Category Archives: ACLU

Drones: Soon Coming To A Sky Near You

The technology used for air traffic control is changing and so is the civilian aviation landscape. Last month,

James Tarbox, Junior Editor, Alabama Civil Rights and Civil Liberties Law Review

James Tarbox, Junior Editor, Alabama Civil Rights and Civil Liberties Law Review

Congress approved a plan that would phase out radar as the means of tracking planes and shifted to a system using GPS-satellite tracking.

Under this plan, the FAA would be required to phase in unmanned drone flights in currently-restricted U.S. airspace.[1] At the present time, the United States military maintains an arsenal of roughly 7,500 remote-controlled drones. With the end of combat operations in Iraq and the scale-back of combat operations in Afghanistan, there will be more drones back in the United States. Under current FAA regulations, remote-controlled drones are not allowed in U.S. airspace without special permission. This restriction is in place because the technology is not compatible with manned aircraft. The FAA is unsure of how the unmanned aircraft will interact with manned aircraft in U.S. cities.[2] To test how to integrate the drone force into the current civilian airspace, the FAA must establish a testing ground by June 30th of this year. The manufacturers of the drone fleet will have to create technology that allows the drones to sense they are flying too close to commercial or other manned aircraft and react accordingly. The FAA has yet to create guidelines as to how the technology needs to be developed and what the technology must contain.[3] Furthermore, there are broader questions as to how military technology used on the battlefield will be implemented back on the home front.

Several organizations have come out against the creation and implementation of these new policies by the FAA. Groups, such as the American Civil Liberties Union, have petitioned the FAA to ensure that the privacy rights of citizens are included in the analysis of allowing drones to be used domestically. The group warns in their petition that drones can easily intrude on the privacy of everyday people, and that this intrusion is a violation of the Fourth Amendment.[4] The ACLU’s petition states that these drones can “track up to 65 different targets across a distance of 65 square miles.” In addition, in the near future, these cameras may soon include facial recognition technology that would make it possible to remotely identify individuals at parks, schools, and political gatherings.”[5] The petition further urges that drones offer the user the ability to survey an area undetected by persons below. The drones can provide constant surveillance that previous technology could not sustain. Additionally, the petition argues that once facial recognition software is available for use on the drones, the FBI and other monitoring agencies could use that same technology against political dissidents. This use would, according to the ACLU, violate the would-be dissident’s First Amendment rights. The petition goes on to urge the FAA to evaluate the available options and conduct a study balancing the public and private interests in drone usage.

According to a recent Rasmussen poll, “that despite a willingness on the part of Americans to see the use of drones by the military in overseas situations, 52% oppose the use of surveillance drones by private entities, police agencies, and government agencies inside the US. Just 30% said they were in favor of the use of drones in the US.”[6] Jay Stanley, of the ACLU’s Speech, Privacy and Technology Project, says, “the FAA should be rightly concerned about ‘the safety effects of filling our skies with flying robots.’”[7] The concerns of these groups can be summed up in an additional quote by Stanley where he stated, “Congress — and to the extent possible, the FAA — need to impose some rules (such as those we proposed in our report) to protect Americans’ privacy from the inevitable invasions that this technology will otherwise lead to. We don’t want to wonder, every time we step out our front door, whether some eye in the sky is watching our every move.’”

Are the fears of the ACLU and other civil rights and watchdog groups well-founded? Will law enforcement in the United States be able to capitalize on this drone technology to decrease the amount of privacy we as Americans enjoy? In a world filled with security cameras and electronic monitoring of our activities such as credit card purchases, how much further can (should) the government go? The ACLU cites facial recognition software as a concern on these drones if used for domestic surveillance. This technology has already been used at large events such as the Super Bowl (since 2001) to target suspected terrorists in the crowd.[8] While it is apparently still in the development stages for use on aircraft, the fact of the matter is that we as Americans already subject ourselves to the use of this technology in some areas of our lives already. Additionally, police helicopters already have the technology to track individuals using infrared sensors. In this day and age, it is nearly impossible to get away from a police helicopter that is equipped with the most up-to-date technology.

