Jones v. North Carolina Prisoners Labor Union,

gh Mo. Be oy, rr 5, 6,7,11,12
O'Lone v. Shabazz,

Me UD. DOe CHR) wc ee ee a Cee ee ee passim
Pell v. Procunier,

ee Ss ee Ge oa ha bee ee oes 9,17
Procunier v. Martinez,

a, Ee. vk oes bee een ewes 2,6,7,12
Turner v. Safley,

tk ee re ree 2,5,13,17

ill
Regulations Cited:
N.J. Admin. Code tit.10A, §4-4.1(a)*.010 (1999) . 10,15
N.J. Admin. Code tit.10A, §4-4.1(a)*.0T1 (1999) . 11,15
Alaska Admin. Code tit.22, §05.069 .......... 11,15
New York Comp. Codes R. & Regs. Tit.7, § 200.2 . 11,16
af FM CRS 6 kt 11,16

STATEMENT OF AMICI INTEREST

The amici States have a compelling interest in protecting
the security of their prisons through the uniform application
of prison regulations intended to protect corrections officers,
to inhibit inmate escapes, and to facilitate the secure and
orderly operation of correctional institutions. The Sixth
Circuit's decision to scrutinize constitutionally valid prison
disciplinary regulations on a case-by-case basis for the
purpose of creating individual-inmate exceptions to those
rules, merely because certain prisoners happen to have no
history of serious disciplinary infractions, threatens the
security of prisons nationwide by unnecessarily restricting
State prison officials in the execution of their responsibilities.
The potential impact of the Sixth Circuit's ill-considered and
legally flawed decision on the operation of State correctional
facilities, and the resulting threat to public safety, warrant
review by this Court.

The Sixth Circuit has determined, contrary to the
holdings of this Court and other courts of appeals, that the
judiciary may decide, on a case-by-case basis, whether a
specific inmate may be exempted from abiding by
constitutionally valid prison regulations. This decision
challenges the efforts of this Court to protect the deference
given to prison administrators in maintaining security in
correctional facilities. Specifically, this Court has repeatedly
found that "the problems that arise in the day-to-day operation
of a corrections facility are not susceptible of easy solutions."
Bell v. Wolfish, 441 U.S. 520, 547 (1979) (citing Jones v.
North Carolina Prisoners' Labor Union, 433 U.S. 119, 128
(1977)). Thus, "[p]rison administrators...should be accorded
wide-ranging deference in the adoption and execution of
policies and practices that in their judgment are needed to
preserve internal order and discipline and to maintain
institutional security." Jd. As a result, "prison administrators
.. . , and not the courts, [are] to make the difficult judgments
concerning institutional operations" because "courts are ill
equipped to deal with the increasingly urgent problems of
prison administration and reform." Turner v. Safley, 482

2

U.S. 78 (citing Procunier v. Martinez, 416 U.S. 396, 405
(1974)). .

Nevertheless, the Sixth Circuit has found that the
judiciary may substitute its judgment for that of State prison
officials to determine whether a particular inmate may be
exempted from valid prison regulations based on the inmate's
prior disciplinary history. If the Sixth Circuit's decision is
permitted to stand, the corrosive impact on prison safety will
grow as the number of inmates seeking exemptions from
otherwise generally applicable regulations rises. Moreover,
if the courts substitute their judgment for that of prison
officials and permit exemptions for individual inmates from
security regulations, the ability of prison officials to maintain
security will inevitably falter, thereby placing the safety and
welfare of prison staff, inmates, and the general public at risk.

The Petition for Certiorari filed by the State of Ohio
details how the decision of the Sixth Circuit conflicts with the
legal precedents of this Court and the decision of other courts
of appeals and highlights the detrimental effect of the Sixth
Circuit's decision on prison security. The amici States bring
to the Court's attention the widespread effect of this decision
on state correctional facilities nationwide. In light of the
dangerous implications to prison security presented by the
Sixth Circuit's decision and the importance of the issue
presented in the petition, the amici States join Ohio in urging
the Court to grant certiorari.

