Constitutional Law is a game that anyone can play.
All you need to know are a few rules, and how to bend them.
The rules are flexible enough until the U.S. Supreme Court rules "Foul." This sets up a barrier forcing the players to continue on a slightly different track, a thin slice to the side. Creating distinctions with very little difference is a form of salami tactics.
While the game can be played in all doctrinal arenas, the controversies we're most likely to see in the news have to do with religion, expression, and politics.
The issue is "Can people with whose views I disagree force them down my throat by using my government to do their dirty work for them?"
Must we stand by for this?
I'm afraid so, eternal vigilance being the price of liberty.
Or can we tell Government to F*ck Off and Mind Your Own Business?
This is the old MYOB principle of Constitutional Law that we keep working toward but never quite achieve.
Suppose that you are sufficiently in tune with modern Western, secular, culture as it has developed since the Renaissance, the Enlightenment, the Scientific Revolution, and the American Space Program, to believe that Earth is no longer flat.
And that you cannot fall off the edge by sailing too far out to sea.
Further that the Sun does not revolve around Earth, as Ptolemy thought, but rather, Earth revolves around the Sun, as Copernicus, Galileo, Newton, Einstein, the Catholic Church (despite the false start with Galileo) and Tom Hanks of Apollo 13, the movie, fame, have all understood and more or less staked their lives on.
If, by contrast, a sizable part of the American population held to the old view on religious grounds, should we be forced, assuming they have enough votes, to teach the old view in classrooms and textbooks?
Edwards v. Aguillard (1987) says no, that a Louisiana law prohibiting the teaching of Darwin's Theory of Evolution is unconstitutional on on Establishment of Religion grounds, First Amendment.
Evolution vs. Creationism has been a battleground of Consitutional Law having remarkable persistence. Perhaps it shouldn't be remarkable, considering the persistence of religious beliefs. No mere Supreme Court decision is apt to shake the foundations of a person's faith.
"Just wait until the Court changes," a person of faith might say, "Wait 'til next year."
Just like the Red Sox fans, where against all the laws of God, man, and the law of large numbers, Boston won eight straight to come back from three down in the pennant race against the Yankees to sweep the St. Louis Cardinals in the World Series.
The forces of religion vs. the forces of science.
SCIENTIFIC INVESTIGATION
The celebrated Scopes "Monkey" trial was an early battle in this contest for the hearts and minds of our little ones in school, religion vs. science, William Jennings Bryan (for God) vs. Clarence Darrow (for the Devil Reason).
John Scopes was a public high school teacher in Tennessee who taught Darwin's Theory of Evolution in violation of a Tennessee criminal statute in the 1920s. Science was outlawed in Tennessee in favor of religion. H.L. Mencken's "Booboisie" was in voting control.
Charles Darwin's theory holds, contrary to the religious teaching that God created man and the world in seven days, according to Genesis, that the various species evolved slowly over time through a process favoring those better adapted to circumstances without Divine Intervention.
Those less well adapted die off, leaving survivors to reproduce with similarly advantaged survivors. The principle of natural selection, as this process is called, accounts for such things as specialized cells which grow into eyes, legs, hands, giraffe necks, elephant trunks, fish fins, bird beaks, wings, and, oh, yes, our brains and ability to speak. All without the help of God.
It disturbs some folks mightily, not only to have Earth displaced as the center of the Universe, as God apparently in their view intended, but to have Him displaced from his position as the Creator of Man.
It hasn't occurred to these good people that man creates gods out of some deep need, not the other way around.
Alas, many have placed faith in a theory subject to disproof. It seems to me that a religion which teaches values that enable its adherents to get along together, and with others, that is, to live peacefully in the world, might be satisfaction enough.
Values, being preferences and opinions, may be subject to disagreement, but are not subject to disproof.
Sacrificing virgins to the false god of rain, however, can be shown to be a truly false exercise in futility, using the Q&A based techniques of scientific observation and evaluation.
It takes a special form of arrogance to say "My god is bigger, better, or stronger, than yours." Yet that is what civilization does, imposing the faith backed by the stronger army. See the Spanish Conquistadores vs. the indigenous faiths of the New World and putting a halt to human sacrifice.
Claiming comparative god-advantage seems a fairly juvenile form of urinating contest. To this day I would like someone to tell me why one god is better than many, other than the fact that the latter had been the victim of the Christian overthrow of Paganism.
