October 2011 Archives

October 28, 2011

Alexandra Natapoff By Professor Alexandra Natapoff

In the wake of new revelations about FBI informant crimes, U.S. Representative Stephen F. Lynch (D-MA) has introduced important new legislation that would require federal investigative agencies to report their informants' serious crimes to Congress. H.R. 3228, The Confidential Informant Accountability Act, would require the FBI, the DEA, Secret Service, ICE and ATF to report every six months to Congress all "serious crimes" committed by their informants, whether or not those crimes were authorized. "Serious crime" is defined as any serious violent felony, any serious drug crime, or any crime of racketeering, bribery, child pornography, obstruction of justice, or perjury. The bill prohibits the disclosure of informant names, control numbers, or any other personal information that might permit them to be identified. Under the U.S. Attorney General's Guidelines, the FBI is already required to disclose its informants' crimes to federal prosecutors.

The bill would also help the families of two men who were killed in connection with FBI informant Whitey Bulger to recover damages from the FBI. For more background, see these stories in the Boston Globe: Bill would aid kin of two slain men, and Pants on Fire. Full disclosure: I provided information to Congressman Lynch's office in support of this bill and I am strongly in favor of the effort.


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October 26, 2011


Loyola Law School and the Loyola of Los Angeles Law Review hosted a daylong discussion of the most pressing issues facing the gay, lesbian and transgender community during the symposium "LGBT Identity and the Law" on Friday, Oct. 21 on Loyola's downtown L.A. campus. Antidiscrimination, constitutional culture, healthcare and family issues will be the focus of four panel discussions. The keynote speaker was Dr. Gary Gates, Williams Distinguished Scholar, The Williams Institute, UCLA School of Law.

"Speakers addressed how sexual orientation issues are shaping constitutional law and politics, how antidiscrimination law both protects and fails to protect sexual minorities, how issues around healthcare access and medical care shape the lives of transgender and intersex individuals, and how the law recognizes and regulates families headed by same-sex couples," said Associate Professor Doug NeJaime, an organizer and moderator of the symposium. "Not only did the panelists chart the trajectory of the LGBT rights movement, they provided fresh commentary and presented new research on current and emerging issues that will shape the future of LGBT rights litigation, policy work and scholarship."


8:45-9:00 A.M. | WELCOME
Victor J. Gold, Fritz B. Burns Dean and Professor of Law, Loyola Law School; Senior Vice President, Loyola Marymount University


Moderator: James Gilliam, Deputy Executive Director, ACLU of Southern California; Adjunct Professor, Loyola Law School

Cary Franklin, Assistant Professor of Law, University of Texas at Austin School of Law

Holning Lau, Associate Professor of Law, University of North Carolina School of Law

Jennifer Pizer, Legal Director and Arnold D. Kassoy Senior Scholar of Law, The Williams Institute, UCLA School of Law

Cliff Rosky, Associate Professor of Law, University of Utah S.J. Quinney College of Law

10:30-10:45 A.M. | BREAK


Moderator: Douglas NeJaime, Associate Professor of Law, Loyola Law School

Dale Carpenter, Earl R. Larson Professor of Civil Rights and Civil Liberties Law, University of Minnesota Law School

Jon Davidson, Legal Director, Lambda Legal

Julie Nice, Herbst Foundation Professor of Law, University of San Francisco School of Law

12:15-1:45 P.M. | LUNCH

Keynote: Dr. Gary Gates, Williams Distinguished Scholar, The Williams Institute, UCLA School of Law


Moderator: Brietta Clark, Professor of Law, Loyola Law School

Julie Greenberg, Professor of Law, Thomas Jefferson School of Law

Ilan Meyer, Ph.D., Williams Senior Scholar for Public Policy, The Williams Institute, UCLA School of Law

Katie Pratt, Professor of Law, Loyola Law School

Brad Sears, Executive Director and Roberta A. Conroy Scholar of Law and Policy, The Williams Institute, UCLA School of Law

3:15-3:30 P.M. | BREAK


Moderator: Jennifer Rothman, Professor of Law and Joseph Scott Fellow, Loyola Law School

Courtney Joslin, Acting Professor of Law, UC Davis School of Law

Melissa Murray, Professor of Law, Berkeley Law

Nancy Polikoff, Professor of Law, American University Washington College of Law; McDonald/Wright Visiting Chair of Law and Faculty Chair, The Williams Institute, UCLA School of Law

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October 20, 2011


Visiting Associate Clinical Professor Jessica Levinson published a commentary titled, "Villaraigosa Donor Found Guilty of Money Laundering," on KCET's "1st and Spring" blog on Oct. 13, 2011:

"This week the Los Angeles City Ethics Commission found Alexander Hugh, a real estate executive and a donor of Mayor Villaraigosa's re-election campaign, guilty of laundering money to the mayor. The Commission unanimously voted 4-0 to impose the maximum fine allowed under the law, $183,750, for campaign finance violations."

