Why Kagan Has Skin in the Game

December 5th, 2011 at 12:00 am | 52 Comments |

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In my last post I argued that Justice Elana Kagan is obliged by 28 U.S.C. 455 (b)(3) of the federal recusal statute, which applies to Supreme Court justices, to recuse herself from the challenge to the Obama Health Care law. The provision requires a judge to recuse if he or she “has served in governmental employment and in such capacity participated as counsel, adviser… concerning the proceeding or expressed an opinion concerning the merits of the case in controversy.”

I pointed out that e-mails made public through Freedom of Information Act litigation show that Kagan expressed her opinion (glee) as solicitor general when the law was enacted, and that she personally participated as Solicitor General in formulating a response to the challenges to the constitutionality of the law. There is simply no basis to dispute that she was a governmental official at the relevant time, expressed her opinion about the law, and therefore, “participated as counsel concerning the proceeding.”

One of the few astute comments pointed out that the case before the Supreme court may not be the same “case in controversy” to which she participated. This may be technically true; I expect her to make this point in any opinion she releases concerning her recusal or non-recusal. Many cases were filed challenging the constitutionality of the law. Some were filed by states and others by individuals throughout the nation.

I cannot say for sure that the Complaints she read last year were in the cases which the Supreme Court consolidated and agreed to hear. It is very likely that she participated in the massive multi-state challenge to the law filed in Florida since it joined about 15 different states. But if I’m wrong, and she somehow managed to evade participation in all of the big challenges to the law, and only considered the small, less consequential ones, this would be quite odd. The Solicitor General is the government’s top courtroom advocate, and normally would be expected to weigh in on all of the big challenges to the constitutionality of any federal law.

Many of the commenters accused me of ignoring the supposed case for Justice Clarence Thomas’ recusal. If there is such a case, nobody made it in a lawlerly manner by citing the provision of the Recusal Statute that applies. Rather, it was pointed out over and over again that his wife is employed by a conservative advocacy group in Washington which opposes the law.

Even if this is true, it does not support recusal under the broadly worded sec. 455(a) (providing a judge shall recuse himself in a case where his “impartiality might reasonably be questioned.”) There is no reported decision interpreting this provision in the way the commenters advance, i.e., basing recusal on the mere opinions of a family member, no matter how strongly felt or expressed.

Such a standard, would, of course, cast an incredibly wide net because federal judges are political people and have politically engaged family members. According to the Seventh Circuit Court of Appeals “between half and four-fifths of all federal judges are involved in partisan politics before appointment.” Matter of Mason, 916 F.2d 384, 386 (7th Cir. 1990). This is not, nor has it ever been, a basis for Thomas’ recusal.

Judges must recuse themselves if a case involves a family member as a party, lawyer or where the relative “has an interest that could be substantially affected by the outcome of the proceeding.” 28 U.S.C. 455(b)(5). But all of the cases interpret “interest” as a financial one not a political one. So if Mrs. Thomas’ organization promised to elevate her to Executive Director or otherwise reward her financially if the Supreme Court ruled the law were unconstitutional, then she would have a direct tangible interest in the outcome of the case. But, there is no evidence that this is so. All we know from the comments is that she toils in one of thousands of advocacy groups in Washington, and happens to be married to a Supreme Court justice.

Justice Ruth Bader Ginsburg’s late husband’s extensive stock portfolio led to many calls for her recusal from cases involving these companies. There, a financial interest might exist. But she never recused herself from a case based upon this argument and the calls for her to do so never gained traction. More importantly, she has not ceased her affiliation with the N.O.W. Legal Education and Defense Fund, which has signed onto many amicus briefs in Supreme Court cases involving gender, discrimination and abortion.

The recusal statute does not forbid judges from exposure to opinion. It only forbids judges from judging when they have skin in the game. Justice Kagan has skin in the outcome of the health care litigation. Does anyone really believe she can be open-minded about the constitutionality of the health care law?

Recent Posts by Howard Foster



52 Comments so far ↓

  • TJ Parker

    Ah yes, and the Silent Justice has what, a pubic hair in the game?

  • Rabiner

    “I pointed out that e-mails made public through Freedom of Information Act litigation show that Kagan expressed her opinion (glee) as solicitor general when the law was enacted”

    True.

