"Plaintiff's allegations are emotionally and politically charged, and ... Plaintiff is a member of certain groups subject to discrimination. That, however, is true of a plethora of cases in the federal courts and has generally not been understood to authorize anonymous pleading."
The Complaint alleges the following facts [which at this point are of course only allegations -EV]. Plaintiff John Doe is a "Jewish Israeli citizen who proudly served with the Israel Defense Forces," and who has family members currently living in Israel. Plaintiff first moved to the United States to "establish [a] U.S. market presence" for a "Startup" he was working for at the time. Shortly thereafter, Intel acquired the company and Plaintiff "began working for Intel as an Engineering Lead." In the ensuing years, Plaintiff had a successful career at Intel and was ultimately promoted to "Vice President of Engineering."
Following the October 7, 2023 attack on Israel by Hamas, Defendant Badr, "the Vice President of Customer Success at Intel," allegedly made a number of statements and interacted with a number of social media posts supporting Hamas's actions and "advocat[ing] for and celebrat[ing] the murder of Israelis like [Plaintiff] and the members of his family." On January 29, 2024, Badr became Plaintiff's direct manager. Plaintiff complained, but Intel "did not respond." Subsequently, Badr took actions to "mak[e] [Plaintiff's] professional life as intolerable as possible because of his Jewish and Israeli heritage," including acting "frigid and isolating" toward Plaintiff, asking Plaintiff which of his fellow employees were Israeli and making disparaging comments about them, refusing to approve Plaintiff's expense requests, interrupting Plaintiff in meetings, and interfering with Plaintiff's job responsibilities.
Plaintiff again complained and Intel conducted an investigation. Following the investigation, "Intel took no corrective action against Badr," but, on April 2, 2024, Plaintiff was "laid-off." When Plaintiff complained, "Intel then created a new job" for him, albeit "with a significant pay cut." Badr allegedly replaced Plaintiff in his old position with a new employee, "Ahmed," who "shared the same anti-Israel sentiments as Badr."
On July 3, 2024, Intel's Human Resources department informed Plaintiff "that his retention bonus was being cancelled." Plaintiff claims that this was done as "punish[ment] for protesting discrimination."
The court concluded that plaintiff, like other plaintiffs, had to sue under his own name:
Federal Rule of Civil Procedure 10(a) requires that "all the parties" be named in the title of the complaint. "This requirement, though seemingly pedestrian, serves the vital purpose of facilitating public scrutiny of judicial proceedings and therefore cannot be set aside lightly." … Plaintiff has "invoked the public forum of litigation in which there is a strong presumption of public access." "[P]seudonyms are the exception and not the rule, and in order to receive the protections of anonymity, a party must make a case rebutting that presumption."
And the court concluded that the strong presumption against pseudonymity wasn't rebutted here:
In November 2023, X Corp. sued Media Matters, Inc., Eric Hananoki, and Angelo Carusone (collectively, "Media Matters") for (1) interfering with X Corp.'s contract, (2) disparaging X Corp's business, and (3) interfering with X Corp.'s prospective economic advantage. X Corp. alleges that Media Matters "knowingly and maliciously" manipulated images to "portray X Corp. as a social media platform dominated by neo-Nazism and anti-Semitism," which "alienate[d] major advertisers, publishers, and users from X."
In discovery, X Corp. requested that Media Matters produce the identity of donors, their addresses, and its communications with them. Relevant to this appeal are X Corp.'s Requests for Production 17, 18, 21, and 35:
Request for Production 17. Documents sufficient to show the identity of all Your donors or any others who provide financial support of any kind, their residence, the time and place of their donation or provision of financial support, and the amount of their donations or other financial support.
Request for Production 18. Any document or communication reflecting Your attempts to solicit donations or financial support of any kind, including but not limited to any discussions with any donors or any others who provided, considered providing, or were asked to provide financial support of any kind.
Request for Production 21. All documents and communications regarding Your sources of funding for research, investigation, reporting, publication, or any other work related to X, the Platform, Elon Musk, or Linda Yaccarino.
Request for Production 35. All materials regarding or communications with any donor or potential donor to Media Matters mentioning or regarding in any way this Matter, Elon Musk, Linda Yaccarino, X, Twitter, or the Platform, including misinformation, brand safety, or ad pairing on the Platform.
