Students for Fair Admissions v. Harvard

# Students for Fair Admissions v. Harvard

## Abstract

Students for Fair Admissions v. Harvard, 600 U.S. 181 (2023), is a landmark decision of the Supreme Court of the United States in which the court held that race-based affirmative action programs in college admissions processes violate the Equal Protection Clause of the Fourteenth Amendment. With its companion case, Students for Fair Admissions v. University of North Carolina, the Supreme Court effectively overruled Grutter v. Bollinger (2003) and Regents of the University of California v. Bakke (1978), which validated some affirmative action in college admissions provided that race had a limited role in decisions.

In 2013, Students for Fair Admissions (SFFA) filed suit against Harvard University in U.S. District Court in Boston, alleging that the university's undergraduate admission practices violated Title VI of the Civil Rights Act of 1964 by discriminating against Asian Americans. In 2019 a district court judge upheld Harvard's limited use of race as a factor in admissions, stating lack of evidence for 'discriminatory animus' or 'conscious prejudice'.

In 2020, the U.S. Court of Appeals for the First Circuit affirmed the district court's ruling. In 2021, SFFA petitioned the Supreme Court, which agreed to hear the case. Following the appointment of Justice Ketanji Brown Jackson, a member of the Harvard Board of Overseers at the time, the cases were split with Jackson recusing from the Harvard case while participating in the North Carolina one.

On June 29, 2023, the Supreme Court issued a decision in Harvard that, by a vote of 6–2, reversed the lower court ruling. In writing the majority opinion, Chief Justice John Roberts held that affirmative action in college admissions is unconstitutional. Because of the absence of U.S. military academies in the cases, the lack of relevant lower court rulings, and the potentially distinct interests that the military academies may present, the Court, limited by Article III, did not decide the fate of race-based affirmative action in the military academies.

## Background

The historical and legal background of the case spans several decades from the 1978 case Regents of the University of California v. Bakke over the 2003 case Grutter v. Bollinger to the 2016 case Fisher v. University of Texas (2016). The U.S. Supreme Court ruled in Bakke, a 1978 landmark decision, that affirmative action could be used as a determining factor in college admission policy but that the University of California, Davis School of Medicine 's racial quota was discriminatory. The Court upheld this case in Grutter v. Bollinger, a 2003 landmark decision. Concurrently, the Court ruled that the points system used by the University of Michigan to favor underrepresented minorities was unconstitutional in Gratz v. Bollinger. The Court vacated Fisher v. University of Texas (2013) and upheld the lower court's decision to apply strict scrutiny to the University of Texas at Austin 's race-conscious admissions policy in Fisher v. University of Texas (2016). In Fisher II, strict scrutiny requires that the use of race serve a "compelling governmental interest"—like the educational benefits that stem from diversity—and be "narrowly tailored" to satisfy that interest. Institutions that receive federal funding, such as Harvard University, are subject to Title VI of the Civil Rights Act of 1964, which outlaws racial discrimination.

For years prior to the decision which took place in 2023, affirmative action in the United States was considered by some to be a wedge issue among Asian Americans. It was contended in such circles that the practice drew criticism from white and Asian Americans, but support from African Americans, and mixed support among an ethnic designation, Hispanic and Latino Americans. In polling for affirmative action, answers varied depending on how the question is asked, suggesting ambivalence. Among Democrats and Republicans, there is a divide.

Opposition to affirmative action emerged in the neoconservative journal The Public Interest, particularly with editor Nathan Glazer 's book Affirmative Discrimination: Ethnic Inequality and Public Policy (1975). In the Roberts Court, Chief Justice John Roberts questioned the benefits of diversity in a physics class in Fisher II. Justices Clarence Thomas and Samuel Alito have opposed affirmative action; the remaining three conservative justices had no track record of opposing affirmative action prior to the ruling, although a 1999 article Justice Brett Kavanaugh wrote in The Wall Street Journal signaled he would end it. The liberal Sotomayor has repeatedly and proudly said that she is a “product of affirmative action” and has defended affirmative action in previous cases before the Court.

## District Court case

### Lawsuit

SFFA filed a lawsuit in federal district court against Harvard University on November 17, 2014, representing a group of anonymous Asian American plaintiffs rejected from the university. The suit made the claim Asians were being discriminated against in favor of whites. SFFA was founded by conservative legal strategist Edward Blum, who also founded the Project on Fair Representation, with a goal to end racial classifications in education, voting procedures, legislative redistricting, and employment. Blum participated in cases such as Bush v. Vera, Shelby County v. Holder, and Fisher v. University of Texas. The SFFA case was the first high-profile case on behalf of plaintiffs who were not white, and who had academic credentials that, according to Vox, were "much harder to criticize." The lawyers for SFFA stated that the initial hearing focused on the issue of discrimination against Asian American applicants, instead of trying to challenge affirmative action in general.

Certain Asian American advocacy groups filed amicus briefs in support of SFFA, believing that they or their children are discriminated against in college admission processes. Other Asian American advocacy groups filed amicus briefs in support of Harvard. On May 15, 2015, a coalition of more than 60 Asian American organizations filed federal complaints with the United States Department of Education and Department of Justice against Harvard University. The coalition asked for a civil rights investigation into what it described as Harvard's discriminatory admission practices against Asian American applicants. The complaints at the Department of Education were dismissed in July 2015 because a lawsuit making similar allegations had already been filed by Students for Fair Admissions (SFFA) in November 2014.

However, in 2017, the coalition resubmitted their complaints to the Department of Justice under the Trump administration. It opened an investigation into allegations against Harvard's policies, and that investigation was ongoing as of February 2020.

### Plaintiff allegations

In the lawsuit, the plaintiffs claimed that Harvard imposes a soft quota of “racial balancing" that artificially depresses the number of Asian-American applicants admitted to Harvard. The plaintiffs maintained that the percentage of Asians admitted to Harvard was suspiciously similar year after year despite dramatic increases in the number of Asian American applicants, as well as the size of the Asian American population.

During the lawsuit, the plaintiffs gained access to Harvard's individualized admissions files from 2014 to 2019 and aggregate data from 2000 to 2019. The plaintiffs also interviewed and deposed numerous Harvard officials. From these sources, the plaintiffs alleged that Harvard admissions officers consistently rated Asian American applicants, as a group, lower than others on "positive personality traits," such as likability, courage, and kindness. The plaintiffs alleged that Asian Americans scored higher than applicants of any other racial or ethnic group on other admissions measures like test scores, grades and extracurricular activities, but the students' personal ratings significantly hampered their admissions chances. The plaintiffs also claimed that alumni interviewers (who, unlike admissions officers within Harvard, actually met individual applicants) gave Asian Americans personal ratings comparable to white applicants. Harvard's admissions staff testified that they did not believe that different racial groups have better personal qualities than others, but nevertheless, Asian applicants as a racial group received consistently weaker personal scores over the period surveyed, and Harvard's admissions office rated Asian Americans with the worst personal qualities of any racial group. African-Americans, on the other hand, consistently scored the lowest on the academic rating, but highest on the personal rating.

Peter Arcidiacono, a Duke University economist testifying on behalf of the plaintiffs, concluded that Asian American applicants as a group performed stronger on measures of academic achievement (which Arcidiacono measures using applicants' SAT and ACT scores) and extracurricular activities. Despite this, they received a statistically significant penalty relative to white applicants in the "Personal Rating" and "Overall Rating" assigned by Harvard officials. As a result, the plaintiffs allege Asian American applicants have the lowest chance of admission of all racial groups in the United States, despite scoring highest in all objective measurements. Arcidiacono testified that removing the personal score penalty of Asian applicants relative to white applicants would result in a 16% increase in the number of admitted Asian Americans.

Arcidiacono suggested that the applicant's race played a significant role in admissions decisions. According to his testimony, if an Asian American applicant with certain characteristics (like scores, GPAs, and extracurricular activities, family background) would result in a 25% statistical likelihood of admission, the same applicant, if white, would have a 36% likelihood of admission. Hispanic and Black applicants with the same characteristics would have a 77% and 95% predicted chance of admission, respectively.

Arcidiacono's report also alleges that Harvard's preferential treatment of African-American and Hispanic applicants is not the result of the university's efforts to achieve socioeconomic diversity of its student body, as "Harvard admits more than twice as many non-disadvantaged African-American applicants than disadvantaged African-American applicants." He also stated that if Harvard were to remove all other factors for admissions preference— racial preferences for under-represented minorities, penalties against Asian Americans, and legacy and athlete preferences— the number of Asian-American admits would increase by 1,241 over six years, a 50% increase.

The plaintiffs also claimed that Harvard's own Office of Institutional Research found a statistically significant penalty against Asian American applicants in an internal investigation in 2013, but had never made the findings public or acted on them. Plaintiffs and commentators have compared the current treatment of Asians with the Jewish quota in place in the early 20th century, which used the allegedly “deficient” one-dimensional personalities of immigrant Jews and their alleged lack of leadership traits as the reason for excluding non-legacy Jews in elite universities, including Harvard.

### Defendant responses

Harvard denied engaging in discrimination and said its admissions philosophy of considering race as one of many factors in its admissions policy complies with the law. The school also said that it receives more than 40,000 applications, that a large majority of applicants are academically qualified, and as a result, it must consider more than grades and test scores to determine admission for its 2,000 available slots. Harvard also stated that its personal rating "reflects a wide range of valuable information in the application, such as an applicant’s personal essays, responses to short answer questions, recommendations from teachers and guidance counselors, alumni interview reports, staff interviews, and any additional letters or information provided by the applicant."