Read the entire post here.

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October 20, 2011


Visiting Associate Clinical Professor Jessica Levinson published an op-ed titled, "Kinde Durkee's Alleged Fraud Continues to Take Its Toll on California Politicians," on the Huffington Post on October 7, 2011:

"The effects of the stunning fall from grace and subsequent arrest on September 2nd of veteran campaign treasurer Kinde Durkee continue to ripple throughout the California political community. Durkee is accused of stealing and misappropriating campaign funds from Assemblyman Jose Solorio (D). However, many more alleged victims have come forward. The reach of Durkee's alleged fraud is unprecedented. No less than 400 political committees were under her control."

Read the entire post here.

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October 20, 2011


This op-ed was originally published by the Los Angeles Daily Journal.

By Jessica A. Levinson

This week marks the 100th anniversary of the enactment of the political reforms that brought the Golden State the initiative, the referendum, and the recall. A century later, one thing is clear; our system of direct democracy is deeply flawed.

In 1911, Gov. Hiram Johnson enacted a series of reforms - including the initiative, the referendum, and the recall - to increase the power of citizens across the state. At the time a special interest, Southern Pacific Railroad, had a stranglehold over lawmakers, and Johnson instituted a system of direct democracy in part to change that. The sad irony is that 100 years later, while their names are different - Amazon, Mercury Insurance, and PG&E - our systems of direct democracy are now controlled by the same interests they were meant to guard against.

Moneyed interests now control the processes meant to give power to all of the citizens. What does one need to qualify a measure for the ballot? Money. Money won't guarantee a measure's success, but it will mean that members of the electoral must invest time and resources on a ballot measure, regardless of the propriety of the idea behind the measure.

Why is money the driving force behind direct democracy? Because in 1988 in [Meyers v. Grant,] the U.S. Supreme Court invalidated a ban on paid signature gatherers. Simply put, if money spent in politics is speech, then prohibitions on the use of paid signature gatherers amount to restrictions on speech.

The processes of direct democracy are wrought with problems, but it is here to stay. The least we should do is limit their reach. Here are a few suggestions. [Prohibit constitutional amendments by initiative or make it harder to enact constitutional amendments by initiative]: Constitutions should be fundamental governing documents. California's constitution is not. It is one of the longer constitutions currently in force. It has been amended more than 500 times. It is a bloated document stuffed to the gills (in fact a ban on the use of gill nets is in our Constitution) with amendments. It is frighteningly easy to amend California's constitution by initiative. Voters can amend it by a simple majority vote. Our elected lawmakers, on the other hand, can only amend the Constitution by a two-thirds vote that is later put to a ratifying vote of the people.

If the state will not prohibit constitutional amendments by initiative altogether, then it should at least make such amendments much more difficult. For instance, perhaps constitutional amendments could only pass by a two-thirds vote of the people. Another option is to require constitutional initiatives to pass in two consecutive general elections. In addition, constitutional initiatives should sunset after a certain period of time unless they are reenacted by a supermajority vote of the people. (In fact, it is wise to implement sunset provisions for all initiatives, whether statutory or constitutional).

[Allow the Legislature to amend statutory initiatives]: Currently California is the only state with a initiative process that does not allow the Legislature to modify statutory initiatives. It should not be more difficult to amend initiatives than legislatively enacted statutes. Initiatives should not be etched in stone. The Legislature must be able to revise or repeal statutory initiatives without going to a vote of the people. Circumstances change, laws must be changeable as well. [Prohibit initiatives on budgetary matters or institute pay-go]: Fewer than half of states that have the initiative process permit budgeting by initiative. Initiatives can affect taxes and public expenditures. The initiative process allows members of the electorate to make decisions about the budget in isolation without a comprehensive view of the budget or the consequences of enacting certain ballot measures. It is worth considering joining the majority of states with a initiative process that prohibit initiatives on budgetary issues.

