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William and Mary Law Review
Number of Followers: 5  Open Access journalISSN (Print) 0043-5589 - ISSN (Online) 2374-8524 Published by College of William and Mary  [5 journals]
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- Afraid for the Dark: Regulating Light Pollution Under the Clean Water Act
Authors: Katrina Umstead
Abstract: Currently, light pollution is only regulated at the state and local level. However, not all states implement legislation to mitigate the adverse effects of ALAN [Artificial light at night]. Nineteen states, the District of Columbia, and Puerto Rico have implemented laws to reduce light pollution. In states without such laws, or in federal waters, light-intensive activities remain unchecked. The rapid increase in light pollution in recent years illustrates the inadequacies of existing state and local regulatory schemes and calls for a new understanding of ALAN as a pollutant to marine ecosystems.This Note argues that the existing tools in the Clean Water Act (CWA, or “the Act”) provide authority for the U.S. Environmental Protection Agency (EPA) to regulate light pollution and preserve the integrity of the nation’s waters. Part I examines the existing body of research on ALAN’s damage to marine and wetland ecosystems. Part II surveys the insufficiency of existing state and local regulation of light pollution. Part III addresses the need for federal regulation of light pollution through ALAN’s classification as a pollutant under the CWA. Part III also confronts counterarguments to recent concerns about regulatory overreach in the wake of West Virginia v. EPA.This abstract was taken from the author's introduction.
PubDate: Thu, 09 May 2024 14:00:56 PDT
- Section 898: Targeting the Companies Behind Gun Violence in New York with
Public Nuisance Doctrine
Authors: Mara Kravitz
Abstract: On July 6, 2021, the New York State Legislature enacted sections 898-a to -e of the New York General Business Law (section 898), creating a clear path for public entities and private gun violence victims to sue gun industry members for their role in the gun violence public nuisance in New York. This Note explores why the legislature took a public nuisance approach to curbing gun violence, framing section 898 within public nuisance doctrine’s broader common law history and legal elements.To unpack how and why New York took this approach, the first Part of this Note traces the history of public nuisance doctrine from its origin in medieval common law, through modern applications, into gun violence lawsuits in New York, and finally, into section 898. To understand why this approach is legally useful, Parts II and III compare the elements of common law public nuisance doctrine to the elements of section 898 and explore constitutional issues, respectively.This abstract has been taken from the author's introduction.
PubDate: Thu, 09 May 2024 14:00:53 PDT
- Rage Rhetoric and the Revival of American Sedition
Authors: Jonathan Turley
Abstract: We are living in what Professor Jonathan Turley calls an age of rage. However, it is not the first such period. Professor Turley explores how the United States was formed (and the Constitution was written) in precisely such a period. Throughout that history, sedition has been used as the vehicle for criminalizing political speech. This Article explores how seditious libel has evolved as a crime and how it is experiencing a type of American revival. The crime of sedition can be traced back to the infamous trials of the Star Chamber and the flawed view of free speech articulated by Sir William Blackstone. That view continues to resonate in “bad tendency” rationales for criminalizing what Professor Turley calls “rage rhetoric.” An advocate for a broader theory of free speech, Professor Turley suggests that the United States should break this cycle and reject a crime that it is not only superfluous in many cases, but the product of the anti-free speech theories extending back to the seventeenth century. The elimination of the crime would fulfill what Professor Turley believes is the original and revolutionary view of free speech articulated by some figures at the start of the Republic. It would finally slay what James Madison called the “monster” lurking in our political and legal systems for centuries.
PubDate: Thu, 09 May 2024 14:00:50 PDT
- Unreasonable Traffic Stops
Authors: Sam Kamin
Abstract: In 1996, the Supreme Court announced in Whren v. United States that a traffic stop is constitutional if there is probable cause to believe a traffic infraction has occurred. So long as the officers who stop an individual can point—even after the fact—to any violation of the traffic laws, their actual, subjective motivations for initiating a stop are legally irrelevant. Case-by-case determination of reasonableness is unnecessary in the traffic stop context, the Court concluded, because the balancing of interests has already been done. Unlike warrantless entries into homes, the use of deadly force, or unannounced warranted entries, a traffic stop is not an “extreme practice,” and therefore the existence of probable cause invariably outweighs an individual’s interest in avoiding police contact.In this Article, I argue that the Court was half right in Whren: there is little need for case-by-case adjudication of the reasonableness of traffic stops. Given that the government interest in these stops is relatively low, that such stops can result in harm to both the officer and those stopped, and that other, less intrusive means are nearly always available to serve the government’s stated interest in traffic enforcement, courts should presume that the use of sworn officers to conduct traffic stops is unreasonable. While there may be some situations in which the use of armed police officers to make traffic stops is reasonable, the government should bear the burden of demonstrating that fact in each individual case. This straightforward legal change would significantly reduce needless police stops, thereby increasing overall safety for both officers and the public.