Technological developments generally make their way from military use to civilian use, just look to cell phone technology and sport utility vehicles. Why aren’t drones just the next step of technology in a long stream of innovations that have traveled through the military to civilian use cycle? While the ACLU uses a “parade-of-horribles” for their scenario, it does make a valid point. If the police already have the technology to pursue criminals with infrared from a helicopter, why do the police need to be able to track people up to over 65 square miles? If the FAA program is successful in implementing the use of drones, strict limits will have to be put in place. Battlefield technology does not need to be implemented in whole on the home front. There should be certain exceptions allowed for entities such as the Department of Homeland Security and the FBI; however, these exceptions should have to go through the highest levels of authority to be approved.

The FAA has the opportunity to upgrade our air traffic systems to the highest level. The future of shipping could one day be changed because some of these drones can carry such large payloads. While helicopter pilots will not be replaced, there could be fewer deaths from helicopter crashes. While few and far between when compared to the number of helicopters flying every day, there are frequent helicopter and even small aircraft crashes in the United States. If a news crew needs to get a shot of morning traffic, no longer will a helicopter have to take the camera man to the scene. A drone could take off, circle the city, and relay the images of the interstate back to the station to be broadcast. The possibilities for new innovative uses are endless; however, the possibilities for government use against the people are endless, as well, and must be closely monitored to ensure that our right to privacy is not infringed upon by a piece of technology that the eye cannot even see.


Disclaimer: The copyright in each article and post is owned by its respective author. Opinions expressed are those of the respective contributor and not presented as the views of the Alabama Civil Rights and Civil Liberties Law Review, its editors, the University of Alabama School of Law or the University of Alabama Board of Trustees or any other entity not specifically mentioned. All statements on this site belong to its writer. In addition, the views, opinions, and conclusions expressed in this page are those of the author and not necessarily those of The University of Alabama or its officers and trustees. The content of this page has not been reviewed or approved by the University of Alabama, and the author is solely responsible for its content.

Amendment 26 Is A Mississippi Bad Idea

Casey Bonner, Junior Editor, Alabama Civil Rights and Civil Liberties Law Review

Casey Bonner, Junior Editor, Alabama Civil Rights and Civil Liberties Law Review

Our neighbor to the west and my home state, Mississippi, could become the first state to effectively ban abortions next month if many pro-life supporters have their way. On November 8th, Mississippi voters who approach the voting booth to vote for the state’s next governor will also be faced with the initiative to amend the state constitution to define “personhood” as life that begins at conception – the moment a human egg is fertilized.

The initiative, known as Amendment 26, is backed by the Colorado-based group Personhood USA. Their mission statement declares their mission to be “to serve Jesus by being an Advocate for those who can not [sic] speak for themselves, the pre-born child. We serve by starting / coordinating efforts to establish legal ‘personhood’ for pre-born children through peaceful activism, legislative efforts and ballot-access petition initiatives.” Personhood USA is currently assisting in petition initiatives in several states, including Florida, Montana, Oregon and Ohio. Several states, including Alabama, have had Personhood USA-supported bills presented in their state legislatures, but only Mississippi will have the amendment proposal on their ballots this election year. Similar amendment proposals were defeated by voters in Colorado in both 2008 and 2010.

The language that Mississippi voters will encounter on the ballot reads: “Be it Enacted by the People of the State of Mississippi: SECTION 1. Article III of the constitution of the state of Mississippi is hereby amended BY THE ADDITION OF A NEW SECTION TO READ: SECTION 33. Person defined. As used in this Article III of the state constitution, “The term ‘person’ or ‘persons’ shall include every human being from the moment of fertilization, cloning or the functional equivalent thereof.”

Personhood USA and its Mississippi branch, Personhood Mississippi, hope to have greater success with their proposal in Mississippi, which is one of the most conservative states in the country. If Amendment 26 passes, it would define “person” to “include every human being from the moment of fertilization, cloning or the functional equivalent thereof” – which would make abortions illegal in the state, including those pregnancies that occur as a result of incest or rape.

Of course, the first question that should be asked about Amendment 26’s impact on a woman’s right to choose is “What about Roe v. Wade?”  In the well-known Supreme Court decision, the Court held that there is a fundamental due process right to decide to terminate a pregnancy, although within reason. In Roe, the majority used a strict scrutiny approach to analyze Roe’s challenge to Texas’s criminal abortion statutes. Strict scrutiny is applied when there is a fundamental right involved; in order for Texas’s statutes to survive a strict scrutiny challenge, there must have been a compelling state interest and the means used to regulate abortion must have been narrowly tailored. Texas claimed a compelling interest in ensuring patient safety and protecting prenatal life, but the Court held that a fetus is not a “person,” thus there was no real state interest in protecting the “life” of the fetus. Instead, the court held that the state may have an interest in protecting maternal life, but only at the end of the first trimester of the woman’s pregnancy. Only once the second trimester begins may the state regulate abortion.