The school also said the percentage of Asian American students admitted has grown from 17% to 21% in a decade, while Asian Americans represent around 6% of the U.S. population. Harvard further claimed that it had studied more than a dozen race-neutral admissions alternatives and allegedly found none "promote Harvard’s diversity-related educational objectives as well as Harvard’s … admissions program while also maintaining the standards of excellence that Harvard seeks in its student body."

Using the same data given to the plaintiffs, UC Berkeley economist David Card testified on behalf of Harvard and claimed in a report that SFFA's analysis of the personal ratings excluded applications from a sizable percentage of the applicant pool, personal essays, and letters of recommendation from teachers and guidance counselors and that there was no statistically significant difference in personal scores compared to white students. Furthermore, Card claimed that if SFFA's analysis showed that the personal ratings assigned to Asian Americans were unexpectedly poorer, Asian Americans also unexpectedly scored higher on the academic rating than other racial groups, which would add complexity to the claim that Harvard is intentionally discriminating against Asian Americans. In response to Arcidiacono's analysis, Harvard contended that Arcidiacono had "mined the data to his advantage" by excluding applicants that received preferable treatment due to being legacies, athletes, the children of staff and faculty, including Asian-Americans. Harvard also argued that the documents the plaintiffs alleged as proof of discrimination against Asian Americans represented "a preliminary and incomplete analysis" that Harvard's Office of Institutional Research (OIR) conducted "without the benefit of the full admissions database or a full understanding of the admissions process" and that " OIR documents themselves directly acknowledge various missing data and aspects of the admissions process that are not taken into account."

Various students, alumni and external groups filed amici briefs on both sides.

### Lower courts

In 2013, SFFA filed suit against Harvard in U.S. District Court in Boston, stating that the university's admission practices were unconstitutional. In 2019 a district court judge upheld Harvard's limited use of race as a factor in admissions, stating that SFFA had provided no evidence that Asian Americans, or any other racial groups, had been harmed by it. In 2020, the U.S. Court of Appeals for the First Circuit affirmed the district court's ruling. In 2021, SFFA petitioned the Supreme Court, which agreed to hear the case.

In October 2019, Judge Allison D. Burroughs ruled that Harvard College's admissions policies do not unduly discriminate against Asian Americans. While the system is "not perfect", Burroughs ruled, it nonetheless passes constitutional muster. In her ruling, Burroughs states that there were "no quotas" in place at Harvard, despite acknowledging that the school attempts to reach the same level of racial diversity each year and "uses the racial makeup of admitted students to help determine how many students it should admit overall."

In February 2020, SFFA filed an appeal in the United States Court of Appeals for the First Circuit. The court heard oral arguments in mid-2020 and ultimately ruled in late 2020 in favor of Harvard, concluding that Judge Burroughs had not erred in her ruling and major factual findings. The Justice Department filed friend-of-the-court briefs in both the initial hearing and the appeal, arguing that Harvard imposes "a racial penalty by systematically disfavoring Asian American applicants".

## Supreme Court

SFFA petitioned the Supreme Court to review both the First Circuit's decision in the Harvard case, which focused on the impact of the admissions process on Asian Americans, and a similar decision from the Middle District of North Carolina, Students for Fair Admissions v. University of NC, et al., which focused on the impact on both Caucasian and Asian American applicants at the University of North Carolina and which had been decided in the school's favor in October 2021. Both petitions sought the court to overturn Grutter v. Bollinger. In Harvard, SFFA asked if Harvard's admission practices were in violation of Title VI of the Civil Rights Act given possible race-neutral selection processes, while in North Carolina, they asked if a university can reject a race-neutral admission process if they believe they need to protect the diversity of the student body and quality of education.

Harvard filed an opposing brief seeking to have SFFA's petition rejected by the Supreme Court. In June 2021 the Court requested that the U.S. government submit a brief of its stance on the case, and in December the Solicitor General of the United States under the Biden administration urged the Supreme Court to reject the appeal.

The Supreme Court certified both petitions on January 24, 2022, and consolidated them under Harvard. After Ketanji Brown Jackson testified during her confirmation hearing that she would recuse herself from the case because she is on the Harvard Board of Overseers, the Supreme Court separated the two cases, allowing her to participate in the UNC case. Both cases were argued on October 31, 2022.

### Amicus briefs

The Court received thirty-three amicus briefs in support of SFFA, and sixty in support of Harvard and UNC.

Among those in support of SFFA, fourteen senators and 68 representatives, as well as 19 states, wrote that Grutter was inconsistent with the Equal Protection Clause. Others wrote that the admission policies at Harvard and the University of North Carolina were discriminatory in that any favoritism towards one race results in discrimination towards others. Other arguments in the SFFA-supporting briefs, including those from Cato Institute and the Pacific Legal Foundation, considered that affirmative action policies are generally arbitrary, do not enhance diversity on campuses, and also violate the allowance for federal funding under Title VI.

In support of the universities, both the Biden administration and several current and former senators wrote that historically, both the legislative and executive branches have worked to combat racial imbalances through affirmation action and are not intended to violate Title VI. Sixty-five senators and representatives stated that despite both Brown and Grutter, segregation at K–12 schools continues to worsen, and affirmative action policies are needed to fight racial imbalance. Several groups, including the American Bar Association, the American Psychological Association, and the American Civil Liberties Union, wrote to support that racial diversity is essential to college and beyond.

A number of other Asian American groups have submitted amicus briefs in support of race-conscious admissions policies and Harvard. They include the Asian American Legal Defense and Education Fund, representing itself and 44 other Asian American groups and higher education faculty, and Asian Americans Advancing Justice - Los Angeles, representing several Asian American students. The NAACP Legal Defense and Education Fund filed a brief in support of Harvard, representing 25 Harvard student and alumni organizations consisting of "thousands of Asian American, Black, Latino, Native American, and white students and alumni."

### Opinions

Both Harvard and North Carolina were decided jointly on June 29, 2023, with the Court ruling that race-based admissions adopted by both Harvard University and UNC were unconstitutional under the Equal Protection Clause of the Fourteenth Amendment. Jackson had recused herself in Harvard, resulting in a 6–2 vote, while she joined the dissents in North Carolina, resulting in a 6–3 vote there. The majority opinion, written by Roberts, stated that the use of race was not a compelling interest, and the means by which the schools attempted to achieve diversity (tracking bare racial statistics) bore little or no relationship to the purported goals (viewpoint and intellectual diversity and developing a diverse future leadership). It was noted however that this prohibition on the use of race in deciding who would be accepted did not stop universities from considering a student's discussion of how their race has impacted their life "so long as that discussion is concretely tied to a quality of character or unique ability that the particular applicant can contribute to the university."

In an unusual move, both Thomas and Sotomayor elected to read portions of their separate opinions from the bench as part of the announcement of the decision. Thomas's reading of his concurrence was the first time any justice had read a concurring opinion from the bench in almost 10 years.

#### Majority opinion

In the majority opinion, Justice Roberts wrote that the Equal Protection Clause of the Fourteenth Amendment applies "without regard to any difference of race, of color, or of nationality" and thus must apply to every person. As such, "Eliminating racial discrimination means eliminating all of it", adding that "For 'he guarantee of equal protection cannot mean one thing when applied to one individual and something else when applied to a person of another color. ' " Roberts wrote that the affirmative action programs "lack sufficiently focused and measurable objectives warranting the use of race, unavoidably employ race in a negative manner, involve racial stereotyping, and lack meaningful end points. We have never permitted admissions programs to work in that way, and we will not do so today".

#### Concurrences

Justices Thomas, Gorsuch, and Kavanaugh each submitted their own concurring opinions. In his concurrence, Justice Thomas laid out an originalist argument for the "colorblind constitution" and also cited statistics that indicate race-conscious admissions to universities are done at the expense of a student's individual value. Thomas also wrote:

While I am painfully aware of the social and economic ravages which have befallen my race and all who suffer discrimination, I hold out enduring hope that this country will live up to its principles so clearly enunciated in the Declaration of Independence and the Constitution of the United States: that all men are created equal, are equal citizens, and must be treated equally before the law.

Although Justice Gorsuch joined the majority opinion, his concurrence emphasized that Title VI of the Civil Rights Act bars affirmative action. That statute barred discrimination "on the ground of" race, so Justice Gorsuch reasoned that affirmative action was forbidden by statute regardless of any constitutional arguments.

#### Dissents

In a dissenting opinion joined by Justice Kagan and Justice Jackson, Justice Sotomayor wrote that "Ignoring race will not equalize a society that is racially unequal. What was true in the 1860s, and again in 1954, is true today: Equality requires acknowledgment of inequality." Sotomayor wrote that the majority opinion's "interpretation of the Fourteenth Amendment is not only contrary to precedent and the entire teachings of our history... but is also grounded in the illusion that racial inequality was a problem of a different generation."

In a separate dissenting opinion, Justice Jackson wrote:

With let-them-eat-cake obliviousness, today, the majority pulls the ripcord and announces 'colorblindness for all' by legal fiat. But deeming race irrelevant in law does not make it so in life...It would be deeply unfortunate if the Equal Protection Clause actually demanded this perverse, ahistorical, and counterproductive outcome. To impose this result in that Clause's name when it requires no such thing, and to thereby obstruct our collective progress toward the full realization of the Clause's promise, is truly a tragedy for all of us.

