It is all set. I will begin my series of lecturees at UNC on the use and abuse of formal methods in political philosophy on Monday, February 20. Six two-hour lectures are planned, but we shall see whether that much time is required for what I have to say. The lectures will be videotaped and posted on YouTube, probably in one hour segments. I am looking forward to it.
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35 comments:
Very nice, looking forward to it as a Youtube viewer!
Great news!
bravo
Have fun, professor! I've been teaching fairly regularly for 11 years now; it still gives me a little high afterwards every time.
It is being reported today that five Black police officers employed by the Memphis Police Dept. have been charged with 2nd degree murder of Tyre Nichols, who was also Black. The Shelby County District Attorney will be releasing a video tomorrow of the attack by the police officers which resulted in Mr. Nichols’ death. Preliminary reports are that the beating was extremely savage, occurring after a traffic stop in which there was some sort of confrontation between Mr. Nichols and the police, and apprehension after he fled the scene. Presumably, the fact that Mr. Nichols may have been confrontational angered the officers, who were further angered when he took off on foot. But the use of deadly force in the absence of any threat of physical violence against the police officers is clearly unjustifiable and a violation of Mr. Nichols’ constitutional rights. Surely the officers knew this at some level of their consciousness.
What, frankly, has stunned me is that all five of the accused police officers are Black. Had their race not been disclosed, I would have assumed that this was a repeat of the Rodney King beating by White police officers, and was racially motivated. Some may say, e.g., s. wallerstein, that this reveals my naivete, that there is no reason to believe that members of one race will not mistreat other members of their own race – that it is no more surprising that Black police officers could brutally beat another African-American than White police officers doing so to another Caucasian. But I would have thought that Black police officers who probably have been the victims of racism themselves would demonstrate more self-control and empathy for another African=American. Is this a form of racisms on my part? As s. wallerstein has responded to me in previous comments, quoting W. H. Auden, those to whom evil is done do evil in return. But I would have thought that the reciprocal evil would not be perpetrated against other victims of the same evil. Some may claim that this is just an example of the tendency to violence which is part of the police culture, and has nothing to do with race. Still, I am surprised that Black police officers would savagely beat another African-American to the point of killing him. Am I alone regarding this sentiment?
Hi Marc,
As far as I know, there is a very high homicide rate of blacks killing blacks, not necessarily black police officers killing other blacks, but most black violence is directed against members of their own community.
I leave it to social psychologists to explain said phenomenon.
here's an article from The Guardian about the increase of the homicide rate against black women.
https://www.theguardian.com/world/2022/jun/25/homicide-violence-against-black-women-us
Homicide rates tend to be higher in poorer neighborhoods, which also tend, at least in larger urban areas, to have majority-minority populations. This relates to what s.w. is talking about, though I'm not purporting to have a particularly sophisticated explanation.
1. Thugs are thugs regardless of ethnicity or skin color, e.g. Border Patrol officers accused/convicted of excessive force, rape, etc. often seem to have names that end in a vowel. Gangs (tatoos, etc.) have been a problem with the Los Angeles County Sheriff and the department is plurality Latino.
2. Be interesting to know the educational level of those officers. IMO a four year real degree should be required prior to POST which s/b graduate level.
3. My initial reaction was that those guys are totally screwed. BLM, etc. isn't going to cut them any slack and the folks who instinctively defend white cops doing the same thing will fall back.
4. Administrative matters like this is one area where citizen actions can make a difference. Absent a seventeen y/o girl with a phone and BLM, etc., Derek Chauvin would have gotten away with murder.
5. The video must be really bad as they were outright fired soon after and arrests/charges quickly filed.
s.w., I believe recent stats show Black women buying firearms at record rates.
Being brutalized tends to make people brutal.
And poverty and discrimination (which generally comes with poverty in most places) brutalize.
There are exceptions, people will say and there's no doubt about that.
For example, in Chile participation in leftwing political movements turned a lot of people from very brutalized poor backgrounds into very scrupulous and ethical individuals.
Religion too in some cases, although some religions, such as fundamentalistic Islam,
may turn brutalized people into fanatically brutal killers.
But when God is dead and dreams of liberty, fraternity and equality are too, there seem to be very brakes on the tendency of people who have been treated brutally to lash out against whoever is at hand with brutality and violence.