To some, the Roe decision should be the nail in the coffin for Amendment 26.  However, Personhood Mississippi views the rationale used in Roe as the reason Amendment 26 will succeed. The Mississippi Personhood Memorandum points to two cases cited by the Court in Roe that recognize a state’s right to define “person” in a manner that is more protective of an unborn child, McGarvey v. Magee-Womens Hospital, 340 F.Supp. 751 (W.D. Pa. 1972) and Byrn v. New York City Health & Hospitals Corp., 31 N.Y.2d 194 (N.Y. 1972).

According to the Memorandum, this right of the state to define terms at its discretion will allow the state to effectively ban abortions in the state while not enacting laws that explicitly state the illegality of abortion. In fact, the Memorandum states, “It cannot be emphasized too strongly that the Amendment does nothing more than define the word ‘person.’ It does not criminalize abortion . . . .” Instead, declaring a fetus to be a person would allow the state courts or legislature to appoint the unborn a representative to advocate for the unborn in a judicial decision regarding whether the pregnancy could be terminated. However, the Memorandum sees the judicial process to terminate the pregnancy a non-issue – the Memorandum states that it would be “difficult, if not impossible to imagine a basis depriving the innocent child of life . . . .”

Oddly enough, the Memorandum also recognizes that if the Initiative passes, it will immediately be met with challenges from individuals and women’s rights groups. The group even “safely assumes” that the federal courts will find the Amendment unconstitutional under Roe. Despite the challenges and likely unconstitutional finding by a federal court, the Personhood USA remains optimistic. Keith Mason, a co-founder of Personhood USA, has said that a positive vote in Mississippi would send shock waves around the country, creating a momentum that could be used to eventually amend the U.S. Constitution.

What is curious about Personhood Mississippi’s faith in the Amendment’s ability to basically defeat the Supreme Court’s reasoning in Roe is that the group utterly ignores the Court’s holding in Planned Parenthood of Southeastern Pennsylvania v. Casey, 505 U.S. 833 (1992). In that case, the Court upheld the following essential parts of Roe: (1) women have a right to abortion before fetal viability; (2) the state does have an interest in restricting abortions after viability; (3) the state does have interests in protecting both the life and health of the mother and the potential life of the fetus. However, unlike in Roe, the Court did not rely on a strict scrutiny test, but rather focused on the burden abortion regulations placed on women. Casey did not overturn the Roe decision, but instead re-emphasized a woman’s right to choose by ensuring that any state restrictions on her choice were not so burdensome as to effectively eliminate her free choice. It is Casey, not Roe, that should concern Personhood advocates.

If Amendment 26 passes in Mississippi, it will be challenged not only on Roe standards and a woman’s right to abort but also under Casey’s undue burden test. Unfortunately for Personhood Mississippi, Amendment 26 probably will not withstand an undue burden examination. The objective of Amendment 26 is to effectively ban abortions in the state of Mississippi. Moreover, the current unavailability of abortions in Mississippi is probably the most burdensome restriction of all.

Nevertheless, perhaps not surprisingly, Amendment 26 has raised issues beyond a woman’s right to choose to terminate her pregnancy. One of the most contentious talking points surrounding Amendment 26 is the effect its passage would have on contraceptives and IVF. Proponents of the measure state while they do not condone the use of contraceptives, the Amendment will not outlaw “the pill.” Another pro-Amendment group, Yes on 26, states on their website that they oppose the use of contraceptives that act as abortifacients, which the group concedes could include some forms of the pill, intra-uterine devices (IUDs) and the “morning-after pill.”  Proponents oppose contraceptives such as these because they do not allow for the implantation of a fertilized egg. If “personhood” begins with fertilization, anything that deprives the “person” of life has violated its due process rights, and anyone who has caused the deprivation could be held liable.