Justice Jackson's dissent was criticized for falsely claiming that "for high-risk Black newborns, having a Black physician more than doubles the likelihood that the baby will live, and not die." Justice Jackson based this claim on an amicus brief that misrepresented the findings of a study examining mortality rates in Florida newborns between 1992 and 2015.

## Reaction

### Political

#### Support

Former president Donald Trump said, "This is a great day for America. People with extraordinary ability and everything else necessary for success, including future greatness for our country, are finally being rewarded. This is the ruling everyone was waiting and hoping for." Former vice president Mike Pence said, "There is no place for discrimination based on race in the United States, and I am pleased that the Supreme Court has put an end to this egregious violation of civil and constitutional rights in admissions processes, which only served to perpetuate racism."

Florida Governor and 2024 presidential candidate Ron DeSantis said, "College admissions should be based on merit and applicants should not be judged on their race or ethnicity. The Supreme Court has correctly upheld the Constitution and ended discrimination by colleges and universities." 2024 presidential candidate Vivek Ramaswamy wrote on social media that "affirmative action is a badly failed experiment: time to put a nail in the coffin & restore colorblind meritocracy."

Republican Senators Mitch McConnell, Tom Cotton, Tim Scott, and Marsha Blackburn each voiced their support for the decision.

#### Opposition

In a speech, president Joe Biden said, "This is not a normal court" and that the United States needed "a new path forward that is consistent with the law."

Senate Majority leader Chuck Schumer said, "The Supreme Court ruling has put a giant roadblock in our country's march toward racial justice." Other Congressional Democrats, such as Senator Cory Booker, House Minority leader Hakeem Jeffries, and Congressman Hank Johnson, voiced their disagreement with the decision.

Former president Barack Obama said, "Like any policy, affirmative action wasn't perfect. But it allowed generations of students like Michelle and me to prove we belonged. Now it’s up to all of us to give young people the opportunities they deserve — and help students everywhere benefit from new perspectives." Former First Lady Michelle Obama stated, "My heart breaks for any young person out there who’s wondering what their future holds — and what kinds of chances will be open to them."

### Civil rights

President and CEO of the NAACP, Derrick Johnson, said that "affirmative action exists because we cannot rely on colleges, universities, and employers to enact admissions and hiring practices that embrace diversity, equity and inclusion," and that "Race plays an undeniable role in shaping the identities of and quality of life for Black Americans. In a society still scarred by the wounds of racial disparities, the Supreme Court has displayed a willful ignorance of our reality."

President and executive director of the Lawyers' Committee for Civil Rights Under Law, Damon Hewitt, said that "No matter what this court says, we will continue to fight. No matter what this court says, nothing can deprive us of what we call a race conscious future. The future that we deserve, the future that students deserve. Because affirmative action and holistic admissions is not a handout. It's not even really a hand up. It is what students deserve when they bring their whole selves to the table".

Founder of Students for Fair Admissions, Edward Blum, called the ruling "the beginning of the restoration of the colorblind legal covenant that binds together our multi-racial, multi-ethnic nation", adding that "These discriminatory admission practices undermined the integrity of our country's civil rights laws".

### Universities

President of the University of California system, Michael V. Drake, said in a statement that the ruling ends a "valuable practice that has helped higher education institutions increase diversity and address historical wrongs over the past several decades." University of Southern California president Carol Folt said, "we will not go backward," and, "This decision will not impact our commitment to creating a campus that is welcoming, diverse, and inclusive to talented individuals from every background". President of Johns Hopkins University Ron Daniels called the court's ruling a "significant setback in our efforts to build a university community that represents the rich diversity of America." Rice University officials called the ruling "disappointing."

Columbia University spokesperson Ben Chang said that "Diversity is a positive force across every dimension of Columbia, and we can and must find a durable and meaningful path to preserve it". The University of Pennsylvania said that "In full compliance with the Supreme Court's decision, we will seek ways to admit individual students who will contribute to the kind of exceptional community that is essential to Penn's educational mission".

Stacy Hawkins, vice dean and professor at Rutgers Law School, said that despite the ruling, colleges and universities can continue to employ "race-neutral" means to promote diversity, such as increased consideration of socioeconomic status and targeting certain schools for recruitment, both of which are said to correlate with race and ethnicity. Institutions in California and Florida have already adopted similar methods, because they are not allowed to consider race and ethnicity under their respective state law.

### Other

Attorney General Merrick Garland said in a statement that "the Department of Justice remains committed to promoting student diversity in higher education using all available legal tools. In the coming weeks, we will work with the Department of Education to provide resources to college and universities on what admissions practices and programs remain lawful following the Court’s decision."

Michael Wang, whom USA Today described as "a poster child for the anti-affirmative action movement" who had filed discrimination complaints against three universities with the federal Department of Education’s Office for Civil Rights in 2013 and met with SFFA's founder, later said, "a part of me regrets what I’ve put forward". Wang further clarified that he did not regret filing his three original complaints and that while he was not "anti-affirmative action", he supports reforming it.

America First Legal, a conservative litigation outfit headed by former Trump adviser Stephen Miller, sent letters to more than 200 U.S. law schools within days of the Court's ruling threatening them with lawsuits unless they immediately terminate all race and sex preferences in student admissions, faculty hiring, and law-review membership or article selection.

A 2023 poll from the nonpartisan Pew Research Center showed that the majority of Americans disapprove of the use of race and ethnicity in college admissions.

## Impact

### College admissions

Outgoing president of Harvard University Lawrence Bacow said that Harvard will comply with the law but remains steadfast in its belief that "deep and transformative teaching, learning, and research depend upon a community comprising people of many backgrounds, perspectives, and lived experiences". The University of North Carolina also said that they would comply with the law, but were disappointed by the court's decision.

In August 2024, MIT was the first major private college to release data on the ethnic makeup of their new freshman class, showing a drop off in Black and Latino students, while Asians made a significant gain.

In September 2024, Harvard University released data on the ethnic makeup of their Class of 2028, showing a four percent decrease in Black enrollment, a two percent increase in Hispanic or Latino enrollment, and no change in Asian American enrollment compared to the Class of 2027. Notably, the College did not provide a figure for students who identified as white and reported that 8 percent of class members did not report a race or identity, twice the prior year's percentage.

### Corporate diversity programs

Will Hild, director of the conservative advocacy group Consumers' Research said that Students for Fair Admissions v. Harvard puts a "wind in the sail" of groups that seek to end diversity, equity, and inclusion programs. Although the case regards education, employers may reassess their policies, according to former Equal Employment Opportunity Commission lawyer Stephen Paskoff.


Bingöl Province

# Bingöl Province

## Abstract

Bingöl Province (Turkish: Bingöl ili; Kurdish: Parêzgeha Çewlîg; Zazaki: Wîlayetî Çewlîg; Armenian: Ճապաղջուր զավառ) is a province of Turkey. The province was known as Çapakçur Province (Armenian: Ճապաղջուր, lit. ' spread out water ') before 1945 when it was renamed as Bingöl Province. Its area is 8,003 km, and its population is 282,556 (2022). The province encompasses 11 municipalities, 325 villages and 693 hamlets.

The town of Genç was the scene of origin for the Kurdish Sheikh Said rebellion in 1925 and most of the region was captured by the rebels during the rebellion.

As the current Governor of the province, Ahmet Hamdi Usta was appointed by the president in August 2023.

## Geography

The largest lake in Bingöl Province is Lake Bahri. The main mountains in Bingöl province are the Genç Mountains, Akçara Mountains, Şerafettin Mountains and Bingöl Mountains.

## Demographics

Kurds comprise the majority of the province and the province is considered part of Turkish Kurdistan. Its population is majority Sunni, conservative and many adhere to the Naqshbandi order. The province moreover has a significant Alevi minority. Linguistically, the southern parts of the province speak Zaza, while the northern parts speak Kurmanji. Many Zaza-speakers speak Kurmanji as well.

### Language and religion statistics

Bingöl Province was part of Bitlis Vilayet during the Ottoman era as Genç Sanjak and had a population of 36,011 in the 1881-1882 census. 85.7% of the population was Muslim and the remaining 14.3% was Armenian. In the census of 1897, the sanjak had a population of 47,652, of which 88.1% was Muslim and 11.9% was Armenian. All of the Armenians adhered to the Armenian Apostolic Church.

In the 1906-1907 census, the sanjak had a population of 45,215 of which 86.8% was Muslim and Armenians comprised the remaining 13.2%. In the last Ottoman census in 1914, the region had a population of 38,096 of which 93.9% was Muslim and 6.1% Armenian.

The first Turkish census which included Bingöl Province was the 1945 census, where the population was 75,550 who all were Muslims. Linguistically, the most spoken first language was Kurdish at 55.7%, followed by Turkish at 43.8% and Circassian at 0.4%. In the 1950 census, Kurdish was the first language for 76.5% of the population of 97,328, while Turkish remained the second largest language standing at 22.9% and Circassian at 0.4%. In the last census in 1965, Kurdish stood at 58.3% and Turkish at 41.6%.

## History

From 1923 to 1929, Bingöl Province was part of Elazığ Province and part of Muş Province from 1929 to 1936. It ultimately became a province in 1936.