    “and that she personally participated as Solicitor General in formulating a response to the challenges to the constitutionality of the law”

    False. And thus your argument is wrong.

  • balconesfault

    I pointed out that e-mails made public through Freedom of Information Act litigation show that Kagan expressed her opinion (glee) as solicitor general

    Howard, why don’t you read this statement once again, and reflect on just how stupid it is?

    Your assertion is that she was serving in her capacity as solicitor general when expressing glee?

    Doubling down on the same specious claim is seldom productive.

  • Rabiner

    “Judges must recuse themselves if a case involves a family member as a party, lawyer or where the relative “has an interest that could be substantially affected by the outcome of the proceeding.” 28 U.S.C. 455(b)(5). But all of the cases interpret “interest” as a financial one not a political one. So if Mrs. Thomas’ organization promised to elevate her to Executive Director or otherwise reward her financially if the Supreme Court ruled the law were unconstitutional, then she would have a direct tangible interest in the outcome of the case. But, there is no evidence that this is so. All we know from the comments is that she toils in one of thousands of advocacy groups in Washington, and happens to be married to a Supreme Court justice.”

    Thomas didn’t disclose the earnings of his wife for many years from conservative organizations who have financial and political interests in this case. In addition if it is perceived that his wife has sway with him on judicial hearings (due to his voting against the law) then financially she will gain from future employment and investment in her by such organizations.

    “The recusal statute does not forbid judges from exposure to opinion. It only forbids judges from judging when they have skin in the game. Justice Kagan has skin in the outcome of the health care litigation.”

    The emails you mentioned with her showing ‘glee’ was an exposure of opinion which you say is okay at the bottom of your article. What skin exactly does Kagan have in the game? She has no political gain since she can’t get promoted to a higher court, and she has no financial gain since she has no way to profit from this case so I wonder what exactly is her ‘skin’?

    • MSheridan

      +1

      Expressing glee (or any other emotion) in a nonpublic email not intended for distribution and with no legal force is not equivalent to acting in an official capacity. We do not demand that the Justices have no personal opinions going into any case. What we expect is that they have not acted in regards to the case or expressed those opinions publicly.

      However, let’s look at that code, shall we (excluding the long definitions section at the end):

      28 U.S.C. § 455 (a-c)
      “(a) Any justice, judge, or magistrate judge of the United States
      shall disqualify himself in any proceeding in which his
      impartiality might reasonably be questioned.
      (b) He shall also disqualify himself in the following
      circumstances:
      (1) Where he has a personal bias or prejudice concerning a
      party, or personal knowledge of disputed evidentiary facts
      concerning the proceeding;
      (2) Where in private practice he served as lawyer in the matter
      in controversy, or a lawyer with whom he previously practiced law
      served during such association as a lawyer concerning the matter,
      or the judge or such lawyer has been a material witness
      concerning it;
      (3) Where he has served in governmental employment and in such
      capacity participated as counsel, adviser or material witness
      concerning the proceeding or expressed an opinion concerning the
      merits of the particular case in controversy;
      (4) He knows that he, individually or as a fiduciary, or his
      spouse or minor child residing in his household, has a financial
      interest in the subject matter in controversy or in a party to
      the proceeding, or any other interest that could be substantially
      affected by the outcome of the proceeding;
      (5) He or his spouse, or a person within the third degree of
      relationship to either of them, or the spouse of such a person:
      (i) Is a party to the proceeding, or an officer, director, or
      trustee of a party;
      (ii) Is acting as a lawyer in the proceeding;
      (iii) Is known by the judge to have an interest that could be
      substantially affected by the outcome of the proceeding;
      (iv) Is to the judge’s knowledge likely to be a material
      witness in the proceeding.
      (c) A judge should inform himself about his personal and
      fiduciary financial interests, and make a reasonable effort to
      inform himself about the personal financial interests of his spouse
      and minor children residing in his household.”

      How Mr. Foster can read the above and seize on (a)(3) as the only problematic provision affecting any of the Justices (and only Kagan) is beyond me.

  • drdredel

    “There is no reported decision interpreting this provision in the way the commenters advance, i.e., basing recusal on the mere opinions of a family member, no matter how strongly felt or expressed.”