In a similar vein, Yes on 26 promises that IVF would not be banned by the new definition, but it would place limits on the process. During in-vitro fertilization, several fertilized embryos may be created, but usually only one or two embryos are implanted in the woman, as recommended by the American Society for Reproductive Medicine. Any remaining embryos are usually frozen and stored in case the implanted embryos fail to result in a pregnancy. However, if there is a situation when embryos could or would be destroyed at the request of the parents, under Amendment 26, the parents, doctors or technicians could be held liable.

Those opposing the Amendment claim a redefinition of “personhood” would effectively ban many birth control methods, including the pill and IUDs. Parents Against MS 26 argue because many oral contraceptives change the lining of the uterus to keep a fertilized egg from implanting and developing, the new definition of personhood would keep these contraceptives from being available, even when needed for non-contraceptive medical uses. Parents against MS 26 also claims while the Amendment may not facially ban IVF, the definition of personhood would be a de facto ban on the treatment since IVF carries a risk of the destruction of embryos, whether intentional or accidental. Many university newspapers in Mississippi have published opinion articles by students against the Amendment, including an article in the Daily Mississippian, the University of Mississippi’s student newspaper. In the article, the writer wonders if the Amendment would allow women who miscarry to be prosecuted for manslaughter or even murder. While proponents of Amendment 26 denounce this theory as nothing more than a scare tactic, the logical extension of a new definition of personhood could result in such stark repercussions.

On November 8th, the voters of Mississippi will probably pass Amendment 26.  Both gubernatorial candidates have publicly backed the measure and polls conducted by the state’s major newspaper indicate that public sentiment backs the amendment.  Mississippi is widely recognized as one of the most conservative states in the U.S., as well as one of the most religious, and these superlatives will probably be the reason the Amendment passes. I think passing the Amendment will be a mistake and a waste of state resources and time.

Amendment 26 is a mistake, regardless of the good intentions behind the definition change because the repercussions extend beyond banning abortion. While advocates claim the new definition of person would not affect the availability of contraceptives or IVF, if these methods affect the existence of a fertilized egg, the definition will indeed affect contraception and IVF. Again, this is a mistake and a potentially devastating effect of the Personhood movement. Mississippi already has the highest teen pregnancy rate and highest infant mortality rate. By decreasing or even eliminating the availability of contraceptive devices, this measure could prove costly for the state and its taxpayers.

Amendment 26 will result in criminal prosecutions of women who have miscarriages, even though I agree with Yes on 26’s stance that such a claim is nothing more than a scare tactic. I also feel that Yes on 26 presents many distasteful statements of their own – including the declaration that “Planned Parenthood makes millions of dollars every year by killing babies.” Both sides have engaged in offensive smear campaigns, with both sides exaggerating the possible repercussions and ignoring the logical extensions of the plan. Even after reading countless articles and perusing websites by both advocates and opponents, I admit that I still am unsure of the real effects the new  amendment would have – other than changing the definition of “person.” My only hope for Mississippi voters is that they make an effort to discern the truth – because man, woman, mother, father, conservative, liberal, abstinent, indulgent – it will affect them and those they love.

The irony in all of this is that regardless of the outcome at the voting booth, the Amendment will not stand. Roe and Casey both held that a woman has a fundamental right to choose and that the state can place no undue burden on her rights. Absent a dramatic reversal of precedent, the long-term effects on the state will be few. Mississippi may enact Amendment 26 and it may change the reproductive rights of women in the state for a short time, but Amendment 26 is sure to be met with a multitude of legal challenges and the clear holdings of Roe and Casey should ensure women’s rights will prevail.




Disclaimer: The copyright in each article and post is owned by its respective author. Opinions expressed are those of the respective contributor and not presented as the views of the Alabama Civil Rights and Civil Liberties Law Review, its editors, the University of Alabama School of Law or the University of Alabama Board of Trustees or any other entity not specifically mentioned. All statements on this site belong to its writer. In addition, the views, opinions, and conclusions expressed in this page are those of the author and not necessarily those of The University of Alabama or its officers and trustees. The content of this page has not been reviewed or approved by the University of Alabama, and the author is solely responsible for its content.