PubDate: Thu, 09 May 2024 14:00:47 PDT
- The Anti-Innovation Supreme Court: Major Questions, Delegation, Chevron,
and More
Authors: Jack M. Beermann
Abstract: The Supreme Court of the United States has generally been a very aggressive enforcer of legal limitations on governmental power. In various periods in its history, the Court has gone far beyond enforcing clearly expressed and easily ascertainable constitutional and statutory provisions and has suppressed innovation by the other branches that do not necessarily transgress widely held social norms. Novel assertions of legislative power, novel interpretations of federal statutes, statutes that are in tension with well-established common law rules, and state laws adopted by only a few states are suspect simply because they are novel or rub up against tradition. In periods of governmental innovation and assertions of expanded authority, this aggression becomes evident and perhaps more robust.In recent years, the Court has created new barriers to government innovation even as government is confronted with serious threats to the health and welfare of mankind. Chief among this new set of limitations on the power of federal administrative agencies is an interpretive device that has become known as the Major Questions Doctrine (MQD). This doctrine purports to be based on a traditional view of legislative intent and judicial role, but in reality it resonates more with conservative anti-regulatory political views. Under this new doctrine, the Court rejects agency assertions of regulatory authority when it finds that the agency’s action would have major social and economic effects and lacks crystal clear congressional authorization. Ironically, because the MQD has no basis in the Administrative Procedure Act or prior law, the Court has in effect created a major new doctrine of administrative law severely limiting agency authority without clear authorization from Congress.The Court has also suppressed agency innovation by confining Chevron deference to unimportant issues of statutory construction. Chevron, for all of its faults, has the virtue of validating agency policy innovation so long as Congress had not clearly denied agency authority. This reform to Chevron, together with the creation and application of the Major Questions Doctrine, in effect accomplishes the aim of some Justices to impose a more robust nondelegation doctrine, making agency innovation even more difficult. In addition, the Court has worked to prevent innovation in other areas of law, such as agency structure, gun control, and the spending power, preventing the state and federal governments from taking action to deal with pressing social problems. The current Court has truly become an anti-innovation Court.
PubDate: Thu, 09 May 2024 14:00:44 PDT
- Table of Contents (v. 65, no. 6)
PubDate: Thu, 09 May 2024 14:00:41 PDT
- Ukraine v. Russia: A Case for Change in International Enforcement
Authors: Katy Malloy
Abstract: A scant few territorial violations have occurred in the twentieth and twenty-first centuries, and those that have occurred generally prompted quick and unequivocal condemnation, as well as efforts to return to the status quo. Notable violations—the Six-Days War, the Turkish invasion of Cyprus, the Falklands War, Iraq’s invasion of Kuwait, and Russia’s annexation of Crimea—have prompted a short menu of international responses. The Six-Days War and the invasion of Crimea both prompted years’ worth of political criticism for Israel and Russia, respectively, as both nations have held onto at least parts of the lands seized. The Falklands War prompted almost immediate diplomatic condemnation and efforts to negotiate a peace settlement, but was resolved with military force beyond the control of the international community. Iraq’s invasion of Kuwait and Turkey’s invasion of Cyprus also prompted virtually unanimous condemnation and economic and diplomatic sanctions, as well as military intervention.[...]These violations of territorial integrity highlight pervasive concerns regarding the enforceability of international law. This Note will explore this question by examining the events unfolding in Ukraine, categorizing Russia’s actions thus far, and assessing the potential mechanisms that might be brought to bear. Part I will overview the recent history of Russia’s involvement in Ukraine. Part II will discuss the presently-available international enforcement mechanisms and their general ineffectiveness. Part III will discuss how the broad ineffectiveness of international law is best expressed in the structure and practice of the U.N. Security Council. Finally, Part IV will offer recommendations for the improvement of current enforcement structures.This abstract has been taken from the author's introduction.