    It’s not about her “opinion”. It’s about the fact that she’s paid to have it, and he benefits, financially (and substantially so) from it. If she was just sitting around his kitchen having opinions (or even having them loudly and in public, but without any fiscal rewards), then obviously there would be no issue. But as his financial wellbeing is tied to her holding said opinions…

    actually… come to think of it, this may work in the Obama administration’s favor for him NOT to recuse himself. If he votes that Obamacare is constitutional, he actually stands to make more money, as his wife can continue to lobby against it, in various ways. If, however, he votes against it, there’s nothing left to argue about and they lose that income avenue.

  • armstp

    The question is why does the author want Kagan to recuse herself from any potential from challenge to the ACA?

    We know it is all politics! The author is just looking for advantage for his obvious view that the ACA should be rejected. He is not looking for justice, just for political advantage.

  • baw1064

    Anyone who has health insurance should be required to recuse themselves!

  • Kevin B

    Clearly, Howard Foster has skin in the game. That’s why he is so insistent that Kagan recuse herself, and that Clarence Thomas NOT recuse himself.

    It’s also why Foster’s opinions on the subject can be summarily dismissed.

  • mlindroo

    Conservative judge Michael Mukasey is right: both Kagan and Thomas should decide the case –

    http://online.wsj.com/article/SB10001424052970204012004577070162911944188.html
    [...]
    “Although critics have portrayed Justice Kagan during her tenure as a “cheerleader” for the health-care bill, and although she did send an email to a former faculty colleague that applauded the legislation, the solicitor general ordinarily is not called on to advise on issues of constitutionality of proposed legislation; that task usually falls to the Office of Legal Counsel. There has been no evidence that she acted personally in her official capacity as solicitor general in connection with any issue in the case.”

  • Kevin B

    Really, do you think these arguments are going to convince Elena Kagan to recuse herself? That’s what it comes down to. It’s her decision. That’s the Constitutional reality, and we all love the United States Constitution, don’t we?

  • jamesj

    This is seriously getting embarrassing.

  • SteveT

    re: Ginni Thomas: “But, there is no evidence that this is so. All we know from the comments is that she toils in one of thousands of advocacy groups in Washington, and happens to be married to a Supreme Court justice.”

    Toils? Good Lord.

    • balconesfault

      Toils? Good Lord.

      Dammit, someone has to eat those $60 lunches at The Oceanaire or Charlie Palmer’s.

  • Frumplestiltskin

    What I find most amusing is Foster’s hubris that he can imagine anything he says could possibly lead Kagan to recuse herself. He might as well hang a signpost around himself and rant on street corners for all the difference it will make.

    Obviously she has no intention to recuse herself, she never would have been nominated if she were going to.

    • TerryF98

      THE END OF THE WORLD IS NIGH.

    • sweatyb

      the point is not to get Kagan to recuse, the point is when the Supreme Court votes 7-2 in favor of ACA idiots like Foster can say that the whole thing was fixed.

      We all know that Supreme Court is an elitist, anti-Democratic institution full of socialist Obama-sympathizers.

  • Falling Rock

    Nobody making a “lawyerly argument” is a fantasy.

    The genie’s been released from the bottle, I don’t see it returning over this.

  • Demosthenes

    So Kagan, who expressed a personal opinion in her personal correspondence, has “skin in the game,” even though those calling for her to recuse herself readily admit she never had any financial interest at stake in the constitutionality of PPACA.

    But Thomas, who demonstrably lied about his wife’s income from anti-ACA lobbying groups, does not have any “skin in the game,” because he does not have any “interest that could be substantially affected by the outcome of the proceeding.” Such as, I don’t know, his wife’s job?

    In all seriousness I feel bad for your clients, if the above is the best legal argument you can muster it is a wonder you passed the Illinois Bar.

    P.S.

    I cannot say for sure that the Complaints she read last year were in the cases which the Supreme Court consolidated and agreed to hear. It is very likely that she participated in the massive multi-state challenge to the law filed in Florida since it joined about 15 different states. But if I’m wrong, and she somehow managed to evade participation in all of the big challenges to the law, and only considered the small, less consequential ones, this would be quite odd. The Solicitor General is the government’s top courtroom advocate, and normally would be expected to weigh in on all of the big challenges to the constitutionality of any federal law.

    If you were following this with any of the attention to detail of a real-life high stakes attorney you would already know that Kagan had been completely insulated from the government’s internal proceedings re: PPACA because of President Obama’s intention to elevate her to the Federal judiciary. Preparation fail.