Obama Administration Justified in Targeted-Killing

Jared Miller

Jared Miller, Junior Editor, Alabama Civil Rights and Civil Liberties Law Review

Anwar al-Awlaki (Awlaki) is dead. Before September 29, 2011, this leader was relatively unknown to most citizens of the United States. However, Awlaki’s story has quickly developed and been publicized due to America’s demand for instantaneity and aggressiveness from its news sources. Why Awlaki was killed, who killed him, and the nature of his killing was exposed in two days. The covert operations penetrating his life, the intelligence leading to his demise and the subsequent blow to his constituency has been plastered across various print and electronic media. Everything from his religious beliefs, the way he lived his life, schools he attended, and the scope of his marriages are in steady conversation rotation across the country. As these facts continue to come to light, it is Awlaki’s citizenship which will most likely have the most significant impact in the foreseeable future.

Awlaki was an admitted member of al-Qaeda. He had every right to join al-Qaeda and promote the beliefs of his organization. Awlaki had free will to support al-Qaeda and encourage their direction. He routinely expressed his hatred for America and Western Civilization. Awlaki used his radical influence to cause harm and continue a jihadist “holy war” against America.  U.S. military officials have called him a master propagandist and said he had immense ability to harm our country.  Subsequently, his dedication led him to become a supremely powerful figure within their ranks. However, it was Awlaki’s actions, not beliefs, which led to his being targeted. Al-Qaeda’s destructive actions and operational tactics have been widely held as terroristic in America. Their attacks on American soil and around the world have led the U.S. government to classify them as a legitimate threat to our national security. Awlaki’s speeches indicate he knew of al-Qaeda’s extremist reputation and he used his position to perpetuate these actions himself. He publicly praised numerous attacks on the nation and was charged with plotting attacks. President Obama even described Awlaki as the “leader of external operations for Al-Qaeda.”  Awlaki was perceived as such a threat that he was approved for targeted killing by the Central Intelligence Agency (CIA). Naturally, he met the same fate as most do when they are placed on this list.

The death of Awlaki came early Friday morning while he was hopping into a pickup truck.  He was caught in the crosshairs of an armed CIA drone and there was nothing he could do.  His death was carried out in Yemen and has been widely praised by their government. It is broadly speculated that the Yemeni Government helped carry out this military operation. Nonetheless, the U.S. Government has not given the exactness of their intelligence. Yemeni officials have commented that Awlaki was a threat to all and that his death was the direct consequence of his actions.  This rationale aligns with the comments being made by United States officials.  However, there is an increasingly growing underlying conversation being had in America about this military action.  Anwar al-Awlaki was born in New Mexico, making him an American citizen.

The conversation being had is the legality of the U.S. government killing an American citizen without judicial process.  The critics of Awlaki’s killing point to the Fifth Amendment to the Constitution that states no one shall be “deprived of life, liberty, or property, without due process of law.” These critics argue that there was not a single legal process that led to Awlaki becoming the first U.S. citizen placed on the CIA’s targeted killing list. They argue that this is America and in America actions such as these have to be fulfilled through a legal process. Further, critics point to the potential precedent this targeted listing and killing imposes. It is believed this opens the door to expanded executive authority to the killing of Americans. The American Civil Liberties Union’s (ACLU) Deputy Legal Director Jameel Jaffer said, “It is a mistake to invest the President — any President — with the unreviewable power to kill any American whom he deems to present a threat to the country.” Decriers say Awlaki’s murder goes against the framework of our country and has severely eroded the power of the judiciary.  The ACLU filed a lawsuit last year challenging the constitutionality of adding an American citizen to the targeted killings list. The lawsuit was dismissed and the federal judge noted that Awlaki had shown no interest in pursuing a claim in a U.S. justice system “he despised.” However, these conflicting views on the legality of the targeted killing of Americans has not been limited to the parties involved in litigating the preceding laws.

Presidential candidate Ron Paul has even expressed skepticism. He stated U.S. leaders must analyze “assassinating American citizens without charges” even if they do have strong terrorist ties and affiliations. Individuals with similar views of Ron Paul and the ACLU argue that there is no nexus between Awlaki’s actions and superseding the constitution. It is clear that he was implicated in various terrorist acts around the world, but Awlaki never was convicted in an American courtroom. It is this point that is fueling the debate. The critics of the killing argue that the Fifth Amendment requires a trial and conviction in court in order to kill any American citizen.

