It's Not Going to Be Popular to Say This Around Some Circles, But the Supreme Court Did the Right Thing in Striking Down the U.S. District Court's Attempt to Alter Wisconsin's Voting Framework

I don't think it's any secret that I don't like Donald Trump.  He's got an authoritarian streak, he can't stand criticism, and he does try to grab power he doesn't have.  But, I'm not going to join those who have a knee-jerk reaction every time some branch of the U.S. Government takes an action or makes a decision that has the effect of decreasing the opportunities to cast or count votes and claim that it's part of some vast right-wing conspiracy to suppress the vote and keep Trump in power.  There are times when lower courts, in an effort to do what the trial judge subjectively thinks is the morally right, overstep their authority.  When that happens, the Supreme Court is within its authority to remind those lower courts that they need to work within the framework of the law and the Constitution.  Among those constitutional principles that is important to uphold are the separation of powers and federalism.  This is why the Supreme Court's decision on Monday, April 6th,addressing the election in the State of Wisconsin, although poorly written, was the right thing to do.

The Supreme Court's decision did not elaborate on the facts too well.  For that, I had to go back to the decision of the U.S. District Court for the Western District of Wisconsin dated April 2, 2020.  That decision addresses three consolidated cases, in all of which the plaintiffs challenge Wisconsin's election framework, within the context of the current COVID-19 crisis.

The entire world is the middle of a pandemic, from a virus which heretofore had not been identified, and had not infected humans.  That is SARS-CoV2, which many have been identifying by using the shorthand, the coronavirus.  It is actually just one, and indeed the newest, of many different types of coronaviruses, which, unfortunately, is confusing some people.  The virus causes the disease that the World Health Organization calls COVID-19.  COIVD-19 appears to cause mild symptoms in the vast majority of people.  But in some people, it can cause serious respiratory issues, and death.  There is some dispute over the death rate, but it appears to be between 1% and 3%, which is a much higher death rate than the flu.  In addition, the virus appears to be more contagious than the flu.  Because humans have not developed natural immunity to this virus yet, and because we currently do not have a vaccine against the virus, it has swept across the globe.  With the first case in humans being identified in December of 2019, as of the time of writing, over 1.2 million people have been infected worldwide.  Over 72,000 people have died from COVID-19.

COVID-19 has the potential to overwhelm the medical resources throughout the world.  The recommendation of medical professionals has been to isolate those who have the virus, quarantine those who have come in contact with those who have the virus, and generally practice social distancing and safe personal hygiene for everyone else.  Governors across the United States have issued stay-at-home orders, to prevent people from congregating and giving the virus more opportunities to spread.  Surfaces are being cleaned more often, and people are being advised to wash their hands often, to wear masks in public and to try not to touch their faces.  Most importantly, medical professionals have advised that we avoid large public gatherings.

However, this is an election year in the United States.  In November, Americans will go to the polls to either to choose a new president, or re-elect President Trump.  This spring, we are in the midst of primary season.  That is, the separate states and territories are holding primaries or caucuses to nominate the Democratic candidate for president.  In some states, they are holding elections for local and state offices at the same time as the primaries.  The COVID-19 crisis has caused numerous states who had elections scheduled for April to postpone them, or to expand the opportunity for mail-in absentee ballots, due to the risk of spreading the virus.  Wisconsin is not one of those states.

Wisconsin scheduled its election to be held on April 7, 2020 long before the current crisis. More well over a month, the Governor has been calling on the Wisconsin Legislature to postpone the election, or make it easier for people to cast mail-in absentee ballots.  The Legislature has not responded.  Meanwhile, because so many election workers are over the age of sixty, a category who is at a high risk of developing the severe symptoms of COVID-19, the rise in absentee ballots as well as opening the polls for the regular in-person voting, threatened to overwhelm Wisconsin election officials.  Many voters requested absentee ballots in the last month leading up to Election Day.  It was almost certain that thousands of applicants would not receive their absentee ballots before Election Day.