Any system that produced Socrates, Plato, and Aristotle couldn't be ALL bad, could it.
My ghosts are better than yours.
Darwinism, as a theory of science, is based on a rigorous system of critical observation and questioning among trained investigators who start from the premise that they don't know, but must question. The result is an idea, or hypothesis, that is testable, meaning falsifiable.
If your idea is not capable of being tested to determine whether it is objectively true or false, you don't have a scientific theory, but a religious, astrologic, or otherwise supernatural one.
You are free to entertain and arrange YOUR life around it, but it's not science and you shouldn't try to arrange MY life around it.
It is pseudo-science or nonsense as far as the unbeliever is concerned. Cultural and religious conflict is the result of the clash in belief and values.
Scientific uncertainty is the opposite starting place from the preacher's assumption that God created the World and man, and nonbelievers need to prove that he didn't if they wish. They'll never succeed with a true believer, whose system, since it exists in a conditioned mind, is impervious to reason.
Religious belief may be interesting, comforting and fine, but it is not science, nor does it claim to be.
Religion promises certainty in a risky world, while science relishes doubt, using it as a goad to spur questions requiring investigation to answer.
Religion promises answers, while science promises only provisional answers and more questions.
The only real question is which accounts more fully for nature.
How much faith are you willing to put in astrology, for example?
Religion, as opposed to astrology and palm reading, however, frequently claims the force of law, which is where the Constitution comes in. The Constitution controls whether statute law may stand, calling it constitutional, or not.
The requirement of falsifiability as the test distinguishing science from pseudo-science (magic) was contributed by Karl Popper. You should look him up some time and read his works, for he is a model of clear thinking.
Popper pegged Sigmund Freud as little better than an intellectual fraud and explained why before the rest of the world caught on. Because little if anything that Freud suggested was capable of being tested. Pseudo-science is what Popper called it.
Even if Freud and his disciples described a person using Freud's constructs, there was no certainty that the subject would behave according to the prediction of models that had held much of the world in thrall for decades.
Now psychiatrists use drugs to treat mental and emotional illness, not Freudian psychotherapy. Talk therapy is, however, used by various counselors.
A really good scientific theory is good because it is fruitful, meaning that it leads to new discoveries previously unthought of. It is robust in the sense that it explains observable phenomena accurately and well. It is thus not easily dislodged except when is shown by example to be false.
The theory that a seer can predict your fate based on your date of birth under a particular planet or star has been hugely influential but vastly false. Science grew out of astrology. From the mud grows the lotus.
Astrology never holds up to testing, and when shown to be false, the seer always leaves an 'out' (or creates one on the spot by making an "ad hoc" exception) or ignores the evidence and proceeds as before anyway.
A really good scientist, that is a scientific investigator who searches for answers to novel questions of nature competently and with integrity, leans over backwards to show how even his favorite theory, the one that might bring him tenure, fame, fortune, a Nobel Prize, is wrong.
Or if he cannot prove himself wrong, the good scientist sets down in writing in advance what it would take to prove his theory wrong. This helps him stay out of the traps of falling in love with his own theory.
To take Newton's famous observation of the apple falling on his head while sitting under the tree, which is said to have inspired his theory of gravity, Newton's theory holds as a necessary corollary that if so much as one apple falls UP, the theory is wrong.
No apple so far has ever fallen upwards, away from the earth. A few have been thrown and blown away by other forces than gravity temporarily, but all have fallen back to earth once those forces have spent themselves, under the force of gravity.
That was a robust theory, and the one we still use here on earth for normal activities, such as hurling projectiles during war, flying in machines, and hitting baseballs.
Albert Einstein, however, came up with a new theory, that he called Relativity, which he believed supplanted Newton's gravity theory. Einstein provided mathematical proofs and thought experiments that needed to be checked out thoroughly, something scientists are still doing.
But the really cool thing that Einstein did, for our purposes of understanding scientific theory, was to say:
My great new theory, if it is a great theory, will be proved false if you look for and find Such-and-such.
There was to be no ad hoc exception making for Albert Einstein, any more than there was for Isaac Newton. For each knew that nature cannot be fooled. People can, but not nature.