3
SUMMARY OF ARGUMENT

Review of the question presented by the petition is a
matter of critical importance to the amici States because the
decision by the Sixth Circuit to allow individual inmates to
litigate, on a case-by-case basis, whether the inmate may be
exempted from a constitutionally valid prison regulation
threatens the security of correctional institutions throughout
the country. Despite this Court's unequivocal holding that
"prison officials must be free to take appropriate action to
ensure the safety of inmates and corrections personnel and to
prevent escape or unauthorized entry," Bell v. Wolfish, supra,
441 U.S. at 546, the Sixth Circuit undermined the important
work of State prison officials by arming inmates with a novel
and potentially far-reaching method of evading appropriate
and necessary prison regulations.

The decision of the Sixth Circuit, if not reversed, will
certainly impact the States' ability to manage safely their
prisons by erecting an obstacle to the enforcement of
regulations created to prevent security problems, and to
protect corrections officers, inmates and the public. If
followed by other courts of appeals, the rationale of the Sixth
Circuit will necessitate an unmanageable and unnecessary
tracking by prison administrators of individual-inmate
exceptions to hundreds of prison rules. Ultimately, the Sixth
Circuit's decision to allow repeated inmate Challenges to
otherwise valid prison regulations will create an unworkable
patchwork of regulations and exceptions that will neither be
manageable nor enforceable in an institutional setting that
requires order and security to survive.

4
ARGUMENT

THE DECISION OF THE SIXTH CIRCUIT TO ALLOW
INDIVIDUAL-INMATE EXEMPTIONS FROM
CONSTITUTIONALLY VALID PRISON SECURITY
REGULATIONS THREATENS THE ORDERLY
OPERATION OF CORRECTIONAL INSTITUTIONS
NATIONWIDE, WARRANTING REVIEW BY THIS
COURT.

The Sixth Circuit's decision creates both a security
hazard within our nation's correctional institutions and
offends this Court's precedents by removing security and
administrative decisions from State prison officials in favor of
the substituted judgment of the judiciary. The Sixth Circuit
has determined that an inmate who seeks to challenge a prison
regulation previously determined to be constitutional may
subject the regulation to fresh scrutiny under an analysis
tailored specifically to the individual inmate's circumstances.
This determination is contrary to Turner v. Safley, supra, and
other Supreme Court decisions. See O'Lone v. Shabazz, 482
U.S. 342 (1987); Bell v. Wolfish, supra, 441 U.S. 520
(1979); Jones v. North Carolina Prisoners Labor Union,
supra, 433 U.S. 119 (1977).

Contrary to the finding of the Sixth Circuit, this Court
has routinely accorded a great amount of deference to the
decisions of State prison officials regarding the
administration, operation and security of their institutions.
For example, in Procunier v. Martinez, supra, this Court
expressed the importance of providing deference to the
decisions of prison authorities. The Court found:

Traditionally, federal courts have adopted a broad
hands--off attitude toward problems of prison
administration. In part this policy is the product of
various limitations on the scope of federal review of
conditions in state penal institutions. |More

5

fundamentally, this attitude springs from
complementary perceptions about the nature of the
problems and the efficacy of judicial intervention . .

. Suffice it to say that the problems of prisons in
America are complex and intractable, and . . . are
not readily susceptible of resolution by decree. Most
require expertise, comprehensive planning, and the
commitment of resources, all of which are peculiarly
within the province of the legislative and executive
branches of government. For all of those reasons,
courts are ill equipped to deal with the increasingly
urgent problems of prison administration and reform.
Judicial recognition of that fact reflects no more than
a healthy sense of realism.

Procunier v. Martinez, supra, 416 U.S. at 404-405.

This Court has clearly provided that State prison
administrators are to be accorded deference in the
administration, operation and security of their institutions.
For example, in Bell v. Wolfish, supra, this Court found that
"the problems that arise in the day-to-day operation of a
corrections facility are not susceptible of easy solutions.
Prison administrators therefore should be accorded wide-
ranging deference in the adoption and execution of policies
and practices that in their judgment are needed to preserve
internal order and discipline and to maintain institutional
security." Bell v. Wolfish, supra, 441 U.S. at 547, (citing
Jones v. North Carolina Prisoners' Labor Union, supra, 433
U.S. at 128). "[W]e have often said that evaluation of
penological objectives is committed to the considered
judgment of prison administrators, 'who are actually charged
with and trained in the running of the particular institution
under examination.'" O'Lone v. Shabazz, supra, 482 U.S. at
349.