This is the situation where the U.S. District Court found itself.  Three different lawsuit lawsuits were filed to do something about the Wisconsin election, such as extending deadlines, and waiving witness requirements for mail-in ballots.  Under Wisconsin election law, ballots had to be received by April 7th in order to be counted.  Wisconsin law also gave the municipal canvassing boards until April 13th to certify the vote count to the counties.  The District Court, in a decision entitled Democratic National Committee, et al., v. Marge Bastelmann, et. al., issued a preliminary injunction which, among other things, permitted absentee ballots received by April 13th to be counted, regardless of when the ballots were postmarked.  A party submitted a request to stay the preliminary injunction (i.e. to prevent the injunction from taking effect) to Supreme Court Justice Brett Kavanaugh (submitting such a request to a Justice on the Supreme Court is normal Court procedure), who in turn referred the matter to the full Court.  In a decision that pitted the five conservative members of the Court against the four liberal members, the majority issued a per curiam opinion, meaning the five member majority spoke as one, granting the stay of the preliminary injunction.  The sole issue for the Court was whether the District Court overstepped its authority by permitting ballots postmarked after April 7th to be counted so long as they were received by April 13th.  That is, the Supreme Court permitted Wisconsin to continue to count ballots received by April 13th, so long as they were postmarked by Election Day, April 7th.

Many liberal pundits saw the Supreme Court's action as one of intentional voter suppression, aimed specifically at helping the Republican Party, and in particular Donald Trump, stay in power once the November presidential and congressional elections come around.

I read the Supreme Court's decision much differently.

Let me be clear, I am all in favor of taking action now to prepare for the November elections, and the possibility that the current crisis may still be around.  I, too, have some fear that Trump and the Republican Party may take some action that may negatively affect the elections.  After all, not only did Russia interfere in his favor in 2016, Trump has already been impeached for seeking Ukrainian interference in the 2020 election.  The only thing that saved him from removal was the fact that the Republicans control the Senate, and Senate Majority Leader Mitch McConnell made sure that the Senate trial was a farce with no witnesses being called at all.  I would love it if state legislatures acted now to address the November elections to expand the availability of early voting and mail-in voting just in case the coronavirus still has us sheltering in our homes at that time.

But let's be clear on some things.  Trump has no authority to do anything directly to change, postpone or cancel the November elections.  There is nothing in the Constitution, or any of the numerous federal statutes addressing the president's emergency powers that grant the president such authority.  How the November elections are to be run is a matter for the people of the several states, through their legislatures, to address.  Many Trump opponents fear he will nonetheless attempt to use the declaration of a national emergency to seize a power that is otherwise not granted to the presidency.

Yet, as I read the U.S. District Court decision, I noticed that the very thing that Trump's critics fear that he will do in the abstract, grab power that he doesn't have, is exactly what the District Court did.  In its opinion, the District Court essentially states, "There is a crisis out there that nobody is doing anything about, so I'm going to create a solution, whole cloth, despite their being no statute or constitutional provision giving me the authority to do so."  It is quite amazingly.  The decision is bereft of any citation to law or constitutional provision giving it the authority to interfere and fundamentally alter Wisconsin's election framework.  The District just says, "Voting is a fundamental right, so here's what you need to do."  That is, the District Court just assumed that it had the authority to make its own deadlines and impose them upon Wisconsin's state government as a whole.  Put another way, the U.S. District Court thought that it could act as if it were a legislature.

Again, if Trump had done this, those very same liberal pundits complaining about the Supreme Court would be up in arms over Trump's action.

Our Constitution engages in a dispersion of powers among not only the three branches of government, but also between the federal government and the government of the several states.  This is known as separation of powers when it refers to the three branches of the federal government, and federalism when it refers to the division of powers between the federal government and the governments of the several states.  They are the fundamental principles upon which our system of government is created, in order to avoid any one part of the government becoming too powerful and acting tyrannically.  In this regard, a court that oversteps its authority can be just as tyrannical as an authoritative executive.  The Supreme Court was absolutely within in prerogative to slap down a decision by a U.S. District Court that overstepped its power.

The lesson is two-fold.  First, all branches of government need to respect the limits placed on their authority by the Constitution.  Second, the state legislatures, as the law-making branch of government in their respective states, need to address the November elections now, before it becomes a crisis where well-intentioned courts will feel obligated to step in, regardless of the limits on judicial power.

By:  William J. Kovatch, Jr.

References

For general facts about the virus, I referred to the World Health Organization's website.

Information can also be found on the Centers for Disease Control's website.

The U.S. Supreme Court Decision can be found here:  Republican National Committee, et al., v. Democratic National Committee, et al., Slip Op. Crt. No. 19A1016 (U.S. Supreme Court April 6, 2020).