The panel granted a stay of the district court's order enforcing the subpoenas:
While I am eager for the Court to take another public use case, I am actually happy the justices chose to reject this one. Its unusual facts made it a poor vehicle for revisiting Kelo v. City of New London.
Today, the Supreme Court refused to review the case of Brinkmann v. Town of Southold, which raised an unusual and extremely difficult issue about the meaning of "public use" in the Takings Clause of the Fifth Amendment. Three justices (Thomas, Gorsuch, and Kavanaugh) wanted to take the case, but four votes are necessary to grant a petition for writ of certiorari. I summarized the key issue in the case in a previous post about it (in part by quoting takings litigator Robert Thomas):
The Takings Clause of the Fifth Amendment says the government may only "take" private property for a "public use." In cases like Berman v. Parker and Kelo v. City of New London, the Supreme Court has ruled (wrongly, in my view) that almost any potential benefit to the public qualifies as a "public use." Thus, in Kelo the Court upheld the condemnation of homes for purposes of promoting privately owned "economic development…"
But the Kelo majority also indicated that a taking can still be invalidated if the government tries to "take property under the mere pretext of a public purpose, when its actual purpose was to bestow a private benefit…."
How do courts determine whether a taking is pretextual? Since Kelo, lower-court decisions on that issue have been all over the map. In Chapter 7 of my book The Grasping Hand: Kelo v. City of New London and the Limits of Eminent Domain, I identified at least five different approaches to this issue adopted by state and lower federal courts since Kelo….
Most pretextual takings cases deal with situations where the government condemns property for transfer to a private party. But in Brinkmann v. Town of Southold, the US Court of Appeals for the Second Circuit addressed a case where a condemnation for transfer to public ownership might still be pretextual, because the official rationale was a pretty obvious smokescreen for a different motive….
[what follows is excerpted from Robert Thomas's summary of the case and lower court rulings:]
The Brinkmanns wanted to build a big box hardware store on a 1.7 acre vacant parcel. The usual objections from area residents and the Town itself appeared… Even a failed attempt by the Town to buy the property itself before the Brinkmanns closed their purchase.
When all those didn't succeed in stopping the development, the Town began proceedings to forcibly acquire the land by eminent domain. What for, you ask? A public park. More precisely, a "passive use park." What's that, you ask? It isn't what you might think make a typical public park. Things like public facilities, art installations, walking trails, recreational and entertainment spots…. No, this was to have none of those things, it was to be "a park with no significant facilities or improvements," also known as a big open, empty field….
Next step was a federal court section 1983 action by the Brinkmanns, "alleging a pretextual taking in violation of the Takings Clause of the Fifth Amendment…." The Town may have claimed that the taking was for a "classic" public use…., but the Town's actual reason, the Brinkmanns alleged, was what we call a "spite taking"—the Town didn't like the use we're making or going to make of our property, so decided to take it from us. This was the real motivation to take our property, and that's not a public use, according to the complaint. The district court wasn't having any of it, and dismissed for failure to state a claim.
A divided panel of the Second Circuit affirmed…..
As the opinion put it, "Plaintiffs have not pointed to any Town purpose that violates the Takings Clause…"
In short (and this is our characterization, not the court's), the Fifth Amendment contains a Public Use Clause, not a "Good Motivation Clause…"
I would very much like the Supreme Court to take another public use case, and overrule Kelo and Berman, or at least cut back on those badly flawed precedents. But, for reasons noted in my earlier post, I think this case would have been a bad vehicle for reviewing these issues:
Having written a book and numerous articles on public use issues, I rarely run across a public use case where I'm unsure what the right outcome should be. But this is one of those rare times.
Pretextual takings doctrine is a mess generally. But I think it can legitimately be used to strike down a variety of takings for transfer to private parties; indeed, I believe most such takings are unconstitutional even aside from the pretextual motives, because I support the "narrow" view of "public use" under which the government may only take property for publicly owned facilities or private ones that have a legal duty to serve the entire public.
In most situations, the narrow view is satisfied when the government takes property for public ownership…. But this case is different from most takings for public ownership because the government isn't actually using the condemned property for anything. As Judge Menashi puts it [in his dissenting opinion], the supposed "public park" is actually "fake."