If you would like to read further on the philosophy of scientific investigation, Notre Dame Press has a wonderful book collecting the work of a number of thinkers on the subject. It's been a long time since I've seen the book, and no longer recall the title, but NDP is where I'd start looking.
Richard P. Feynman is the most practical and plain-spoken person I've seen on the subject of investigating competently with integrity. Start with "Surely You're Joking, Mr. Feynman," especially the last chapter called "Cargo Cult Science," and proceed to the excellent James Gleick biography.
Also of interest is E.O. Wilson, entomologist (ants), and his autobiography. Note his caveat about drawing conclusions based on finding what you wanted to find. There's a name for this logical fallacy and I forget what it is offhand.
I recall now; it's called the Fallacy of Affirming the Consequent and Wilson gives a nice example of his awareness of the fallacy and avoidance of the mistake. You can affirm an antecedent, and refute a consequent, but it can be a mistake to affirm one.
However, I've long since given up tryng to argue logic to judges, especially after Holmes has written that "The life of the law is not logic but experience."
Nevertheless, the field of study in which you will find logical fallacies discussed is called "Critical Thinking," and I recommend becoming familiar with it to anyone pursuing law as a profession.
We're in the business of correcting other people's papers, so we ought to know what we're about, oughtn't we.
One doesn't often see direct references to logic in law, since, probably it is such a large part of what we do that we take it for granted until we see a glaring mistake.
Evidence, to be admissible, must be relevant, that is, it must have a tendency in reason to support or refute a contention in issue. This is the rule of logic. By this rule we import the whole subject of logic and critical thinking into law. See Cal. Ev. C. Secs. 201 - 210.
Nevertheless, a good story that brings a tear or a smile from a juror is apt to be far more persuasive than the sweetest syllogism.
Don't let your opponent get away with any non sequitors, however.
See also the Circumstantial Evidence Rule and the rules as to who has the Burden of Proof and to what Standard of Proof.
These can be found most easily in California by consulting CALJIC (California Jury Instructions, Criminal) and BAJI (Book of Approved Jury Instructions), the criminal and civil jury instruction books, respectively, used in all California civil or criminal trial courts. Federal courts rely on Devitt and Blackmar. Instructions may vary from Circuit to Circuit. California is replacing BAJI with a new set of 'plain English' jury instructions here.
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FOXGLOVE
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On the subject of needing to understand at the beginning of an investigation that certain circumstances, if satisfactorily established, will give the lie to your theory, which must then be abandoned, I would like to describe an experience where this did not happen.
As a result a single case took over a decade to resolve. The prosecution wasted over a million dollars of public funds in pursuing what turned out to be a phantom. My job as defense attorney was to play a force of nature, one that could not be fooled.
Foxglove was a celebrated case which I tried, or began to try, as it derailed shortly after cross-examination of the first witness, the Medical Examiner who purported to have found poison in a person where it should not have been.
Foxglove started out as a death penalty murder investigation in late Spring or early Summer of 1993 and ended in August, 2004. It later turned into a conspiracy to commit murder when police investigators decided they couldn't that prove anyone had been murdered, despite their digging up four bodies from their graves in cemeteries.
The theory was that my client, a beautiful young Gypsy, was going around befriending lonely older men and murdering them to inherit their money.
What made the case interesting, apart from the beautiful young Gypsy angle (the newspapers LOVED this part), was that Angela was open to befriend rich older gentlemen. When she was 17, she DID marry an eldely gentleman who was 89.
And he DID die a few weeks after they got married.
And he DID leave her a fortune consisting of a lovely home in San Francisco, cash and a sizable bank account.
After a windfall like this, what young woman wouldn't want to go after even bigger game, or allow bigger game to catch her, which she certainly did. The others, and there were several, were even older and richer!
Oh, the relatives were all upset about this.
The relatives of the elderly men who felt that THEY were the ones entitled to inherit when he croaked, not some latecomer, especially not some Gypsy, who aced them out by being there, with the elderly man, every day until he died, were distressed at the unfairness of it all.
Of course, this is exactly what the elderly gentleman wanted, didn't he. To have a bright, young, energetic tonic of a woman around every day keeping him interested in life until the day he died. Otherwise he was lonely and depressed.
To the elderly, lonely man, it was worth the money to lure the sweet-young-thing by making gifts as they went along together, and maybe even a gift that took effect after he was gone.