There are two somewhat separate issues here: 1) police behavior (irrespective of the officers' race/ethnicity) and 2) the broader question about members of minority groups victimizing other minorities. In this particular case, the two issues overlap, but they shd be kept somewhat separate, istm. On "brutal conditions brutalize": that can be true, of course, but it can be hard to disentangle causes in particular cases.
A relevant question wd seem to be the culture of the Memphis Police Dept and its leadership, neither of which I know anything about.
Very interesting responses. I find this all very depressing.
https://www.cnn.com/videos/us/2023/01/27/tyre-nichols-ben-crump-police-video-memphis-sot-cnnt-vpx.cnn
I have a persona story about the abuse of power by police, and how the legal system and judges allow it to continue. The incident involved a traffic stop, in which I challenged the basis for the stop. I am sure that had I been Black, I would not be alive today to tell this story.
On February 1, 2020, I had spent the afternoon at the home of a witness in Ann Arbor relating to a lawsuit which I had filed in federal court. I was interviewing the witness in order to prepare an affidavit to attach to a motion I was going to file in court. It took several hours to finalize the wording of the affidavit, and I left her home at approximately 5:45 P.M. I was tired, and had not eaten all day. When I left, it was snowing. I was driving to my home East of Ann Arbor, taking the most direct route, when I came to an intersection where there was a police vehicle parked on a diagonal, blocking the lane I was driving in. The vehicle had its emergency lights flashing. I drove up to the vehicle and lowered my window to see if there was an officer nearby to give me directions regarding how to proceed. There was no officer in the vicinity of the vehicle. There were no traffic cones down; no flares; no barriers of any kind blocking the other lane, so I started driving around the police vehicle in the other lane, in which there was no oncoming traffic. I was the only car on the road. I had barely driven 100 feet when a police officer, who turned out to be a sheriff’s deputy, came running down the lane toward my car, with his hands waving. I immediately stopped.
The officer approached my car and I lowered my window. He said, “Didn’t you see my police car with its emergency lights flashing?” I said that I did, but there was no police officer nearby to tell me what to do, and I was on my way home. The officer said, “Well, you’re getting a ticket.” I said, “For what?” He said, there was a fatal car accident up ahead and I had trespassed onto a crime scene. I said, “How could I possibly know that there was an accident up ahead, and that it involved a fatality?” I asked the officer to just let me go with a warning and I would turn around and take an alternate route home. He said, “No, you’re getting a ticket.” At this point I raised my voice, and accused the officer of being negligent for not blocking both lanes of traffic with his vehicle; not putting any traffic cones or flares down to warn motorists not to proceed further. I was yelling. At no point did I use any profanity, or threaten the police officer. (The U.S. Supreme Court has held in several decisions that citizens have a 1st Amendment right of freedom of speech to argue with police officers, even curse at them, as long as they do not physically threaten them.) Another officer came up the road from the accident and asked for my license, which I gave him, along with my Bar card. He angrily returned the Bar card. Both officers were White.
I asked permission to get out of my car to take pictures of the scene showing the positions of his vehicle and mine, and he said, “Go ahead.” I took several pictures and returned to my vehicle. I then turned my camera to take pictures down the road, and the officer told me I could not take any pictures down the road, because it was a “crime” scene. He asked, “Do you want to get arrested for disorderly conduct?” Not wanting to get arrested, even though nothing I did constituted disorderly conduct under the law, I heeded his command and got back in my car. The other officer came back with the ticket and told me to “just leave,” which I did. I am convinced that the only thing that saved me from being dragged out of my car and severely beaten within an inch of my life was the fact that I am White, and they saw my Bar card. Had I been Black, and not an attorney, they would have beaten the crap out of me, and charged me with disorderly conduct and resisting arrest. I would now either be dead or severely maimed.
(Continued)
From there, the legal system got involved, which demonstrated the corruption of prosecutors and judges. The ticket for $500 charged me with failing to yield, a bogus civil infraction claim since there were no other moving vehicles in the vicinity to yield to. I returned the ticket to the court, denying culpability and demanding a trial. Before the hearing date was set, I sent a letter to the prosecutor in which I quoted the Michigan statute on failing to yield and stated that there was absolutely no basis for the charge and demanded that the ticket be dismissed. I received an email from the prosecutor stating that I had brought up some valid points and he was going to dismiss the ticket. I did not have to appear in court. I sent him an email thanking him for his integrity.