The U.S. District Court decision can be found here:  Democratic National Committee, et al., v. Marge Bostelmann, et al., Slip Op. Crt. No. 20-cv-249-wmc (W.D. Wis. April 2, 2020).

Johnson, Jake, "'One of the Most Brazen Acts of Voter Suppression in Modern Times,' as US Supreme Court Blocks Absentee Ballot Extension in Wisconsin," Common Dreams (April 7, 2020).

Liptak, Adam, "Supreme Court Blocks Extended Voting in Wisconsin," The New York Times (April 6, 2020).

Litman, Leah, "The Supreme Court's Wisconsin Decision Is a Terrible Sign for November," The Atlantic (April 7, 2020).

Perrett, Connor, "'Voter suppression on steroids': Wisconsin's decision tohold the state's in-person primary amid the COVID-19 pandemic will suppressvoters, advocates warn," Business Insider (April 7, 2020).

Stern, Mark Joseph, "The Supreme Court's Wisconsin Election Decision is 2020's Bush v. Gore," Slate (April 7, 2020).

Trump's Narcissistic Desire to Use the Border Wall to Cement his Legacy Has Created a Cruel and Unnecessary Government Crisis

Two and a half weeks into the partial government has given Americans yet another opportunity to assess the leadership skills, or lack thereof, of its current President, Donald Trump.  While I am not a psychologist and don’t claim to be making a clinical diagnosis, Trump’s refusal to sign a budget that doesn’t appropriate $5.7 billion for a wall on the US-Mexico border only further shows his dangerously narcissistic tendencies.

 

Like many narcissists, Trump is manipulative.  He has shown his character for taking advantage of people’s weaknesses for his own benefit.  For example, all during the presidential campaign Trump insisted that not only would he build a wall, but that Mexico would pay for it.  Having Mexico pay for the wall was never even a remote possibility.  But the claim won him cheers ad accolades from his supporters.  Now that it is clear that Mexico will not be paying for the wall, Trump is manipulating the ignorance of trade agreements and how tariffs work among his supporters to make the claim that Mexico really will be paying for the wall.

 

Trump argues that by scrapping NAFTA and concluding the United States-Mexico-Canada Agreement (USMCA), Mexico will be paying for the wall through tariffs paid to the United States.  Let’s breakdown the inaccuracies of this claim.  USMCA did not really scrap NAFTA.  Rather, it built upon NAFTA structures to adjust some of the agreed upon tariff rates.  In fact, trade agreements are not really a vehicle for a country to raise revenue.  Government typical enter into trade agreements to try to open more markets for its exporters by having their counterparts lower their tariffs.  The United States attempted to open more markets for US agricultural goods, for example, by getting Canada and Mexico to lower their tariff rates.

 

At any rate, governments do not pay tariffs.  Importers do.  Importers need to make a profit, so they typically pass the tariffs of to the consumer in the form of higher prices.  Even where US tariffs increase, Mexico will not be footing the bill.  US consumers will.

 

Moreover, USMCA is not yet part of US law.  To become US law, Congress will have to act.  Either 2/3 of the Senate must ratify it as a treaty, or both Houses of Congress must approve implementing legislation, just as they did for NAFTA.  Until Congress acts, the USMCA has no effect on US law.

 

However, many Americans lack the very specific knowledge of how trade agreements and tariffs work.  Trump is manipulating that ignorance to make it appear as though he is living up to his campaign promise.

 

Trump is attempting to  manipulate the racially-based fears of his supporters to support his refusal to sign legislation to fund the Government unless he gets his wall.  In defending his desire for a wall, Trump cherry-picks cases where heinous crimes were committed by undocumented aliens.  In doing so, Trump creates the impression that all undocumented aliens are violent criminals.  This is consistent with his claims during the campaign that Mexicans are rapists and murders.  He and his supporters ignore statistics showing aliens, including undocumented aliens, commit fewer crimes than native born US citizens.