    • indy

      This is the crux of it, isn’t it? On one hand, the standard is such that Foster dismisses accusations of impropriety on the part of Thomas because there is no ‘evidence’ that Mrs. Thomas will stand to financially benefit directly from the outcome of the case. So the standard for Thomas to recuse himself is ‘evidence’.

      On the other hand, he cannot say ‘for sure’ that Kagan read the complaints or was involved in any way in them, just that it is ‘very likely’. So the standard for Kagan to recuse herself are conjectures that are ‘very likely’ in his mind but evidence is not required.

      I believe most people who are not political hacks refer to that as a double standard.

  • bdtex

    Your Motion For Recusal is again denied Mr. Foster.

  • armstp

    “basing recusal on the mere opinions of a family member, no matter how strongly felt or expressed.”

    I think it is a little more than “mere opinions”. The Thomas family massively financially benefited from opposition to the ACA. Ginni and therefore her household is getting paid big bucks to oppose the ACA.

    Howard, there is the technical definitions and then there is the long history of doing what is right and the standard. Up until the most recent court, SCOTUS justices would never give speeches at political events and organizations (maybe at a university at best) and had spouses that operated and worked in areas that had very little to do with any potential conflicts of interest. Today, thanks to those on the right, SCOTUS justices and their spouses seem to do whatever they want. We have clearly lost something.

    “On the question of recusal, the law is clear that the decision is entirely up to Thomas; the Supreme Court operates on an honor system. The federal statute governing judicial conflicts of interest covers only lower-court judges. “Congress has always felt a greater sensitivity when it tries to regulate something related to the Supreme Court,” Michael Gerhardt, a professor at the University of North Carolina School of Law, told me. “The tradition is that the Justices can be trusted to deal with these issues themselves.”

    As for whether Thomas should recuse himself regarding health care under the standards that prevail for lower-court judges, that appears to be a close question. “I think it is possible she”—Ginni Thomas—“might have significant interests in the dispute before the Court,” Gerhardt said. “And these interests are not restricted only to financial ones. The code, after all, forbids judges from engaging in conduct that undermines their impartiality or the appearance of impartiality. In Thomas’s case, the evidence so far seems compelling enough to put the burden on the Justice to explain why he does not believe he has to recuse himself.” Patrick Longan, who holds a chair in ethics and professionalism at the law school of Mercer University, in Macon, Georgia, disagrees. “The standard is whether there is something materially to be gained by the judge or his spouse from the outcome of the litigation,” he said. “It’s hard for me to see how his vote in the case would help her materially, one way or the other.” In any event, there is no sign that Thomas plans to recuse himself on health care or on any other case related to his wife’s political activities.”

    http://www.newyorker.com/reporting/2011/08/29/110829fa_fact_toobin#ixzz1ffrf0sGS

  • JosephP

    This article is rich!

    You’re arguing that Justice Kagan, because she was formerly Solicitor General when the health care law was passed (and might at the time have expressed her support of the law) is ineligible to argue its Constitutionality.

    But it is fine for the wife of Justice Thomas to consult for an organization, Heritage Foundation, DEDICATED to the goal of overturning the health care law, and to accept millions of dollars working there—not to mention Justice Thomas failing to report his wife’s earnings from this anti-health care organization, as well as Thomas himself speaking at Heritage events.

  • indy

    I keep wondering why Mr. Foster ignores 28 U.S.C. 455 (b)(4)

    He shall also disqualify himself in the following circumstances:

    4) He knows that he, individually or as a fiduciary, or his spouse or minor child residing in his household, has a financial interest in the subject matter in controversy or in a party to the proceeding, or any other interest that could be substantially affected by the outcome of the proceeding;

    Although if ‘glee’ is ‘expressing an opinion concerning the merits of the case in controversy.’ for Mr Foster, his definitions are rather kooky, so maybe these words don’t mean the same thing to him as it does the rest of us.

    Apparently being a well-paid participant in the subject matter in controversy is entirely a ‘political’ interest.

    • TerryF98

      You have to ask yourself WHY Justice Thomas stopped reporting his wife’s income, why stop doing something he had previously done?

    • josebrwn

      28 U.S.C. 455 (b)(4)

      smoke, meet fire.

