# Amicus Curiae Brief — Richardson v. Belcher > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40386413_0360%3A06 ## Record - **Collection:** Supreme Court brief - **Document type:** Amicus Curiae Brief - **Published:** January 1, 1971 - **Citation:** 404 U.S. 78 ## Text INDEX on tot Page Interest re re ee: ee ee ee 1 The Nature of Workmen’ s Compensation in the United OURLOE: aiiencu nee Cy eee sss ee OER EES S Oars 3, The eons of the Social Security” Laws To In- clude Disability ON ON Nf 565. 63% sah eaten « Pei rnreainss i) The Need for the Offset Beovisioil Lehecvesccseeeeee Wf The Offset Provision Is Crucial to the Success of State Rehabilitation Programs ................. 7 The Offset Provision Maximizes the Incentive to. States To Improve Their Benefit Structures ..... 11 | . The Offset Provision Contributes Toward Mainte- nance of sad Responsibility .............. 13 Conclusion Rieti aaas ea eeae sabe nees , errs .. 140 % ; | ‘TABLE OF AUTHORITIES Gises : : Bartley, et a v. Richardson, No. 703, O.T. 1970, Su- preme Court-of the United States ...........0... 3 Hurtado v. CF &I Steel Corporation, — Colo. —, 449. P.2d 819 aie re te Mivkteeasoeeseysveees 12 STATUTES: - Act of August 1, 1956, Pub. L. No, 84-880, § 103, 70 NT BS oes hone neers eee res sheng eees ts 5 - Act. of Augusf 28, 195 ub. L. No. 85-840, § 206, 72 IAG, FOS0 ei cean stg tpncesde vciedcvtnsnsneses 5 N.Y. Workmer’s< Compensation Law § 15(c)(v) | RCRInaEy jb) ae a a ii | , Index Continued Page Occupational Safety and Health Act of 1970, Se eT er rr 14 “Workmen’s Compensation Act, 1965 Perm. Supp.. C.B.S.1963, 81-12-1(4) 2... gece ec cece cece eens 12 42-U.S.C. § 402 .......... gis ssadeeeleuees Aes teaaae 5 42 U.S.C. § 423(a)(1)(B) ......... 0. eee eee, wees +6 $2 UC. 5 900 ees cece nes pense pn ceneanonens 6 MISCELLANEOUS: ANALYSIS OF WORKMEN’S CoMPENSATION Laws (Cham-" ber of Commerce of the United States 1971) ..3;5, 7, 13 Kup & BALL, Casualty INSURANCE (Ronald Press Co. 1968) sans Seoerheseeveneues ss eee wiewe eae ness 8, 14 Lane, WorKMEN’s COMPENSATION INSURANCE MonopoLy oR FREE .CoMPETITION? (Richard D. Irwin, Ine. 1947) ....... Su cee seus cas esa edb eee yee anes ees 3 Report of the Rehabiligation Committee, late raational Association of Industrial Accident Boards*.and Commissions (U.S. Bureau of Labor Standards, Bulletin 142) .........eccececcdececcuveuceuces Io Research and Statistics Note No. 21, 1970 (US. Department of : Health, Education and Welfare, ; Noveniber yA LL) ge 7 S. Rep. No. 404, 89th Cong., Ist Sess. 1 U. 8. Code | Cong. € Ad. News 2040 (1965) ......-...0.. via 6 IN THE Supreme Court of the United States OCTOBER TERM, 1970 © No. 1091 - - Exuior L. RICHARDSON, Secretary of Health, Education and Welfare, Appellant, V. ' RayMonD BELCHER On Appeal From the United States District Court for the Southern . District of West Virginia BRIEF FOR THE AMERICAN MUTUAL INSURANCE ALLIANCE, AMERICAN INSURANCE ASSOCIATION AND THE AMERICAN ASSOCIATION OF STATE COMPENSATION INSURANCE FUNDS AS. AMICI CURIAE : Pas | LF INTEREST | This brief amici curiae.is filed by the American Mu- tual Insurance Aliance (AMIA), the American Insur- ance Association (AIA),.and the American Association of State Compensation Insurance Funds (AASCIF), with the consent of the parties, as provided in Rule 42 of the Court’s Rules. >. 2 AMIA is an association of over 100 property and casualty insurance companies.’ Together they write almost one billion dollars annually in-workmen’s com- pensation insurance. This constitutes approximately 29 percent of the private workmen’s compensation in the United States and represents almost 30 percent of their total property and liability insurance business. ATA is also an association of over 100 property and casualty insurance companies. These companies write approximately .