If California will not prohibit initiatives on budgetary matters, then it should at least impose a system of pay-go. Ballot measures present voters with a binary choice; they can vote "yes" or "no." Voters are often asked, "Do you want this program or service?" or "Do you want lower fees or taxes?" The rational voter will say "yes" to both questions. However, voters are only given half of the information. They are not asked, "Do you want this program if it means we need to raise taxes or less money can be used for X?" or "Do you want lower taxes if it means less money will be available for Y?" California should require initiatives that will cost the state money to designate a funding source, and initiatives that will cut programs or services to identify those programs or services.

[Implement pre-election review]: The vast majority of successful initiatives are later challenged in court. At least half of those initiatives are invalidated in whole, or in part. This represents a waste of time and resources, both on an election for a ballot measure, which may not be constitutionally sound, and on a court case surrounding issues, which could have been resolved earlier with a pre-election legal review of initiatives. A legal review could include an examination of procedural requirements like qualification rules, subject matter requirements like the single-subject rule, and state and federal constitutional requirements. A word of caution, this pre-election legal review should be implemented in way that does not provide more tax on judicial resources than the current system.

Jessica A. Levinson is a visiting associate clinical professor at Loyola Law School. She studies governance issues, including campaign finance, ethics, ballot initiatives, redistricting, term limits, and state budgets.

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October 10, 2011


Visiting Associate Clinical Professor, Jessica Levinson originally published this on KCET's "1st and Spring" blog.

Depending on your perspective Los Angeles' gross receipts tax on businesses either provides much needed revenue -- to the tune of $425 million per year -- or harms economic growth. Last week the City Council's Jobs and Business Development Committee suggested it is the latter. Specifically, the committee asked the city to study halting the tax for new businesses or eliminating it all together. The tax is essentially a tax on the revenue that businesses generate. The tax ranges from about $1 per $1,000 to $5 per $1,000.

Read the complete blog post.

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October 6, 2011

Goldmanblog.jpg By Professor Jay Dougherty


Recent extensions of copyright have generated much controversy. Some of these controversies have led to important judicial decisions (on the Supreme Court level) concerning Congress' power to legislate in the copyright arena and the interplay between copyright laws and freedom of speech and expression. Most challenges have failed, with the courts signaling a judicial deference to Congress. In the most recent battle, Golan v. Holder, plaintiffs who have relied on the public domain status of certain foreign works challenged a law that restored copyright to those works. Assertions that the restoration exceeded Congressional power were fairly routinely rejected at the lower court levels after the U.S.S.C.'s decision in Eldred v. Ashcroft, 537 U.S. 186 (2003) (affirming the 1998 Term Extension Act), but a claim that restoration violated the First Amendment seemed to have some traction. The Supreme Court accepted cert in Golan, and recently heard oral argument. In Eldred, the Court had said that a law that altered the traditional contours of copyright law would be subject to First Amendment scrutiny, and one 10th Circuit panel in Golan had held that the restoration statute would be subject to such scrutiny. The district court on remand held that the restoration statute failed First Amendment scrutiny, but that decision was reversed by another 10th Circuit panel. One might have expected the oral argument to focus on related unsettled issues, such as the level of scrutiny and requirements for its satisfaction, which would have added clarity and certainty in future disputes regarding the relationship between copyright laws and the First Amendment. Unfortunately, in this author's view, the plaintiffs spent most of the oral argument beating the dead horse of Congress' copyright legislative power and missed an opportunity to persuade the Court on appropriate First Amendment scrutiny. That might have led the Court to find that the restoration statute did not satisfy scrutiny, for example, and that there should have been more protection for reliance parties who had developed businesses utilizing public domain foreign works. It is of course still possible that the Court in its decision will address those issues. The decision, which will determine the U.S. copyright status of thousands of foreign works, will presumably be issued sometime in 2012. Below is a more detailed review of the case and the U.S.S.C. oral argument.

