HUMOR ONLY PEOPLE WHO GREW UP IN AN ALCOHOLIC HOME WILL APPRECIATE

Revenge is a jealous husband and/or an angry wife.

The Democratic Party is like a drunk, and the Republican Party is like his drunk father, and the Electorate is like their wives. The Democratic Party is in office for 4-8 years until it’s so bad, the Republican Party gets sent in to clean up everyone’s act, and is in office for another 4-8 years until it’s so bad, people are begging for the first…and it keeps getting worse and worse and worse…

Unfortunately, alcoholics don’t keep their promises, but a lot of them do roll with the gravy train, so you can be assured that going with the flow by following the alcohol will always put you first AND last. The alcoholic may pick up the alcohol, but we pick up the alcoholic.

Aint’ no terrorist like a drunk terrorist…and his family.

Community service in alcoholic families has lots of opportunities, giving more service than anyone else.

This can take many forms. Case-in-point: One of my family members is firmly committed to not only fixing his family members, but society. Since there are so many addicts, he decided to make himself of service. By actively hiring addicts and managing all aspects of their lives and finances for them, this business model not only remediates homes and property he purchases as investments but remediates lives. Sure, he has problems with theft and there is a lot of dysfunction on the job site and their lives, and he has had to confront, chase down and rough up a few of these individuals in parking lots, but who else is going to take that on unless he does, for the good of society? Meth is an epidemic, and the problem is that people don’t work and need to be put to work, or know how to manage their own finances. Work will set you free, lest we forget the lessons of Auschwitz, which wasn’t all bad, after all. If you just do what he tells you and follow his example. Yes, his family thought he was crazy, but they just don’t understand these people like he does, and they’re alcoholics anyway with screwed up lives of their own that also just need his guidance. His service, his financial success and his capacity to function through anything proves anyone can do it. He was once a wayward young man himself but look at him now. It’s all about the money and being functional. Examples of community service like this are just one of many where not just alcoholics, but addicts of all kinds, and products of their families like adult children, are having incredible community impact. With community service at an all-time low, you can be assured that alcohol and drugs will continue to motivate and perpetuate participation in service to our communities. Thank you, alcohol and drugs, and all that you do for our families and community! Our children need this kind of example. The next generation is assured. Where would we be without it?

Humor is sarcastic, bitter, ironic, passive-aggressive and dark stemming from the experience of families & friends of alcoholism. But for our higher power, shared experience, tasteless humor and Gonzo journalism, life would just be too serious. In the folds of its severity, it is ridiculous, and therein lies our redemption, in our laughter and our tears.
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A REAL STORY

This is a real story about an adult who grew up with alcoholism within the family and had children. They range in age, and the eldest is now an adult herself. She was the most amazing and beautiful little girl from the moment she entered the world. She grew into a beautiful woman. She wanted to be respectable person and successful. It comes with what most people want and she herself has worked hard for; money, success, status, reputation and the image of respectability associated with that. She identified with the image of respectability that comes with learning it from someone close to herself. In her family, that meant she identified with an alcoholic, and is in danger of becoming one herself. Her future is clear. It’s not good.

Few understand the family illness and disease, but those who do will understand this. It doesn’t make sense, but it makes sense to those in it. Ironically, for those who don’t know, what they see makes “sense” but has a different meaning than for those within. To use an analogy, it is a wendigo, a chimera, the wolf in sheep’s clothing, not the good shepherd or his flock. Alcohol devours the pain, and the person, and their soul…and finally, their body with it.

Memories…
Retaliation. Flipping everything on its head. Gaslighting. A realignment of the parties to fit the status quo, exerting power and control, asserting and reasserting power and control, reinforcing it, maintaining it. How does this promote itself?

Control is necessary.
This is the alcoholic’s fallacy.
Control comes with being a man, especially for men.
Control of oneself. Control of one’s emotions. Status. Reputation.
Physical dependency introduces slipping control. Struggles with control.
Alcohol adapts the alcoholic to the alcohol.
A tug-of-war ensues.

Alcohol adapts the alcoholic to the alcohol.
The alcoholic adapts the environment to the alcoholic.


Controlling one means controlling the other, but this is the inherent fallacy, because alcohol is in control, not the person. It will win every time. Because of the nature of physical dependency, the more control an alcoholic exerts, the more alcohol’s control manifests. Alcohol has the edge. Alcoholism mirrors the alcoholics efforts to assert control over it, in reverse, an uphill challenge for those with physical dependency. Controlling alcoholism is shadow work.

Controlling alcohol, like controlling people, doesn’t work. Relationships built on control, including with alcohol, fail. Alcohol wins. People lose. Including the alcoholic.

Since alcoholism introduces physical dependency, issues of self-control, emotional control, and control in general, where an alcoholic views their relationship with alcohol in terms of control, this develops and builds it. This strengthens and reinforces the power alcohol has over the person and their relationship with it. Since alcohol adapts the alcoholic to itself, and the alcoholic adapts the environment to the alcoholic, the relationship and alcoholic has with alcohol is central and translates to people. The closer people are to the alcoholic, the greater the effects. We call this the family illness of alcoholism. It is a social disease. Alcoholism is a physical disease.

Alcoholism doesn’t just affect the alcoholic. It becomes a shared disease. It is progressive and destructive. Alcohol and physical dependency don’t just take lives, they destroy relationships and families. Families are social units. A member’s relationship with alcohol easily translates to relationships with people and between them.

It should come as no surprise that where power and control over alcohol defines an alcoholic’s relationship with it, this can promote and manifest other problems in addition to alcoholism, like domestic violence and abuse. This is one reason why statistically there is a higher-than-average rate of domestic violence and abuse associated with drinking, as well as assaults and violence in general.

The Justice System…
Much focus has begun to develop in the Thurston County courts and the Washington State judicial system towards adopting Cognitive Behavioral Therapy as a general model for both those ordered to treatment and those impacted and effected. Carl Jung, a Swiss psychiatrist and psychotherapist, the founder of modern analytical psychology, by contrast, has received far less attention. Little understood and often misinterpreted for his work with “dream analysis”, he addresses “shadow work.” His best understood publication and example explaining this was with “Man and His Symbols.” It is a model for promoting holistic integration of the entire self for the health of the individual and incorporates the social health of the community and people’s relationships of all kinds in its considerations. Psychoanalysis faded in the 1980s after a resurgence in its popularity. Mental health is just as subject to trends as other social points of interest. The courts favor cognitive behavioral therapy because it focuses on personal accountability.

