Denied a license, Missouri’s only abortion clinic awaits judge’s ruling

FILE PHOTO: Planned Parenthood's employees look on as anti-abortion rights advocates hold a rally in St. Louis, Missouri, U.S., June 4, 2019. REUTERS/Lawrence Bryant

By Robert Langellier

ST. LOUIS (Reuters) – Missouri health officials on Friday refused to renew the license of the state’s only abortion clinic, but the facility will remain open for now as a judge left in place an injunction blocking its closure.

At a brief circuit court hearing on Friday, Judge Michael Stelzer said it might be days before the court would come to a decision on whether the state could shut its only abortion clinic, which is operated by women’s healthcare and abortion provider Planned Parenthood.

“I think you guys are expecting an order soon. I don’t know that order is going to be today,” Stelzer said during the hearing, which lasted less than five minutes.

If the clinic were to close, Missouri would become the only U.S. state without a legal abortion clinic.

Missouri officials did not immediately respond to a request for comment.

“This decision signals the true motive behind this license renewal mess that has left patients in limbo, uncertain about their health care: to ban abortion without ever overturning Roe v. Wade,” Dr. Colleen McNicholas, a physician at Planned Parenthood’s Missouri clinic, said in a statement.

The state is one of 12 to pass laws restricting abortion access this year, some aimed at provoking a U.S. Supreme Court review of the landmark 1973 Roe v. Wade decision that recognized a woman’s right to terminate her pregnancy.

Planned Parenthood sued Missouri health officials after they warned they would decline to renew the license of the Reproductive Health Services of Planned Parenthood clinic in St. Louis on the grounds it failed to meet their standards.

Stelzer on June 10 issued a preliminary injunction blocking the clinic’s closure until the state made an official decision on its license.

Abortion is one of the most divisive issues in the United States, with opponents often citing religious beliefs to call it immoral.

The legal battle in Missouri began after Governor Mike Parson, a Republican, signed a bill on May 24 banning abortion beginning in the eighth week of pregnancy.

Planned Parenthood has vowed to fight to protect abortion access in Missouri and to push back on regulatory standards that the women’s healthcare organization believes put a burden on abortion rights.

Court documents show that Missouri health officials declined to renew the clinic’s license to perform abortions because they were unable to interview seven of its physicians over “potential deficient practices.”

(Reporting by Robert Langellier in St. Louis; writing by Gabriella Borter; editing by Scott Malone, Sonya Hepinstall and Jonathan Oatis)

Planned Parenthood sues to block U.S. rule that may limit abortions

FILE PHOTO: A sign is pictured at the entrance to a Planned Parenthood building in New York August 31, 2015. REUTERS/Lucas Jackson/File Photo

By Jonathan Stempel

NEW YORK (Reuters) – Planned Parenthood and other nonprofits offering family planning services sued the Trump administration on Tuesday to block a new federal rule letting healthcare workers refuse abortions and other services because of religious or moral objections.

The two lawsuits filed in Manhattan federal court said enforcing the “conscience” rule would encourage discrimination against women, minorities, the poor, the uninsured, and lesbian, gay, bisexual, transgender and queer people by curbing access to legal healthcare procedures, including life-saving treatments.

They also said the rule, issued by the Department of Health and Human Services and scheduled to take effect on July 22, would impose heavy costs on healthcare providers dependent on federal funding, which they could lose by refusing to comply.

The plaintiffs also include Planned Parenthood of Northern New England Inc, the National Family Planning and Reproductive Health Association and Public Health Solutions Inc. The American Civil Liberties Union represents the latter two nonprofits.

“Trust is the cornerstone of the physician-patient relationship,” Leana Wen, president of Planned Parenthood Federation of America, said in a statement. “No one should have to worry if they will get the right care or information because of their providers’ personal beliefs.”

HHS pledged to defend the rule vigorously. Planned Parenthood said the rule might affect more than 613,000 hospitals, health clinics, doctors’ offices and nonprofits.

The lawsuits escalate the legal battles over a rule announced on May 2 by Republican President Donald Trump, who has made expanding religious liberty a priority, in a Rose Garden speech marking the National Day of Prayer.

They were filed after California, New York, New York City, Chicago and 20 other mostly Democratic-controlled or Democratic-leaning states and municipalities sued the government on May 21 over the rule. San Francisco filed its own lawsuit on May 2.