On October 5, 2011, the U.S. Supreme Court heard oral arguments in the most recent case challenging the constitutionality of a provision of the Copyright Act added in 1994 by the Uruguay Rounds Agreement Act (URAA) that restored copyright to certain foreign works that had lost their U.S. copyright through a failure to comply with formalities. That section, ยง104A, also granted federal copyright to certain foreign sound recordings first fixed before Feb. 15, 1972, and provided for copyright in certain foreign works whose origin is a foreign country whose works are not subject to U.S. copyright, when the U.S. enters into copyright relations with that country.


Members of the Berne Convention are required under Article 18 to protect works of other countries when they become Berne members. New members are supposed to extend that protection to works that existed prior to the treaty relationship, as long as the works' terms would not have expired under the new member's law and the works' terms have not expired in their source country. The U.S. failed to do anything about this when it adhered to the Berne Convention in 1989, but as it saw that some foreign countries were refusing to grant retroactive protection to U.S. works and pushed to bring copyright into the larger world trade system and its enforcement mechanisms through the TRIPs agreement, Congress finally acted to comply with its own international obligations in part by enacting the restoration statute.

Members have flexibility in determining the conditions under which they will accord such retroactive protection. An important issue in according copyright to works previously unprotected is how to balance the interests of the "new" copyright owner with existing interest of persons who have relied on the prior "public domain" status of the works prior to that time. In fact various countries strike that balance in a variety of ways. The U.S. statute gives reliance parties a year to sell-off inventory after they receive notice (or a type of constructive notice) of the restored copyright, and, if the reliance party had created a derivative work prior to the enactment of the URAA (or prior to a country entering into treaty relations with the U.S.), that reliance party may continue to exploit the derivative work thereafter, subject to paying "reasonable compensation."

This statute has been disputed by a group of orchestra conductors, educators, performers, film archivists and motion picture distributors, who relied for years on the free availability of these works in the public domain, which they performed, adapted, restored and distributed without restriction, for many years. Their challenge to the restoration statute is perhaps one aspect of the larger attack against a variety of extensions of copyright protection, one prior part of which resulted in the Supreme Court's decision in Eldred v. Ashcroft, which upheld the constitutionality of the Copyright Term Extension Act. Many similar arguments have been made in the Golan case. To oversimplify somewhat, one challenge is that Congress does not have the power under the Constitution's "copyright clause" to take works out of the public domain (or, in the Eldred case, to keep them from entering the public domain when they previously would have), because it violates the limited times restriction on Congressional copyright power and does not promote the progress of knowledge. Another is that removing works from the public domain violates the First Amendment's freedom of speech clause.

There has been a long chain of decisions leading to the Golan case in the U.S.S.C. (this is the third Attorney General to be the named defendant). In the first decision, the District Court of Colorado in 2004 rejected both of the plaintiffs' arguments, finding that the Copyright Clause does not categorically preclude Congress from removing material from the public domain and there is a rational basis for doing so--attempting to promote possible U.S. authors' interests abroad by protecting foreign authors here and complying with the Berne Convention. It also found that there were no First Amendment concerns implicated. The 10th Circuit heard the appeal, and affirmed that the restoration statute did not exceed Congressional power, but that "restoring" works to copyright from the public domain altered the traditional contours of copyright, and therefore, according to the U.S.S.C.'s Eldred decision, should be subjected to First Amendment scrutiny. On remand, the District of Colorado considered whether the statute was content neutral or content based and the appropriate level of scrutiny. It decided that the law was a content neutral regulation of speech, subject to intermediate scrutiny. That requires that it advances an important governmental interest unrelated to the suppression of speech, and that it doesn't burden substantially more speech than necessary to further that interest. The government had asserted three important interests furthered by the restoration statute: (1) compliance with Berne, (2) protecting U.S. authors abroad, and (3) correcting historical inequities in the treatment of foreign authors who have lost copyrights through failure to comply with U.S. formalities. The district court this time around found that complying with Berne is an important government interest, but that the second asserted interest is merely tied to the first (and that there was little support that U.S. granting foreign works stronger protection here would actually benefit U.S. authors abroad) and that there is no important U.S. government interest in protecting foreign authors. As to the First Amendment, the district court this time found that there is an important First Amendment interest in public domain works' use, and that the statute burdened more of that speech than necessary to achieve Congress' goal of compliance with Berne.

On appeal, a different 10th Circuit judge reversed. This time it focused on the asserted interest of protecting American copyright holders' interests abroad, which it found to be substantial. It reasoned that granting stronger protection to foreign authors here (and correspondingly less protection to reliance parties) would further that interest, because the assertion is that foreign countries will reciprocate as to U.S. works restored to copyright abroad. Since that furthers the asserted interest, the statute is not overbroad.