This was much better than leaving his wealth to relatives who didn't come around and care for him, wasn't it? Relatives he didn't much care for in the first place, either, perhaps?
So my client was a murderer, according to the police.
They went around telling everybody my client was part of an international serial murder conspiracy to inherit from elderly men using an impossible to detect poison.
This was a GREAT story.
I couldn't have made it up.
All the police needed was to find the poison in a body where it shouldn't be.
That's why they dug up the bodies from graves. If they could find poison in the bodies, they had a good murder case, right?
But if they didn't find poison in the bodies, their investigation wasn't over, was it? My client could have poisoned the men, killing them, but their bodies might have lain in the ground too long to recover the poison.
Angela would have committed the perfect crime, perhaps many times over. The Medical Examiner could not let the Gypsies out-smart him, no way.
The poison Angela was thought to have administered could have gone away. Thus she was still on the hook, as far as the San Francisco police, Medical Examiner, and District Attorney (Hallinan, Randle-Johnson, A. Murray, and Searle) were concerned.
They spent years on this one case.
I'd never seen that before. I'd been in that office for five years myself and had litigated with it for decades.
What made matters worse for the beautiful Gypsy was the fact that one day, while she was visiting one elderly male friend (she had several) named Richard Nelson, a whole team of police arrived with detectives, the Medical Examiner and a social worker.
Police slapped handcuffs on Angela, took her to the police station, and put her in a cell for three hours before returning her to the home of the man she was supposedly trying to kill.
Meanwhile, as Angela was kept in the cell at the police station, the investigating team at Mr. Nelson's house searched in his refrigerator and took food samples. They searched his kitchen, bedroom and bathroom medicine chest. They saw what he had in his whole house. They interviewed him to their heart's content.
The Medical Examiner also took samples of Mr. Nelson's blood, which he then drove to his private laboratory and tested, himself. Boyd Stephens, M.D. had been the San Francisc Medical Examiner for years, and taught Pathology at UCSF. Prosecutors from all over consulted him, as did defense attorneys.
The Medical Examiner told police in a letter that they should consider that they had a murder investigation on their hands, for he had found the supposedly undetectable poison, a heart medicine that can kill when taken to excess, in Mr. Nelson's blood.
Not only that, but Nelson's doctor hadn't prescribed any heart medicine because Nelson's heart was fine.
The medicine was called digoxin, as in digitalis, which comes from the Foxglove plant. Foxglove has been used since Biblical days to strengthen and regularize the heart beat.
Angela went to an attorney to protest being arrested for three hours.
This attorney referred her to me. She called and said she wanted an attorney to sue the police for false arrest. Three hours worth. I turned her away.
A week later she called again, more insistently, and asked to come in. She arrived with her boyfriend, George. I didn't know which one had the legal problem, so I let them sort it out. "The one who has the legal problem and needs an attorney, please come into my office," I instructed, as I left them in the waiting room. As Angela entered, the next eleven years of my life exited.
I listened to her story, caught her in a lie, confronted her with it, had her explain it until I was satisfied, and sorted out what was going on. She was Gypsy. She hadn't wanted to admit that part for fear I'd be prejudiced against her, like so many others. She had friends. Elderly. So had her mother. The mother had inherited two properties. Angela one. Mom had elderly friends. Angela had more.
Police had come to the pharmacy across the street from where her boyfriend, George, operated a cafe, with his mother, in San Francisco. The police told the pharmacist that George and Angela were international killers, using a heart medicine, to inherit.
Unless the pharmacist cooperated in turning over records, he would be implicated with supplying the poison. The pharmacist turned over records showing that George's father used Lanoxin, which is digoxin. This was the source of the poison!
I don't think your problem is 3-hours in jail, I told her. Police are investigatino you for murder. They'll need to dig up bodies to search for poison. Are they going to find any?
No, she said, there was no poison. All who died did so of illnesses at an advanced age, attended by doctors, nurses, and aides in the hospital or nursing home, of natural causes.
Good, then you should have nothing to worry about I told her.
By the way, did any of these folks, other than the one you married and left you the home, etc., have a will or a deed or anything else that would provide you a benefit when he died?
No, she said. Are you sure? I asked. She was quite sure. Same answer as to George.
I hope you're telling me the truth, I advised, because if that's true I can help you. If not, you're in big trouble.