Two days later, I received certified mail letter from the Washtenaw County Sheriff’s Dept. which contained a new ticket charging me with “Disobeying A Police Officer While Directing Traffic,” a criminal misdemeanor which, if I were convicted, could result in my disbarment. The new ticket was signed by the same sheriff’s deputy who had signed the first ticket and refused to let me leave with a warning. The new ticket charged me with having committed this offense on July 24, 2020, at 5:45 A.M. – i.e. I had committed a different offense 5 months after the first offense, at a totally different time, at the very same intersection – a cosmological coincidence with the likelihood of 0. I wrote a letter to the prosecutor challenging the issuance of this new ticket after he had dismissed the original ticket. He responded that it was out of his hands, that it was a new ticket which the police had a right to issue. I wrote back, again quoting the language from the relevant statute, which makes it a criminal offense to disobey a police officer while the officer is directing traffic, and in this case there was no police officer directing traffic. He demurred, stating that his obligation was to represent the interests of the police. I responded that that was not his obligation – that his obligation was to represent the people of Michigan, not the police, and the he had an ethical obligation to decline to prosecute since there was no probable cause to charge me with a criminal offense I had not committed. He refused to dismiss the second ticket.
So, I filed a motion to dismiss the ticket, on two grounds: (1) that the sheriff’s deputy had committed perjury by accusing me, under oath, of having committed a second offense on a different day, different time, at the same location, when I had been in bed with my wife; (2) that, regardless, I had not committed the offense in question because there was no police officer in the vicinity of the patrol car directing traffic. The prosecutor opposed the motion, stating that the date and time on the second ticket was due to a computer glitch, and that the deputy had been directing traffic through his vehicle, even if he was not near his vehicle. At the hearing, the judge allowed the prosecutor to amend the ticket to change the date to February 1, 2020, and change the time to 5:50 P.M. Regarding the offense itself, I argued that the statute requires that there be a police officer directing traffic, a human being, not an inanimate object with its emergency lights flashing. The judge rejected my argument, agreeing with the prosecutor that a police officer can direct traffic from a distance through his patrol car – a ruling which contradicted the clear, unambiguous wording of the statute itself, and which violated case law about how statutes, particularly criminal statutes, are to be interpreted. I appealed that decision to the next higher court and filed a brief requesting reversal of the lower court decision and dismissal of the ticket. The prosecutor failed to file opposing my brief, and the appellate court granted my appeal and dismissed the ticket.
(Continued)
While the appeal was pending, I filed a lawsuit in federal court alleging that the conduct of the deputy sheriff and the prosecutor was taken in retaliation of my having argued with the deputy sheriff and thereby violated my 1st Amendment right to free speech. I named the governmental employers of both the deputy and the prosecutor. (I did not name the prosecutor, because the S. Ct. has ruled that prosecutors have absolute immunity from being sued, except under very narrow circumstances.) In the course of discovery, I obtained an exchange of emails between the prosecutor and the deputy sheriff, in which the prosecutor stated that he was going to dismiss the first ticket, which would make me think that I was a “badass,” and then recommended that the deputy sheriff issue a second ticket charging me with the criminal offense of disobeying him while he was directing traffic. He also suggested that a ticket be issued against me for disorderly conduct, which they would agree to dismiss if I pled guilty to the disobeying a police officer ticket. The deputy sheriff responded to the prosecutor’s proposal by stating, “Good plan!”
The email exchange demonstrated several things: (1) That the prosecutor’s assertion to me that his hands were tied and that he had nothing to do with the issuance of the second ticket was a lie; (2) that the threat to charge me with disorderly conduct was an admission that they were retaliating against me for having argued with the police officer, thereby violating my right to free speech; and (3) they were both involved in a conspiracy to violate my constitutional rights. The deputy sheriff and his employer moved to dismiss the claims against them, arguing that I did not have sufficient evidence to prove that issuance of the second ticket was in retaliation for exercising my 1st Amendment right. Guess what- the federal judge agreed, claiming that the claim was “tenuous.” Moreover, nowhere in his decision did the judge – a federal judge, mind you, who is supposed to be of a higher caliber than a state judge, who is recommended by the President and appointed by Congress, and has life-time tenure – did the judge make reference to the email exchange which I had attached to my brief, and which proved that they had engaged in an agreement, i.e., a conspiracy, to violate my constitutional rights. Moreover, in his decision the judge included a footnote, stating that anyone with common sense would know not to drive past a patrol car with its emergency lights flashing. But that was not the issue – the issue was whether, regardless whether I had any common sense, had I violated the law. Moreover, by including this remark in his decision, the judge violated the Federal Rules of Civil Procedure, under which a judge in rendering a decision is required to assume that all of the allegations made by the non-moving party, and the reasonable inferences made from those allegations, are true. The judge instead improperly interjected his personal views regarding my lack of common sense.