$1.2 billion of workmen’s compensation insurance annually. This constitutes 35 percent of the private workmen’s compensation in the United States - and represtnts approximately 15 percent of their total ~ property and liability insurance business. AASCIF is the association of state. workmen’s com- pensation insuranee funds. Such state-created and state-administered funds presently exist in 18 states and represent approximately $850 million in insurance | premiums annually. In six of these states, the state fund is ‘‘exclusive’’ (t.e., employers are required.in , those states to insure their risks in the fund). In the remaining 12:states, the funds are ‘‘competitive”’ (7.e.,_ employers may elect to insure in the state fund, with a. private insurance company, or to qualify as self- insurers). The state funds in all 18 states are members of AASCIF. hr These associations and the companies which they rep- resent are vitally concerned with the satisfactory oper- - ation of the nation’s compensation system. They are interested in all matters affecting workmen’s compen- sation and social. security, since they believe it is im- portant that the two systems be coordinated so that a proper development of each not be impeded. They 3 particularly want to insure that workmen’s compensa- tion laws continue to provide full and adequate pro- tection and rehabilitation to those who are the victims of work-related disability. As a result of their interest and long experience in this area, they are uniquely able’to assist the Court by _ discussing the significance of Section 224 of the Social Security Act and the reasons why, from the point of view of the industry most intimately concerned, .it is both reasonable and essential to the proper working. of state workmen’s’ compensation systems.! It is their position that the decision below, if allowed to stand, will genpaniiee attainment of this eve THE NATURE OF WORKMEN'S COMPENSATION IN THE UNITED STATES Workmen’s compensation laws have existed in the United States for some 60 years as an outgrowth of the inadequacies of the common law. They have now been adopted by all states and the District of Columbia and are basically similar in concept, scope and oper- ation. Common to all these laws is the elimination of fault ag the basis of liability. The workman | or his family 1 This brief will not discuss the authorities considered. at jength in the Jurisdictional Statement and Brief of the United States herein and in the Motion to Affirm, filed by the United States in Bartley, et al. v. Richardson, No. 703, O.T. 1970. We endorse’ the position of the United States on the constitutional issues as set forth therein. 2See generally, LANG, WoRKMEN’s COMPENSATION: TusuRiNcE: ~ Monopory or FREE CoMPETITION?, 3-10 (Richard D. Irwin, Ine. 1947) ; ANALYSIS OF WORKMEN’S COMPENSATION Laws, 3: (Chamber of Commerce of the United States 1971). 4 is indemnified, regardless of fault, for injuries or death arising out of employment. The benefits include medi- eal and hospital care, usually unlimited in time and amount, periodic payments to replace wages, and re- habilitation. In - essence, -workmen’s . compensation laws hold that employers should assume the costs of occupational, disabilities and that the resulting eco- ‘nomic losses should be considered costs of production. The enactment of workmen’s compensation was an important step forward in the protection of employees. For the employee, it eliminated the uncertainties of liti- gation, increased his financial security, and erased the -employer’s defenses of contributory negligence, as- sumption of risk and the fellow-servant rule. It pro- vided employers with a much-needed method of dealing with the financial hazards and uncertainfies of occu- pational imjuries, The United States Chamber of Commerce has pointed to six basic objectives of workmen’s compensation laws: 1. Provide sure, prompt and reasonable income and medical benefits to work-accident victims, or income benefits to their dependents, regardless of fault; | _ 2, Provide a angle remedy and dedines court de- lays, costs and work Joads—arising out of- per- sonal injury litigation; . 3. Relieve public and private charities of Anan: cial drains—incident to uncompensated industrial | accidents ; 4. Eliminate payments of fees to lawyers and- witnesses as well as time-consuming trials and appeals ; 5. Encourage maximum - suaployer interests in safety and rehabilitation—through appropriate ~ experience rating mechanisms ; and ~- o 6. Promote frank study of causes of accidents (rather than concealment of fault)—reducing pre- ventable accidents and human suffering. ‘LANALY- SIs OF WORKMEN’S COMPENSATION Laws, 3 (Cham- ber of Commerce of the United States 1971). ] | Most laws. require employers to meet their work- men’s compensation obligations either by insurance or by proving their financial capacity to act as self-in- . Surers. Some laws permit or