In December 1935 the Tunceli Law was passed which demanded a more powerful government in the region. Therefore, the region containing the present Bingöl province, together with the provinces of Tunceli, Erzincan and Elaziğ were included in the Fourth Inspectorate General (Umumi Müfettişlik, UM) in January 1936. The fourth UM was governed by a Governor Commander. All the employees in the municipalities were to be from the military and the Governor Commander had the authority to evacuate whole villages and resettle them in other parts of the province. in 1946 the Tunceli Law was abolished and the state of emergency removed but the authority of the fourth UM was transferred to the military. The Inspectorate General was dissolved in 1952 during the Government of the Democrat Party.

## Districts

Bingöl province is divided into 8 districts (capital district in bold):

- Adaklı

- Bingöl

- Genç

- Karlıova

- Kiğı

- Solhan

- Yayladere

- Yedisu


List of Canadian films of 2024

# List of Canadian films of 2024

## Abstract

This is a list of Canadian films slated for release in 2024:


Blennerhassett

# Blennerhassett

## Abstract

Blennerhassett is an English surname.

## Origin

The name originates from the village of Blennerhasset (with one t) in Cumbria, England.

## People with the surname

- Arthur Blennerhassett, multiple people Arthur Blennerhassett (1687–1758), Anglo-Irish lawyer, politician and judge Arthur Blennerhassett (1719–1799), Anglo-Irish politician Arthur Blennerhassett (1799–1843), Irish politician

- Arthur Blennerhassett (1687–1758), Anglo-Irish lawyer, politician and judge

- Arthur Blennerhassett (1719–1799), Anglo-Irish politician

- Arthur Blennerhassett (1799–1843), Irish politician

- Charlotte, Lady Blennerhassett (1843–1917), German writer and biographer

- Conway Blennerhassett (1693–1724), Irish politician

- Giles Blennerhasset (1895–1978), Irish military aviator

- Harman Blennerhassett (1765–1831), Anglo-Irish aristocrat, plantation owner in western Virginia

- John de Blennerhassett (1350–1384), English politician

- John Blennerhassett, multiple people John Blennerhassett (English MP) (by 1521–1573), English landowner and member of parliament John Blennerhassett (judge) (c.1560–1624), Anglo-Irish judge and politician John Blennerhassett (died 1677), Anglo-Irish politician John Blennerhassett (died 1709), Anglo-Irish politician John Blennerhassett (1691–1775), Anglo-Irish politician John Blennerhassett (1715–1763), Anglo-Irish politician John Blennerhassett (1769–1794), Anglo-Irish politician John Blennerhassett (politician) (1930–2013), Irish politician

- John Blennerhassett (English MP) (by 1521–1573), English landowner and member of parliament

- John Blennerhassett (judge) (c.1560–1624), Anglo-Irish judge and politician

- John Blennerhassett (died 1677), Anglo-Irish politician

- John Blennerhassett (died 1709), Anglo-Irish politician

- John Blennerhassett (1691–1775), Anglo-Irish politician

- John Blennerhassett (1715–1763), Anglo-Irish politician

- John Blennerhassett (1769–1794), Anglo-Irish politician

- John Blennerhassett (politician) (1930–2013), Irish politician

- Margaret Agnew Blennerhassett (1771–1842), English-American poet and aristocrat

- Richard Blennerhassett (1889–1957), Australian Anglican priest

- Robert Blennerhassett (MP for Tralee) (c.1622–c.1689), Anglo-Irish soldier and politician

- Robert Blennerhassett (1652–1712), Irish lawyer and politician

- Rowland Blennerhassett, multiple people Sir Rowland Blennerhassett, 1st Baronet (1741–1821), Anglo-Irish lawyer Sir Rowland Blennerhassett, 4th Baronet (1839–1909), Anglo-Irish politician Rowland Ponsonby Blennerhassett (1850–1913), Irish politician Rowland Blennerhassett (priest) (1919–2009), Irish priest, Archdeacon of Tuam 1956–69

- Sir Rowland Blennerhassett, 1st Baronet (1741–1821), Anglo-Irish lawyer

- Sir Rowland Blennerhassett, 4th Baronet (1839–1909), Anglo-Irish politician

- Rowland Ponsonby Blennerhassett (1850–1913), Irish politician

- Rowland Blennerhassett (priest) (1919–2009), Irish priest, Archdeacon of Tuam 1956–69

- Thomas Blennerhassett (fl. 1584–1611), English politician


Glentel

# Glentel

## Abstract

Glentel Inc. is a Canadian telecommunications retailer based in Burnaby, British Columbia, jointly owned by BCE Inc. and Rogers Communications.

In Canada, the company operates over 350 wireless outlets under the Tbooth Wireless (La cabine T sans-fil in Quebec, formerly The Telephone Booth) and WirelessWave (Wave sans fil in Quebec) brands, particularly in mall kiosks. The company operates store-within-a-store kiosks at Canadian Costco locations under the Wireless etc. banner. Glentel outlets sell services from Bell Mobility and Rogers Wireless, their respective subsidiary brands (such as Chatr Wireless, Fido, Lucky Mobile, and Virgin Plus), and SaskTel in Saskatchewan.

For a time, it operated the Target Mobile kiosks at Target Canada locations until the chain's closure in 2015, and owned the Australian wireless retail chain Allphones, and U.S. Verizon retailers Diamond Wireless and Wireless Zone.

On November 28, 2014, BCE Inc. announced that it would acquire Glentel for $670 million, pending regulatory approval, in an effort to boost its retail presence. After a dispute with Rogers, who argued that due to supply agreements it was contractually required to consent to any change in ownership of the company, Bell announced that it would divest a 50% stake in Glentel to Rogers upon the closure of the acquisition, turning the company into a joint venture between them.

## History

The company has its origins in Speedy Celtel, the company founded by Alan and Tom Skidmore as a retailer of Cantel, the country's first cellular carrier. In 1989, the company bought Glenayre, that was provider of business wireless hardware, and was re-named Glenayre Technologies. In 1992, the company's retail arm was spun-out as Glentel, and in 1997, it opened a Rogers dealer at Metropolis in Burnaby known as WirelessWave. WirelessWave subsequently grew into a larger chain.

In 2005, Glentel acquired its Montreal-based rival Cabtel Corp., which operated as La Cabine Telephonique in Quebec, and The Telephone Booth in Alberta and Ontario. The deal added 49 stores to its holdings. In 2007, Glentel reached a multi-year agreement with Costco Canada to operate wireless kiosks, branded as "Wireless, etc." at its locations.

In 2010, the company first expanded into the United States with its acquisition of Diamond Wireless, a chain of Verizon Wireless retailers. In 2012, it acquired an 83% majority stake in AMT Group, an Australian operator of mobile retailers under the Allphones and Virgin Mobile brands. That year, Glentel acquired the U.S. firm Automotive Technologies Inc., doing business as Wireless Zone, which operated 421 Verizon Wireless retailers, for $83.3 million. Glentel also reached a deal to operate Target Mobile kiosks at the short-lived Target Canada chain.

### Acquisition by Bell and Rogers

On November 28, 2014, Bell Canada announced that it would acquire Glentel for $670 million, pending regulatory and shareholder approval, in an effort to boost its retail presence. Bell also operates first-party retail outlets for its services, and owns The Source, a Canadian electronics store chain that also sells Bell services. The company planned to continue serving as a retailer for non-Bell brands after the acquisition was completed.

On December 17, 2014, Rogers Communications filed for an injunction against Glentel in the Ontario Superior Court, seeking to have the acquisition blocked. It argued that pursuant to Glentel's supply agreements with the company, Rogers had to consent to any change in company ownership. The company also foresaw the possibility of Glentel's retailers showing favouritism towards Bell brands following the merger. Glentel CEO Tom Skidmore disputed Rogers' complaint, stating that "Rogers has the right to remove their products from our Canadian stores if they choose to terminate its agreement with us, but has no right under its agreement to block the acquisition of Glentel."

On December 24, 2014, Bell announced that it had agreed to divest a 50% stake in Glentel to Rogers upon its completion of the acquisition. The acquisition was completed on May 6, 2015.

In 2016, Wireless Zone was sold to Round Room, LLC. Diamond Wireless was also sold to A Wireless. In February 2017, Allphones went into receivership after being sold to a "Canadian shareholder" in May 2016.


# Northwestern University Pritzker School of Law

## Abstract

The Northwestern University Pritzker School of Law is the law school of Northwestern University, a private research university. The law school is located on the university's Chicago campus. Northwestern Law is considered part of the T14, an unofficial designation in the legal community as the best 14 law schools in the United States.

Founded in 1859, it was the first law school established in Chicago. Notable alumni include numerous governors of several states; Arthur Goldberg, United States Supreme Court justice; Adlai Stevenson, governor of Illinois, cabinet secretary, and Democratic presidential candidate; John Paul Stevens, United States Supreme Court justice; Newton Minow, former chairman of the FCC; and Harold Washington, the first black Mayor of Chicago (1983–87) and, previously, a member of the United States House of Representatives.