The problem is there is no proof it works in the way the judicial system is employing it. This use by our justice system is unproven and entirely experimental. The goal is to curb recidivism and repeat offenses, especially for those involving drugs and alcohol. There is only one model that has been proven repeatedly, over time, to work, for all parties. Voluntary participation in a twelve-step program. These come in a variety of forms and originated with Bill Wilson who formed Alcoholics Anonymous in 1935 and his wife, Louis Wilson, who formed Al-Anon for Families & Friends of Alcoholics. University of Colorado studies repeatedly demonstrate that most people, when they do quit, do so on their own, regardless of the type of dependency, and not because they are court ordered. The justice system and laws in place have very little to do with people’s substance abuse or use and decision-making process, remarkably. Studies and research from the New York Brennan Center for Justice also support this. This makes sense when considering the physical nature of dependency and addiction. Personal willpower, independent of consequences, is subverted. For every action there is a reaction, and cognitive behavioral therapy examines actions and consequences, coping skills and decision making. This is helpful, but just scratches the surface. Twelve steps programs like A.A. and Al-Anon deal with the shadow work.


Washington State has developed a guide based on Cognitive Behavioral Therapy and Washington State judicial application titled the “CBT Guide to Intimate Partner Violence.” It begins with “There is currently no well-established effective program specifically for individuals who engage in Intimate Partner Violence. Work is ongoing to develop and test such interventions. In the absence of a specific proven program, this Guide provides a generic CBT-based treatment manual with clinical supports. It has not been tested in a research study. No claims are made that it is effective in reducing IPV. However, it is based on a well-established theory and the clinical skill-oriented content is supported by research. As well it is based in part on a generic CBT and DBT based treatment manual for sex offender treatment in WA. Like DVIPs, Sex Offender Treatment Providers (SOTPs) also operate within WACs. CBT is based on a theory that thoughts, feelings and behaviors mutually influence each other.”
The justice system is looking for a universal solution and CBT is a catch-all.


The Guide emphasizes “CBT based treatments target: unhelpful thoughts; difficulty managing intense negative feelings; ineffective or problem behaviors. CBT based treatments are effective for many clinical conditions and behavioral problems. CBT is the underlying theory for many effective therapies for common clinical conditions such as anxiety, depression, PTSD, and disruptive behaviors. Effective treatments for individuals who break the law or abuse their children are also typically CBT based. There are a number of branded CBTs that target law breaking behavior. We want to be fully transparent that we come at this Guide from the perspective of evidence-based practice. EBP means preferring treatments that have been shown to be effective in research studies. We are aware that evidence-based is a relatively newer idea in the delivery of psychosocial treatments. While evidence-based medicine is embraced as the standard for health conditions, that has not always been the tradition for behavioral health conditions and practice.”


“Behavioral medicine” or “behavioral health” is what Washington State’s judicial system has been employing and heavily reliant on for decades. “There continue to be controversies and disagreements,” they write, “As well we are very far from arriving at proven treatments that work for every behavioral health problem.” Standards in treatment, especially evidence based, that work and are established, with a prescription and formula that can be incorporated into the current justice system model and pop out healthy, whole, healed individuals who are rehabilitated and recovered, ready for re-entry into society with the social contract restored, is elusive.


The Brennan-Center for Justice in New York City notes in its report examining justice policies in “What Caused the Crime Decline?” that “One of the great problems we face today is mass incarceration, a tragedy which has been powerfully documented.” They write “How many people sit needlessly in prison when, in a more rational system, they could be contributing to our economy? And, once out of prison, how many people face a lifetime of depressed economic prospects? When 1 in 28 children has a parent in prison, the cycle of poverty and unequal opportunity continues a tragic waste of human potential for generations.” Americans spend $260 billion every year on criminal justice. That is more than one-quarter of the national deficit.

A year in prison can cost more than a year at Harvard. This is not a hallmark of a well performing economy and society. The report presents a rigorous and sophisticated empirical analysis performed on the most recent, comprehensive dataset to date. The authors conclude that incarceration had relatively little to do with the crime decline. They find that the dramatic increases in incarceration have had a limited, diminishing effect on crime. And they have quantified those minimal benefits. At today’s high incarceration rates, continuing to incarcerate more people has almost no effect on reducing crime.

The report demonstrates the value of interdisciplinary thinking. It melds law, economics, science, criminology, and public policy analysis to address the challenges facing our country. This starts with our families. Individual psychology and group psychology are two distinct branches of psychology that focus on different aspects of human behavior. Group psychology studies human behavior in the context of group associations. It examines how people behave in groups, interact with each other and how they are influenced by the group. The family is a fundamental social group. Group psychology helps explain why people tend to conform to the norms of a group, even when those norms are not in their best interest.

Full Circle…
No man (or woman) is an island. Being human is social. Just because community doesn’t look like what we think it should does not mean it doesn’t exist or isn’t present, whether we acknowledge and recognize it or not. In reality, many alcoholics have jobs, homes, families and untarnished images of respectability. In reality, 80% of women who have been homeless report having been victims of domestic violence and abuse. What we see in the streets is just the tip-of-the-iceberg, the fringes of a much larger phenomenon hidden from view within families and homes.

One of community and families most basic functions is the health of children. Promoting that can be strengthened by family, or family may be abandoned or absent for individuals who seek community in place of family. Where community does not represent a safety net, people are reduced to their individual efforts. The family illness of alcoholism, for example, promotes isolation within the family, isolating its members and creating feelings of isolation. Health that is absent in both family and community promotes/reduces people on a large-scale to individual efforts. Family exclusion, with community exclusion, in a society that has witnessed progressive and destructive alcoholism and physical dependency exponentially since the largest generation came of age in the 1960s, means the swelling numbers of elderly, their children and grandchildren, in American streets today, will continue to swell, tax our limited resources, increase our national deficit and consume more while defeating us economically in the face of a declining national birth rate. Combine this with a pandemic, and the effects are amplified exponentially that much more. Unless we get real and develop a group conscience, divided we fall, instead of united we stand.