require employers to ac- quire insurance through state-established funds. Pen- -alties are imposed for failure to provide: required coverage. - | 7 THE EXPANSION OF THE SOCIAL SECURITY LAWS TO. INCLUDE DISABILITY BENEFITS The original Social Security Act of 1935 did not provide for disability benefits. In 1956, Congress amended the law to provide for payment of benefits to those who were permanently and totally disabled and had attained the age of 50 but had not reached 65. Act of August 1, 1956, Pub. L. No. 84-880, § 103, 70 Stat. 848. The social security benefit payable to such an individual was reduced, however, by the amount of any periodic benefit payable to the recipient under a workmen’s compensation law. Id: . — This offset provision was repealed in 1958. Act of August 28, 1958, Pub. L. No. 85-840, § 206, 72 Stat. 1025. After two years’ experience under the offset provision, Congress concluded that the provision could be eliminated since at that time there did not appear — to be any serious duplication of benefits. At the same a time, Congress further liberalized: social security dis- ability payments by providing benefits for dependents - of disabled persons. 42 U.S.C. § 402. Congress again i a aa a eo \ \ \ Sha SY AMPA ARR La et AL PE Sg SEIMEI EEG AE ir LAA L ETA EF PEN aR | 6 expanded the range of beneficiaries in 1960 by eliminat- ing the age 50 requirement. 42 U.S.C. § 423(a) (1) (B). Jn 1965, Congress reinstated the workmen’s compen- sation offset provision, but in a form different from the 1956 version. 42 U.S.C. §424a. The 1956 provision required an offset of social security payments equal to the amount of workmen’s compensation received. The 1965 provision required only that combined social security and workmen’s compensation benefits could not exceed 80-percent of the ‘‘average current earn- ings’’ credited to the worker’s social security account . — before disability. In adopting this provision, the Sen- ate Finance Committee observed that it had ‘‘taken note of the concern that has been expressed by many witnesses in the hearings about the payment of dis- ability benefits concurrently with benefits payable un- der State workmen’s compensation programs.’’ S. Rep. No. 404, 89th Cong., Ist Sess. 1 U.S. Code Cong. & Ad. News 2040 (1965). The Committee found that it was ‘‘desirable as a matter of sound principle to prevent the payment of excessive combined benefits.”’ Id. Under the new provision, a worker’s benefits would never be reduced ‘‘below the amount of the un- reduced monthly social security benefits.”? Id. Moreover; in order to overcome the effect of inflation in wage levels and living costs, the offset provision now requires periodic automatic redetermination of ‘‘aver- age current earnings.’’ Jd. at 2200. As a result, when wages and, living costs increase, the amount of social . security benefits to be offset is reduced or eliminated. Thus, the disabled worker is able to maintain the ‘same standard of benefits. In addition, the level of - disability benefits automatically increases with every basic social security increase. oe - 7 ; ° At the start of 1970, 1,410, 900 disabled workers and their 1,151,000 dependents were receiving petal secur- ity disability benefits.* — THE NEED FOR THE OFFSET PROVISION The offset is “crucial to the success of rehabilitation programs under state laws, to the continuation of vig- orous employer safety programs, and to the continu- ance and improvement of state workmen’s compensa- tion laws. The Offset Provision Is Crucial to the Success of State Rehabilitation Programs A characteristic of all state workmen’s compensa- tion programs is provision for worker rehabilitation.‘ Rehabilitation has .been defined as the ‘‘restoration of - the handicapped workman to the fullest physical, men- tal, social, vocational and economic usefulness of which he is capable. . Historically, the state workmen’s compensation sys- tems have provided the principal impetus for disabled worker rehabilitation. The AIA, AMIA, their mem- ber companies and the AASCIF have been leaders in 7 developing rehabilitation programs and in urging more advanced state legislation in the area. In fact, the first _ clinics used exclusively for the’ physicial restoration of 3 Research and Statistics Note. No. 21, 1970 (U. S. Department of Health, Education and’ Welfare, November 23, 1970). ‘ Thirty-six states provide by statute for some form of rehabili- . tation. However, aecording to the Chamber of Commerce of the United States, ‘‘rehabilitation is provided in all ‘states even if un- specified in the law.’’ ANALYSIS or WORKMEN’s COMPENSATION Laws, supra, at 7, 30-31. 5 Report of the Rehabilitation Coeniies, International Assocta- tion of Industrial Accident Boards and Commissions, 170 (US. Bureau of Labor Standards, Bulletin 142) eR tal PR AOR NIB UR Ob MOR wing Te a EOE Wes Yiegs 08 VO iL es Liaeee: toa ee Ne 4 BRA adc Ha de Col or Fak Rated A re: ve LOOM Cae Se 8 | er in the United States were eeeouenen by work- “ men’s compensation insurance carriers.’ Rehabilitation gives the disabled worker the oppor- tunity to regain his economic and social utility by re- turning to the ranks of the wage earners. “It is equally important to employers, not only because of the ad- vantages of restoring trained workers to their jobs, but also because the savings resulting from properly administered rehabilitation programs are passed on to employers in the form of reduced workmen’s compen-. sation rates. This results in a built-in incentive. for ’ both employers and their insurance carriers to maxi- - mize rehabilitation efforts. | Based upon their experience under the earlier pro- visions of the social security laws, the AIA, AMIA © and AASCIF are convinced that the absence of an off- set acts as a deterrent to the rehabilitation of a dis- abled worker. Their experience has demonstrated that which common sense suggests is true: efforts to moti- vate a disabled worker receiving through disability pay- ments as much money as or more money than he had previously earned through working are frequently nn- successful. Under the existing levels of social seenrity and workmen’s compensation benefits, the lack of an offset provision will result in combined benefits in excess of average weekly take-home pay in 48 of 51 jurisdictions. As the following table demonstrates, only in three juris- dictions are combined social security and workmen’s compensation benefits less than or equal to average weekly benefits—Alaska, 81%; California, 97%; and ~ Ohio, 997% .. ®Kuutp & Hau, Casualty INSURANCE, 235 (Ronald Press. Co, 1968). - Nebraska / * ‘Combined » ; Workmen’s Workmen’s | Average Weekly Compensation Compensation and Combined Benefits Take Home -Maximum Social Security as Percentage of Jurisdiction ~ Pay (a) Weekly Benefit (>) Benefits (c) Take-home Pay Alabama $ 87.77 $ £u.90 $112.08 128% Alaska 179.26 82.55 144.63 81% Arizona 113.24 152.50 214.58 189% Arkansas 84.81 49.00. 111.08 131% California 118.21 52.50 114.58 97% Colorado - 102.21 59.50 121.58 119% “Connecticut ——-111.39 ~ 80.00 142.08 127% Delaware 98.93 75.00 137.08 138% Dist. of Col. 105.34 70.00 132.08 125% Florida 94.61 56.00 118.08 125% Georgia 91.61 50.00 112.08 122% : Hawaii 118.40 112.50 174.58 147% Idaho 106.49 99.00 161.08. 151% Illinois 112.73 71.00 " 133.08 118% Indiana 103.11 57.00 119.08 115% Towa 100.94 56.00 118.08 117% Kansas 101.02 56.00 118.08 117% Kentucky 96.05 52.00 114.08 119% x Louisiana 102.02 49.00. 111.08 109% Maine. 90.79 73.00 135.08 149% Maryland 102.10 85.00: 147.08 144% “Massachusetts 108.12 88.00 150.08 139% © Michigan 119.35 104.00 166.08 139% Minnesota 104.22 70.00 132.08 127% . Mississippi 84.15 40.00 102.08 - 121% Missouri 101.33 52.00 120.08 - 118% Montana 113.35 65.00 127.08 112% . 98.13 55.00 117.08 119% | 10 , . : | Combined Workmen’s Workmen’s : Average Weekly Compensation Compensation and Combined Benefits Yes ; Take Home - Maximum Social Security as Percentage of. ‘ Jurisdiction = ‘Pay (a) Weekly Benefit (>) Benefits (¢) Take-home Pay Nevada. | 114.53 66.46 - | 128.94 112% ‘New Hampshire 97.43 67.00 129.08" 132% New Jersey 102.90 91.00 _ - 153.08 , = 149%, ‘New Mexico 102.58 - 48.00 ° 110.08 107% New York — 105.82 80.00 . 142.08 134% North Carolina 88.50 50.007 112.08 27% - North Dakota 94.22 94.00 156.08 166% | Ohio 119,20 56.00 ~ °° 118.08 99% Oklahoma «93.98: —s- 49.00 —S—~*é«S'1 8.08 118% ~ Oregon 114.50 62.50 124.58 109% = = Pennsylvania 10543 °. 60.00. ~ 122.08 ~ 116% Rhode Island 101.49 82.00 _ 144.08. 142% South Carolina 87.07 50.00: > 112.08. - 129% South Dakota 93.36 30.00 11208 * 120% Tennessee 89.48 47.00 — 109.08 22% Texas 105.01. | 49.00 ~ 11108 - . 