PubDate: Fri, 26 Apr 2024 10:11:01 PDT
- Decommodifying Cultural Heritage: A Linguistic Unpacking of "Cultural
Property"
Authors: Zoe Creamer
Abstract: The complex history of cultural property regulation in the United States, discussed below, suggests a lack of consensus regarding the definition of the legislation’s target. However, as this Note argues, it is futile to attempt crafting a precise definition of the objects qualifying for protection under such legislation without first addressing the dueling interests inherent in the operative words. An examination of the various aims of cultural property legislation reveals two competing goals. On one side exists the desire to protect cultural heritage for the world’s enrichment, and on the other is the desire to protect private ownership rights. These interests are embodied in the inherent tension between, and within, the words corresponding to these respective goals—“heritage” and “property”—and their interactions with what are arguably more straightforward supporting words, such as “objects” and “antiquities.” This Note argues that colloquial word associations with “property” contribute to the difficulties legislators and courts face in regulating and prosecuting cultural property trafficking. Due to these connotations, the international conventions using these terms have laid an insufficient foundation for American federal legislation aiming to regulate cultural property because the use of the word “property” characterizes cultural heritage as a commodity, rather than as something of value for entire communities.[...]This Note proceeds in four Parts. Part I provides an overview of relevant cultural property legislation spanning from the Hague Conventions of 1899 and 1907 to the Convention on Cultural Property Implementation Act of 1983. Part II explores the impact of connotations associated with the word “property” by analyzing observable usage as it exists in academic literature and case law. To add quantitative strength to the anecdotal observations, Part III introduces a corpus linguistics study which analyzes corpora, bodies of text consisting of a large number of sources, for common words and patterns. Part IV contextualizes the results of this corpus linguistics study within the relevant case law, showing how the phrase “cultural property” is unavailing in such disputes, and proposes new terminology as a solution.This abstract has been taken from the author's introduction.
PubDate: Fri, 26 Apr 2024 10:10:59 PDT
- Afterward: A Reply to Commentators
Authors: Gabriel J. Chin et al.
Abstract:
Authors Gabriel J. Chin and Paul Finkelman respond to the comments on their article, The "Free White Person" Clause of the Naturalization Act of 1790 as Super-Statute.
PubDate: Fri, 26 Apr 2024 10:10:56 PDT
- Paradoxical Citizenship
Authors: Amanda Frost
Abstract: In their article, The “Free White Person” Clause of the Naturalization Act of 1790 as Super-Statute, Gabriel J. Chin and Paul Finkelman make a powerful case that the Naturalization Act of 1790 is a “super-statute” that has shaped not only U.S. immigration law and policy, but also America’s conception of itself as a “White nation.”[...]This Comment explores the conflict between the Naturalization Act’s racial restrictions on citizenship (and its proponents’ vision of the United States as a White nation) and the Fourteenth Amendment’s Citizenship Clause (and its proponents’ vision of the United States as a multiracial nation). In important and interesting ways, the Citizenship Clause complicates the story Chin and Finkelman are telling. America has always been a bundle of contradictions, with a paradoxical view of itself as a White European nation on the one hand and a nation of immigrants that eschews bloodline and caste on the other. Those contradictions are on vivid display in the interplay between America’s worst impulses, as exhibited by the White supremacist naturalization law, and its better angels, displayed in the multiracial promise of birthright citizenship.[...]Part I of this Comment describes how the Citizenship Clause bestowed universal citizenship that extended beyond the newly freed slaves to the children of non-White immigrants. Birthright citizenship provides a counterpoint to the racial bars in the Naturalization Act, demonstrating that—if only fleetingly—the Reconstruction Congress embraced equality for all, including for children of non-White immigrants. Part II describes how the contradiction between the racially exclusive Naturalization Act and the universal Citizenship Clause played out in politics, law, and immigration policy in the following years. For decades, the government tried to reconcile the conflict between these two laws by denying birthright citizenship to non-Whites. Not until 1952 did the pendulum swing the other way, resolving this legal anomaly by eliminating all racial bars to naturalization.This abstract has been taken from the author's introduction.