It's true, she said, despite the earlier lie that she admitted when confronted with an inconsistency. I had to be a pretty good investigator myself, otherwise I could wind up in a terrific bind.
We are talking about theories of investigation, weren't we. About how scientists, any investigator for that matter, must have a theory to test.
Police investigators are like scientists, or should be. They need to test a theory. If there's something wrong with it, they must either shut down the investigation or modify the theory.
If you are willing to modify the theory every time a piece of fruit falls up, pretty soon you have a bad theory. If apples fall up, pears fall up, cocoanuts fall up, suddenly you have no Newton's law of gravity for fruit.
The police never came up with a will benefiting Angela from Mr. Nelson. He left everything to his family. Without some legal instrument benefiting Angela or her boyfriend George, whom Mr. Nelson had not met, there would be no sense in her poisoning him, would there.
This was the fatal flaw in the Foxglove investigation that I knew about, with reasonable confidence. It enabled me to take an aggressive posture towards the litigation in the press.
"A fascinating story, poison-murder," I told reporters, "but missing a couple of things, like poison and murder." They printed that.
There were other fatal flaws that I didn't find out until much later.
The second was that the San Francisco Medical Examiner, the one with the quarter century of experience establishing cause of death scientifically as a pathologist, had made a mistake. He used the wrong test on which to claim he'd found digoxin in Mr. Nelson's blood while Angela was visiting.
With the able assitance of my own medical examiner, I caught Dr. Stephens out.
The number his testing equipment produced on Mr. Nelson's blood was meaningless.
It would have produced that number testing distilled water.
The third fatal flaw was that, unbeknownst to me, the police had a witness, George's nephew, who told them that George had bragged he that he and Angela were murdering elderly people to inherit by sprinkling their food with "magic salt," digoxin, at the cafe George and his mother owned.
However, this nephew had now recanted. He'd been put up to saying this, he now said, because George was at war with Jerry, his older brother, who was jealous of George's success in business. That and the fact that Angela was Gypsy. George's mother and sisters hated the fact that George had taken up with a Gypsy, especially one who had inherited a house from an 89-year-old man whom she'd tried to pass off as her grandfather when in fact she'd been married to him.
They learned this when George and his mother bought the house she'd inherited from Angela. After inheriting, Angela found a job in a cafe, owned by George and his mother, and eventually began living with him in an apartment to the rear of this home.
George's family wanted Angela our of George's life and the mother wanted him to return to them.
I interviewed the nephew on tape, with an investigator, and tried to turn it over to the district attorney, who refused to listen to it!
This, among other things, confirmed that this was no ordinary criminal case, but a witch-hunt, a field in which I'd had some experience, as a matter of fact.
In the end, I succeeded at trial, during preliminary motions, after cross-examining the Medical Examiner, and getting him to admit his mistakes, in having 95 of 96 counts dismissed on motion of the district attorney, including the murder-conspiracy counts with their punishments of life in prison.
Angela had served two years of dead time before trial, so I breathed life into the time by making a deal to plead guilty to one count of stealing $4,000 from Nelson (he'd made her many gifts worth, in total, about $24,000) in return for credit for time served, without admitting any factual basis or that she stole.
Yes, you can plead a client guilty to something she didn't do in order to spare the risk of further punishment. The trial, if completed, would have taken another year, with Angela in custody.
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SCIENTIFIC THEORY, CON'T
If only the San Francisco authorities had followed Einstein's lead and said, concerning their poison-murder theory: Our great new theory, if it is a great theory, will be proved false if you look for and find, of fail to find, Such-and-such. Such as no will. Lack of a will at the time of alleged poisoning proves the murder to inherit theory to be false.
If your theory is that A is poisoning B in order to inherit, then there must be a will to make the effort worthwhile. No self-respecting commercial poisoner practices his, or her, trade for free, do they? We don't take dry runs with poison in anticipation of a will, do we? Of course not.
We want to have the will safely in our little hands and THEN we'll bump off the old guy, so we can inherit.
Poisoning someone in advance of gathering in his will means we don't inherit. It either kills him for no profit or makes him sick and he'll see his doctor, and then the game is up, isn't it.
I don't know why the police had such trouble figuring this out. Don't they read murder mysteries?
The answer is that investigators fall in love with their theories all the time. If it's not the Nobel Prize they're after, then it's something else: fame, glory, a gold detective's badge or money.