106% Utah 100.22 65.00 ~~ 127.08 127% Vermont 98.23 61.00 123.08 125% Virginia 93:30 62.00. "124.08 133% Washington 117.40 ~ 123 ~~ 14831 ——:1228% West Virginia 113.40. 65.50 ~ 127.58 112% Wisconsin 101.13 79.00 141.08 =. 139% Wyoming © _—95.53 63.46 125.54 131% 2 eee) Average weekly wages less federal income and social security taxa (four dedustions). Based upon wages of employees to whom compensation paid. National Council on Com- pensation Insurance, December 1969. (b) Ag of December 1970. Includes maximum. allowance for dependents, except in Massa- chusetts, Utah, Vermont and owas where benefits for additional dependents may be paid. . ; . (c) Compensation benefits based upon a worker with a wife and two children. Social security © benefits based upon average family monthly benefit as of December 1970 ‘of $269. 00, or $62.08 average ps benefit. Source—Social Security Administration, U. S. Department of Health, Educ&tion and Welfare. . ¢ : 7 11 &t id . ° Pa - - ; / ; _ THese computations, it should be noted, do net in- cludé medical payments, which aré in addition to the wage replacement benefits, nor do they reflect the fact that workmen’s compensation and social security bene- fits 4re not subject to taxatiqm:. Congress enacted the offset proyision in 1965 in order to restoresome incentive toward rehabilitation. At the ‘same time, Congress was liberal in its allowance so that the disabled worker would receive substantially what he had received from working.. In addition, Congress -proyided for regular adjustment of the offset level so that benefits*would keep pace with wages and the cost of living. Under these circumstances, the offset provi- sion is a mare than reasonable method of providing the, essential incentive for rehabilitation. a v. The Offset Provision Maximizes the iacenlies to States To Improve Their Benefit Structures. \ <-Mitwaeh sophisticated employers are ‘willing’ to ac- cept reasonable higher compensation costs to insvre that their employees will receive adequate suppott when injured, ‘they are demanding greater efficiency . in the beyefit distribution mechanism. When duplica- - tion of benefits occurs, there-is reluctance to- ‘upgrade: state workmen’s compensation laws. a, NO. Workmen’s compensationaws in a number of states still lag in their benefit levels. Many individuals and groups have been working to improve these levels, and” - while such efforts have met with considerable’ success, _ continued improvement i is necessary to keep pace with increases in the cost of living and improved wage | seales. . a . There are specific examples of the ay in which social security benefits reduce the pregsures on the . - = ry | \ -“ 12 ’ states to provide full workmen’s compensation benefits. For instance, since 1958, the year the offset provision was repealed, nine states increased benefits for tem- porary total disability (for which there-is no social © security coverage), but did not increase benefits for permanent total disability (for which there may be social security coverage).® ,It is significant that five of these nine jurisdictions fir st enacted this différential in 1959, the year-following repeal of the original offset : provision. Two states reduce workmen’s compensation. benefits when social security benefits. are payable.® . \ -Widow’s benefits provide a further illustration of. the chilling effect of social security. Workmen’s com- — 8 Permanent, Temporary — Original Year ° P—Total Disability Total Disability. - of Enactment ~ State Benefit Benefit ' . of Difference Alaska $73.45 . —- $127.00 1959 California ——+552.50 87.50 1959 Illinois. 71.00 91.00 1965 Iowa . 56.00 : 6h00 1959... Missouri 58.00. 63.50 | 1959 Montana —_—60.00 After first 65.00 ~ 1969. _ 26 weeks of . oo - disability os = % gy + New York —_80.00 95.00 1968 ‘Ohio 56.00 63.00 Payable for 1967 first 12 weeks @ a _ | __ of disability Oregon >i. — a | 80.00—(asi‘ ;*#«z ®In New York, benefits may be awarded for loss of earnings in ‘addition tp loss of function—but these additional benefits are offset by 50% of any social security benefits [N.Y. Workmen’s Compen- sation Law § 15(c)¢v) (McKinney 1970)]. The Supreme Court - -of Colorado has construed the-Workmen’s Compensation Act, 1965 Perm: Supp. C.R.S. 1963,°81-12-1(4), to allow an employer to re- duce payments under that Act when the employee becomes eligible for benefits under tha Social Security Act. Hurtado v. CF&I .