The U.S.S.C. accepted cert on both issues: 1. Does the Progress Clause of the United States Constitution prohibit Congress from taking works out of the Public Domain? 2. Does Section 514 violate the First Amendment of the United States Constitution?


At oral argument, Tony Falzone on behalf of the plaintiffs initially focused on the broader question of whether the Constitutional copyright clause empowers Congress to remove works from the public domain at all. Justice Ginsburg immediately engaged in questioning him on this assertion, asserting that a foreign composer should be able to receive the same term of protection as a domestic one without violating the limited times restriction, and Falzone arguing that a term of zero is a "limited time" and that once it is set, it cannot Constitutionally be revised. Twenty-three pages of Falzone's 27 pages of oral argument transcript reflect argument over this aspect of the case, largely with Justice Ginsburg. Justice Sotomayer challenged the plaintiffs' position that Congress has never removed material from the public domain, noting that the first U.S. federal copyright law did that. Justice Kennedy initiated a discussion about the extent of the plaintiffs' claims as to the inviolate nature of the public domain (he seemed to forget the name of the Court's Eldred decision). Justice Roberts inquired as to how the plaintiffs' argument could apply when Congress elects to protect previously unprotected categories of material, such as it did with "architectural works". Falzone seemed to assert that to the extent applied to existing works, such protection would not be Constitutional because it would not satisfy the "promote the progress of science" limitation. Justices Sotomayer and Roberts engaged in questioning this proposition, seeming to argue that the restoration would give incentives to foreign authors, satisfying at least the minimal "incentive" effect apparently required. For a moment, the discussion seemed to shift to the First Amendment arguments, but quickly returned to the question of whether the statute provided "incentives" and therefore satisfied the "promote progress" requirement, which Justice Breyer seems to doubt (as he argued in his dissent in Eldred as to prior existing works). To this author, the plaintiffs failed to reach their much more supportable argument, that the restoration statute fails to satisfy First Amendment scrutiny.

In its argument, the government initiated discussion about whether the prior law had set the term for foreign works at "zero". Justice Alito immediately asked whether Congress could grant copyright to works whose term had expired (an issue not required to be addressed in Eldred). Donald Verrilli, the Solicitor General, seemed to argue that it could, but that there were "limits," such as that only "authors" can be accorded protection, which led to problems for him, as the Justice Alito pointed out that the restoration statute can give copyright to works when the author is long dead. Verrilli then argued trade policy: that Congress was motivated by a desire to commit to international standards under Berne, and protect U.S. copyright owners against infringement abroad. Justice Scalia said he did not find that an "appealing argument"--a treaty cannot expand the Constitutional powers granted Congress. Justice Breyer (who dissented in Eldred and in the past has argued for minimal copyright protections) engaged Verrilli in an argument as to whether Congress could give copyright protection where it would not elicit production of works, saying that here, "there is no benefit given to anything at all that is not already created." Justice Roberts then shifted to the First Amendment issues, stating "there is something at least at an intuitive level appealing about Mr. Falzone's First Amendment argument" (presumably the ones in the Briefs, since oral argument had essentially not reached that discussion). Verrilli argued that the government had removed material from the public domain in the past by adding new subject matter to copyright protection, and if that triggers First Amendment scrutiny, then any exercise of copyright power would do so. He argued that the only laws that would "alter the traditional contours of copyright," which the Court in Eldred had said would trigger scrutiny, would be a law extinguishing fair use or providing exclusive rights in ideas. Justice Kennedy took issue with that proposition, attempting to refocus the discussion on the level of scrutiny. Verrilli claimed that the law would satisfy "intermediate scrutiny" (which the lower courts had found to be the appropriate level of scrutiny), but again asserted that intermediate scrutiny should not apply, unless a law "alters the traditional contours of copyright," which in his view would be limited to the extreme cases described previously. Justice Roberts then questioned whether this law would satisfy even "rational basis" scrutiny, where the government interest is "vanishingly small" and the law limits free speech rights. Justice Breyer mentioned that millions of works could be affected and use prohibited, but Justice Ginsburg jumped into the discussion to point out that only works as to which notice of intent to enforce is given. Verrilli then diverted the discussion back to the historical question as to whether Congress can ever restore copyright to works in the public domain, arguing that history shows that it can and has--a claim that the Court seemed to favor during the plaintiffs' argument. Justice Alito asked if that only showed that Congress could do so "when there is an enormous interest...the establishment of the uniform copyright system at the beginning of the country." The Court then allowed General Verrilli to speak uninterrupted for the remaining four pages of his argument about other examples purporting to support the claim that the Court should defer to the legislature, including its judgment in how to "make a transition into full participation in an international system."