  • Houndentenor

    For years groups have been bribing Clarence Thomas by giving money to his wife. Their failure to report $100,000 in bribe money should have been enough to force him to resign. There’s no excusing this. Making excuses for Thomas while going after Kagan just makes you a partisan hack. There is a case to made for Kagan’s recusal but it pales in comparison to Thomas being a corrupt public official who should be thrown out on his ass.

    • armstp

      I agree, at this point it is not just about a recusal because of the ACA, but is should be about throwing Thomas out of the SCOTUS entirely. He should be thrown-out/impeached period.

    • LFC

      “But, but, but … he’s on MY team!”

      – The Scholarly Howard Foster

  • icarusr

    “There is simply no basis to dispute that she was a governmental official at the relevant time, expressed her opinion about the law, and therefore, ‘participated as counsel concerning the proceeding.’” (emphases added)

    I confess I am not a US lawyer, nor do I know much about the various conflict of interest rules the apply to federal judges.

    Premise one: from what I understand (first week of law school was a long time ago), there are three sorts of “opinion”: personal, legal and juridical. A personal opinion is what it is and no more: “The ACA is a f**king big deal.” A legal opinion delivered by a lawyer expresses that lawyer’s legal views on the subject: “the ACA is crap, but in my legal judgement, arguments exist to justify it as constitutional.” And then there is the opinion juridical, which does not concern us right now.

    What we know is that Kagan expressed a “personal” opinion on the ACA (the sum total of the “opinion” about the “law”, was an expression of “glee” (what a f**king sexist thing to say) about its passage). What we also know is that she was not in a position to offer a legal opinion and, in fact, she did not do so.

    Premise two: It is my understanding (small brain and all – could be wrong on this) that there are two sorts of “counsel”: the counsel personal and counsel legal, but that, in the ordinary sense of the word, and in particular when the word is used in legislation in the context of judicial proceedings, the word “counsel” implies “legal counsel giving legal opinions on the substance of the proceedings.”

    Here’s the curious thing. On the basis of this expression of a personal opinion, Kagan is held by the writer of this learned article to have ‘participated as counsel concerning the proceeding.’ Now, this demonstrates one of two things. Either the good man has no idea what “opinion” and “counsel” mean, in which case he really should go back to law school, or just jump from the Sears Tower, as the most honorable thing to do in the fact of this embarrassing demonstration of ignorance. Or he knows and simply lies in order to besmirch the character of a judge with whom he disagrees, in which case not only he, but the Forum that hired him to write this, should be pillories and tarred and feathered – and run out of town, riding an ass backward.

    Just sayin’.

    • indy

      The definition is even narrower: the opinion expressed must be concerning the merits of the case in controversy.

      Glee is expressing an opinion on the legal merits of the case?

    • balconesfault

      What is frustrating is that while Foster seems to be responding to critics of his earlier piece – I had written:

      The question – which Mr. Foster either wishes us to ignore, or is simply too poor a lawyer to pick up in the midst of his haste to condemn – did Ms. Kagan express an opinion in her capacity as a government employee? Since “expressing glee” was probably not part of her job description, I would say no.

      He does not even attempt to address this point, which was made as clear as a 2×4 in the face. Rather, he just goes right back to it. Which does begin to suggest that he is fundamentally incapable of understanding it, blinded by partisanship as he is.

  • Graychin

    OK – I’m not a lawyer, so my comment isn’t going to be “lawyerly.” (This kind of condescension is one reason why people hate the legal profession almost as much as they hate Congress.)

    That said – does “appearance of impropriety” mean nothing? Nothing at all? How would you like to be the defendant before a highly-opinionated judge whose wife is employed by your opposing plaintiff?

  • Demosthenes

    I just want to note how amusing it is that Foster has been so completely and thoroughly dismantled. And now thanks to indy citing the U.S. Code (there was a great video a while back that had FOX attributing the relevant quote from “U.S.C.” to the “U.S. Constitution”) we have a “lawyerly” response as well.

    Really, the only way you could genuinely believe Thomas above suspicion while demanding Kagan to recuse herself would be by inhabiting an alternate dimension where up is down.

    • heap

      belief is kinda a flexible term – i don’t think anyone believes it in a sense comparable to ‘i believe the sun will rise tomorrow’, but believe it in a sense comparable to ‘i believe this is the best case i can make’…yah, i can see that.

      this is ‘both sides are bad, so don’t recuse republicans’ writ large. and poorly.