PubDate: Fri, 26 Apr 2024 10:10:53 PDT
- Creating a Racialized Liminal Status: The 1790 Act and Interstitial
Citizenship
Authors: Rose Cuison-Villazor
Abstract: This Comment began with De La Ysla’s case to highlight the political status that Filipinos held when the Philippines was a U.S. territory. This Comment argues that this status, which a court would later describe as a “hybrid status ... the so-called ‘non-citizen national,’” was a racialized liminal political status with roots in the 1790 Naturalization Act (1790 Act). Professors Jack Chin and Paul Finkelman claim that the 1790 Act played a critical role in shaping “the very composition of the people of the United States” by including the “free white person” clause in the country’s first naturalization law. One of the goals of Congress in passing this law, as Chin and Finkelman contend, was to intentionally encourage the immigration of primarily White immigrants and ensure that the country would be a White nation. The 1790 Act did so not only by explicitly restricting the group of immigrants who were deemed racially eligible to become citizens but by providing the “foundation for a variety of other discriminatory laws” as well.[...]In Part I, I briefly situate the arguments presented in this Comment within the liminality literature and the work of other legal scholars who have theorized liminality in immigration law. I have previously used liminality as a concept to describe noncitizen nationals as liminal or interstitial citizens and explored how this status disrupts the framing of citizenship along a citizen or noncitizen binary paradigm. I build on this prior work by connecting interstitial citizenship to the 1790 Act.In particular, as I claim in Part II, the 1790 Act laid the foundation for the denial of citizenship to Filipinos at the turn of the twentieth century, which led to their interstitial political status. Congressional remarks surrounding the Treaty of Paris, which ended the Spanish American War, demonstrate the overarching sentiments against extending citizenship to residents of the Philippines, Puerto Rico, and Guam. Based on fears of millions of people of color acquiring U.S. citizenship, Congress subsequently passed laws that created a new political status that was liminal in nature. This in-between status would subsequently receive the support of the Supreme Court in the Insular Cases.Part III discusses the role that the 1790 Act played in naturalization cases filed by Filipinos residing in the United States. As that Part explains, courts interpreted subsequent amendments to the 1790 Act as indicative of Congress’s goal to continue to limit naturalization based on race and, in so doing, ensured that Filipinos would never be able to leave their racialized liminal status.The final Section explores the implications of this colonial history for Chin and Finkelman’s understanding of how the 1790 Act shaped the United States as a White nation.This abstract has been taken from the author's introduction.
PubDate: Fri, 26 Apr 2024 10:10:51 PDT
- The Road Not Taken: A Critical Juncture in Racial Preferences for
Naturalized Citizenship
Authors: Ming Hsu Chen
Abstract: In The “Free White Person” Clause of the Naturalization Act of 1790 as Super-Statute, Gabriel Jack Chin and Paul Finkelman argue that racist results in naturalization have arisen despite, or maybe because of, the race neutral interpretation. This happened in a manner that could have been predicted by the federal government’s attitudes toward non-White persons in the Naturalization Act of 1790 and the nearly unbroken chain of legal developments. This leads them to think of the law as a “super-statute.” While I agree that this is the path actually taken in history, I view the mid-1960s civil rights era as a “critical juncture” when the U.S. government could have taken a counterfactual path that was less racist. The counterfactual path would have required legal interpretations of Constitutional equality and statutory nondiscrimination that remained cognizant of racial implications of purportedly race neutral laws, which was briefly captured in language rights and voting rights statutes in the late 1960s to 1970s. But the egalitarian interpretations unraveled due to contradictions within the liberal national ideology that permitted a post-racial pragmatism about colorblindness that stalled the political incorporation of some non-White immigrants—Asian, Latino/a, Arab—due to their racialization as perpetual foreigners (racialized foreigners).
PubDate: Fri, 26 Apr 2024 10:10:48 PDT
- Separate, Sovereign, and Subjugated: Native Citizenship and the 1790 Trade
and Intercourse Act
Authors: Bethany Berger
Abstract: In 1790, the same year Congress limited naturalization to “free white persons,” it also enacted the first Indian Trade and Intercourse Act. The Trade and Intercourse Act may have even stronger claims to “super statute” status than the Naturalization Act. Key provisions of the Trade and Intercourse Act remain in effect today, and the Act enshrined a tribal, federal, and state relationship that profoundly shapes modern law. Unlike the Naturalization Act, the Trade and Intercourse Act reflected the input of people of color: it responded to the demands of tribal nations and—to a degree—reflected tribal sovereignty. While Indigenous people could not naturalize in 1790, early laws and policies encouraged them to become citizens of the United States. Indigenous citizenship, however, was a tool of subjugation, designed to undermine tribal sovereignty and thereby increase White authority. This history is inconsistent with Chin and Finkelman’s claim of a persistent vision of White citizenship, but it is consistent with allocation of citizenship as a tool of White power.