In his rebuttal argument, Mr. Falzone said he had four points to make, including that granting copyright where Congress has previously "set the term at zero" violates the "limited times" restriction, and that the statute cannot "promote progress." Justice Ginsburg again challenged him on these points. Finally, Falzone attempted to make his First Amendment argument, stating that the burden imposed is "remarkable." Justice Ginsburg asserted that all of that "rides on accepting your argument that zero is a limited time." Falzone claimed that the First Amendment argument is independent of the "zero term" claim, arguing with Justice Ginsburg as to whether or not the statute was required by Berne or TRIPs. He concluded with a statement that seems to attempt to draw upon some Justices' reluctance to allow U.S. rights to be limited because of foreign law, saying "If the government can get around First Amendment limits by signing a treaty...then the First Amendment is defined only by the perceptions, the complaints and frankly the imagination of foreign countries. That can't be the way it works."

It was disappointing to see that most of the oral argument focused on an issue seemingly resolved by the Court in the Eldred decision (although admittedly the restoration statute goes beyond the CTEA in granting copyright to works in which there was no protection in the U.S. prior to the statute). This strikes me as an argument the plaintiffs will lose, assuming the Court persists in its deference to Congress where there is some minimal "rational basis" for a statute. The last three lower court decisions had focused almost exclusively on the First Amendment problems with the statute, and one would have expected the plaintiffs to energetically argued that the asserted interest--that foreign countries might someday give more protection to U.S. authors if the U.S. gives their authors strong protection here--is far too remote to justify depriving reliance parties of their First Amendment rights to use public domain speech. Instead, the argument seemed to be cabined almost entirely to a broad claim that Congress can never grant copyright to works not previously protected, which strikes this author as more than was necessary to win this case, and not likely to be endorsed by the Court. It will be exciting to see the outcome, and in particular whether the Court endorses the government's claim for an extremely narrow articulation of what type of law would "alter the traditional contours of copyright protection." If the Court does not accept that characterization, one hopes for some explanation of the relevant level of First Amendment scrutiny should apply, how strong the evidence supporting the purported government interest must be, and how narrowly a law must be tailored when works are "removed" from the public domain. And perhaps we will receive some clarification of the relative importance of trade policy concerns in determining domestic intellectual property rights. If one had to guess based on the oral argument, it seems possible that Justice Breyer would want to reverse, based on the lack of incentives to create, that Justice Scalia might be moved to reverse based on his position that an international treaty does not justify limiting U.S. rights, Justice Roberts focusing on the possible overbreadth of the statute and Justice Alito finding that Congress alters the traditional contours of copyright when it removes material from the public domain and possibly applying a more demanding First Amendment scrutiny when that occurs. Of course, ultimately, the Court remains inscrutable on these points and we will await the final judgment.

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October 4, 2011

The Loyola Law School Center For Conflict Resolution (CCR) partnered with the South Asian Institute of Advanced Legal and Human Rights Studies (SAILS) and the Judicial Administration Training Institute (JATI) of the Government of the People's Republic of Bangladesh to present a training program on Alternative Dispute Resolution in Bangladesh from July 16-22, 2011. Clinical Professor Mary B. Culbert, director of the Center For Conflict Resolution, and Associate Professor Hiro N. Aragaki provided 30 hours of mediation training to 25 judges and 12 attorneys in Bangladesh. They also met with other high ranking member of the Bangladesh legal system to discuss ways to create an ADR culture and to better utilize ADR to reduce the backlog in their court system, including the minister of Law, Justice and Parliamentary Affairs, Barrister Shafique Ahmed, and the chief justice of Bangladesh, Mr. Justice Md. Muzammel, and other justices of the Supreme Court of Bangladesh. Professors Culbert and Aragaki also met with various law schoosl to discuss the integration of skills training in to their curriculum.


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