A quick resolution to this debate seems bleak since no real precedent exists.  Members of the legal community have tried to compare it to the detention of Americans who sided with our enemies in World War II. The precedent established by the actions taken in that point in history is unlikely to gain popularity because a lot of people do not accept America’s conflict with al-Qaeda as a real war. Robert Chesney, a law professor at the University of Texas who specializes in national security law, said that he does not believe “there has ever been a case quite like this.” With that said, most people opposed to Awlaki’s killing are not contentious about the circumstances surrounding his death. These people understand that he was a radical man and did not view America in the best light. However, they are worried about the slippery slope his placement on the targeted list has created.

Nevertheless, the Obama administration has heard the critics and has taken a position to rebut them. The Obama administration claims they were justified in placing Awlaki on the CIA’s targeted killing list because of his shifted focus and subsequent actions. They claim he went from a role of propagandist to operationally active during wartime. They point to Awlaki’s influence within the al-Qaeda sector in the Arabian Peninsula and his role in al-Qaeda in developing terrorist plots against America. The administration focused on three elements to support their argument when they rebutted ACLU’s lawsuit. First, they established that Awlaki was an imminent threat to American citizens. They produced evidence of his participation in plots to blow up specific American based airliners and cargo planes. Next, the administration relied upon the fact Awlaki was fighting with the enemy in armed conflicts against American forces. This was said to further his direct threat against America. Finally, and most importantly, the administration pinpointed the fact that they could not find a feasible way to arrest him. Awlaki’s dual citizenship, allegiance of followers, fleeing ability and pure determination to avoid capture made him “a hard target.” A hard target that was inevitably hit.

“If you’re a terrorist, you’re a terrorist,” exclaimed Secretary of Defense Leon Panetta when commenting on Awlaki’s killing. Anwar al-Awlaki was a terrorist.  He was a threat to anyone in this country and anyone whose religious and cultural views did not align with his. His preaching of violence and hate was heard around the world and became more threatening every day. He was just one man, but his influence inspired countless. My views support the officials around the globe acknowledging a safer world without him in it. A stereotype of the al-Qaeda network does not lead me to believe this way. My reasoning comes solely from the words out of his mouth. Awlaki’s destructive words and slant towards violence against America is unacceptable. And I fully agree with the Obama administration legal justification.

It is the federal government’s duty to protect the sovereignty of our nation and provide safety from threats.  Awlaki’s influence and his own hands were an immediate threat to American citizens. He preached for our deaths and took up arms against our troops. His actions were a direct threat against every citizen in the United States and considered treason in the U.S. Constitution (Article 3, §3). The Constitution further signifies that treacherous behavior is punishable by death.  Although Awlaki was not convicted of treason, his words and admittance to crimes made his traitorous stance clear. Furthermore, he was a wanted man and could have turned himself in to clear his name. Awlaki made the choice to elude law enforcement and forgo the judicial process.  America gives any citizen charged with a crime an opportunity to turn themselves in. Clearly, rectifying actions have to be taken when a charged party neglects this right, especially when federal organizations classify this party as a threat. It is true, Awlaki was not given a trial and this seems to cut against the Fifth Amendment. However, the Constitution has to be read and interpreted in the aggregate when the situation warrants. We know of at least three constitutional arguments that arise from Awlaki’s killing. His killing was executed without the exercise of the judicial process. Awlaki was thought to have committed treason. And it is the federal government’s duty to protect its citizens from foreign and domestic threats.

The Obama administration fulfilled their duty by adding Awlaki to the targeted killing list and executed their agenda. Taking away a President’s authority to order someone placed on the targeted killing list would not make America safer. I believe it would impede the national government’s duty to keep its citizens safe. Extreme measures are needed when time is of the essence and threats are imminent. The country elects our leaders to make the hard choices and sometimes they have to be made for our protection. It is a fallacy to demand constitutional protection from threats as an American citizen but chip away at the weapons used to protect us. I am sure the administration would have loved to minimize the Awlaki threat in a more judicially sound way, but CIA drones do not carry handcuffs.


Disclaimer: The copyright in each article and post is owned by its respective author. Opinions expressed are those of the respective contributor and not presented as the views of the Alabama Civil Rights and Civil Liberties Law Review, its editors, the University of Alabama School of Law or the University of Alabama Board of Trustees or any other entity not specifically mentioned. All statements on this site belong to its writer. In addition, the views, opinions, and conclusions expressed in this page are those of the author and not necessarily those of The University of Alabama or its officers and trustees. The content of this page has not been reviewed or approved by the University of Alabama, and the author is solely responsible for its content.

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