  • blueshark

    “and that she personally participated as Solicitor General in formulating a response to the challenges to the constitutionality of the law.”

    Well, I read those emails and I cannot see how the author arrives at this conclusion. What does emerge from them is that Kagan appointed (then) deputy SG Neal Katyal to deal with it, and Katyal makes it absolutely clear that Kagan had been isolated from the strategic preparations made in contemplation of future litigation right from the very start.

  • esmoore

    To Mr Foster: This article is intellectual dishonesty, pure and simple. Others here have made all the points I could make, so I won’t repeat them, but you should really examine why it is you write.

    The the Administrators of the Frum Forum:
    I am a lifelong conservative who broke from the GOP at some point during GWB’s first term. I could not handle the intellectual dishonesty and party members putting politics ahead of the good of the country. Both parties are guilty of this, but the GOP is much worse than their Democratic counterparts. When I discovered Frum Forum several months ago, I was ecstatic to find an intelligent conservative voice. Even if I don’t agree with many of the opinions expressed here, I believe that, for the most part, the writers and especially the readers are intellectually honest, educated, and able to look past party lines to see the merits of an argument, no matter who made it. This place has been a candle in the dark for me.

    But articles like this taint this mostly excellent forum. Not because I disagree with their premise (I often disagree with the writers here, but don’t have the same reaction) but because they are partisan crap spouted by an intellectually dishonest person.

    I think that Frum and whoever else is responsible for choosing content should consider more carefully the writers that they deem to be worthy of writing here. This article and those like it (see: any of the ignorant vitriol spouted by Sean Linnane) are a smelly s**tstain on this otherwise excellent collection of intelligent conservative writing. They take the forum from an A+ to a B-, and anything C or below is not worth reading or recommending.

  • Nanotek

    just so the inherent nature of conservative hypocrisy is clear…

    “In 2000, the Supreme Court had to decide whether to accept an expedited review of a district judge’s ruling against Microsoft. Chief Justice Rehnquist’s son James is a Boston lawyer who was helping to defend Microsoft in a separate, private antitrust case. Nonetheless, Justice Rehnquist refused to recuse himself…”

    “These general standards apply to Justices Scalia and Thomas in the particular case of Bush v. Gore.

    “Let’s start with Justice Scalia. At the time when Bush v. Gore came before the SupremeCourt, Justice Scalia’s son Eugene, age 37, was a partner in the Washington office of Gibson, Dunn,and Crutcher. Another partner in the same firm was Theodore B. Olson, the attorney who twice had argued before the Supreme Court on behalf of Bush.

    Anotherof Justice Scalia’s sons, John, age 35, had accepted a job offer in the Washington office of Greenberg Traurig. A partner in that firm’s Tallahassee office is Barry S. Richard,who represented Bush in Florida.”

    http://sites.duke.edu/wsa/papers/files/2011/05/wsa-recusalandbushvgore2002.pdf

  • Solo4114

    Surely this must be satire.

  • valkayec

    It’s obvious Foster’s continuous diatribe against Kagan is hyper partisanship. I continue to come to this forum because it, more than most other sites, offers less partisan commentary on the GOP…and those commenting on the posts are quite often even better than the original blog post.

    However, in the case of Foster, I cannot decide whether to boycott his posts simply because of his hyper-partisanship, hypocrisy and poor arguments or to continue to point out the logical fallacies of his arguments so non-commenting readers don’t take his view as generally accepted or correct.

    I don’t expect Frum Forum to go all lefty, but I’d surely appreciate a highly level of non-partisanship and expertise on complex issues from which to form my own opinions.

      • Primrose

        I couldn’t be bothered to read yet another Kagen should recuse post on the forum from people who defend Scalia’s refusal to do so repeatedly and defend Thomas even though his wife has taken money lobbying on that side.

  • Ray_Harwick

    The “glee” argument.

    NEXT!

  • josebrwn

    You don’t have to speak in a “lawlerly manner” to see that Thomas’ impartiality might reasonably be questioned.

    You also don’t have to be particularly “lawlerly” to understand that this debate isn’t about right and wrong. It’s just another moot debate in an endless tribal war.

    How tiresome.

  • Ogemaniac

    This “skin in the game” is so weak that by that standard, every American would have too much “skin in the game” to judge the case.

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