HHS has said the rule protects the rights of workers who might oppose particular procedures, such as sterilizations and assisted suicides.

It has also said the rule requires compliance with roughly 25 federal laws protecting conscience and religious rights, some of which date back decades.

Roger Severino, director of HHS’ Office for Civil Rights, on Tuesday repeated his May 21 statement that the rule “gives life and enforcement tools” to those laws.

The cases are Planned Parenthood Federation of America Inc et al v Azar et al, U.S. District Court, Southern District of New York, No. 19-05433; and National Family Planning and Reproductive Health Association et al v Azar et al in the same court, No. 19-05435.

(Reporting by Jonathan Stempel in New York; Editing by Tom Brown and Richard Chang)

Judge weighs fate of Missouri’s only abortion clinic after court hearing

Planned Parenthood's employees look on as anti-abortion rights advocates hold a rally in St. Louis, Missouri, U.S., June 4, 2019. REUTERS/Lawrence Bryant

By Gabriella Borter and Brendan O’Brien

(Reuters) – A St. Louis judge said on Tuesday he will work quickly to decide whether Missouri’s only abortion clinic can remain open after a hearing on a lawsuit aimed at forcing state health officials to renew the facility’s license to perform the procedure.

Women’s healthcare and abortion provider Planned Parenthood sued Missouri last week after state health officials refused to renew the license of the St. Louis clinic, called Reproductive Health Services of Planned Parenthood, because, they said, they were unable to interview seven of its physicians over “potential deficient practices,” according to court documents.

Judge Michael Stelzer held a hearing on Tuesday morning on motions filed by Planned Parenthood in its request for a preliminary injunction that would keep the clinic open longer. He could schedule more hearings or rule on the request.

Stelzer intervened on Friday before the clinic’s license to perform abortions was set to expire hours later, issuing a temporary restraining order against the state at the request of Planned Parenthood that enabled the clinic to continue providing the procedure.

After listening to arguments from both sides on Tuesday, Stelzer said he will work “expeditiously” to come to a decision in the case, according to a court spokesman.

Abortion is one of the most divisive issues in U.S. politics, with opponents often citing religious beliefs to call it immoral. Abortion rights advocates have said restrictions being passed at the state level amount to state control of women’s bodies.

If the facility’s license is not renewed, Missouri would become the only U.S. state without an abortion clinic since the Supreme Court’s landmark Roe v. Wade decision in 1973 that legalized abortion nationwide and recognized a woman’s right to terminate her pregnancy.

The legal battle in St. Louis began after Missouri Governor Mike Parson, a Republican, signed a bill on May 24 banning abortion beginning in the eighth week of pregnancy, making Missouri one of nine U.S. states to pass anti-abortion legislation this year.

Anti-abortion activists have said they hope to prompt the conservative-majority U.S. Supreme Court to overturn the Roe v. Wade ruling by enacting laws such as the one recently passed in Missouri that are assured of facing court challenges.

The Supreme Court last week sent a mixed message on abortion, refusing to consider reinstating Indiana’s ban on abortions performed because of fetal disability or the sex or race of the fetus while upholding the state’s requirement that fetal remains be buried or cremated after the procedure is done. Several other abortion-related cases also are heading toward the high court.

(Reporting by Brendan O’Brien in Chicago and Gabriella Borter in New York; Editing by Scott Malone and Will Dunham)

Fate of Missouri’s only abortion clinic at stake as St. Louis judge holds hearing

A banner stating "STILL HERE" hangs on the side of the Planned Parenthood Building after a judge granted a temporary restraining order on the closing of Missouri's sole remaining Planned Parenthood clinic in St. Louis, Missouri, U.S. May 31, 2019. REUTERS/Lawrence Bryant

(Reuters) – The fate of Missouri’s only abortion clinic will be at stake on Tuesday when a St. Louis judge hears arguments in Planned Parenthood’s lawsuit aimed at forcing state health officials to renew the facility’s license to perform the procedure.

Planned Parenthood sued Missouri last week after state health officials refused to renew the license of Reproductive Health Services of Planned Parenthood in St. Louis because, they said, they were unable to interview seven of its physicians over “potential deficient practices,” according to court documents.

Abortion is one of the most socially divisive issues in U.S. politics, with opponents often citing religious beliefs to call it immoral. Abortion-rights advocates say the bans amount to state control of women’s bodies.