After the judge dismissed the claims against the deputy sheriff and his employer, the governmental employer of the prosecutor moved to dismiss as well. Although a prosecutor has absolute immunity, the S. Ct. has held that where a governmental employee has violated the law, the employee’s employer can be held liable for the employee’s actions if the employee in question is a policy-making employee of the governmental agency. Well, in this case the prosecutor is a policy-making employee who decides whom to prosecute and for what. I filed my response opposing the motion last week. I am not optimistic that I will prevail and that the judge will deny the motion to dismiss, in which case I will file an appeal with the Sixth Circuit Court of Appeals in Cincinnati.
(Contineud)
When I was a partner in a law firm, I used to have a framed copy of Kafka’s allegory “Before The Law” hanging on my wall. The allegory is essentially a cynical critique of the law – whether the law is the law of Czechoslovakia or the law of Russia or the U.S. – that the law consists in a series of hoops and fences through which litigants must crawl and climb over, only to have the law slammed in their face at the end. I have often thought that instead of the inscription which appears on the lintels of courts which states “Equal Justice Under Law,” it should state “Abandon All Hope Ye Who Enter Hear.” So, why do I continue to practice law? Hope, the hope that with perseverance and cogent legal arguments, eventually, in some cases, justice will prevail. Also, I don’t know how to do anything else, and, as my comments on this blog attest, I like to argue.
Corection:
"Abandon All Hope Ye Who Enter Here."
Marc,
I've been stopped by cops in several countries and it's senseless to argue with them.
They are always right.
If you enjoy arguing (and you apparently do), that's what philosophy blogs are for.
s. wallestein,
I have an advantage that you and most others do not have. Since I am a licensed attorney, I can continue the argument in a court of law without having to pay another attorney $500/hr to represent me, and contrary to the familiar adage, I am not a fool. I am very good at what I do.
Marc
Someone long ago explained to me there is a mafia that controls things everywhere- it was my commander in the IDF, I think. This is a tough call- of course you want to stand up for what's right and of course we don't want a police state, but it's wise to pick your fights.
These people have absolute power in a very limited purview and they're probably ass holes about it.
It's like that scene in Pulp Fiction when one of the characters stumbles into some kind of I think a pawn shop and in that shop the owner is the law.
It sounds like you are so idealistic and want the system to bring about justice so much that you put yourself at risk.
Would you do it again knowing what you do now?
Howard,
First, I want to say that I am impressed (probably unlike most of the commenters on this blog) that you served in the IDF.
Second, would I do it again? Absolutely. For American citizens (and immigrants who wish to become citizens, or just want to live in the U.S.), the United States government and its legal and judicial system are the only game in town. Unlike the pawn shop, it has a written Constitution, which, with all of its imperfections (with several commenters on this blog repeatedly point out) it is, in my opinion, still a pretty remarkable document. As is true with religions, the deficiencies in our government and its legal system are not attributable to the principles and rules which they embody, but to the imperfections, flaws and hypocrisies of those whose responsibility it is to implement them – the legislators, attorneys, prosecutors and judges (particularly the judges). The only way to fulfill those principles and rules and correct their erroneous and defective implementation by the humans whose responsibility it is to enforce them is to fight to redress the erroneous implementation in court, even with their defective judges, and to appeal their erroneous decisions to the next higher court, and then to the Supreme Courts of each state and of the U.S. It can be done. I have done it. And as rare as success may be, it is worth. It is worth all the arduous work and the periodic disappointments, because, as you know, and as it states in Deuteronomy, “Justice, justice shall you seek.”
Marc,
Once the appellate court dismissed the ticket, you had basically won. The ticket was invalidated and you didn't have to pay it.