This opens up the possibility there can be public ownership without public use. To be sure, there can sometimes be "use" even if the government doesn't build anything on the land it takes…. But there is no such use here, not even a "passive" one. The only goal is to block the Brinkmanns' plan to build a hardware store, not to use the land for any affirmative purpose.
Perhaps such blocking can still be a "use." But the issue is a difficult and murky one…..
Pretextual takings jurisprudence has long been a mess, and at least four Supreme Court justices have expressed interest in clearing it up, and perhaps overruling or limiting Kelo in the process.
I very much hope the Supreme Court does clean up the mess and—better still—overrules Kelo. But this case is not a good vehicle for that.
Unlike Kelo, it does not address the issue of condemnations for transfer to private parties.vIt instead deals with the unusual situation where the government retains the condemned property but has no desire to do anything with it other than block a private use it objects to. The issue is an extremely difficult one. And even if the Court resolves this hard question correctly, doing so would not do much to improve public use doctrine more generally.
Legal issues aside, I think the Brinkmanns were victims of an egregious abuse of government power here. Even if it doesn't violate the Public Use Clause to do so, local governments shouldn't use the "despotic power" of eminent domain merely to eliminate uses of property neighbors dislike. It's even worse if they end up turning a potentially valuable land use into an empty lot of no value to anyone. Calling it a "passive park" doesn't make that right. But not every injustice makes a good Supreme Court case. Sadly, this is one of the many that doesn't.
NOTE: The Brinkmanns are represented by the Institute for Justice, with which I have worked on other property rights issues over the years. I have no involvement in this case.
I think we need to update the metaphors we use around free speech. Everyone can see that our communication tools and practices are evolving fast, with a mix of welcome and unwelcome results. But there is an aspect of this evolution that is seriously underappreciated. Our communication tools and practices are increasingly subject to standardizing and homogenizing pressures. We are being corralled into a narrower range of devices and methods for talking to each other. We need to actively strategize about how to deal with the threat that this homogenization poses to our abilities as creative, reflective, thinking beings. But first, we need to recognize it as a threat.
The dominant moral metaphor in free speech discourse—namely, the marketplace of ideas—inadvertently desensitizes us to this threat. This metaphor invites us to worry, primarily, about authorities controlling the ideological content of public communication. At the same time, it analogically portrays homogenization in our methods of communication as something benign or even good. We need another metaphor that frames this homogenization as something to worry about.
Cities are more liveable when they are connected, when they have an integrated mix of trains, cars, buses, cycle paths, and walking paths, which provide a diverse array of locomotive affordances. Similarly, societies are more liveable if they enable us to use a variety of idea-transmission media with diverse communicative affordances with respect to expressive formats (text, voice), stylistic options, breadths of audience, and tempos of exchange. We should be able to freely exchange ideas and information, subject to reasonable caveats. But we should not be content with this measure of freedom. We should also be free to exchange ideas using a heterogeneous repertoire of media and methods, suited to various communicative purposes. We should have a connected city of ideas.
With today's cert grants, the Court now has four cases that address the issue of where suits can be filed against federal agencies and who can file them.
This morning the Supreme Court denied certiorari in a case asking the justices to revisit Humphrey's Executor. Do not think for a moment that this means we are not in for a significant administrative law term. There are some potentially big cases in the pipeline, and the Court has quite a few cases this term that deal with important, if not headline-grabbing, administrative law questions.
In today's order list the Court accepted certiorari in multiple cases concerning the interpretation and application of the Clean Air Act's venue provisions. This means the Court now has four administrative law cases this term concerning where certain types of claims against federal agencies can be filed, and who can file them. Here's a quick rundown.
First, in Nuclear Regualtory Commission v. Texas the Court will consider whether parties who did not participate in the relevant administrative proceeding may challenge an agency order for exceeding the agency's statutory authority under the Hobbs Act. The U.S. Court of Appeals for the Fifth Circuit said yes (and subsequently held that the NRC lacks the delegated authority to permit temporary off-site storage of nuclear waste).
Next, in FDA v. R.J. Reynolds Vapor Co. the Court will consider the question "Whether a manufacturer may file a petition for review in a circuit (other than the D.C. Circuit) where it neither resides nor has its principal place of business, if the petition is joined by a seller of the manufacturer's products that is located within that circuit." Here again the Fifth Circuit answered the question in the affirmative. The FDA's position, as you might expect, is that the manufacturer plaintiff was engaged in an impermissible form of forum shopping by adding a local retailer to the case.