As aforementioned, this is the story of a real girl, now for all appearances sake an amazing and beautiful woman, but whose future is uncertain, even given all that. She has a family that’s not that different from your own or those you know or are familiar with, alongside your community, your country and nation. Each of us, as it turns out isn’t so unique, because the story of our nation and our families is our own, and there are so many others like us. What seems isolating, even American Isolationism, is a shared experience. It is easily understood by others, especially if we open up and begin to talk about it. We can do so anonymously, with anonymity, if we choose. No one has to be embarrassed or humiliated. We may find that what personal shock and embarrassment we have had fades and isn’t so bad when we face it in proactive, healthy ways that mutually benefit each of us. Our efforts can be private, within the supportive group of an A.A., AlAnon or other family group or settings, with people just like us, or we might be more extroverted and public, depending on our personalities. Because others share our experience, and also have strength and hope, their recovery offers hope for our own and true insight that only comes from the lived experience we also share.

We often turned to others for help, especially within our own families, and were often disappointed. Well-meaning friends and family members may have offered plenty of advice, but few were truly able to understand our circumstances or offer useful suggestions. In fact, some of the advice we blindly followed did more harm than good. We may have sensed or known something was wrong, deep down, but nothing we did ever seemed to get to the root of it. Our efforts left us feeling more alone and ashamed than ever. Jails, institutions and death. We couldn’t figure out what was wrong or why nothing was working. What are we doing wrong? we asked. Who’s to blame? Why can’t I fix it? We fix it? Why won’t he or she fix it? If he just did this… If she would just… These are symptoms of the family and social disease and illness we call alcoholism, addiction, physical dependency, and sometimes “America.” We can’t figure out how to successfully isolate ourselves from it or treat it. We don’t understand that it’s like cancer, with all the progressive destruction and stages of grief, from anger to loss, impact on family and more. We don’t understand why it keeps recurring or why our best effort fail.


“But I’m not an alcoholic. I’m not an addict. Those are other people.” As much as we are individuals, we are interdependent, because we are social, by nature, and this is the irony and dichotomy of being human. What affects one radiates and affects others, including ourselves, whether we realize it or not.


The truth is none of us are getting out of this thing called “life” alive. How we face it, and our relationship with our life, personally or interpersonally, in the shadows of it, is what critically matters. That is the inherent challenge, solution and meaning. Mission Impossible: “Your mission, should you choose to accept it…” You accepted it. You’re here. You’re alive. Do you dare to accomplish and complete the assignment successfully?

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Return Of The Witch

It used to be that people could be disposed of by being convicted as witches. However, to lend the appearance of legitimacy and authenticate and formalize this, those orchestrating and conducting “witch trials” determined “evidence” and “procedures” for it. “Dunking” or “swimming” a witch was one such 17th century practice. At the same time that the Puritans rose and declined in early United States settlements in the Massachusett’s Bay and nearby colonies, witch trials occurred in both America and England.

Witchcraft was a “crime.” Rules for “evidence” were not yet formalized at that time. Debate arose about what constituted “proof.” No doubt, these “witches”, these “criminals”, were guilty, but a system of establishing it was a matter of opinion. “Proof” of things supernatural varied widely among judges, writers and the broader population. England came up with a great strategy, the practice of “ducking” a “suspected” witch. It was known as the ordeal of the cold water, or judicium aquae frigidae, and the result as judicium dei. These were crimes that were simply not amenable to other forms of judicial proof, for which there was no witness. Trials usually started with the accused taking an oath of innocence. It was “standard” to question a suspect afterwards before any charges were stated. This was followed by a “trial by oath”, otherwise known as compurgation, by a number of the accused’s “peers” or “equals.” At the same time, clerics accused of sins or crimes had immunity, with the “oath of purgation”, granting that any evidence of guilt gave the accused canonical “license” with absolution and a non-guilty judgment.

Everyone knew those accused were guilty, and that the accusers could do no wrong. Since the accused witch’s oath of innocence was always taken to be unreliable, evidence was needed that was absolute. The ordeal of the cold waters offered that because it was accepted by many people at the time and consistent with their beliefs. The “dunking” test was deemed a “good help” in confirming witchcraft accusations. Since witches dealt with the devil, and thereby refused the benefit of baptism, and water was an element of baptism, it would “spit” them out and prevent them from sinking, refusing to receive them, and therefore the test would demonstrate for all present their guilt. If the accused sank, they were innocent, but they often drowned.

The administration in witchcraft proceedings of “ducking” or “swimming” a witch was “often a thinly concealed act of mob justice.” Up to 5,000 people at a time are recorded as gathering for such acts of justice in “proceedings.” Over time, people simply converted to lynching. The “court of public opinion” ruled, and those that held that witchcraft was no justice at all and the proceedings for it barbaric were in the minority. Gossip generating “public opinion” with stories and narratives that reflected each other in the “evidence” of a witch’s guilt preceded mob-justice that resulted in the loss of many innocent lives. Even though “innocent until proven guilty” received a nod, the accused was already condemned, in public opinion, which was often overwhelming and therefore could not possibly be wrong, and the weight of proceedings quickly shifted to the accused assumed guilt until proven innocent, a horror show for the accused and whatever minority, if any, might be in their support. The allegation of being a witch was enough, and since it might be true, inquiries and a search for the truth centered on this fact, predictably leading to more “evidence” and testimony of the same with a biased tribunal and set of authorities just as prejudicial as the mob formed awaiting the spectacle for its anticipated schadenfreude.

Our jury system arose from this. The Framers and the heroes of the American Revolution were the descendants of these popular spectacles and administrations of pseudo-justice. While lending the appearance of legitimacy and “official” proceedings, the Framers were cognizant of how majority-rule could lead to oppression of the minority and individual. In a democracy, the people rule, and in a pure democracy, the majority always gets its way, with what is unpopular always being outvoted. Any minority can’t count on any protections. The “court of public opinion” determines that only those rights the majority deems appropriate will be respected, or even protected, under the law. Individualism is defeated by conformity, fear of the authoritarianism that dominates, and individual rights, freedoms and expressions die with it. Rather than give in to the oppression of the majority, the US Constitution attempts to strike a delicate balance between majority and minority rule, conceding that the government cannot function by expecting a unanimous decision on every issue, but striving to take the rights of the minority and the individual into account. This is the spirit of the stacked and staggered layers of government that represent the United States and its Constitution.