In addition, contrary to the Sixth Circuit's finding that
prison regulations may be subjected to repeated scrutiny on

6

the basis of the vagaries of each inmate's disciplinary history,

this Court has specified that a State prison regulation, once

found to meet constitutional muster, should not be subjected

to repeated challenges. This Court's decision in Turner v.

Safley, supra, is instructive with respect to the across-the-

board application of constitutionally valid prison regulations

to all inmates, rather than the case-by-case obstacle course

mandated by the Sixth Circuit. As the dissenting judge in
Flagner noted:

By creating the 7urner test, the Supreme Court
surely did not intend to provide a mechanism
through which prisoners could mount repeated
challenges to prison regulations and require courts to
analyze, in detail, the impact such regulations would
have in any particular factual setting, even if prior
court precedent would seem to dictate the validity of :
the regulations. On the contrary: the Supreme
Court's creation of the Turner standard was
motivated by a desire to "ensure the ability of
corrections officials to anticipate security problems
and to adopt innovative solutions to the intractable
problems of prison administration, and avoid
unnecessary intrusion of the judiciary into problems
particularly ill suited to resolution by decree."

Flagner v. Wilkinson, 241 F.3d 475, 489 (6th Cir.
2001)(Nelson, C.J., dissenting)(citing O'Lone v. Shabazz,
supra, 482 U.S. at 349). Judge Nelson convincingly
explained that:

[t]he Turner opinion does not imply that an inmate
who seeks to challenge a prison regulation the
constitutionality of which has already been
established is entitled to have the regulation
subjected to fresh scrutiny under a four-factor
analysis tailored to the plaintiff's individual
circumstances.

7
Flagner v. Wilkinson, supra, 241 F.3d at 489.

Moreover, this Court has repeatedly recognized that
"[mJaintaining institutional security and preserving internal
order and discipline are essential goals that may require
limitation or retraction of the retained constitutional rights of

. . convicted prisoners .. . ." Bell v. Wolfish, supra, 441
U.S. at 546. "[C]entral to all other corrections goals is the
institutional consideration of internal security within the
corrections facilities themselves." Jd. (citing Pell v.
Procunier, supra, 417 U.S. at 823). Thus, "prison officials
must be free to take appropriate action to ensure the safety of
inmates and corrections personnel and to prevent escape or
unauthorized entry." /d., 441 U.S. at 546. However, the
decision of the Sixth Circuit hinders the ability of State prison
administrators to operate safe and orderly prison facilities
and, ultimately, contradicts this Court's instructions to protect
the determinations of State prison officials.

The Sixth Circuit has overlooked the dynamics of prison
life and the problems that lie therein and has placed prison
security in jeopardy by doing so. Specifically, the court failed
to recognize that prison security regulations are promulgated
in anticipation of security problems because such regulations
are necessary in order to discourage inmates from
endangering safety, escaping, or disrupting correctional
facilities. This Court has recognized that it is entirely
appropriate for prison officials to enact disciplinary
regulations as preventive measures. See O'Lone v. Shabazz,
supra, 482 U.S. at 349 (corrections officials must have the
ability "to anticipate security problems and to adopt
innovative solutions to the intractable problems of prison
administration"). Nothing in this Court's precedents suggests
that prison officials must wait for an inmate to create a risk to
safety before imposing valid restrictions on prisoner behavior.
To require such an approach would eliminate the ability of
State officials to anticipate threats to security before they

8

occur and deter dangerous behavior through predictable and
uniform application of disciplinary regulations.

The Sixth Circuit further fails to recognize that a personal
exemption from regulations will permit an inmate to easily
cause a security threat by implicitly authorizing otherwise
prohibited and potentially dangerous conduct. Rather, the
court bases its. decision on the unrealistic prediction that
simply because an inmate has not engaged in a specific
security problem in the past he or she will continue to behave
in an appropriate manner, even without the threat of discipline
for misconduct. This reasoning is contrary to the findings of
this Court and fails to consider the criminal element that is
housed in our nation's prisons. It strains reason to suggest
that convicted criminals will abide by prison regulations
during their incarceration if they are aware that exceptions to
the rules are doled out by the courts based on a lack of
previous disciplinary infractions.