Not being satisfied with that victory, you decided to file a suit in federal court alleging violation of your constitutional rights (which it is of course your right to do). You say the district court is likely to rule against you, at which point you will file an appeal with the Sixth Circuit. What that probably means as an initial matter is that some judge's law clerk in the Sixth Circuit is going to have to spend time with your appeal and give the judge a memo about it (or maybe they have a different process, I don't know, I was never a clerk for a federal appellate judge, or a clerk for any judge for that matter). The point is that the suit you filed is taking up scarce judicial resources that could be used in dealing with suits that allege, frankly, more serious wrongs and grievances.
Marc,
It's not the 500 dollars (or more) that I'd have to pay to a lawyer to defend me that stops me from arguing with the cops, but very simply, that seems like an incredible time-consuming hassle when it's so easy just to agree with everything cops or other government bureaucrats say.
I'd rather listen to Mozart.
Before you jump on me, let me assure you that there are many cases where it's worthwhile to take it to the courts, but not in the case you mention above or similar instances.
I assume that daily life is full of minor instances of abuse of power and I accept that.
Just as I don't argue with the many bullies I run into daily in the streets or in the subway, I generally don't argue with bullies in uniform or with a badge.
LFC and s. wallerstein,
I vehemently disagree with both of you. The case, and the appeal, deal not only with the violation of my 1st Amendment rights, and the 1st Amendment rights of every citizen who gets pulled over by a police officer and who is intimidated into just shutting up and being mistreated by police abusing their power – like Tyre Nichols who had the audacity to talk back to a police officer, but with corruption and abuse of power by a prosecutor who engaged in a civil conspiracy to violate my constitutional rights. Such conspiracies are not just limited to 1st Amendment rights, but extend to police use of excessive force, to denial of Miranda rights, to - the list goes on and on. And a judge who condones this conduct, who deliberately misapplies his power and violates the standard of review which he is constitutionally bound to uphold, who took an oath of office to uphold, needs to be challenged and called to account for violating his office. This is worth taking up the precious time of the appellate judges and their clerks – to send a message to the deputy sheriff, to the prosecutor, and to the judge who is turning a blind eye to their misconduct that their violation of citizens’ constitutional rights will not be tolerated, however insignificant they think that constitutional right is. Most people don’t have the education, the legal means and the time to do this. I do, and I intend to use them, and I have no regrets and make no apologies for doing so.
P.S.:
When should police officers be called to account for violating the rights of citizens’ whom they illegally stop and ticket? Only after they have used excessive force and killed an innocent man? That may deter the police from using excessive force in the future, which is a good thing, but it won’t stop them from making illegal stops and violating the constitutional rights of those whom they stop and heir intimidation and abuse of power.
"When should police officers be called to account for violating the rights of citizens’ whom they illegally stop and ticket? Only after they have used excessive force and killed an innocent man?"
For me the question isn't whether police officers shouldn't be called into account for violating the rights of citizens whom they illegally stop and ticket, but rather whether I
would go to all the hassle of doing that and I wouldn't.
I accept that in every social order there are going to abuses of power by those in power and that if you give a bunch of people a gun and the right to ticket and arrest others, they are going to abuse that power from time to time just as all other groups with a bit of power abuse it, including university professors, doctors, government bureaucrats, etc.
At some point you have to put limits on that power, but in the case you mention I myself would not feel called upon to go to the trouble to put limits. If you feel called upon,
I'm not going to moralize about it in any case.
s. wallerstein,
I never stated that I expected you, or others in your position, to take such issues to court. But if this happened to you in Michigan, I would be more than happy to represent you pro bono, and you would not even have to concede that I was right regarding all the other disputes we have had on this blog. You would just have to pay for the court costs.
i am currently representing 8 clients in 12 different lawsuits in state and federal court, including in federal court in New Jersey. I charge them nothing. They only are required to pay the court costs. And thee are cases where they are the underdogs, where I believe their rights have been clearly violated, but they could not find any other attorney to take their case. And they all appreciate what I am doing for them, and will not relent, I will not abandon them, like many attorneys do, and, if necessary, I will take their cases to the Supreme Court of Michigan, if it is a state case, or to the Supreme Court, if it is a federal case - as long as I have breath to breathe. in fact, I am today preparing a motion and brief to strike two pleadings which were filed against one of my clients in federal court yesterday.