While everyone has a sense of their own rights and freedoms, the Framers were broader in scope and incorporated gauging how human rights and freedoms were extended to others and guaranteed for all. Those espousing what is popular need no protections since they are aligned with the majority. The Bill of Rights provided for the minority, especially citizens suspected of or charged with crimes under the Fourth, Fifth and Sixth Amendments. For example, the limitations on “searches”, the right to indictment by the Grand Jury, “pleading the Fifth” with the right not to testify against oneself, the guarantee of due process of law in any prosecution, the right to counsel, and the right to a jury trial. The Fourteenth Amendment is intended to protect citizens from violations of due process of law while also ensuring equal protection under the law. The Thirteenth, Fifteenth, Nineteenth, and Twenty-Sixth Amendments were adopted to provide
explicit protections to racial, gender, and age-based minorities, which promotes the general welfare by securing a functional government and community life while “still protecting the rights of citizens when they find themselves in a minority segment of the population.”

Our own sense of justice is not enough. It is how we extend justice to even what we deem the least of persons, even those we hate or despise, or disagree with the most, that guarantees human rights, freedoms and justice for all members of our society. In conclusion, consider this recent quote from the United States District Court of the Eastern District of Tennessee, dated October 2023: “The Courts must decide these cases even in the face of popular sentiment against the litigants or the causes they espouse. Courts must be faithful to the law and the Constitution, not majority opinion or sentiment.”

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Feelings Alanon Thoughts by Grayman

“Gonzo” journalism.

The argument goes…be as loud or obnoxious or brash or whatever is necessary to be overt in the exercise of one’s rights.

When anyone asks what happened to the Free Press in the era of notorious President Donald J Trump, this explains it all, except instead of “under the cover of darkness” it is “under the cover of Freedom of the Press.” In the late 19th century, “yellow” journalism gave way to investigative journalism, but while history may repeat itself that doesn’t mean that it always repeats itself in the same way, and our age’s brand of muckrakers gave way to the revival and resurgence of Hunter S Thompson riding side-saddle with President Donald J Trump with a gun touting cat riding a unicorn in fashionable anarchist flourish leaving all traditional thinkers questioning everything. Difficult to define but a reality noine the less, what other explanation is there? As 1984 sweeps American imagination complete with Elon Musk leading the charge with AI, quantum computing, automation of everything, including human existence being prepped for a real life version of The Matrix, America has continued to find its voice and expression in new ways defiantly, demanding and asserting itself through every influence to the contrary. As history reflects, suppression or oppression in America only has one ultimately predictable reaction every time: the opposite, in any way, shape or form, dedicated to inherent rights and freedoms irrespetive of…well, anything else. No compromise. No negotiation. Don’t tread on me, Live Free or Die, all the regular rhetoric plus the reinvention of it. Granpa would be proud, and so would Grandma standing next to him with a wry smile and shotgun in hand. As American as Apple Pie.

I take this all tongue-in-cheek. I’m a more cautious rider and observer, even if moved by the modern American Spectacle at times. I believe in a bit more prudence and balance, and would argue wisdom, but that only reveals me as a prude to many more than it does prudent. Still, like Justice herself, I carefully weigh the scales and consider. Not that she’s around to consider. Lofty Justice, great lady, high and mighty, just for a moment, could you tip in my direction, only a little so that I might touch your graces and experience them for myself? The great majority, the unwashed masses, understand this point and so much more. Far from being dumb Americans, America teaches repeatedly not to underestimate its intelligence, because it is less important how it is said and more the questions that it asks with the heart that pounds beneath it and defends it. I am an observer. A writer. A freelance journalist. A member of the Free Press. Simply reporting. Over and out. Roger? Roger.

When they come to your great city on The Hill and look confused when they see Christ sitting at the table with the Anti-Christ, aged hippies with neo-nazis and ma and pa ranting with tribal elders, black panthers and a black Grand Wizard and homeless people urinating on the sidewalk nearby because of the lack of bathrooms while everyone present seems to take it as par for the course, and then ask what hedonism and heathenism this can possibly be, and say “We must have Order! Order!” this only betrays what they cannot perceive of, do not understand and haven’t appreciated about the American social fabric that refuses to be anything but liberated. No invading force could ever understand or has yet to date, including the British. They can have Edwardian England, our standard is far more dynamic, radical and diverse just on a regular day. I won’t tell you what my politics are, simply trust that I disagree with you. Our disunity miraculously unifies insensibly by every global standard. American people’s rights are survival itself and they must breath and take new breath, without question, always rising to that occasion. You don’t have to approve, and you don’t have to agree, but being American is enough. Irrespective of our differences, when they come to The Hill, what they “see” and what they see is easily resolved by one answer: they are Americans, and we are all Americans. Keep on Rockin’ in the Free World, America.

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CAMERAS/RECORDING COURTROOM EVENTS

9th Circuit Courthouse
9th Circuit Courthouse

The 11th circuit in Smith v City of Cummings said that we are legally allowed to record anything of public interest. This is in alabama they allow recordings.

The 9th U.S. Circuit Court of Appeals overturned Oregon’s law prohibiting recording people in public without their consent. The court ruled that the law was unconstitutional and violated the First Amendment right to freedom of speech. The court also struck down a decades-old Oregon law that prohibited recording in-person conversations without informing everyone involved.

The court found that Oregon does not have a compelling interest in protecting individuals’ conversational privacy from recording in places open to the public. The court also found that the law was content-based because it distinguished between topics by which subjects are restricted. For example, the official activities of a state executive officer cannot be recorded without consent, but those of a police officer can.

The 9th Circuit allows anyone to bring cameras and electronic devices into the courthouse. To broadcast, record, or take still photographs during court proceedings, an application must be received by the clerk of court more than two business days before the date of the oral argument. The application can be completed online at https://www.ca9.uscourts.gov/news-media/camera-application/.

However, the Ninth Circuit last week overturned Oregon’s strict recording law with its decision in Project Veritas v. Schmidt. The court ruled that Oregon’s recording law was an unconstitutional violation of the First Amendment right to free speech.Jul 17, 2023

(CN) — Siding with a conservative media organization famous for its ambush and undercover work, the Ninth Circuit ruled 2-1 Monday that Oregon trampled the First Amendment in requiring consent to record public conversations.

“Oregon law generally prohibits unannounced recordings of conversations, subject to several exceptions,” U.S. Circuit Judge Sandra Segal Ikuta wrote in the majority opinion. “We conclude that Oregon’s law is a content-based restriction that violates the First Amendment right to free speech and is therefore invalid on its face.”