This Court has consistently recognized the unique
dynamics of prisons and the resulting effect on security. For
example, in Jones v. North Carolina Prisoners' Labor Union,
Inc., supra, 433 U.S. at 129, this Court explained:

Prisons, it is obvious, differ in numerous respects
from free society. They, to begin with, are
populated, involuntarily, by people who have been
found to have violated one or more of the criminal
laws established by society for its orderly
governance. In seeking a ‘mutual accommodation
between institutional needs and objectives (of
prisons) and the provisions of the Constitution that
are of general application . . . this Court has
repeatedly recognized the need for major restrictions
on a prisoner's rights.

(citations omitted).

9

Similarly, in Procunier v. Martinez, supra, 416 U.S. at
404, this Court noted that:

Prison administrators are responsible for maintaining
internal order and discipline, for securing their
institutions against unauthorized access or escape,
and for rehabilitating, to the extent that human
nature and inadequate resources allow, the inmates
placed in their custody. The Hurculean obstacles to
effective discharge of these duties are too apparent to
warrant explication.

Despite the recognition by this Court that, due to the
unfortunate but very real dangers presented by prison life
State officials are to be given discretion by the judiciary in
implementing security regulations, the Sixth Circuit has
restricted that discretion by allowing the judiciary to substitute
its judgment for that of State officials on a case-by-case basis
whenever an inmate can demonstrate that he or she has not
previously violated prison rules.

In effect, the decision of the Sixth Circuit will open
numerous prison regulations, previously found by this Court
to be constitutional, to a new round of judicial review in the
federal courts and, ultimately, will produce dangerous results
for prison security. For example, in Turner v. Safley, supra,
this Court upheld a regulation promulgated by the Missouri
Division of Corrections prohibiting inmate correspondence
between prison institutions. Missouri prison officials
provided testimony that the correspondence rule was security
based because "mail between institutions can be used to
communicate escape plans and to arrange assaults and other
violent acts". Jd., 482 U.S. at 91. This Court found that the
regulation reasonably related to legitimate security concerns
of prison officials and upheld its validity. Jd.

However, under the Sixth Circuit's analysis, inmates
confined in a Missouri correctional facility could bring suit

10

against that State alleging that they should be exempted from
the simply because, in the past, they had never used the mail
to communicate escape plans or to arrange assaults or other
violent acts. As a result, those inmates who qualified for
exemptions could freely engage in the exchange of
correspondence that communicates escape plans, assaults or
other violent acts, the very dangers that the regulations were
designed to prevent. Because of the individualized
exemptions, Missouri officials would be unable to detect the
security threat, the effectiveness of the rule would be severely
hampered, and the security of Missouri's prisons jeopardized.

Similarly, in Bell v. Wolfish, supra, this Court upheld
federal prison security regulations prohibiting receipt of books
not sent directly from the manufacturer, as well as packages
of food and personal items sent from outside of the prison.
The reason for the rules was to keep individuals from
smuggling contraband into the institution. /d., 441 U.S. at
555. Under the Sixth Circuit's approach, this Court's
decision in Bell would be subjected to repeated exemptions for
any inmate who had never been caught smuggling contraband
into the prison in the past. Such an exemption would enable
inmates to smuggle contraband into the prison undetected. A
weapon is no less dangerous if it is the first piece of
contraband introduced by an inmate into the prison setting.
Yet, the Sixth Circuit's decision would allow a free pass to
traffic in weapons for any inmate who can demonstrate that he
or she has not been adjudicated guilty of violating prison rules
in the past.