## History

Founded in 1859, the school now known as the Northwestern University Pritzker School of Law was the first law school established in Chicago. The school was originally the law department of the Old University of Chicago under the founding direction of Henry Booth and enrolled twenty-three students. The law school became Union College of Law when it was jointly affiliated with Northwestern University in 1873. In 1891, the law school formally became Northwestern University School of Law when Northwestern assumed total control

During the 20th century, programs such as the JD-MBA and JD-PhD were added, helping to maintain the school's position among America's top-ranked law schools. In the 1930s, the school was home to the Scientific Crime Detection Laboratory, which student Fred E. Inbau would direct and from which he would develop the Reid technique of deceptive interrogation to obtain confessions.

In October 2015, it was renamed Northwestern University Pritzker School of Law after J. B. Pritzker and his wife, M.K. Pritzker, who gave $100 million to the law school.

In July 2024, a lawsuit was filed by a conservative group against the university citing its activities to increase the hiring of women and people of color for its faculty, as a violation of federal law prohibiting discrimination for reasons of race or sex, one year after affirmative action college admissions in the United States was struck down by the Supreme Court of the United States. The suit asserts that the law school discriminates against, specifically, white men in faculty hiring, as well as in selection of articles published in its noted law review.

## Campus

Northwestern Law is located on Northwestern University's downtown campus in Chicago's Streeterville / Gold Coast neighborhood. The law school is on Lake Shore Drive and Chicago Avenue, adjacent to Lake Shore Park and Lake Michigan, and a few blocks from the John Hancock Center, Magnificent Mile, Water Tower, Oak Street Beach, and Navy Pier.

The law school's location in the heart of downtown Chicago provides a wealth of part-time employment options for students while in school and a setting in which to study law. The proximity to courts, commerce, and public interest activities enables students to experience the practice of law, as well as its theory.

## Admissions

Admission to Northwestern Law is highly selective. For the class entering in the fall of 2021, 1,031 out of 7,410 (13.9%) were offered admission, with 234 matriculating. The 25th and 75th LSAT percentiles for the 2021 entering class were 167 and 172, respectively, with a median of 171. The 25th and 75th undergraduate GPA percentiles were 3.60 and 3.93, respectively, with a median of 3.86.

The law school's practical philosophy is manifested in a strong preference for applicants with at least two years of work experience. Approximately 90% of the school's students enter with at least one year of full-time work experience; 70% possess more than two years of experience.

## Employment

According to U.S. News & World Report's 2021 Edition, 94% of the law school's 2021 graduates obtained prospective, full-time employment prior to graduation, with a median starting salary of $215,000. According to Northwestern's official 2022 ABA-required disclosures, 94% of the Class of 2022 obtained full-time, long-term employment ten months after graduation. Northwestern's Law School Transparency under-employment score is 4.4%, indicating the percentage of the Class of 2018 unemployed, pursuing an additional degree, or working in a non-professional, short-term, or part-time job nine months after graduation.

Northwestern Law is well-established among BigLaw firms (defined as firms with 251 or more associates). In Vault's 2016 survey, of over 15,000 BigLaw associates, Northwestern Law ranked #2 as a "feeder" school for BigLaw firms, after accounting for school size. According to Vault, Northwestern Law outperforms its expected BigLaw representation by 315%. Northwestern Law ranked 2nd, 4th, and 3rd in 2021, 2022, and 2023 respectively for the highest percentage of juris doctor graduates who receive associate positions at the largest 100 law firms in the country.

The law school enrolls approximately 985 students in its J.D., LL.M., S.J.D. and M.S.L. (Master of Science in Law) programs. The school employs an interdisciplinary research faculty, and has a low student-faculty ratio. The 2016 student/faculty ratio was 6.5 to 1. According to Northwestern's 2016 ABA-required disclosures, 93% of the Class of 2016 obtained full-time, long-term employment nine months after graduation.

## Costs

The total cost of attendance (indicating the cost of tuition, fees, living expenses, books, and other miscellaneous expenses) at Northwestern Law for the 2022-2023 academic year is $104,564. The Law School Transparency estimated debt-financed cost of attendance for three years is $367,588.

## Journals

Northwestern Law sponsors seven student-run scholarly legal journals. Student staff members are selected based on a writing competition, editing competition, and first-year grades, or a publishable note or comment on a legal topic.

### Northwestern Journal of International Law & Business

The Journal of International Law and Business has a substantive focus on private international law, as opposed to public international law or human rights. It seeks scholarship analyzing transnational and international legal problems and their effect on private entities. The Journal's stated goal is to promote an understanding of the future course of international legal developments as they relate to private entities.

### Northwestern University Law Review

The Northwestern University Law Review was first published in 1906 when it was called the "Illinois Law Review." Prior editors include: Roscoe Pound, long-time dean of Harvard Law School; Judge Robert A. Sprecher of the United States Court of Appeals for the Seventh Circuit; US Supreme Court Justice John Paul Stevens; Dean James A. Rahl; Illinois Governor Daniel Walker; and former chairman of the Federal Communications Commission Newton N. Minow; US Supreme Court Justice Arthur Goldberg and Presidential Candidate Adlai Stevenson.

### Northwestern Journal of Technology and Intellectual Property

The Northwestern Journal of Technology and Intellectual Property addresses subjects relating to law at the intersection of technology and intellectual property, including law and biotechnology, copyrights, the Internet, media, patents, telecommunications, and trademarks.

### Journal of Criminal Law and Criminology

The School states that its Journal of Criminal Law and Criminology "is one of the most widely read and widely cited publications in the world". It is the second most widely subscribed journal published by any law school in the country. It is one of the most widely circulated law journals in the country. The journal was founded in 1910 by Dean John Henry Wigmore.

### Journal of Law and Social Policy

The Journal of Law and Social Policy is an interdisciplinary journal that explores the impact of the law on different aspects of society. Topics covered include race, gender, sexual orientation, housing, immigration, health care, juvenile justice, voting rights, family law, civil rights, poverty, the environment, and privacy rights.

### Journal of Human Rights

The Journal of Human Rights is an interdisciplinary journal for the discussion of human rights issues and law.

### Northwestern Law Journal des Refusés

The Northwestern Law Journal des Refusés is a "journal of law for legal rejects and the legal avant-garde" founded in 2022. It was inspired by the Paris Salon des Refusés and aims to discuss legal issues in a way that is more accessible to the general public, as well as help readers trying to understand more difficult works. It publishes one print-issue each Spring and additional online articles throughout the year.

## Pritzker Legal Research Center

The Pritzker Legal Research Center is the library, and fulfills the research and information needs of the faculty and students of Northwestern Law. The Center is named after the Pritzker family, a philanthropic Chicago family. Jay A. Pritzker (1922-1999) graduated from Northwestern University in 1941 and Northwestern University School of Law in 1947.

## Bluhm Legal Clinic

Clinical education at Northwestern dates back to the law school's beginnings. An innovative program developed by Dean John Henry Wigmore in 1910 with the Chicago Legal Aid Society evolved into the Legal Clinic, which opened its doors in 1969 with only two staff attorneys. In 2000, the Clinic was named for Northwestern University trustee and alum Neil Bluhm, a billionaire in real estate and casinos. Today, the Bluhm Legal Clinic houses around 20 clinics within 14 centers and is widely recognized as one of the most comprehensive and effective clinical programs in the country. Through the law school's clinical program, students gain direct experience representing clients and fine-tune their skills as advocates. They also work with clinical faculty and staff to challenge the fairness of our legal institutions and to propose solutions for reform. From 2000 to 2013, its director was Steven Drizin.

### Center on Wrongful Convictions

The Center on Wrongful Convictions (CWC) is dedicated to identifying and rectifying wrongful convictions. The Center investigates possible wrongful convictions and represents imprisoned clients with claims of actual innocence. It also focuses on raising public awareness of the prevalence, causes, and social costs of wrongful convictions and promoting reform of the criminal justice system. In 2009, faculty member Prof Steven Drizin co-founded a sister project to this Center, a Center on Wrongful Convictions of Youth, which was merged back into the main center after 2018.

### Appellate Advocacy Center

Established in 2006, the Appellate Advocacy Center includes the Federal Appellate Clinic and the Supreme Court Clinic, along with a moot program for practitioners. The Appellate Advocacy Center is directed by Xiao Wang.

#### Federal Appellate Clinic

In the Federal Appellate Clinic, students research and brief cases in federal appellate courts across the country. In certain instances, where a case involves significant federal issues or interests, students will also participate in state appellate court work. Clinic cases generally focus on immigration, qualified immunity, and criminal sentencing and post-conviction issues, although other topics and matters are covered as well. Where possible, Clinic students participate in oral argument before a United States court of appeals.

#### Supreme Court Clinic

In the Supreme Court Clinic, students work with attorneys at Sidley Austin to draft certiorari, merits, and amicus briefs before the Supreme Court. Sidley attorneys Carter Phillips and Jeffrey Green co-direct the Supreme Court Clinic.

The Clinic works on a variety of legal matters. During any given year, the Clinic will file briefs in cases concerning international law, tribal law, sentencing, criminal procedure, habeas, and the First Amendment. The Clinic frequently collaborates with state and federal public defenders. The Clinic also works with nonprofit organizations, including the National Association of Criminal Defense Lawyers. In fall 2021, the Clinic partnered with Northwestern's Center for International Human Rights, Amnesty International, Global Justice Center, and Human Rights Watch to file an amicus brief in Dobbs v. Jackson Women's Health Organization, asserting that Mississippi's abortion ban was inconsistent with international law.