The statute at issue requires all persons of a conversation to be “specifically informed” for individuals to record public, in-person communications. Project Veritas, an organization dedicated to revealing supposed liberal bias in the media, filed suit over the law in August 2020, claiming the law limits the First Amendment rights of investigative journalists to engage in undercover newsgathering.

While Oregon is only one of five states that prohibit individuals from recording public conversations without notice or consent, most professional journalists identify themselves and inform their subjects if they are recording a conversation. Indeed, when it comes to the style of reporting favored by Project Veritas, the Society of Professional Journalists recommends in its Code of Ethics to avoid “undercover or other surreptitious methods of gathering information unless traditional, open methods will not yield information vital to the public.”

Oregon’s recording law did exempt those recording a conversation during a felony that endangers human life, and it permitted recordings of on-duty law enforcement. Another exemption covered instances where it’s evident that a recording is taking place, in circumstances where someone should have reasonably known a recording was being made or during phone calls if at least one person on the call knows that the conversation is being recorded.

Were it not for Oregon’s law, Project Veritas said it would investigate allegations of corruption” involving the Oregon Public Records Advocate and the Public Records Advisory Council.

“In 2019, Oregon’s Public Records Advocate resigned due to alleged pressure from or mismanagement by Governor Kate Brown,” the group wrote in its complaint, adding that it would have also investigated the “dramatic rise in violent protests in Portland between the police and members of Antifa and other fringe groups.”

“Because protests and even ordinary public life in Portland have proven dangerous to reporters,” the group explains, it fears that the safety and lives of its journalists would be endangered if it were to record conversations openly or inform participants of the recording. Outside of organized rallies, the group said it would do most of its secret recording in public.

Project Veritas went to the U.S. Court of Appeals in Pasadena, California, after the state won a partial dismissal of the case.

“Here, the state law at issue regulates individuals’ conduct in making an audio or video recording. Under our case law, such conduct qualifies as speech entitled to the protection of the First Amendment,” wrote Ikuta, citing Animal Legal Defense Fund v. Wasden, a case in which an animal rights group secretly filmed an Idaho dairy farm abusing its cows.

Ikuta notes that, at the outset, Oregon does not assert a compelling interest but argues that it has a significant interest in protecting individuals’ conversational privacy.

“In analyzing this interest, we are bound by Wasden’s conclusion that ‘the act of recording is itself an inherently expressive activity’ that merits First Amendment protection,” the George W. Bush appointee added. “Therefore, prohibiting a speaker’s creation of unannounced recordings in public places to protect the privacy of people engaged in conversation in those places is the equivalent of prohibiting protesters’ or buskers’ speech in public places for the same purpose.”

Ikuta also found that Oregon’s law is not narrowly tailored to be the least restrictive or intrusive means of achieving the government’s interest either. Tailoring is required for a law that regulates protected speech, as here. Because the law also distinguishes between topics by which subjects are restricted — the official activities of a state executive officer cannot be recorded without consent, but those of a police officer can — the law is additionally considered content-based, the court found.

U.S. Circuit Judge Morgan Christen wrote in dissent that Oregon adopted its law with a goal of ensuring that Oregonians would be free to engage in the “uninhibited exchange of ideas and information,” without fearing that their words would be broadcasted, disseminated or “worse, be manipulated and shared across the internet devoid of relevant context.”

Christen accused the majority of rewriting the state’s articulated purpose for the law and recasting its interest as one in “protecting people’s conversational privacy from the speech of other individuals.”

That reframing, the Obama appointee wrote, “serves as the springboard for the majority’s reliance on an inapplicable line of Supreme Court authority that pertains to state action aimed at protecting people from unwanted commercial or political speech; not protection from speech gathering activities like Project Veritas’s, which are qualitatively different because they appropriate the speech of others.”

Christen also noted that the majority’s rationale contravenes that of the Ninth Circuit, which has explained that hidden mechanical contrivances are not indispensable tools of newsgathering.

“Investigative reporting is an ancient art; its successful practice long antecedes the invention of miniature cameras and electronic devices,” Christen wrote, citing Dietemann v. Time Inc. “Because modern technology now allows voice recordings to be manipulated and disseminated worldwide with a few keystrokes and clicks, the protection afforded by section 165.540(1)(c) is more important than ever. For all these reasons, I respectfully dissent.”

Project Veritas v. Michael Schmidt No.22-35271 VIEW DOCUMENT

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Hidden Alternative Search Engines

Google is so powerful that it “hides” other search systems from us. We just don’t kn0w the existence of most of them. Meanwhile, there are still a huge number of excellel’lt searchers in the world who specialize in books, sciel’lce, other smart information.

Keep a list of sites you never heard of.
www.refseek.com CLICK – Academic Resource Search. More than a billion sources: encyclopedia, monographies, magazines. www.worldcat.org – a search for the contents of 20 thousand worldwide libraries. Find out where lies the nearest rare book you need.

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23-4-00859-34 Estate of HANS CARL STOKER

Case Information – Hans Carl Stoker Bites the Dust

23-4-00859-34 | Estate of HANS CARL STOKER
Case Number
23-4-00859-34

Court
Thurston

File Date
09/14/2023

Case Type
EST Estate

Case Status
Active

Party

Petitioner
STOKER, KATHRYN LORENE

Active Attorneys

Lead Attorney

Worth, Cynthia Sue

Retained

Deceased
STOKER, HANS CARL

Events and Hearings

13 23.9.20 Rcpts Kat 0859
  • 1 09/14/2023 View Document Case Information Cover Sheet
  • 2 09/14/2023 Petition for Probate of Will View Document Petition for Probate of Will
  • 3 09/14/2023 Last Will and Testament View Document Last Will and Testament
  • 4 09/14/2023 Oath View Document Oath
  • 5 09/14/2023 Notice of Appointment and Pendency of Probate View Document Notice of Appointment and Pendency of Probate
  • 6 09/14/2023 Notice to Creditors View Document Notice to Creditors
  • 7 09/14/2023 Order Admitting Will Appt Personal Representative Adj Solv View Document Order Admitting Will Appt Personal Representative Adj Solv
  • 09/14/2023 Ex Parte Action With Order
  • 09/14/2023 Case Resolution Personal Representative Guardian Appointed
  • 8 09/14/2023 Affidavit of Mailing View Document Affidavit of Mailing
  • 9 09/18/2023 Certified Copy of Death Certificate View Document Certified Copy of Death Certificate
  • 10 09/19/2023 Notice to Creditors View Document Notice to Creditors
  • 11 09/20/2023 Receipts View Document ReceiptsComment
    of Probate Documents
  • 12 09/20/2023 Receipts View Document ReceiptsComment
    of Probate Documents
  • 13 09/20/2023 Receipts View Document ReceiptsComment
    Kat Stoker
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First Amendment Public Forum Analysis

February 1, 2023.

checklist for determining the classification of and constitutional standards of review for traditional, designated, limited, and non-public forums for free speech purposes under the First Amendment.