Today, the Court added more cases in this vein, all concerning the interpretation and application of the Clean Air Act's venue provisions. These provisions seek to channel petitions challenging EPA regulations of nationwide scope and application to the U.S. Court of Appeals for the D.C. Circuit while allowing challenges to more localized agency decisions to be filed regionally. Drawing that line is easier in some cases than in others.
In EPA v. Calumet Shreveport Refining, L.L.C the Court will consider whether challenges to the EPA's denial of petitions for exemptions from renewable fuel regulations must be filed in the D.C. Circuit. Here, again, the Fifth Circuit did not think so and denied the government's motion to transfer challenges filed by six refineries.
In Oklahoma v. EPA and PacifiCorp v. EPA (consolidated) the Court will consider a similar question, but where it is the EPA that is arguably engaged in venue shopping. Normally, challenges to state implementation plans (SIPs) under the Clean Air Act are filed in the regional circuit in which the state is located. Here, however, the EPA issued a single Federal Register notice finalizing actions with regard to multiple SIPs across multiple states, and the U.S. Court of Appeals for the Tenth Circuit concluded that challenges to portions of that EPA action had to be filed in the D.C. Circuit. Thus the question presented, as one of the petitioners put it, is "Whether the Environmental Protection Agency's disapproval of a State Implementation Plan may only be challenged in the D.C. Circuit under 42 U.S.C. § 7607(b)(1) if EPA packages that disapproval with disapprovals of other States' SIPs and purports to use a consistent method in evaluating the state-specific determinations in those SIPs."
In combination, these cases have significance beyond their rather narrow particulars. In decided these cases it is likely the justices will speak to some of the broader concerns about forum shopping in challenges to federal agency actions and give lower courts more guidance about how they should consider innovative efforts to bring such challenges in favorable jurisdictions. (Thus it may be no coincidence that several of these cases came out of the Fifth Circuit.) Put another way, each of these cases may concern narrow, technical questions of administrative law, but when taken together they could be quite significant.
The United States is in a difficult moment: what basic faith there was in the institutions of democracy has been eroded, constitutional protections have been undermined by the Supreme Court's radical right-wing majority, and reason is no barrier against the libidinal release enabled by former president Donald Trump. In the wild proliferation of paranoia, accusation, retribution, and hate speech that flourishes on the internet and translates into dangerous, sometimes lethal activism in "real life," education in general and the university in particular have been singled out for attack.
The attack on education is itself not new—right-wing think tanks and politicians have been at it for decades. But this moment seems somehow more dangerous, as Republican lawmakers and militant activists use their power to send censors directly into classrooms and libraries, promising conservative parents they will regain control of their children against the specter of "woke" indoctrination.
In one of those inversions of meaning so adroitly practiced by the right, censorship is being enacted in the name of free speech and/or academic freedom. The terms themselves seem to have lost their purchase: once weapons of the weak, they now have been seized as legal instruments by the powerful, who censor what they take to be unacceptable criticism—of state policy, of inequality, of injustice—in the name of freedom.
And, perhaps most hypocritical of all, the censors claim they are ridding the university of "politics." Heightened politicization, in the name of the purging of "politics," is the stunning result. The two are not the same. Politics (as I want to use the term) refers to contests about meaning and power in which outcomes are not predetermined; those who politicize—or, better, rely on partisanship—know in advance the outcomes they want to impose, the enemies they want to defeat. In theory, politics is at the heart of the free inquiry associated with democratic education, partisanship is its antithesis. In fact, the relationship between the two is never as simple as that opposition suggests.
Multiple political commentators and media outlets have spun narratives of potential election disasters, including efforts to overturn the results. Over at Lawfare, Rick Pildes explains why many of these scenarios ignore the legal guardrails that are in place that are likely to prevent such scenarios from taking place.
As Election Day draws near, anxieties are running high among Democrats about how partisan actors backing Donald Trump might seek to steal the 2024 election. Trump himself has commented that "the only way we're gonna lose" is "if they cheat," raising the specter of another attempt to upend the election results like the country saw in 2020. The danger is real, but much of the speculation about mechanisms Trump or his allies might use to overturn election results risks unnecessarily raising the anxiety level of voters. To be sure, partisan actors might well try various ploys to manipulate the outcome, particularly if the election hinges on one or two states. But there are significant legal, institutional, and political guardrails already in place to thwart these partisan efforts.