PubDate: Fri, 26 Apr 2024 10:10:45 PDT
- The "Free White Person" Clause of the Naturalization Act of 1790
as Super-Statute
Authors: Gabriel J. Chin et al.
Abstract: A body of legal scholarship persuasively contends that some judicial decisions are so important that they should be considered part of the canon of constitutional law including, unquestionably, Marbury v. Madison and Brown v. Board of Education. Some decisions, while blunders, were nevertheless profoundly influential in undermining justice and the public good. Scholars call cases such as Dred Scott v. Sandford and Plessy v. Ferguson the anticanon. Recognizing the contemporary centrality of statutes, Professors William Eskridge and John Ferejohn propose that certain federal laws should be recognized as part of legal canon because of their extraordinary influence and duration. These so-called “super-statutes” include the Sherman Antitrust Act of 1890 and the Civil Rights Act of 1964. This Article proposes that the Naturalization Act of 1790 is a super-statute whose impact is not fully appreciated. Responding to George Washington’s first Address to Congress and reflecting a complaint leveled against King George III in the Declaration of Independence, in the 1790 Act, the First Congress limited naturalization to “any alien being a free white person.” The racial restriction, as modified, would remain in effect until 1952, inducing White immigration and discouraging that of others. Through the mechanism of the “declaration of intent to naturalize,” added in a 1795 amendment, Congress made it possible for state and federal law to grant political and economic rights to White immigrants immediately upon arrival while ensuring that non-White immigrants could never enjoy them. The Naturalization Act of 1790 helps explain why, for example, as late as 1960, more than 99 percent of Americans were White or Black. It also resolves the question of the racial attitudes of the Framers—whether or not they supported slavery, a majority of them unambiguously conceived of the United States as a White country.Notwithstanding its racism, the Naturalization Act of 1790 has earned recognition as among the most effective pieces of legislation ever enacted by Congress. It deserves a place of dishonor alongside segregation laws, the Indian Removal Act, prohibitions on interracial marriage, and other laws establishing White supremacy.
PubDate: Fri, 26 Apr 2024 10:10:42 PDT
- Issues
Authors: Evan C. Zoldan
Abstract: The Federal Rules of Civil Procedure have issues—148 issues to be exact. Although the Rules use the term “issue” throughout their text, they do not use it in the same way each time. In some circumstances, the meaning of “issue” is made clear by surrounding context, minimizing any interpretive difficulty. But sometimes context does not clarify the term’s meaning, creating interpretive challenges. This Article argues that the ambiguous term “issue” found in Federal Rules of Civil Procedure 50 and 52 is best read to mean a “dispute of fact.” This reading best comports with judicial interpretations of Rules 50 and 52, best fits their history and purpose, and best connects them with conceptually related rules of civil procedure. In order to eliminate the ambiguity of the term “issue”—and avoid future interpretive difficulties—Rules 50 and 52 should be amended to clarify their meaning.
PubDate: Fri, 26 Apr 2024 10:10:40 PDT
- Table of Contents (v. 65, no. 5)
PubDate: Fri, 26 Apr 2024 10:10:37 PDT
- When All Else Fails: The Doctrine of Foreign Equivalents as a Bar to
Cultural Misappropriation
Authors: Stephanie H. Soh
Abstract: This Note argues that under trademark law, the doctrine of foreign equivalents can be utilized to prevent some aspects of legally enforced cultural misappropriation. While it would be impossible to solve cultural misappropriation in one written piece, this Note proposes that the doctrine can serve to prevent applicants from obtaining trademark protections for certain foreign words.Part I of this Note provides background on cultural misappropriation and the doctrine of foreign equivalents. Part II argues why the doctrine of foreign equivalents is poised to solve some of the harms of cultural misappropriation both in its structure and purpose. Part III proposes changes to the application of the doctrine that will aid not only in its consistency but also in its prevention of cultural misappropriation. Finally, Part IV discusses potential challenges and limitations to this proposed structure.This abstract was taken from the author's introduction.