Practical Law Government Practice

Determine the Forum

Gather information and context on the property at issue to determine whether the forum is:

  • An open public forum where content-based limitations on speech are almost always unconstitutional. Open public forums include:
    • traditional public forums; and
    • designated public forums.
  • A limited public forum or non-public forum where reasonable content-based limitations on speech are generally constitutional.

(For more on the public forum analysis, see Free Speech Limitations on Government Regulation: Overview on Practical Law.)

Identify Traditional Public Forums

Traditional public forums are those portions of public property traditionally open for public:

  • Assembly and expression.
  • Protest.
  • Solicitation.
  • Debate.

Certain types of public property are almost always deemed traditional public forums, including:

  • Streets.
  • Sidewalks.
  • Parks.
  • Town squares.

Identify Designated Public Forums

Designated public forums are those portions of government property:

  • Intentionally opened by the government for open public expressive activity and discourse.
  • Not otherwise traditionally open for expressive conduct. Once the property is designated as a public forum, it is treated identically to a traditional public forum. However, the government is not required to indefinitely retain the open character of the forum.

Examples of designated public forums include:

  • Free speech zones that provide protestors a place to assemble on government property that is not otherwise open for expressive conduct.
  • Lampposts on which the public is allowed to place signs.

Identify Limited Public Forums

Limited public forums are a subclassification of designated public forums that the government specifically opens for:

  • Use by only certain groups.
  • The discussion of only certain subjects or genres. The government may impose blanket restrictions on the discussion of other genres that are outside the scope of the limited public forum’s purpose. However, if the government’s custom or actual practice allows indiscriminate use of or unfettered access to a forum that was previously opened as a limited public forum, courts are unlikely to uphold the original limitations of the forum.
  • A specific manner of communication.

Examples of limited public forums have included:

  • Theaters.
  • University meeting rooms opened for student groups.
  • School board meetings.
  • Subway platforms opened for charitable solicitations.
  • Public libraries.

Identify Non-Public Forums

Non-public forums are government properties not traditionally used or designated for use as a forum for expressive activity. In non-public forums, the government typically either:

  • Limits all private speech.
  • Selectively allows certain speech for proprietary purposes, such as generating revenue.

Examples of non-public forums include:

  • Military bases.
  • Proprietary moneymaking ventures, such as golf courses and racetracks.
  • Jails.
  • Police and fire stations.
  • Public schools.
  • Polling stations.
  • Courthouse lobbies and hallways.
  • Hospitals and nursing homes.
  • Municipal websites.
  • The interior of government office buildings.

Determine the Applicable Standard of Review

Understand that the standard of review differs based on the type of forum.

Apply the Standard of Review for Traditional and Designated Public Forums

In traditional and designated public forums, governmental limitations on speech receive strict scrutiny review unless they are content-neutral time, place, or manner restrictions. This means that:

  • Content-based restrictions are presumed unconstitutional unless the government can prove that the policy is necessary to serve a compelling state interest and narrowly tailored to achieve that end (strict scrutiny). A regulation is not narrowly tailored if a less restrictive alternative serves the government’s purpose.
  • Content-neutral restrictions on speech are reviewed under intermediate scrutiny, which is easier to satisfy than strict scrutiny. Reasonable, content-neutral time, place, or manner regulations are permissible in traditional and designated public forums.

Apply the Standard of Review for Limited Public Forums and Non-Public Forums

Governmental regulations of speech in limited public forums and non-public forums:

  • Must be reasonable in light of the purpose of the forum.
  • Must be viewpoint neutral.
  • Must not selectively deny access for speech in the genre or subject specifically allowed in a limited public forum. The regulations otherwise do not have to be content neutral.
  • Should convey a clear intent that the government is only opening the property as a limited public forum or non-public forum.
  • Should employ selective access policies on an individual, non-ministerial basis.
  • May allow for the closure of the forum at any time.

Related Content on Practical Law

Free Speech Limitations on Government Regulation: Overview

Access on Practical Law

Section 1983: Overview

Access on Practical Law

Content Neutrality in Government Regulations

Access on Practical Law

Regulating Speech and Conduct in a Local Public Meeting

Access on Practical Law

PLJ Widget 1
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23-2-30746-34 James Warren Fowler, Jr v Jennifer L. COMO

Case Information

23-2-30746-34 | JAMES WARREN FOWLER, Jr vs JENNIFER LORRAINE COMO
Case Number
23-2-30746-34

Court
Thurston

File Date
09/15/2023

Case Type
CPO Civil Protection Order

Case Status
Active

Party

Respondent (WIP)
COMO, JENNIFER LORRAINE

DOB
XX/XX/1976

Petitioner (WIP)
FOWLER, JAMES WARREN, Jr

DOB
XX/XX/1970

Active Attorneys

Pro Se

Minor (WIP)
FOWLER-COMO, JORDAN RAIN

DOB
XX/XX/2012

Events and Hearings

  • 09/15/2023 Law Enforcement and Confidential Information Form
  • 1 09/15/2023 Petition for Order for Protection View Document Petition for Order for Protection
  • 2 09/15/2023 Appearance Pro Se View Document Appearance Pro Se
  • 3 09/15/2023 Motion Hearing View Document Motion Hearing
  • 4 09/15/2023 Temporary Order for Protection View Document Temporary Order for Protection Comment
    Protection Order DV
  • 09/28/2023 Protection Order Judicial Officer
    Zinn, Rebekah Hearing Time
    9:00 AMComment
    Protection Order DV
Posted in Uncategorized | 2 Comments