A recent essay Neal Katyal authored in the New York Times is a good illustration of these anxieties. Katyal raised several nightmare scenarios for "a potential election crisis" under which, in his view, corrupt partisan actors could seek to deprive Vice President Kamala Harris of a lawful victory, if in fact she wins the election. But in each of the scenarios Katyal raises, the guardrails that are already in place should temper these concerns.
Some of these guardrails are longstanding. Others were enacted as part of the Electoral Count Reform Act. Together, the various guardrails protect against most of the common nightmare scenarios put forward about rogue governors, electors, or state legislatures. And what about Congress? Pildes writes:
Would Congress nonetheless defy the ECRA and act illegally? To reject a state's electoral votes would require a majority in each house of the newly elected Congress. No matter which party controls the House and Senate, its margin is expected to be thin. Sen. Susan Collins was the leader oncr the Republican side in the bipartisan Senate group that drafted the ECRA. Other Republicans in that group who will still be in the Senate in January 2025 include Lisa Murkowski, Todd Young, and Shelley Moore Capito. Let's assume for the sake of analysis Republicans control the House and have 51 or 52 Senators. It would still take only one or maybe two Republicans to abide by the terms of the ECRA that they themselves drafted to defeat any plot in Congress to steal the election
None of this means the election will be free of trouble or dispute, only that these particular concerns -- that the election will be stolen or the legitimate results subverted -- fail to account for the legal and other safeguards that are in place.
The piece concludes:
There is no way to make the system entirely failsafe against all risks. I'm particularly worried that Pennsylvania and Wisconsin will have long delays in getting to a definitive result, given that their laws still – unconscionably – refuse to permit their election officials to start processing absentee ballots until election day. If the results of the election cannot be known for several days, this will almost inevitably spawn suspicion and distrust, fueled by social-media conspiracy theories, and might lead to major efforts to disrupt the vote-counting process. In advance of the 2020 election, I wrote that this dynamic of late vote counts would likely be a major focal point of efforts to delegitimize the outcome. I fear the situation is even worse this time around. Too many voters are already primed in advance this time around to believe the election is "being stolen" if the numbers change dramatically overnight and in the days after the election.
Post-voting partisan efforts to manipulate the process could undermine public confidence, be disruptive, and even lead to civil unrest. But there are many more mechanisms in place than a lot of anxious public commentary recognizes to ensure the lawful outcome of the 2024 election.
Co-Blogger Jon Adler flagged an exchange in Royal Canin U.S.A., Inc. v. Wullschleger. Chief Justice Roberts asked Ashley Keller if there were any cases where the Supreme Court "came out the other way than every court of appeals had come out." Keller was not able to think of an example on the spot. After a few moments, Roberts thought of a case:
CHIEF JUSTICE ROBERTS: Was that -was that the case in Chadha?
MR. KELLER: INS versus Chadha?
CHIEF JUSTICE ROBERTS: Yes. MR. KELLER: I --I don't know. I apologize.
CHIEF JUSTICE ROBERTS: Somebody will check. I just -
JUSTICE KAGAN: Gosh, I'm not sure which way that cuts.
(Laughter.)
CHIEF JUSTICE ROBERTS: I'm not sure that's true. I just have it in the back of my mind, but --okay.
Yes, someone would "check" that. His name is Seth Barrett Tillman. Seth reminded me that in Chadha, the Supreme Court affirmed the Ninth Circuit. And do you know who wrote the circuit court opinion in Chadha? Judge Anthony M. Kennedy. AMK ruled that the one-house veto violated the separation of powers. So Chief Justice Roberts is wrong on this front. Even better, Antonin Scalia filed an amicus brief on behalf of the American Bar Association supporting affirmance!
But there is one fairly prominent case in which the Supreme Court came out the opposite way of all lower federal courts: Brown v. Board of Education. The Court reversed three federal courts in Kansas, South Carolina, and Virginia. Of course, the Court affirmed the Delaware Supreme Court, which found that the separate schools were not equal.