PubDate: Thu, 11 Apr 2024 13:38:39 PDT
- The Uncertain Future of Tourism on Migrating Barrier Islands: How and Why
the Outer Banks of North Carolina Should Adjust to Growing Threats
Authors: Lillian Coward
Abstract: Erosion, storms, and the migration of the barrier islands that comprise the Outer Banks themselves are not new. The rising seas that have resulted from climate change have merely exacerbated what has always occurred. What is new, however, is the economic havoc that natural processes and disasters alike can wreak on the islands. Today, because climate change has accelerated natural island migration, individuals, local governments, and the federal government alike have a lot to lose in the fight against the tides.[...]This Note will evaluate a variety of potential solutions to the problems that pose nearly existential threats to development on the Outer Banks of North Carolina, with a specific focus on Dare County. Dare County is an important case study in the management of migrating barrier islands on the Outer Banks and elsewhere across the region because it is a site of many competing interests. Dare contains popular and relatively new tourist towns, neighborhoods for permanent residents, unique parklands, and historical landmarks alike. Part I will discuss the history of the islands— both in the long term as migrating barrier islands, and in the nearer term, tracing patterns of development. Part II will discuss current laws and policies, from national programs to county ordinances and their current flaws. Part II will also examine the costs of these policies amid the threats of erosion and climate change. Topics of discussion will include the National Flood Insurance Program (NFIP) as authorized by the Federal Emergency Management Agency (FEMA), North Carolina’s Coastal Area Management Act (CAMA), and a selection of noteworthy Dare County Ordinances. There are six municipalities with their own municipal codes within Dare County. This Note, however, largely will not discuss those municipal regulations because the areas that face the most imminent threats remain unincorporated. Part III will discuss a variety of potential solutions, and how no one solution could adequately address the multi-faceted problems that Dare County faces. Proposed solutions range from the enactment of rolling easements, to changes to local land use and development regulations, and to the institution of a mechanism that would force lenders to bear the brunt of the costs of flood insurance. Part IV will address counterarguments to the notion that sweeping changes are needed in Dare County.This abstract has been taken from the author's introduction.
PubDate: Thu, 11 Apr 2024 13:38:36 PDT
- The Road to Hell is Paved with Good Intentions: Deinstitutionalization and
Mass Incarceration Nation
Authors: Corinna Barrett Lain
Abstract: They say that the road to hell is paved with good intentions, and our failed implementation of deinstitutionalization in the 1970s is a prime example of the point. In this symposium contribution—a response to Jeffrey Bellin’s book Mass Incarceration Nation—I offer a historical account of deinstitutionalization of state mental hospitals, tracing how severely mentally ill patients were discharged from state hospitals and eventually made their way back to secure beds, but in our nation’s jails and prisons instead. Mental health and mass incarceration are not separate crises, I argue, but rather interconnected problems with an interconnected past that require an interconnected solution. The lessons of deinstitutionalization’s failures can inform how our decarceration story plays out, offering an opportunity to avoid the mistakes of our past and move toward a more just, humane, and equitable future—a future that takes the “mass” out of mass incarceration.
PubDate: Thu, 11 Apr 2024 13:38:34 PDT
- Critical Data Theory
Authors: Margaret Hu
Abstract: Critical Data Theory examines the role of AI and algorithmic decisionmaking at its intersection with the law. This theory aims to deconstruct the impact of AI in law and policy contexts. The tools of AI and automated systems allow for legal, scientific, socioeconomic, and political hierarchies of power that can profitably be interrogated with critical theory. While the broader umbrella of critical theory features prominently in the work of surveillance scholars, legal scholars can also deploy criticality analyses to examine surveillance and privacy law challenges, particularly in an examination of how AI and other emerging technologies have been expanded in law enforcement practices, and homeland and national security programs. To take one example of AI’s impact, this Article argues that mass incarceration’s technological interdependencies and trajectories can be better conceptualized through Critical Data Theory. This Article proposes that the theory can help assess the computational and AI impact of technological developments that may exacerbate mass incarceration and limit criminal procedure rights.
PubDate: Thu, 11 Apr 2024 13:38:31 PDT