In Foxglove, a private investigator who was in cahoots with a police department investigator made a deal to make money from the investigation by selling the book or movie rights.
This private investigator was in cahoots with another private investigator who turned the story over to a crime writer who DID write a book about the case, based on news reports which were based on leaks before the indictment even came down and the defense received any of the discovery that changed the picture entirely.
Look, I'd say to reporters from the TV networks that had been chasing the story, "Which is the better story, Gypsies murdering elderly for money, of police falsely believing that Gypsies are murdering elderly for money?"
For some reason the news people, and the police, always liked the first version better, set it adrift on the high seas, and never made any correction, even when the vessel sank under them. They just hopped like fleas and roaches onto the next piece of flotsam drifting by. For this they receive acclaim.
When Mr. Nelson, a successful accountant, told police that he had only one will, prepared by his lawyer, that left all to his family and nothing for Angela, plus he'd like to marry her ("Hope springs eternal" he told police) that should have ended the murder investigation right there.
But serial murder of the elderly for money had become a fixed idea, and police couldn't drop it, especially after news of it leaked and the press had a field day about Gypsies murdering elderly for their money, so they kept it going for more than a decade, almost eleven years, all told.
When a prosecutor is unable to prove that members of a group actually committed a crime, maybe he can prove that they conspired to commit what he couldn't prove they did commit.
The prosecutor may make an ad hoc adjustment in his theory which will be good for years more litigation while your client rots in jail.
An agreement with another person to commit murder will put both in prison for life just as if the murder had been carried out, provided that one takes a step toward the goal, such as by procuring digoxin, or visiting the house of the intended victim.
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It is important to me as a law professor to set forth such examples as teaching models. I am not interested in representing in any more Foxglove type cases. Eleven years is a long time for a guy sporting white hair. World War II took less time than Foxglove.
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STRONG BELIEFS
In Constitutional Law, as we were saying, the strong beliefs that capture the mind keep returning.
True religious believers have a need to preach their gospel, and not only to preach it, but to push it onto non-believers.
Evolution vs. creationism is one example.
"Under God" in the Pledge is another.
Gay marriage.
School prayer is another. If not prayer, how about a moment of silence? Salami tactics toward the same end, devotion to a supernatural power.
Abortion. Life is sacred, a religious concept, and becomes so at the moment of conception, when sperm hits egg.
Christmas creches at City Hall.
Tall crosses, the maximum symbol of Christianity, erected over cities populated by people of all faiths.
The contest between your religion and mine is a never ending battle, for I like mine as much as you like yours. Mine says "Mind your own business and leave me alone," while the evangelist insists on intruding on my attention using force of law.
The law hasn't reached my point of view quite yet, but hasn't allowed urestricted freedom for evangelists, either, when it comes to using government law and facilities. These includes city property, schools, and public observances, such as having "In God We Trust" on the coinage, and opening Supreme Court sessions with the invocation "God save this honorable Court."
If you would like to see the theory on which some references to the historical deity which played such an important part in the origin and development of this country through today, by inspiring and marshalling support, see Justice Sandra Day O'Connor's separate opinion in the recent Newdow, "Under God" Pledge case, in which she makes a distinction between a sincerely felt religious observance and one of those things that we just say out of tradition and habit that no one should mistake for a true religious observance. Sort of like saying "God bless you," when someone sneezes.
It's always difficult to predict how the Court will divide on such issues.
It is not difficult to predict, however, that no matter which way the Court rules, someone will figure a way to make a new attempt at getting their religious idea made into law, forcing yet another Con-Law go-around.
Here's a news excerpt on the gay marriage controversy, in which the battle for hearts and minds of youngsters is fought out in textbook language use and purchasing.
The Texas Board of Education, the 2d biggest purchaser of public school textbooks in the nation, approved new health texts for high schoolers but only after the publishers agreed to reword passages to depict marriage as the union between a man and a woman, according to the Associated Press.
No more of this "two individuals" and "married partners" nonsense, called "asexual stealth phrases" by one proponent of the change, that opens the doors to gays getting together and calling it marriage.
God forbid that people should be allowed to make their own choice of life partner when the Texas Board of Ed is willing to do it for them.
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As to you, you get to decide such questions for yourself.
It's a free country.
Or was.
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