Stare Decisis v. Dicta: Dicta isn’t Precedent & Has No Force

Mercy Counseling Justice
Mercy Counseling Justice

Stare Decisis, Precedent and Dicta
                                         By Joel R. Brandes
          Lawyers and judges regularly treat dicta like a case holding. 1

In this article we attempt to distinguish a holding which is precedent from dicta.
“Stare decisis et non quieta movere” means to stand by things decided and not to
disturb settled points.2 The doctrine of stare decisis provides that once a court
has decided a legal issue, subsequent cases presenting similar facts should be decided in conformity with the earlier decision. 3 Stare decisis is the doctrine of precedent, the “rule that precedents must be followed when similar circumstances arise. “4

            Stare Decisis requires that the decisions of the Court of Appeals which have not
been invalidated by changes in statute, decisional law, or constitutional requirements
must be followed by all lower appellate courts, such as the appellate division and the
appellate term,5 and by all courts of original jurisdiction. 6 The doctrine of stare decisis
requires trial courts in one department to follow precedents set by the Appellate Division
of another department until the Court of Appeals or the Appellate Division in that
Department pronounces a contrary rule. These considerations do not apply to the
Appellate Division. While an Appellate Division should accept the decisions of sister
departments as persuasive it is free to reach a contrary result.7 Trial courts within a
Department must follow the determination of the Appellate Division in another
Department until such time as the Appellate Division of their own Department or the
Court of Appeals passes on the question.

           Where a question has not yet been decided by an Appellate Division, inferior
courts in that Department must follow the determinations of the Appellate Division in any
other Department until such time as their own Appellate Division or the Court of Appeals
passes upon the question.8 Where there is no applicable decision from the Court of
Appeals or from the Appellate Division in the trial court’s Department and the decisions
from other Appellate Divisions are conflicting, the trial court is left to fashion its own
decision, giving appropriate weight and consideration to the views expressed by the
Justices of the Appellate Divisions and, where statutory interpretation is involved,
developing a view which is consistent with the overall objective of the statute.9 A
judgment of a trial court will not receive stare decisis treatment by an appellate court.10

          Findings are a determination by a judge, or jury, of a fact supported by the evidence
in the record.11 A holding is a court’s determination of a matter of law pivotal to its
decision; a principle drawn from a decision.
It is also a ruling on evidence or other questions presented at trial.12
A precedent is a holding that must be followed when similar circumstances arise. 13

          Dicta are opinions of a judge which do not embody the determination of the court;
opinions which are not on the point in question. 14 Statements made that are not
essential to a decision on the questions presented, are the dicta, and not the decision of 
the court. A judicial opinion “is only binding so far as it is relevant; and, when it wanders
from the point at issue, it no longer has force as an official utterance.” 15

          In Matter of Fay, 16 the Court of Appeals wrote, with regard to the question of what
is precedent, “it cannot be said that a case is not authority on one point because, although
that point was properly presented and decided in the …consideration of the cause,
something else was found …which disposed of the whole matter.”

In 40 West 67th Street Corp. v Pullman,17 defendant was a shareholder-tenant in
the plaintiff cooperative building. At a special meeting called by the shareholders, the
shareholders in attendance passed a resolution declaring defendant’s conduct
“objectionable” and directing the Board to terminate his proprietary lease and cancel his
shares. The cooperative terminated defendant’s tenancy in accordance with a provision in
the lease that authorized it to do so based on a tenant’s “objectionable” conduct.”
Defendant remained in the apartment, prompting the cooperative to bring this suit for, inter
alia, possession and ejectment. Defendant challenged the cooperative’s action and
asserted, that his tenancy could be terminated only upon a court’s independent evaluation
of the reasonableness of the cooperative’s action. The primary issue in the Court of
Appeals was the proper standard of review to be applied when a cooperative exercises its
agreed-upon right to terminate a tenancy based on a shareholder-tenant’s objectionable
conduct.

          The Court of Appeals held that the proper standard of review to be applied was the
business judgment rule. The rule could be applied consistently with RPAPL 711 (1), which
applied to this termination and required competent evidence to show that a tenant was
objectionable. Under the business judgment rule, a court should defer to a cooperative
board’s determination so long as the board acts for the purposes of the cooperative, within
the scope of its authority, and in good faith. Here, plaintiff was under a fiduciary duty to
further the collective interests of the cooperative, whose shareholders overwhelmingly
voted in favor of terminating defendant’s tenancy, and it followed the procedures contained
in the lease for doing so. There was no evidence of any bad faith by plaintiff’s which would
trigger further judicial scrutiny.

          In Pullman, the shareholders acted to terminate the defendant’s tenancy – not the
Board. Were the Court of Appeals’ statements about granting business-judgment
deference to board votes directly related to the issue before the Court? Were they dicta?
Does Matter of Fay support the conclusion that the statements were not dicta?18

Matter of McDermott v Bale, 19 was a Family Court custody proceeding, where the
Attorney for the Children (AFC) appealed from an order which incorporated the terms of a
written stipulation executed by the parties granting the parties joint custody of their two
children, with primary physical residence to the mother and visitation to the father. The
AFC refused to join in the stipulation, which Family Court approved over his objection. The
Appellate Division affirmed. 

          The opinion in McDermott stated, in relevant part: “We reject the AFC’s contention
that the court erred in approving the stipulation. Although we agree with the AFC that he
“ ‘must be afforded the same opportunity as any other party to fully participate
in [the] proceeding’ ” …, and that the court may not “relegate the [AFC] to a
meaningless role” …, the children represented by the AFC are not permitted to “veto” a
proposed settlement reached by their parents and thereby force a trial….” “We cannot
agree with the AFC that children in custody cases should be given full-party status such
that their consent is necessary to effectuate a settlement. The purpose of an attorney
for the children is “to help protect their interests and to help them express their wishes
to the court” (Family Ct Act § 241). There is a significant difference between allowing
children to express their wishes to the court and allowing their wishes to scuttle a
proposed settlement. We note that the court is not required to appoint an attorney for
the children in contested custody proceedings, although that is no doubt the preferred
practice … Thus, there is no support for the AFC’s contention that children in a custody
proceeding have the same legal status as their parents, inasmuch as it is well settled
that parents have the right to the assistance of counsel in such proceedings….20

In sum, we conclude that, where the court in a custody case appoints an attorney
for the children, he or she has the right to be heard with respect to a proposed
settlement and to object to the settlement but not the right to preclude the court from
approving the settlement in the event that the court determines that the terms of the
settlement are in the children’s best interests. …”21

          What was the holding? What was precedent? What was dicta? It appears to us that
the holdings were (1) that when an AFC is appointed in a custody case, he has the right to
object to a settlement but not to preclude the court from approving it and (2) children do
not have full party status in a custody case. 22 These holdings are precedent in the Fourth
Department. Everything else was dicta. No other portion of this brief opinion was
“necessary to the result.”