### Children and Family Justice Center

The Children and Family Justice Center represents young people on matters of delinquency and crime, family violence, school discipline, health and disability, and immigration and asylum. Attorneys, a social worker, and affiliated professionals help second- and third-year law students meet with clients, research legal issues, learn pretrial investigation, interviewing, and counseling skills, and litigate cases.

### MacArthur Justice Center

The MacArthur Justice Center focuses its work on police misconduct, wrongful detention compensation, post-9/11 work, and other public interest and civil rights issues. Of particular note is the Guantanamo Bay detainee representation led by Joseph Margulies, author of Guantanamo and the Abuse of Presidential Power and lead counsel in Rasul v. Bush.

### Donald Pritzker Entrepreneurship Law Center

The Donald Pritzker Entrepreneurship Law Center (DPELC), founded as the Small Business Opportunity Center (SBOC), is a transactional clinic that was founded in 1998. Clients include technology executives, consultants, inventors, manufacturers and sellers of consumer products, musical groups, and persons interested in establishing nonprofit organizations.

The Center is also heavily involved in teaching in the field of entrepreneurship law, and hosts symposia and conferences to facilitate that endeavor.

### Center for International Human Rights

The Center for International Human Rights works to advance human rights while enabling students to test and refine their academic learning in real cases. Stressing a comprehensive interdisciplinary approach, the center provides policy perspectives to the United Nations, the Organization of American States, the U.S. Department of State, foreign governments, and nongovernmental organizations. Over the years faculty and staff working in the center have addressed, among other matters, the role of the International Criminal Court, international terrorism, U.S. death penalty laws, truth commissions, economic rights, NATO 's humanitarian intervention, and political asylum cases. Students have investigated cases and had summer internships in Guatemala, Indonesia, and at the U.N. Human Rights Centre in Geneva.

The Center also offers students an opportunity to earn an LLM in Human Rights. The degree program is designed for students from transitional democracies and for those with career interests in international human rights law.

### Investor Protection Center

The Investor Protection Center provides assistance to investors with limited income or small dollar claims who are unable to obtain legal representation. Law students, under the supervision of faculty attorneys, represent customers in handling their disputes with broker-dealers.

During the last few years, the (Financial Industry Regulatory Authority)(FINRA) and other organizations have taken steps to make more information and services available to investors. Northwestern Law's Investor Protection Center operates with the aid of grants from the FINRA Investor Education Foundation and other organizations to focus on priority areas. In particular, the Center is focused on helping to meet the needs of women, novice investors, and the elderly, in connection with securities arbitration.

### Fred Bartlit Center for Trial Advocacy

Named in honor of an innovative leader in litigation and business strategies, the Fred Bartlit Center for Trial Advocacy was established in 1999 to conduct research and teach innovative and technologically advanced trial strategy. The Bartlit Center focuses on changes in trial craft brought on by new technologies and compensation approaches.

The Bartlit Center sponsors and conducts academic research on the litigation process; support teaching skills in the JD program; and holds national conferences to explore and teach innovative trial and trial management strategies. The Bartlit Center works to complement the law school's program in simulation-based teaching of trial skills and builds on the research produced by Northwestern Law faculty.

## Notable faculty

Notable Northwestern Law faculty, past and present, include:

- Ronald J. Allen, renowned evidence scholar and adviser to foreign governments on law reform

- Steven Calabresi, constitutional scholar and founder and chairman of the Federalist Society

- Steven Drizin

- Edwin R. Keedy, dean of the University of Pennsylvania Law School

- Andrew Koppelman, noted legal scholar on same-sex marriage

- Leon Green, former dean; known for pioneering work in the law of torts, especially causation and injuries to relations

- Charles T. McCormick, expert on evidence, damages, and federal court procedure; writings include the classic hornbooks, Handbook on the Law of Damages (1935) and Handbook on the Law of Evidence (1954).

- John O. McGinnis, expert on trade law and one of nation's leading scholars in the field of Constitutional Law.

- Dawn Clark Netsch, expert in governmental organization law and the first woman to be nominated by a major political party to run for Governor of Illinois.

- James E. Pfander, civil procedure, federal courts, and constitutional law scholar

- Roscoe Pound, former dean of Harvard Law School, founder of the movement for "sociological jurisprudence"

- Martin Redish, civil procedure and constitutional law scholar

- David S. Ruder, former chairman of the Securities and Exchange Commission

- David Scheffer, international law and war crimes expert who served as the first United States Ambassador-at-Large for War Crimes Issues

- Charles Taylor, political philosopher, Royal Society of Canada fellow, British Academy fellow, member of the American Academy of Arts & Sciences

- David E. Van Zandt, former dean of Northwestern University School of Law

- John Henry Wigmore, the "father of modern evidence," first full-time dean of Northwestern Law (1901) and author of Treatise on Evidence

## Popular media

- The Chicago Code was substantially filmed on the Northwestern Law campus in Chicago. This television drama premiered on Fox on February 7, 2011. Filming at Northwestern Law began in August 2010. Classrooms in the law school are depicted as interior offices for the fictional offices for City administration. Levy Mayer 212 served as the main taping location at the law school.

- In The Judge, Robert Downey Jr. plays the role of a Chicago defense attorney who is a Northwestern Law graduate.

- Prof Steven Drizin and Prof Laura Nirider feature heavily in the 2016 Netflix documentary Making a Murderer as the post-conviction legal representatives of Brendan Dassey. Dassey’s confession is thought by many to be false and coerced, so both Drizin and Nirider are acting as part of work by the Center on Wrongful Convictions of Youth.

## Alumni

Selected prominent Northwestern Law alumni include:

### Academia

- Diane Marie Amann, the Emily & Ernest Woodruff Chair in International Law and Faculty Co-Director of the Dean Rusk International Law Center at the University of Georgia School of Law, and Special Adviser to the Prosecutor of the International Criminal Court on Children in & affected by Armed Conflict.

- Raoul Berger, one of America 's foremost legal historians, former Senior Fellow in American Legal History at Harvard University and author of Government by Judiciary: The Transformation of the Fourteenth Amendment

- George Burditt, adjunct member of the faculty

- G. Marcus Cole, Professor of Law, Helen L. Crocker Faculty Scholar, and Associate Dean for Curriculum, Stanford Law School

- Steven Drizin, lawyer and law professor at the Northwestern University Pritzker School of Law

- T. Markus Funk, law professor and attorney at Perkins Coie.

- Thomas F. Geraghty, Associate Dean for Clinical Education; Professor of Law; Director, Bluhm Legal Clinic, Northwestern University School of Law

- Kristin E. Hickman, Distinguished McKnight University Professor and the Harlan Albert Rogers Professor in Law at the University of Minnesota Law School

- Charles P. Kindregan, Jr., expert in assisted reproduction law, Professor at Suffolk University Law School

- James Nabrit Jr., president of Howard University and pioneering civil rights law academic and attorney

- Kate A. Shaw, law professor at Benjamin N. Cardozo School of Law, podcast co-host and ABC News Supreme Court contributor

- Jonathan Turley, J.B. and Maurice C. Shapiro Professor of Public Interest Law, The George Washington University Law School

### For-profit / Non-profit organizations

- Ferdinand Lee Barnett, founder of The Chicago Conservator

- Eddie Einhorn, owner of the Chicago White Sox

- Matt Ferguson, president and CEO of Careerbuilder.com

- Elbert Henry Gary, co-founder, president, and chairman of United States Steel Corporation; namesake of Gary, Indiana

- Michael Goodkin, quantitative finance entrepreneur and founder of Arbitrage Management Company ("AMC")

- Randy Kaplan, founder of Akamai Technologies

- Marc J. Lane, founder of The Marc J. Lane Wealth Group

- Robert R. McCormick, United States colonel; co-founder of law firm Stuart G. Shepard and Robert R. McCormick, (later Kirkland & Ellis); publisher of the Chicago Tribune

- Morgan E. O'Brien, co-founder and former chairman of Nextel

- Jay A. Pritzker, co-founder Hyatt Hotels Corporation

- Frank C. Rathje, founder of the Mutual National Bank of Chicago and president of the American Bankers Association

- Jerry Reinsdorf, owner of the Chicago White Sox and Chicago Bulls

- Howard A. Tullman, serial entrepreneur, venture capitalist

- Mark Walter, founder and CEO of Guggenheim Partners and Chairman of Los Angeles Dodgers

### Government and politics

- George Wildman Ball (1933), former Undersecretary of State, former U.S. Ambassador to the United Nations

- Ferdinand L. Barnett, Civil Rights activist and Assistant State's Attorney in Illinois, husband of Ida B. Wells.

- Richard Ben-Veniste, Chief of the Watergate Special Prosecutor's Office Watergate Task Force

- Judy Biggert (J.D. 1963), U.S. representative, 1999–2013

- William Jennings Bryan, former U.S. Secretary of State and three-time Democratic Nominee for president

- Dale Bumpers, former governor of Arkansas and U.S. Senator for Arkansas

- Salem J. Chalabi, First General Director of the Iraqi Special Tribunal to try Saddam Hussein

- Alfred Cilella, Illinois state legislator

- Dennis Daugaard, Governor of South Dakota

- William Dawson, first African American to chair a Congressional Committee, beginning in 1949.