St. Louis Circuit Court Judge Michael Stelzer intervened on Friday before the clinic’s license to perform abortions was set to expire at midnight. He issued a temporary restraining order against the state at the request of Planned Parenthood, allowing the clinic to continue offering the procedure.

Stelzer will hold a hearing on Tuesday morning on motions filed by Planned Parenthood in its request for a preliminary injunction that would keep the clinic open longer. He could schedule more hearings or rule on the request.

If the facility’s license is not renewed, Missouri would become the only U.S. state without an abortion clinic since the Supreme Court’s Roe v. Wade decision in 1973 that established a woman’s right to terminate her pregnancy.

The legal battle in St. Louis began after Missouri Governor Mike Parson, a Republican, signed a bill on May 24 banning abortion beginning in the eighth week of pregnancy, making Missouri one of nine U.S. states to pass anti-abortion legislation this year.

Anti-abortion activists say they aim to prompt the newly installed conservative majority on the U.S. Supreme Court to overturn Roe v. Wade by enacting laws such as the one recently passed in Missouri that are virtually assured of facing court challenges.

(Reporting by Brendan O’Brien in CHICAGO; Editing by Paul Tait)

Missouri abortion clinic to stay open for now after court order

Pro-Life supporters protest outside of Planned Parenthood as a deadline looms to renew the license of Missouri's sole remaining Planned Parenthood clinic in St. Louis, Missouri, U.S. May 31, 2019. REUTERS/Lawrence Bryant

By Pavithra George

ST. LOUIS (Reuters) – Missouri’s only abortion clinic will stay open at least a few more days after a judge on Friday granted a request by Planned Parenthood for a temporary restraining order, allowing the facility to keep operating until a hearing on Tuesday.

Planned Parenthood sued Missouri this week after state health officials said the license for Reproductive Health Services of Planned Parenthood in St. Louis was in jeopardy, meaning the clinic could have closed at midnight unless the judge granted the request for a temporary restraining order.

“Today is a victory for women across Missouri, but this fight is far from over,” Planned Parenthood President Leana Wen said in a statement after Circuit Court Judge Michael Stelzer agreed to the organization’s request.

Representatives for the Missouri Department of Health and Senior Services could not be immediately reached for comment.

Health officials had refused to renew the clinic’s license because, they said, they were unable to interview seven of its physicians over “potential deficient practices,” according to documents filed in a St. Louis court.

The legal battle in St. Louis comes a week after Missouri Governor Mike Parson, a Republican, signed a bill banning abortion beginning in the eighth week of pregnancy, making Missouri one of nine U.S. states to pass anti-abortion legislation this year.

On Friday, Stelzer said the clinic’s license would remain in effect until a ruling is made on Planned Parenthood’s request for a preliminary injunction against the state. A hearing on that matter is scheduled for 9 a.m. on Tuesday.

Outside the clinic on Friday, a handful of anti-abortion protesters stood holding “Choose Life” signs.

Abortion is one of the most socially divisive issues in U.S. politics, with opponents often citing religious beliefs to call it immoral, while abortion-rights advocates say the bans amount to state control of women’s bodies.

Anti-abortion activists say they aim to prompt the newly installed conservative majority on the U.S. Supreme Court to overturn Roe v. Wade by enacting laws that are virtually assured of facing court challenges.

 

(Additional reporting by Gabriella Borter in New York; Editing by Scott Malone, Leslie Adler and David Gregorio)

As conservative U.S. states pass abortion bans, Missouri’s sole clinic could close

People take part in a pro-choice march in St. Louis, Missouri, U.S., May 30, 2019 in this image obtained from social media. Ael Diehm/via REUTERS

By Pavithra George

ST. LOUIS (Reuters) – Missouri could become the only U.S. state without a legal abortion provider on Friday, as its only abortion clinic could lose its license to perform the procedure unless a St. Louis judge intervenes.

The legal battle in St. Louis comes a week after Missouri Governor Mike Parson, a Republican, signed a bill banning abortion beginning in the eighth week of pregnancy, making Missouri one of nine U.S. states to pass anti-abortion legislation this year.

Planned Parenthood sued Missouri this week after state health officials said the license for Reproductive Health Services of Planned Parenthood in St. Louis was in jeopardy because they were unable to interview seven of its physicians over “potential deficient practices,” documents filed in a St. Louis court showed.