Marc,
Thank you very much for your generous offer of professional services.
However, as I stated above, my tendency is to avoid bureaucratic and legal hassles whenever possible.
So if by chance I am in Michigan and that occurs, instead of taking the issue to court, I would prefer to use the money that would otherwise go to pay court costs to take you and your wife to dinner in a good vegetarian or vegan restaurant.
s. wallerstein,
That's a deal.
Marc, is this a general problem in your county? Maybe you should run for DA. Should you win, you could easily make that prosecutor's life difficult. One thing to always keep in mind is that in any line of work a certain number of folks are going to be operating at the limits of competency/honesty and hold the position mostly because inertia.
How was a fatal automobile accident a crime scene? If the number of available officers was limited so the car had to be left unmanned I can see not blocking both lanes which would have prevented other responders from accessing the scene. Not setting a cone or flare seems a problem as that only takes a few seconds. While I wouldn't have gone past the car, the cop should have just sent you back with a warning and set out a cone or two.
LFC, if the police and a prosecutor will conspire against a citizen over something this petty, they will likely do it to others over more serious matters. A cop stole a bayonet from me a number of years ago. I'm sure it was subsequently planted on someone. That was unprovable on my part but Marc has the receipts so good for him.
aalll,
Thank you for your comment.
Yes, the claim that a fatal one vehicle accident (the vehicle, as far as I understand, slid off the road due to the inclement weather, and hit an obstruction, and killing the driver, and perhaps a passenger. This was of course not a crime scene. I can understand that given the inclement weather, the cold, and the darkness, the officers were stressed, but that did not give them the right to take their frustration out on me, They abused their power, as police officers often do. The prosecutor compounded the matter with his dishonesty, He was treating it as some major murder crime on which he could make a name for himself. He should actually be disbarred. Contrary to LFC's take, this caused me a lot of aggravation - having to appear in court several times (via Zoom), and the uncertainty of the possible effects on my license to practice law. The trial judge was intellectually dishonest. Unfortunately, there are a lot of judges like him.
Regarding running for office, I tried that once, as I described in a previous post comment. I am too outspoken and candid to make an electable politicians.
Marc,
That blacks can have racist attitudes towards other blacks is not surprising.
There are very few blacks in Chile, mostly Haitian immigrants, and so I am not familiar with their attitudes, but members of oppressed groups often have stereotyped attitudes about that same group.
I know several feminist women, one of them even a feminist academic and they all at times make sexist remarks about other women that I myself would never dare to express aloud, even if I might think them.
I believe that we've previously discussed in this blog the stereotypes about and prejudices against Jews from Russia and Poland that Jews from Germany or Austria had, in my grandparents' generation at least. My father had similar prejudices against Argentinian Jews.
However, what is surprising is that they would harbor such violent prejudices that they would beat the guy to death. I suspect that there was another trigger there, something the victim said, a look he gave them, etc., that led them to beat him to death.
s. wallerstein,
I share your surprise regarding the brutality with which the Black police officers attacked Tyre. Actually, he did not really do anything which could be regarded as antagonizing them. This is what makes what they did even more horrendous, and in fact troubling, especially for Blacks. You would have to watch the video (there are actually 4 parts, but the 1st and 4th are the most violent) to appreciate how reprehensible their conduct was. In the 1st segment, he is being dragged out of his car. You don’t even know why he is being dragged out of the car, except you assume he committed some traffic offense (which allegedly was reckless driving, which the Memphis police have now acknowledged was not the case), and they start screaming at him to lie down – and he is already lying down and screaming as they tased and pepper sprayed him. In order to get away from their assault, he runs away, which they use as an excuse to hunt him down and literally beat the crap out of him (in the 4th segment), repeatedly kicking, punching him in the head, hitting him with a police baton. It is sickening to see. I saw interviews with some Black commentators this morning who said that it is the lack of provocation on his part that is particularly scary – that there is nothing a Black person can avoid doing which will keep them safe from such police brutality.
Yes, the excess brutality is the weird thing.
While black police officers may have some racist attitudes, they're not the KKK: that is, you would not expect them to seek out a totally innocent black person and beat them to death.
You might expect black police officers to be a bit rougher when dealing with other blacks than with middle class whites, but not to turn into a homicidal lynch mob.
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