- Richard Devine, Cook County Former State's Attorney

- Edward Dunne, Former governor of Illinois, Former mayor of Chicago

- W. Neil Eggleston, White House Counsel under President Barack Obama

- Carl R. Feld, Wisconsin State Assembly

- Florence Kelley (1894), social reformer, early advocate for the minimum wage, eight-hour workdays, and children's rights; first general secretary of the National Consumers League; helped to create the National Association for the Advancement of Colored People (NAACP).

- Ada Kepley, first American woman to obtain a law degree (1870)

- Robert Todd Lincoln (1866), U.S. Minister to the United Kingdom (1889–1893); 35th United States Secretary of War (1881–1885)

- Wendy E. Long, Republican nominee for United States Senate from New York in 2012 and 2016

- Frank Orren Lowden, Former governor of Illinois, third-place finisher in the 1920 Republican party convention, second-place finisher in the 1928 convention

- J. Curtis McKay, Wisconsin State Assembly

- Albert E. Mead, former governor of Washington

- Newton Minow, former chairman of the Federal Communications Commission

- Dawn Clark Netsch, first woman to be elected to a state-wide constitutional office in Illinois

- Graham T. Perry, second African-American elected for assistant attorney general for the State of Illinois

- J. B. Pritzker, Managing Partner of Pritzker Group Venture Capital, and current governor of Illinois

- Pat Quinn, former governor of Illinois

- Tom Railsback, former United States Representative

- Henry T. Rainey, 40th Speaker of the United States House of Representatives

- José Abad Santos, 5th Chief Justice of the Supreme Court of the Philippines

- Jerry Springer, former Mayor of Cincinnati, television talk show host

- Seymour Stedman, former shepherd with only three years of education, admitted while working as a janitor; Socialist Party of America nominee for Vice-President of the United States (and for Mayor of Chicago)

- Halvor Steenerson, former U.S. representative

- Adlai Stevenson, former governor of Illinois, two-time Democratic nominee for president, and Ambassador to the United Nations

- Charles M. Thomson, former U.S. representative

- Jim Thompson, former governor of Illinois

- Daniel Walker, former governor of Illinois

- Harold Washington, first black mayor of Chicago (1983–87), Member of the U.S. House of Representatives

- Richard E. Wiley, former chairman of the Federal Communications Commission

- Paul Ziffren, Democratic National Committee chair

- Albert Goldman (politician) (J.D. 1925), socialist lawyer and political activist, personal lawyer of Leon Trotsky during his stay in Mexico City

### Judiciary

- Simeon R. Acoba, Jr., Hawaii Supreme Court Justice

- Mary Bartelme, influential pioneer in juvenile justice, first woman elected judge in Illinois.

- Dalveer Bhandari, Judge at the International Court of Justice, 2012–present

- Rubén Castillo, Chief Judge of the United States District Court for the Northern District of Illinois

- Edmond E. Chang, U.S. District judge for United States District Court for the Northern District of Illinois

- Joel Flaum, United States Court of Appeals for the Seventh Circuit Judge

- Michael B. Brennan, United States Court of Appeals for the Seventh Circuit Judge

- Michael Y. Scudder, United States Court of Appeals for the Seventh Circuit Judge

- Arthur Goldberg, former United States Supreme Court Justice, U.S. Secretary of Labor, and Ambassador to the United Nations

- Jim Jones, Chief Justice of the Idaho Supreme Court

- Carole Kamin, first woman to become president of a state bar in the United States; Cook County Circuit Court Judge

- Kenesaw Mountain Landis, first Commissioner of Major League Baseball, for U.S. District Judge for the United States District Court for the Northern District of Illinois

- Roberto A. Lange, U.S. District Judge for the United States District Court for the District of South Dakota

- Joan Larsen, U.S. Circuit Judge for the United States Court of Appeals for the Sixth Circuit

- Joan Lefkow, U.S. District Judge for United States District Court for the Northern District of Illinois

- John Paul Stevens, United States Supreme Court Justice

- Richard Tallman, United States Court of Appeals for the Ninth Circuit Senior Judge

- Horace Ward, challenged racial discrimination at the University of Georgia, and first African American to become a judge of the United States District Court for the Northern District of Georgia

### Firsts

- Mary Bartelme, first woman elected judge in Illinois.

- Ferdinand L. Barnett, first African-American assistant State's Attorney in Illinois.

- Salem J. Chalabi, first General Director of the Iraqi Special Tribunal to try Saddam Hussein

- William Dawson, first African American to chair a congressional committee.

- Ada Kepley, first woman in the United States to graduate from a law school

- Kenesaw Mountain Landis, first Commissioner of Major League Baseball, former U.S. District Judge for the United States District Court for the Northern District of Illinois

- Dawn Clark Netsch, first woman to be elected to a statewide constitutional office in Illinois

- Harold Washington, first African American Mayor of Chicago (1983–87), Member of the U.S. House of Representatives

- Horace Ward, challenged racial discrimination at the University of Georgia, and first African American to become a federal judge in Georgia

- Lloyd Garrison Wheeler, first African American admitted to the bar in Illinois.


# List of Veterans Benefits Administration regional offices

## Abstract

The US Veterans Benefits Administration operates a network of regional offices across the country to serve the needs of veterans and their families. These offices provide a range of services including Compensation, Vocational Rehabilitation and Employment (VR&E), Pension Management, Fiduciary Services, Education, Home Loan Guaranty, and Insurance.

## By District

The regional offices are organized into four districts: Northeast, Southeast, Continental, and Pacific. This list provides an overview of the VA regional offices by district, including the services offered at each location, based on the following key:

- Comp: Compensation

- VR&E: Veterans Readiness and Employment

- EDU: Education Processing Office

- LGY: Home Loan Regional Office

- PMC: Pension Management Center

- Fid: Fiduciary Hub

### Northeast District

District Office: St. Louis, MO

### Southeast District

District Office: Nashville, TN

### Continental District

District Office: Lakewood, CO

### Pacific District

District Office: Phoenix, AZ

## By Service Line

Outside of Compensation and VR&E, most other service lines have consolidated the processing of their claims through regionalized processing centers. For Compensation and VR&E, refer to the list by district provided earlier. All Insurance claims are processed at the Philadelphia Regional Office and Insurance Center.


2024 Tennessee Titans season

# 2024 Tennessee Titans season

## Abstract

The 2024 season is the Tennessee Titans ' 55th season in the National Football League (NFL), their 65th overall, their 28th in the state of Tennessee, their second under the leadership of general manager Ran Carthon and their first under head coach Brian Callahan. They will attempt to improve on their 6–11 record from last year, make the playoffs after a 2-year absence, and end their 2-year AFC South title drought. Long time running back Derrick Henry left the team in the offseason and joined the Baltimore Ravens.

The franchise enters 2024 with 493 lifetime wins encompassing regular season and playoffs; should they win seven games they will become the most recent team originating from the American Football League to reach 500 career wins.

## Offseason

### Coaching changes

On January 9, 2024, the Titans fired head coach Mike Vrabel after six seasons with the team. Vrabel had lost 18 out of the past 24 games dating back to the 2022 season and hadn't won a playoff game since the 2019 season. However, many still saw the move as a surprise and believed Vrabel to be a popular head coaching candidate for other teams.

On January 24, 2024 the Titans hired Cincinnati Bengals offensive coordinator Brian Callahan as their new head coach.

### Roster changes

#### Reserve/future free agent contracts

On January 8, 2024, the Titans signed six players from their practice squad to reserve/future contracts.

## Draft

## Regular season

### Schedule

Notes

- Intra-division opponents are in bold text.

- Networks and times from Weeks 6–17 are subject to change as a result of flexible scheduling.

- The date, time and network for Week 18 will be finalized at the end of Week 17.

### Game summaries

#### Week 1: at Chicago Bears

at Soldier Field, Chicago, Illinois

- Date: September 8

- Game time: 12:00 p.m. CDT

- Game weather: Mostly sunny, 67 °F (19 °C)

- Game attendance: 59,403

- Referee: Shawn Smith

- TV announcers (Fox): Adam Amin, Mark Sanchez, and Kristina Pink

- Recap, Game Book

#### Week 2: vs. New York Jets

at Nissan Stadium, Nashville, Tennessee

- Date: September 15

- Game time: 12:00 p.m. CDT

- Game weather: Cloudy, 80 °F (27 °C)

- Game attendance: 65,509

- Referee: Alan Eck

- TV announcers (CBS): Ian Eagle, Charles Davis, and Evan Washburn

- Recap, Game Book

#### Week 3: vs. Green Bay Packers

at Nissan Stadium, Nashville, Tennessee

- Date: September 22

- Game time: 12:00 p.m. CDT

- TV announcers (Fox): Kevin Kugler, Daryl Johnston, and Laura Okmin

- Preview

### Standings


Greg Mangano

# Greg Mangano

## Abstract

Greg Mangano (born October 28, 1989) is an American basketball player for KTP Basket of Korisliiga. He played college basketball for the Yale Bulldogs. He is known for versatility as a frontcourt player and his polished face up game offensively.

## High school

Mangano attended Notre-Dame West Haven, where he was a two-time all-state player and a two-time all-league selection. His senior year was his best year, as he averaged 26 points, 15 rebounds, and 6 blocks per game. These numbers were good enough to get him MVP honors and a nomination for the McDonald's All-American Game. Rivals.com ranked Mahimgnano as a 2-star prospect.

## College

### Freshman year

Mangano received the John C. Cobb Award for the best freshman player on the Yale team as the Bulldogs went 13–15. He received little playing time, averaging just 6.5 minutes per game, although he did manage to score 2.1 points per game.