 

Trump has demonstrated a complete lack of empathy for those adversely affected by the shutdown.  Indeed, through some of his public statements, Trump appears to be saying that those suffering because of the shutdown are getting what they deserve because of their lack of support for him.  He has tried to change lexicon of the debate, calling the shutdown a “strike” in closed door sessions with congressional leaders, as if to shift the blame on the governmental employees.  He has noted that most of the workers furloughed or working without pay are Democrats, as if to say that they deserve what they get for supporting the opposition party.  He has shown little concern for the 800,000 who may be going without a paycheck.  Moreover, he has given no attention to the government contractors, who will not only be going without a paycheck, but who, unlike government employees, will not receive back pay.

 

This is another example of Trump’s manipulation of the ignorance of his supporters.  Many of his supporters, who do not understand how government works, have been quick to argue that since only non-essential employees are being furloughed, it shows the government is too big and ought to be cut.

 

The fact is, Trump is using an immoral tactic essentially to extort something he wants, but for which there is little support, for the sake of creating his legacy.  A government shutdown is immoral because it adversely affects people who have no role to play in the debate over the border wall.  Government employees risk falling behind in mortgage payments, utility bills and other bills because of a lack of a paycheck.  Some employees risk losing health insurance for dependents.

 

Yet, it is being viewed as simply just another tactic to get something out of Congress despite fierce resistance.  The last government shutdown, for example, was forced upon the United States by the Tea Party, who demanded the showdown over funding the Affordable Care Act.  Because the Tea Party saw that as a successful demonstration of its power, it has become just another arrow in the Republicans’ quiver.

 

It is particularly egregious where polls have shown that a majority of Americans oppose the border wall.  In fact, Trump clearly made tough immigration enforcement a hallmark of his message in the mid-term elections, which resulted in the Democrats taking control of the House of Representatives.  Yet, while Republicans like to point out that elections have consequences, they refuse to accept the consequences of losing the House, which include a lack of political support for the wall.

 

Trump has ignored all of this, just so he can push for the wall to have tangible proof of his legacy in American history.  The shutdown is a very selfish use of an immoral tactic for something that does not have strong public support.

 

Indeed, Trump’s mistake is that he has failed to learn from history.  There is strong and vocal support for the wall among hard core Trump supporters.  Trump has chosen to play to his base by projecting an image of being tough on immigration enforcement.  But, Trump engaged in the same tactic leading up to the mid-terms.  He used news coverage of a large group of Central Americans traveling together through Mexico in an attempt to apply for asylum in the United States to incite fear among his supporters of the caravan.  He labeled Democrats as soft on immigration enforcement and supporters of open borders.  In the end, his party lost the majority in the House, giving Democrats a power base upon which to oppose the President.  There is no reason to believe that playing to his base will be any more successful here.

 

As usual, Trump has made this dispute about him.  While he attempts to avoid responsibility now, claiming Democrats won’t give him what he wants, he can’t escape that the government shut-down has real world adverse consequences on people who have nothing to do with immigration policy.  Because Trump is such a wild card, there is no way of telling whether he will back down and attempt to paint it as a victory, or let the shut-down drag on and continue to cause widespread pain.  One can only hope that Trump can overcome his stubborn streak, agree to legislation to re-open the government, and continue to negotiate immigration reform without holding the welfare of government employees hostage.

 

By:  William J. Kovatch, Jr.

What Does the New Democratic Majority in the House Mean for Immigration Reform

With Democrats winning a large number of seats to wrestle control of the House of Representatives away from Republicans, what will that mean for immigration reform?

Immigration reform was considered a “second term” issue for the Obama Administration, meaning that while President Obama saw the need for reform, he focused on issues that he saw as a greater priority in his first term, such as health care reform. When serious legislation addressing such topics as the millions of undocumented aliens already present in the United States, it fell victim to the Tea Party, a coalition of radical right-wing Republicans who gained power through gerrymandering, or the creation of congressional districts with strong conservative populations. The Tea Party flexed its muscle by forcing a government shut down over the funding of the Affordable Care Act, and thus discovered that it had the power to influence Republican House leaders to turn against immigration reform, branding any proposal other than enforcing the laws already on the books as amnesty. Hope for a legislative fix for the nation’s immigration problems died in President Obama’s second term. 

But President Obama did not allow legislative gridlock to hamper his desire to pursue immigration reform. Using solely executive action, President Obama reformed the nation’s deportation policy by ordering Immigration and Customs Enforcement (ICE) to prioritize deportation cases involving dangerous criminals. In a policy called “prosecutorial discretion,” the President had ICE agree to the administrative closure of those cases that were not in line with the new priorities. 