Moreover, the decision of the Sixth Circuit to permit
continual review of valid prison security regulations will have
a detrimental effect on numerous State prison systems. For
example, the New Jersey Department of Corrections
(hereinafter "NJDOC") has adopted security regulations
prohibiting participation in or possession of security threat
group (gang) materials. See New Jersey Admin. Code tit.10A,
§4-4.1(a)*.010 (1999)(prohibiting participation in any activity

1]

related to a security threat group); N./J. Admin. Code tit. 10A,
§4-4.1(a)*.011 (1999)(prohibiting possession of security
threat group materials). The intent of the regulations is to
terminate gang-related violence within the NJDOC prison
system. See Blyther v. New Jersey Dep't of Corrections, 730
A.2d 396 (N.J. Super. Ct. App. Div. 1999). Under the Sixth
Circuit's analysis, inmates could mount numerous challenges
to these regulations and be awarded judicially sanctioned
exemptions merely because they had not previously engaged
in gang-related violence. These "exempted" inmates could
subsequently possess gang paraphernalia and participate in
security threat group activities with impunity until their
actions resulted in a breach of security. Until that time, these
prisoners could easily congregate and plan gang-related
violence, the exact result the regulations were intended to
prevent. The threat to prison security in such circumstances
is obvious and is in no way mandated by law.

Similarly, security regulations and policies, such as
regulations regarding substance abuse testing, grooming,
inmate searches, limitations on mailing and phone use, among
other security regulations, will be jeopardized if the decision
of the Sixth Circuit were to be adopted by other courts of
appeals. See Alaska Admin. Code tit., §05.069 (Alaska
Department of Corrections security regulation permitting the
substance abuse screening of inmates); New York Comp.
Codes R. & Regs. tit.7, § 200.2 (New York Department of
Corrections security regulation allowing the searches of
inmates after visitation to prevent the possession of
contraband); 37 P.A. Code §93.2 (Pennsylvania Department
of Corrections security regulation permitting the opening and
examination of incoming inmate mail to prevent the entry of
contraband); Michigan PD § 04.04.113 (Michigan
Department of Corrections Policy Directive permitting the
identification and management of security threat groups and
their members); Ohio Admin. Code § 5120-9-25(D)(F) (Ohio
Department of Corrections security regulation requiring
inmate compliance with grooming specifications for the

12

detection of contraband). Notably, most States have enacted
similar regulations and policies in anticipation of prison
security issues that would be directly affected by the rationale
of the Sixth Circuit. If the decision of the Sixth Circuit is
permitted to stand as a viable option for other courts of
appeals, countless inmates may be exempted from these and
other prison security regulations, resulting in_ the
unencumbered ability of inmates to wreak havoc on our
nation's prison security.

Moreover, the decision of the Sixth Circuit invites a
dangerous lack of uniformity in the application of prison
rules. Equal treatment of inmates in the context of
disciplinary decisions is essential to the perception of fairness
among prisoners. However, an even-handed application of
security regulations is not possible if individual inmates can
claim an exemption from rules that are applicable to other
prisoners.

The potential effect of the Sixth Circuit's decision clearly
offends the precedents of this Court that allows State prison
officials to promulgate policies in anticipation of dangerous
activity by inmates. See O'Lone v. Shabazz, supra, 482 U.S.
at 349. Moreover, the Flagner decision contradicts this
Court's mandate that State prison officials be accorded
judicial deference in matters of security and prison
administration. See Turner v. Safley, supra, 482 U.S. 78;
Pell v. Procunier, supra, 417 U.S. 817; Bell v. Wolfish,
supra, 441 U.S. 520. If permitted to stand, the decision of
the Sixth Circuit will jeopardize the ability of the States to
maintain security in their prisons, thereby placing the safety
and welfare of prison staff, inmates and the general public at
risk.

13
CONCLUSION

For the foregoing reasons, the petition for a writ of
certiorari should be granted.

Respectfully submitted,

John J. Farmer, Jr.
Attorney General of New Jersey
Attorney for State Respondent

Patrick DeAlmeida
Assistant Attorney General
Of Counsel

Victoria L. Kuhn
Deputy Attorney General
Counsel of Record and On the Brief

R.J. Hughes Justice Complex
PO BOX 106

Trenton, New Jersey 08625
(609) 292-8550

Dated: September 21, 2001

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40386014_2349%3A4. Public record. Not legal advice.