### Sophomore year

Mangano was given a bigger role in his sophomore year. He hit the weight room hard over the summer following his freshman year. His playing time tripled, and he led the Ivy League in blocks with 2 per game. He also added 7.5 points and 5.5 rebounds per game. Despite his success, Yale struggled, going 12–19.

### Junior year

Mangano had a breakout season his junior year, averaging a double-double for the Bulldogs with 16.3 points per game and 10 rebounds per game, along with 3 blocks per game. His 85 blocks were a Yale record, and the third-highest total in Ivy League history. As well as finishing second in scoring, Mangano led the Ivy League in blocks and rebounding; his totals were good for 9th and 24th in the nation respectively. His play was good enough to warrant selection to the All-Ivy first team and the National Association of Basketball Coaches All-district first team. Mangano declared for the 2011 NBA draft, but withdrew his name before the deadline. Yale had some success, finishing the year with a 15–13 record.

### Senior year

Mangano came into his senior year considered a strong contender for Ivy League Player of the Year. The Bulldogs had early success and impressed in many of their games against stronger opposition. Mangano was particularly impressive against the then-10th ranked Florida Gators, scoring 26 points, grabbing 12 rebounds, blocking two shots, and making 4 of the 6 three-pointers that he attempted. The Bulldogs had an outside chance to claim the Ivy League title entering their final 3 games, but losses to Princeton and Penn prevented the Bulldogs from claiming the title. The loss to the Penn Quakers was likely due to Mangano being the target of heckling by the Penn Band. Mangano's statistical numbers were very similar to those in his junior year. He led the Ivy League in rebounds and blocks, averaging 9.7 and 2.2 per game respectively. He was also sixth in the Ivy League in scoring with 18.2 points per game. He was named to the All-Ivy First Team. In terms of team success, Mangano's senior year was his best at Yale, as the Bulldogs went 19-10 and qualified for the CollegeInsider.com Tournament, where the team lost in the first round to the Rakim Sanders -led Fairfield Stags 68–56. Mangano had 17 points and 8 rebounds.

Mangano helped bring Yale back to relevance in the Ivy League after years at the bottom of the league. He finished his career with 213 blocks, which is most in Yale history- more than former NBA player Chris Dudley - and the third most in Ivy League history. Mangano was also sixth in school history in rebounds and 13th in points.

## Professional career

Mangano was honored as one of the nation's best seniors when he was selected to participate in the prestigious Portsmouth Invitational Tournament. His best game was his second; he scored 13 points on 5–11 shooting, including 3 of 5 from three, and grabbed 9 boards. he started and played 26 minutes. Mangano averaged 10.7 points, 6 rebounds, and 1 block per game while shooting 46.2 percent from three-point range, which was the sixth best percentage in the tournament. Despite working out with many teams, Mangano went undrafted in the 2012 NBA draft, although according to his agent Mangano would have been picked if he had been European. Mangano said that this shows that, "the NBA still doesn't respect the level of play in the Ivy League."

After going undrafted, Mangano signed with Antalya BB in the Turkish Basketball League On 29 December 2012, he left Turkey to join Força Lleida in the LEB Oro, Spain's second division. In 2013, Mangano signed with ratiopharm Ulm in Germany.

On August 12, 2018, Mangano signed with the Ukrainian team Kyiv-Basket. He chose the jersey number 44. He spent the 2019-20 season with Bambitious Nara of B.League, averaging 21.6 points and 15.1 rebounds per game. On August 29, 2020, Mangano signed with KTP Basket of Korisliiga.

## USA Basketball

Mangano's play led him to try out for the USA World University Games Team in 2008. He made the team, and appeared in 6 of the team's 8 games. He averaged 3.2 points and 3.2 rebounds per game, while averaging 11.3 minutes per game. He was second on the team with 5 blocks. The US went 7–1, good for 5th place.


Black Point (artist)

# Black Point (artist)

## Abstract

Jonás Joaquín Ortiz Alberto (born 1989), is better known by his stage name Black Jonas Point (credited as Black Jonas Point) is a Dominican rapper, songwriter and producer from Santo Domingo.

## Music career

Ortiz, along with Del Patio, wrote and performed on the Pitbull song " Watagatapitusberry ", which reached number 30 in the US Billboard Latin Songs chart and number 13 in the US Billboard Tropical Songs chart.

Ortiz performed during the 2010 Puerto Rican Day Parade in New York City.

## Discography

### Singles

- 2010 - Watagatapitusberry

### Mixtape

- 2010 - Te Dio Pa Eso


Digital ecology

# Digital ecology

## Abstract

Digital ecology is a science about the interdependence of digital systems and the natural environment. This field of study looks at the methods in which digital technologies are changing the way how people interact with the environment, as well as how these technologies affects the environment itself. It is a branch of ecology that promotes green practices to fight digital pollution. Currently the total carbon footprint of the internet, our electronic devices, and supporting elements accounts for about 3.7% of global greenhouse gas emissions (including about 1.4 per cent of overall global carbon dioxide emissions).

Digital Ecology can also be used to denote the use of technology in the study of ecological systems and processing, examining how technological developments aid in the collection, analysis and management of ecological data. Important fields in this aspect of Digital Ecology include the development of drone technology for wildlife monitoring.

Digital ecology is a complex and multifaceted field that requires a holistic approach to understanding the relationship between digital technologies and the natural world. With the increasing reliance on digital technologies, it is important to consider the environmental consequences of these technologies and work towards more sustainable solutions.

## Negative impact on the environment

One of the main areas of focus in digital ecology is the impact of electronic waste, or e-waste. As more and more devices become obsolete and are replaced with newer models, the amount of e-waste being produced is increasing at an alarming rate. This e-waste often ends up in landfills, where it can leach harmful chemicals into the soil and water supply.

Another aspect of digital ecology is the energy consumption of digital technologies and the digital pollution in causes. The production and use of digital devices requires significant amounts of energy, and as the demand for these devices increases, so does the amount of energy required to meet this demand.. The total carbon footprint of the internet, our electronic devices, and supporting elements add up to about 3.7% of global greenhouse gas emissions. It is as much as for the airline industry and the number keeps on rising. This increase in energy consumption has a negative impact on the environment, as it contributes to climate change and air pollution. Research has shown, that if the internet was a country, it would be the seventh largest polluter in the world, by some estimates.

### Digital Pollution

Digital pollution is a crucial aspect of digital ecology. It is the main problem against which digital ecology is fighting. Digital pollution refers to the negative impact of digital technology and electronic waste on the environment and human health. This can include emissions from electronic devices, toxic chemicals in electronic waste, and the proliferation of e-waste in landfills.

Technology users contribute to digital pollution on a daily basis, which include:

- Data clouds and servers - keeping many data on clouds and servers and transferring them contribute to air pollution through the energy used to power and cool these data centers and sending the data. The energy consumption of data centers results in emissions of greenhouse gases, such as harmful carbon dioxide. The energy is generated by power plants, which often burn fossil fuels such as coal, oil, and natural gas, releasing harmful pollutants into the air. In addition, the air conditioning systems used to cool the servers also consume a significant amount of energy and release heat into the environment. This is primarily influenced by large databases, but people's day-to-day activities are also not insignificant. An example of this would be storing and accessing emails. An average year of emailing emits about 136 kilograms of CO. One inbox consumes enough energy to run a hot shower for about 4 minutes, which is equal to illuminating 40 lightbulbs for an hour and equal to pollution by driving a car 212 metres. Addictionally, data centers consume large amounts of energy to power and cool the servers that store and process spam email data, resulting in emissions of greenhouse gases and other pollutants.

- Production of electronic devices - has a detrimental effect on the environment for several reasons: increasing the demand for raw materials, rare earth minerals, energy, water usage, and other resources, and contribute to environmental degradation through the associated pollution and waste. Manufacturing is the most polluting phase. It accounts for up to 80% of a device's carbon footprint during its lifetime. Buying new equipment every six years rather than every four reduces carbon dioxide production by 190 kg.

- Energy-inefficient electronics - they consume more electricity, which in turn requires more energy to be generated, often from power plants that burn fossil fuels. Additionally, inefficient electronics also generate more heat, which requires more energy for cooling, further increasing the total energy consumption and associated emissions. When these electronic devices reach the end of their lifespan and are disposed of, they can also become electronic waste, which can release toxic chemicals into the environment.

- Unnecessary charging of electronic devices - can contribute to air pollution through the increased energy consumption. Unnecessary charging of devices, such as smartphones or laptops, increases the overall energy demand and contributes to emissions from power plants. Charging smartphones generates more carbon dioxide than charging laptops.

- Electronic waste - electronic devices eventually reach the end of their lifespan and become waste. The improper disposal of electronic waste release toxic chemicals into the environment, contaminating soil and water, and harming wildlife.

## Positive impact on the environment

Despite the environmental impact of electronic devices and data centers, digital technologies positively impact the environment in a variety of ways:

- Energy efficiency: Digital technologies can help increase energy efficiency through the use of smart energy systems, such as smart grid systems and energy-efficient devices.

- Reduced waste: The use of digital technologies can reduce waste by reducing the need for paper and other physical materials.

- Enhanced education: Digital technologies can enhance education by providing access to information and resources, promoting sustainable practices and environmental awareness.