The circuit judge in the case, Michael Stelzer, was expected on Friday to rule on Planned Parenthood’s request for a temporary restraining order and injunction against the state, according to local media.

Outside the clinic, a handful of anti-abortion protesters stood holding “Choose Life” signs early Friday.

If Stelzer rules against Planned Parenthood, the clinic’s license to perform abortions would expire at midnight, making Missouri the only U.S. state without an abortion clinic since the Supreme Court’s Roe v. Wade decision in 1973 that established a woman’s right to terminate her pregnancy.

Abortion is one of the most socially divisive issues in U.S. politics, with opponents often citing religious beliefs to call it immoral, while abortion-rights advocates say the bans amount to state control of women’s bodies.

On Thursday, abortion-rights demonstrators held a rally in downtown St. Louis, where police arrested Alderman Megan Ellyia Green and several Planned Parenthood board members during a sit-in at the Wainwright State Office Building, the St. Louis Post Dispatch reported.

Anti-abortion activists say they aim to prompt the newly installed conservative majority on the U.S. Supreme Court to overturn Roe v. Wade by enacting laws that are virtually assured of facing court challenges.

A series of prominent U.S. media companies said they will rethink working in Georgia, if a new state law takes effect, banning abortions as soon as a fetal heartbeat can be detected by doctors. That standard effectively bans abortions at about six weeks into a pregnancy, before some women would even be aware they were pregnant.

Those companies include AT&T Inc’s WarnerMedia, CBS Corp, Viacom Inc, Comcast Corp’s NBCUniversal, AMC Networks Inc, Walt Disney Co and Netflix Inc.

(Additional reporting by Gabriella Borter in New York and Brendan O’Brien in Chicago; Editing by Scott Malone, Leslie Adler and David Gregorio)

Missouri’s last abortion clinic warns it may close after state action

FILE PHOTO: A sign is pictured at the entrance to a Planned Parenthood building in New York August 31, 2015. REUTERS/Lucas Jackson/File Photo

By Gabriella Borter

(Reuters) – Missouri’s only abortion clinic expects to be shut down this week after the state health department refused to renew its license, which would make it the only U.S. state without a legal abortion clinic, Planned Parenthood said on Tuesday.

The Missouri Department of Health and Senior Services did not respond to a request for comment.

The regulatory move is the latest in a wave of actions in Republican-led states to stop abortion. Anti-abortion activists say they aim to prompt the newly installed conservative majority on the U.S. Supreme Court to overturn the 1973 Roe v. Wade decision that established a woman’s right to terminate her pregnancy.

Missouri Governor Mike Parson on Friday signed a bill banning abortion beginning in the eighth week of pregnancy, making Missouri one of eight states that have passed anti-abortion legislation this year.

“This is a real public health crisis,” said Leana Wen, president of Planned Parenthood Federation of America, which runs the clinic. “More than a million women of reproductive age in Missouri will no longer have access to a health center in the state they live in that provides abortion care.”

The state department of health told the clinic it could not approve a license until it interviewed seven physicians who the state believed might be involved in “potential deficient practices,” CBS News reported, citing written communication between the clinic and the health department. Planned Parenthood said it could not comply with this request because only two of the physicians are employed by Planned Parenthood, and the other five have not agreed to be interviewed, according to CBS.

Planned Parenthood said in a statement that the clinic would sue the state health department on Tuesday to preserve access to legal abortions in the state.

CHALLENGE TO EIGHT-WEEK BAN

Separately, the American Civil Liberties Union (ACLU) of Missouri said on Tuesday that it would seek to repeal Missouri’s law banning abortion after the eighth week of pregnancy through a referendum on the state’s 2020 election ballot.

If the Missouri Secretary of State certifies the referendum petition for circulation, the ACLU would then need to collect over 100,000 signatures before Aug. 28 – when the law is due to go into effect – to delay the law until a 2020 vote.

The recent wave of anti-abortion legislation reflects a boost of confidence among anti-abortion advocates after Republican President Donald Trump named two justices, Neil Gorsuch and Brett Kavanaugh, to the U.S. Supreme Court, establishing a 5-4 conservative majority.