- — Steel Corporation, — Colo. —, 449 P.2d 819 (1969). c ; 13° pensation laws have been criticized because of inade- quate provisions for survivor benefits for widows and -children.”” The lag in this area is easily traceable to _ the fact that the widows and children are entitled to - social security benefits, so there is no-ineentive to ex- tend workmen’s compensation benefits to them. ' Despite such limitations, workmen’s compensation laws afford far broader protection than social security forey worker injuries. It is the workers as a group who _ will’be the ultimate losers if improvements in work- men’s compensation benefits and coverage are dis- couraged. Tne decision below, unless reversed, will have precisely that effect. It could, we believe, con- tribute to the eventual demise of the workmen’s com- pensation system. The Offset Provision Contributes Toward Maintenance of Employer Responsibility Workmen’s compensation insurance is paid for by the employer, while social security contributions are made by both employer and employee. Thus, if social security assumes a greater proportion of disability: compensation, the burden of providing for the injured workman will shift from employer to employee. Aside from its undesirable economic implications, this poses serious concern for job. safety. Because of the gearing of insurance premium costs to claim experience, the existence of workmen’s com-_ pensation ‘has given significant impetus to industrial - 10 See ANALY IS OF WorkMEN’ s COMPENSATION Laws, supra, at 26- 27. 14 safety in the United States," A reduction in accidents in a manufacturing plant serves to decrease the em- ployer’s insurance costs. However, if social security assumes a greater share of the disability benefit burden and the level of workmen’s compensation is reduced, the significance of insurance cost is correspondingly reduced and, with it, the incentive for the development of vigorous and effective job safety programs.” CONCLUSION The foregoing demonstrates the reasonableness of Congress’ determination to readopt an offset provision to prevent excessive duplication of social security and workmen’s compensation disability benefits. This pro- vision strengthens the effectiveness of the state laws and prevents a negation of their goal of rehabilitation. Congress saw the wisdom of maintaining strong state- _ level programs and recognized that the proportion of ' federal benefits should |.» sufficiently restrainéd to insure that these programs not be. weakened nor their purposes frustrated. 11 The National Safety Council computes that the frequency of industrial accidents. has experienced a significant reduction which parallels the expansion of effective workmen’s compensation laws. In 1926 the industrial accident. frequency rating was 31.87. By 1965 this was reduced to 6.53. In addition, the severity rate also dropped during that time from 2,500 man days per. 1,000,000 man hours of employment to 689 man Sod _ Casualty INSURANCE, supra, at 172-173. 7 12 The Occupational Safety and Health Act of 1970, — Stat, —, established the National Commission on State Workmen’ S Laws. The Commission is required to study and report to the President by July 31, 1972, concerning, among other things, the ‘‘relation- ship between workmen’s compensation on the one hand, and old age, disability, and survivors insurance and other types of insur- ance, public or private, on the other hand”’ iBection 27(d) (1) . (O)]. 15 The present offset results in no inequity. In addi- tion to medical payments (including rehabilitation), the permanently disabled worker receives wage replact- ment benefits that approximate the take-home wage pay which he earned before his injury. Additionally, through automatic adjustments, these benefits increase with inflation and can result in benefits beyond the pre-injury wage. The offset is not only reasonable but necessary. Therefore, we urge that the Court Giant the prayer of the United States and reverse the judgment of the court below. - Respectfully submitted, ‘WILuiaM KE. Miner RicHarD A. WHITING James L. McHveu, Jr. STEPTOE & JOHNSON | 1250 Conecticut Avenue, N. W. Washington, D.C. 20036 Counsel for Amici Curiae Of Counsel: Srepror & JOHNSON 1250 Connecticut Avenue, N.W. - Washington, D.C. 20036 April 15, 1971. --- Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40386413_0360%3A06. Public record. Not legal advice.