          In Matter of Newton v McFarlane,23 the Family Court held a hearing, without first
determining if there had been a change of circumstances, and then modified the custody
order to give the mother sole custody of the child. Its three-line decision stated its
conclusions that there were changed circumstances and awarding her custody was in the
best interest of the child, but did not state any findings or its reasoning. The Second
Department reversed the order and dismissed the petition, for the reasons stated in the
opening paragraphs of its opinion. There, it stated:” This appeal raises several important
issues pertinent to child custody determinations. We conclude that: (a) the attorney for
the child has the authority to pursue an appeal on behalf of the child from an order
determining the custody of the child; (b) the child is aggrieved, for appellate purposes,
by an order determining custody; (c) the Family Court should not have held a full
custody hearing without first determining whether the mother had alleged and
established a sufficient change in circumstances to warrant an inquiry into whether the
child’s best interests were served by the existing custodial arrangement; and (d) the
Family Court erred in failing to give due consideration to the expressed preferences of
the child, who is a teenager.”

          There can be no doubt the paragraph quoted above contains the four holdings of
the Appellate Division, which it denominated as its conclusions. Are these holdings
precedent or just limited to the facts of this case? Did the Court hold that the attorney
for “a child” or “the child” has the authority to pursue an appeal on behalf of the child from
an order determining the custody of the child? Did it hold that “a child” or “the child” is
aggrieved by an order determining custody? Did it reverse and dismiss the petition
because there were no findings, and no demonstration of a change of circumstances, or
because the wishes of the child were not considered?

          Not all cases are precedents. A close reading of the opinion will make it clear that
the Court was referring to this child and this set of circumstances. It held that the attorney
for “the child” had the authority to pursue the appeal on behalf of the child from the
order determining the custody of the child. It also held that “the child” was aggrieved by
the order determining custody.

          Assuming the opinion was not limited to this child, the Newton opinion indicates that
the Court based its conclusion that the attorney for the child has the authority to pursue
an appeal on behalf of the child from an order determining the custody of the child on
the language of Family Court Act §1120 (b). It provides that whenever an attorney has
been appointed by the Family Court to represent a child, the appointment continues where
the attorney files a notice of appeal on behalf of the child or where one of the parties files a
notice of appeal. Because there is no requirement in the Domestic Relations Law or
Family Court Act that the court to appoint an attorney for the child in a custody case, the
holding must be limited to a case where an AFC is appointed, and would not be precedent in
the Second Department beyond its holding.

                                                    Conclusion
           It is not easy to distinguish dicta from precedent in an opinion. The easiest way to
determine what is dicta is by the process of elimination. Work backwards from the
holding or holding(s) of the court, which are usually prefaced by the words ‘We hold‘ or
We conclude.” Everything that is not necessary for the court to reach the holding is
dicta.
Remember, that not all holdings are precedent.

1 see Judith M. Stinson, Why Dicta Becomes Holding and Why It Matters, 76 Brook.
L. Rev. 219 (2010). 
2  People v Taylor, 9 NY3d 129, 878 NE2d 969 [2007].
3 People v Bing, 76 NY2d 331, 337-38, 558 NE2d 1011 [1990]
4  Doctrine of Precedent, Black’s Law Dictionary (11th ed. 2019)
5 Warnock v Duello, 30 AD3d 818, 816 NYS2d 595 [3d Dept 2006]
6 Battle v State, 257 AD2d 745, 682 NYS2d 726 [3d Dept 1999].
7 Mtn. View Coach Lines, Inc. v Storms, 102 AD2d 663, 476 NYS2d 918 [2d Dept
1984].
8 Stewart v. Volkswagen of America, Inc., 181 A.D.2d 4, 584 N.Y.S.2d 886 (2d Dep’t
1992), order rev’d on other grounds, 81 N.Y.2d 203, 597 N.Y.S.2d 612 (1993).
9 Summit Const. Services Group, Inc. v. Act Abatement, LLC, 935 N.Y.S.2d 499 (Sup
2011).
10 Matter of Bull, 235 A.D.2d 722, 652 N.Y.S.2d 809, (3d Dept.,1997); Samuels v.
High Braes Refuge, Inc., 8 A.D.3d 1110, 778 N.Y.S.2d 640 (4th Dept., 2004).
11 Finding of Fact, Black’s Law Dictionary (11th ed. 2019)
12 Holding, Black’s Law Dictionary (11th ed. 2019)
13 See Doctrine of Precedent, Black’s Law Dictionary (11th ed. 2019)
14 See Rohrbach v Germania Fire Ins. Co., 62 N.Y. 47 (1875)
15 See Colonial City Traction Co. v. Kingston City R.R. Co., 154 N.Y. 493, 495, 48 N.E.
900 (1897)
16 In re Fay, 291 N.Y. 198, 52 N.E.2d 97 (1943)
17 100 N.Y.2d 147, 149–50, 760 N.Y.S.2d 745, 747 (2003)
18 In London Terrace Towers v Davis, 6 Misc. 3d 600, 612–13, 790 N.Y.S.2d 813, 822–24,
(N.Y. City Civ.Ct., 2004) the Court held that the additional statement was dicta.
19 94 A.D.3d 1542, 943 N.Y.S.2d 708 (4th Dept., 2012)
20 Id. Citations omitted
21 Citations omitted
22 See also Matter of Kessler v. Fancher, 112 A.D.3d 1323, 978 N.Y.S.2d 501 (4th
Dept., 2017); Matter of Lawrence v Lawrence, 151 A.D.3d 187, 54 N.Y.S.3d 358 (4th
Dept., 2017); and Matter of Kanya J v. Christopher K, 2019 WL 3475277 (3d
Dept.,2019) each holding that a child in a custody matter does not have full party status.
23 174 AD3d 67, 2019 WL 2363541 (2d Dept., 2019)

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