Similarly, by executive order, the President created a new program known as Deferred Action for Childhood Arrivals, or DACA.  Deferred action is merely a promise by the Executive Branch not to seek the deportation of an alien present in the country without legal authority. Through DACA, President Obama gave relief to undocumented aliens who were brought to the United States as children, who had a US high school diploma, were working on education or who joined the military, and who did not a significant criminal record. Using his legal authority pursuant to the Immigration and Nationality Act, he then granted those people who qualified for DACA the authority to work legally in the United States. 

The problem with pursuing immigration reform purely by executive action and without congressional action was that President Obama could not grant undocumented aliens a secure legal immigration status. Those who benefitted from prosecutorial discretion and DACA, therefore, were left vulnerable to a change in the presidential administration. 

That change came in 2016, when Republican Donald Trump won the presidency through an Electoral College victory over Democrat Hillary Clinton. Trump had run on a hard-line immigration approach of strict enforcement to be highlighted by building a wall along the southern border to be paid for by Mexico. 

Once in office, the stark contrast between President Obama’s view of immigration reform, and that of President Trump became evident. Emphasizing that even crossing the border without a visa was a criminal act, President Trump changed ICE’s enforcement priorities to include all aliens present in the country without legal authority. ICE began enforcement actions that heretofore had been unthinkable, such as immigration arrests being made in school parking lots, outside hypothermia shelters and in the halls of state courthouses where domestic abuse victims sought protection. 

Other executive action taken by the Trump Administration included the exclusion of aliens from certain countries deemed to be dangerous by the Administration from entering the United States, most of which were Muslim countries, instructing Immigration Judges not to resolve deportation cases through administrative closure, instructing Immigration Judges that in the Attorney General’s view victims of domestic abuse and gang violence did not qualify for the legal protection of asylum, and the rescission of DACA.  

Indeed, legislation proposals demonstrated that the Trump Administration’s definition of immigration reform was far more harsh than that of the Obama Administration. Gone was the idea that reform should provide benefit to those were in the country without authorization.  It was replaced with a drive to contract family based immigration, and to discourage immigration from places the President considered “shit-hole countries.”

The difference between Democratic and Republican priorities in reforming the nation’s immigration laws could not greater. 

President Trump created a crisis for foreign-born young people with his decision to rescind DACA. Although the courts have intervened, preventing the program from ending, DACA recipients find their legal status fragile and their future uncertain. He has insisted that a legislative fix was necessary. Meanwhile, he has bemoaned the efficacy of current immigration law, demonizing groups of Central Americans making the dangerous trek northward in the hopes of applying for asylum as potential gang members and terrorists. He has insisted that any legislative efforts to address the DACA crisis also include greater border security measures (such as the funding of the border wall), the curtailment of family based immigration, and the elimination of a program meant to create greater diversity in those who immigrate to the United States (that is, the annual diversity visa lottery).

Surely, with court action currently protecting DACA recipients, and the vast difference between the parties on immigration issues, it seems highly unlikely that the newly elected Democratic House majority will agree to the Trump Administration’s demands for harsher and more restrictive immigration reforms. Barring intervention on DACA by the Supreme Court, any hope for legislative action to be taken in the next two years on immigration reform would appear to be folly. That is, only if the Supreme Court were to accept a case involving DACA, and side with the President, would there be any pressure on the Democrats to find some common ground on immigration in order to protect a sympathetic group of law abiding young people. Even then, the price may be so high that the Democrats would prefer to have the issue front and center for the 2020 presidential election. 

This continued inaction on addressing the nation’s immigration problems may set-up the issue of immigration reform as an powerful issue going into the next round of federal elections.

By: William J. Kovatch, Jr. 

As Attorney General, Jeff Sessions Can Have Substantial Influence Over the Law of Deporrtation ans emoval

On Friday, President-Elect Donald Trump announced that Alabama Senator Jeff Sessions was his choice to serve as Attorney General.  Sessions has made it clear that he is anti-immigration.  Not anti-illegal immigration.  He is anti-immigration.  Painting with a wide brush, Sessions has made broad statements concerning the desirability of immigrants from the Dominican Republic, for example, claiming Dominicans as a class file fraudulent visa petition and that they have no provable skills that would benefit the United States.  Indeed, he has made statements that immigration -- legal immigration -- has been harmful to the United States.