Earlier this year, Georgia, Kentucky, Mississippi and Ohio outlawed abortion after a doctor can detect an embryonic heartbeat, which can occur at six weeks, often before a woman knows she is pregnant. Two weeks ago, Alabama passed a total ban on abortions except if a pregnant woman’s life is in danger.

Despite the uptick in anti-abortion measures from Republican-led states, a Reuters/Ipsos poll found that 58% of American adults said abortion should be legal in most or all cases, up from 50% in a similar poll that ran 10 months earlier in July 2018.

Abortion-rights activists have pledged legal action against the states that pass laws contradicting Roe v. Wade. The ACLU and Planned Parenthood filed a lawsuit against Alabama last week and have obtained injunctions blocking Kentucky and Mississippi’s anti-abortion laws.

Anti-abortion advocates have said they expected legal challenges to these laws and that they welcome the chance to have a court test their conviction that a fetus’ right to life is paramount.

Meanwhile, U.S. Senator and Democratic presidential hopeful Kamala Harris on Tuesday was set to unveil her plan to protect abortion rights.

(Reporting by Gabriella Borter; Editing by Scott Malone and Bill Berkrot)

Supreme Court upholds Indiana fetal burial law, spurns abortion measure

FILE PHOTO: The U.S. Supreme Court building is seen in Washington, U.S., March 26, 2019. REUTERS/Brendan McDermid/File Photo

By Lawrence Hurley

WASHINGTON (Reuters) – The U.S. Supreme Court on Tuesday upheld Indiana’s Republican-backed requirement that fetal remains be buried or cremated, dealing a setback to abortion provider Planned Parenthood, which had challenged the provision.

The unsigned ruling, with two of the court’s liberals dissenting, said an appeals court was wrong to conclude that the law had a illegitimate purpose.

But the court also turned away the state’s separate attempt to reinstate its Republican-backed ban on abortions performed because of fetal disability or the sex or race of the fetus, which was also struck down by lower courts.

Both provisions were part of a 2016 law signed by Vice President Mike Pence when he was Indiana’s governor.

The ruling stated that the court has previously said that states have a legitimate interest in the disposal of fetal remains. The court noted that in challenging the law, Planned Parenthood did not allege that the provision implicated the right of women to obtain an abortion.

“This case, as litigated, therefore does not implicate our cases applying the undue burden test to abortion regulations,” the ruling said.

Liberal justices Ruth Bader Ginsburg and Sonia Sotomayor both said they disagreed with the court’s decision to reinstate the fetal remains provision.

Indiana’s law was one of many passed by Republicans at the state level putting restrictions on abortion, which was legalized nationwide by the Supreme Court in the 1973 Roe v. Wade ruling.

The Chicago-based 7th U.S. Circuit Court of Appeals upheld a 2017 permanent injunction issued by U.S. District Judge Tanya Walton Pratt against the Indiana law. She found the measure violated the constitutional privacy rights recognized in the 1973 abortion ruling.

Indiana required that abortion providers bury or cremate fetal remains after an abortion.

The law also forbade women from obtaining an abortion if the decision to terminate the pregnancy was based on a diagnosis or “potential diagnosis” of fetal abnormality such as Down syndrome or “any other disability” or due to the race, color, national origin ancestry or sex of the fetus. Indiana said the state has an interest in barring discrimination against fetuses and in protecting the “dignity of fetal remains.”

A similar fetal burial law from Minnesota was upheld by a federal appeals court in 1990 but the Indiana law and another like it in Texas, enacted in 2016, have been struck down by the courts.

In Tuesday’s ruling, the court said its decision not to review the second provision of Indiana’s law “expresses no view on the merits.”

(Reporting by Lawrence Hurley; Editing by Will Dunham)

ACLU, Planned Parenthood sue over Alabama abortion ban

FILE PHOTO: The U.S. Flag and Alabama State Flag fly over the Alabama Governor's Mansion as the state Senate votes on the strictest anti-abortion bill in the United States at the Alabama Legislature in Montgomery, Alabama, U.S. May 14, 2019. REUTERS/Chris Aluka Berry

By Gabriella Borter

(Reuters) – The American Civil Liberties Union (ACLU) and Planned Parenthood filed a lawsuit on Friday challenging a law enacted by Alabama last week that bans nearly all abortions and makes performing the procedure a felony punishable by up to 99 years in prison.