The case is Wade v. Univ. of Mich.; as is common for such denials of review, the majority didn't offer a detailed opinion, but Justice David Viviano, joined by Justice Brian Zahra, dissented:
In 2001, the University adopted Article X, which bans the possession of firearms on its campus or "any property owned, leased or otherwise controlled" by the University. That prohibition applies to all persons regardless of whether they possess a concealed-carry permit. Plaintiff unsuccessfully applied for a waiver under Article X. The record indicates that plaintiff does not work, reside, or study at the University and has a concealed-carry permit….
[T]he Court of Appeals disregarded the analysis required by the United States Supreme Court for Second Amendment disputes and invented a confusing four-factor test that bears almost no resemblance to the Supreme Court's test. On remand, the Court of Appeals set forth the following factors for resolving Second Amendment challenges:
There is growing pessimism about the future of free speech in the United States. Crusaders from all sides of the political spectrum seem intent on suppressing objectionable discussion. The worry is that Americans may be losing their appetite for candid and constructive dialogue. It has become too costly to participate in public discourse. We fear that incorrect speech will be canceled by the left or bullied by the right.
This is surely a troubling state of affairs. But it can be cured only if we first correctly diagnose its causes. There is a widespread tendency to conceptualize the problem as one of free speech. We imagine that the crisis would be resolved if only we could speak more freely. But this diagnosis puts the cart before the horse. The difficulty we now face is not one of free speech, but of politics. Our capacity to speak has been disrupted because our politics has become diseased. We misconceive the problem because American culture is obsessed with what has become known as the free speech principle. It is a principle that is widely misunderstood. Our misconceptions are as deep and as they are consequential.
I shall take as my text a representative and much-discussed 2022 opinion piece by the editorial board of TheNew York Times entitled "America Has a Free Speech Problem." In its first sentence, the editorial warned that Americans "are losing hold" of the "fundamental right" to "speak their minds and voice their opinions in public without fear of being shamed or shunned." The editorial did not focus its attention on government regulation of speech, which is the particular domain of the constitutional law of the First Amendment, but instead on the more basic question of free speech itself. It urged Americans to extend to each other the fundamental right to say whatever is on their minds. The editorial suggested that the more speakers could express their thoughts, the more our politics would heal. It implied that the current dislocation of our politics could be solved by more speech.
The editorial's framing of the issue is not idiosyncratic. Advocates of a free speech principle abound. Yet the editorial rests on a misguided understanding of free speech.
Another interesting tidbit from the oral argument in Royal Camin USA v. Wullschleger concerned what weight the Court should give unanimity on a question among the lower courts of appeals. (In this case, the lower courts of appeals have treated the post-removal amendment of a complaint in one way, but there is an argument the relevant statutory requires a different result.)
In the exchange, Justice Kagan suggests she is not a fan of INS v. Chadha (the decision in which the Court held that a unicameral legislative veto is unconstitutional).
Catching up on Supreme Court oral arguments, I was struck by the following exchange in Royal Canin U.S.A. v. Wullschleger (a case about the effects of post-removal amendments to a complaint) in which Justice Sotomayor suggested that some lower court judges are taking their cues from dicta in Supreme Court opinions.
JUSTICE ALITO: Well, do you think that -- that courts of appeals read our
decisions differently than we may? I mean, you know, I'm -- I was on a
court of appeals for 15 years. If I saw a strong dictum in a Supreme Court decision, I
would very likely just salute and move on. But, here --
(Laughter.)
JUSTICE ALITO: -- we have --
JUSTICE SOTOMAYOR: Not now.
(Laughter.)
JUSTICE ALITO: -- more of an obligation -- it depends, Justice Sotomayor --
(Laughter.)
JUSTICE ALITO: -- both when we're considering -- you know, when we're considering
what we've written -- we know how these things are written. You know, we know how these footnotes are written. Can -- do we have liberty to read them a little bit differently?
Listening to the audio, I took Justice Alito to be suggesting there is dicta and then there is dicta, and justices (particularly those who may have been on the Court at the time) can often tell the difference. I also took Justice Sotomayor to be suggesting that some lower courts don't merely "salute and move on" when they see "strong" dicta in a Supreme Court opinion, but rather take that dicta as their cue for how to proceed and push beyond settled precedent. Justice Alito's response suggests to me he interpreted her comment in the same way. (Again, this may be more clear on the audio.)
I am not sure which case(s) Justice Sotomayor had in mind, but there are many potential candidates.
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