The question arises as to exactly what influence Sessions would have over immigration policy if he were confirmed as Attorney General.  The answer is that the influence can be considerable, particularly with respect to immigration policy in deportation and removal cases.

The Department of Justice does not have the day to day responsibility for enforcing and administering the immigration law of the United States.  That role belongs to the Department of Homeland Security.  But this doe not mean that the Department of Justice has no say or influence over how immigration law is interpreted and enforced.

First the Department of Justice is responsible for representing the United States in litigation before the U.S. courts.  This means that the Justice Department, through the Office of the U.S. Attorney, assesses litigation risk and advises the agency being sued. 

This can mean that the Justice Department injects a bit of reasonableness when an agency is being sued.  The U.S. Attorney's Office can advise an agency that its action is not likely to convince a judge.  In this way, the Justice Department can subtly influence agency policy.

But the Justice Department can also agree to take a more extreme litigation position, thereby encouraging an agency to push the boundaries of the law.

The more important role that the Department of Justice plays in U.S. immigration law is through the operation of the administrative courts used to enforce the deportation and removal law.

Contrary to what many people believe, the U.S. Government cannot simply pick up a person who is present in the country in violation of the immigration law and deport him or her.  The U.S. Constitution guarantees the right to due process of law.  That is, it has to be proven that a person does not have legal status in the United States or that the person has violated that status by, for example, committing a crime.  Then, even if a person is present in the United States in violation of the immigration law, there may still be legal grounds for relief to allow that person to stay, such as asylum law.  Some entity has to make determination.

The entity that makes that determination is the Executive Office of Immigration Review (EOIR), which is housed by the Department of Justice.  The EOIR consists of the first level trial courts, that is the Immigration Courts, and the appellate body, known as the Board of Immigration Appeals (BIA).

In the first place, the Attorney General influences how immigration law is interpreted and enforced through the power of appointment and supervision.  The Attorney General appoints the Immigration Judges, the Members of the BIA, the Chief Immigration Judge and the Chair of the BIA.  Thus, so long as the people appointed meet the minimum requirements of competency, the Attorney General can be sure to appoint people who will interpret immigration law congruent with his thinking.  The EOIR also ensures of the training of Immigration Judges and BIA Members.  Such training programs can be used to subtly influence how the law is viewed and interpreted.

More importantly, by developing case law, the BIA, and indeed the Attorney General, can issue opinions binding on Immigration Judges in similar cases.  The BIA publishes its case decisions.  The BIA can vote to make a decision precedential, which means it announces an interpretation of the law that is binding on Immigration Judges.  The Attorney General may also decide to take jurisdiction over a case on appeal, and issue a decision announcing an interpretation of the law that is precedential.  Indeed, if the Attorney General takes jurisdiction over the case, he does not need to give the parties to the case an opportunity to brief the issues before him.

This power has been used in the past, for example, to define what constitutes a crime involving moral turpitude.  This can be an issue where a state criminal law defines an offense so broadly that it can include both behavior that is morally reprehensible, and behavior that isn't. 

This is the case with assault and battery.  To be considered a crime involving moral turpitude, assault and battery must be a crime of violence.  But, in many states, assault and battery can include a mere unwanted touching, such as a tap on the shoulder.  Moreover, when a defendant pleads guilty, the plea agreement may be worded so as to avoid admitting to actions that would constitute a crime of violence.  This leaves Immigration Judges in a tough position in determining if the conviction before them is actually a deportable offense or not.

In this situation, the Attorney General took jurisdiction over a case, and announced a rule that Immigration Judges could look beyond the record of conviction to determine if an assault and battery is a crime of violence, and thus a crime involving moral turpitude.  The Attorney General's decision permitted the Immigration Judge to go so far as to make conclusions based on the police report.  This particular rule was then the subject of extensive legislation, and has since been withdrawn by a successive Attorney General decision.

Nonetheless, the Attorney General can have substantial sway over immigration law as it applies to deportation and removal cases.  Given Sessions' history, I would expect that immigration law as it applies to deportation and removal cases will be interpreted more harshly.  Indeed, I would even expect interpretations that are constitutionally questionable for the sole purpose of pushing the envelope and seeing if the courts permit it.

By:  William J. Kovatch, Jr.
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