The lawsuit is one of several the groups have filed or are preparing to file against states that recently passed strict anti-abortion measures in an effort to prompt the U.S. Supreme Court to overturn Roe v. Wade, the 1973 landmark case that guarantees a woman’s constitutional right to abortion.

“This dangerous, immoral, and unconstitutional ban threatens people’s lives and well-being and we are suing to protect our patients’ rights,” Leana Wen, president of the Planned Parenthood Federation of America, said in a statement.

The ACLU’s Alabama chapter and Planned Parenthood of America filed their complaint in federal court in Alabama on behalf of the Southern state’s three abortion clinics and Planned Parenthood Southeast.

Anti-abortion advocates expected legal challenges to Alabama’s new law, which will be the most restrictive in the nation when it takes effect in November, and say they welcome the chance to have a court test their conviction that a fetus’ right to life is paramount.

Also on Friday, Missouri Governor Mike Parson signed a bill into law that bans abortion beginning in the eighth week of pregnancy.

Earlier this year, Georgia, Kentucky, Mississippi and Ohio outlawed abortion after a doctor can detect an embryonic heartbeat, which can occur at six weeks, often before a woman knows she is pregnant.

The wave of anti-abortion legislation reflects a boost of confidence among anti-abortion advocates after Republican President Donald Trump nominated two conservative judges, Neil Gorsuch and Brett Kavanaugh, to the U.S. Supreme Court, tilting the court’s political balance to the right.

Alabama state Senator Clyde Chambliss, a Republican, supports his state’s new law and said the whole point of the ban was “so that we can go directly to the Supreme Court to challenge Roe versus Wade.”

The ACLU and Planned Parenthood obtained an injunction from a judge in Kentucky in March, blocking that state’s abortion ban. The organizations have filed lawsuits in Ohio and are preparing to do so in Georgia, they said in a statement on Friday.

(Reporting by Gabriella Borter in New York; Editing by Daniel Wallis and Jonathan Oatis)

Missouri governor expected to sign new abortion restrictions into law

U.S. President Donald Trump speaks with the Governor of Missouri Mike Parson as he arrives in St. Louis, Missouri, U.S., July 26, 2018. REUTERS/Joshua Roberts

(Reuters) – Missouri’s Republican governor could sign a law as early as this week banning most abortions in the Midwestern state after the eighth week of pregnancy, part of a wave of restrictions aimed at driving a challenge of abortion to the U.S. Supreme Court.

Republican Governor Mike Parson told reporters on Friday he planned to sign the bill, which was approved by the Republican-controlled state legislature last week and would enact one of the United States’ most restrictive bans. He did not set a date for the signing but has until July 14 to do so, according to local media reports.

The state is one of eight where Republican-controlled legislatures this year have passed new restrictions on abortion. It is part of a coordinated campaign aimed at prompting the nation’s now conservative-majority top court to cut back or overturn the 1973 Roe v. Wade decision that established a woman’s right to terminate a pregnancy.

The most restrictive of those bills was signed into law in Alabama last week. It bans abortion at all times and in almost all cases, including when the pregnancy resulted from rape or incest but allows exceptions when the mother’s life is in danger. The Missouri bill also offers no exception for cases of rape or incest.

The American Civil Liberties Union has said it will sue to block Alabama’s law from taking effect. Last week, the ACLU joined Planned Parenthood, the women’s reproductive healthcare provider, in suing Ohio over its recent six-week abortion ban.

Abortion is one of the most bitterly contested social issues in the United States. Opponents often cite religious belief in saying that fetuses deserve rights similar to those of infants. Abortion rights advocates say the bans deprive women of equal rights and endanger those who end up seeking riskier, illegal methods to end a pregnancy.

Kentucky, Georgia, Utah, Mississippi and Arkansas have also passed new restrictions on abortion this year.

Conservative lawmakers have been emboldened in their efforts to roll back Roe v. Wade by two judicial appointments by President Donald Trump that have given conservatives a 5-4 majority on the court.

The Supreme Court could act as early as Monday on appeals seeking to revive two abortion restrictions enacted in Indiana in 2016.

Abortion rights activists on Sunday marched on the Alabama state capital in Birmingham to protest that state’s new law, which would take effect in two months.

(Reporting by Jonathan Allen in New York; editing by Scott Malone and Jonathan Oatis)