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Originally Processed With FOIA(s): FOIA Number: 1998-0207-F 1998-0207-F FOIA MARKER This is not a textual record. This is used as an administrative marker by the George Bush Presidential Library Staff. Record Group/Collection: George H.W. Bush Presidential Records Collection/Office of Origin: Cabinet Affairs, White House Office of Series: Blumenthal, Gary, Files Subseries: OA/ID Number: 07790 Folder ID Number: 07790-033 Folder Title: Judge Clarence Thomas [1] Stack: Row: Section: Shelf: Position: G 10 6 1 1 THE WHITE HOUSE WASHINGTON August 20, 1991 MEMORANDUM FOR CABINET AND AGENCY CONTACTS FROM: GARY BLUMENTHAL Mary SUBJECT: Additional Materials on Clarence Thomas Attached are additional materials on Supreme Court nominee Clarence Thomas. These materials were assembled to help summarize Judge Thomas' legal perspective. Therefore, you may wish to share this specific packet with your general counsel. Attachment MATERIALS ON NOMINATION OF JUDGE CLARENCE THOMAS TO THE UNITED STATES SUPREME COURT PERSONAL WEDNESDAY, JULY 17, 1991 Climb the Jagged Mountain The truth of the matter IS we nave excuses. The women who worked in By Clarence Thomas become more interested in designer those kitchens and waited on the bus jeans and break dancing than we are knew It was prejudice which caused in obligations and responsibilities. their plight, but that didn't stop them grew up here in Savannah. I Over the past 15 years. I have from working. I was born not far from nere (in watched as others have jumped My grandfather knew why his busi- Pinpoint). I am a child of quickly at the opportunity to make ness wasn't more successful. but that those marshes. a son of this excuses for black Americans. It IS didn't stop him from getting up at 2 in soil. I am a descendant of the said that blacks cannot start busi- the morning 10 carry ice. wood and slaves whose labors made the nesses because of discrimination. But fuel oil. Sure. they knew it was bad. dark soil of the South productive. I I remember businesses on East They knew all too well that they were am the great-great-grandson of a Broad and West Broad that were run held back by prejudice. But they freed slave. whose enslavement con- in spite of bigotry. It IS said that we weren't pinned down by it. They tinued after my birth. I am the prod- can't learn because of bigotry. But I fought discrimination under W.W. uct of hatred and love the hatred of know for a fact that tens of thousands Law (a Georgia civil rights leader| the social and political structure of blacks were educated at historical- and the N.A.A.C.P. Equally impor- which dominated the segregated. hate-filled city of my youth. and the ly black colleges. in spite of discrimi- tant, they fought against the awful nation. We learned to read in spite of effects of prejudice by doing all they love of some people - my mother. segregated libraries. We built homes could do in spite of this obstacle. my grandparents. my neighbors and in spite of segregated neighborhoods. relatives - wno said by their actions. We learned how to play basketball hey could still send "You can make it. but first you must (and did we ever learn!). even though their children to endure." we couldn't go to the N.B.A. T school. They could still You can survive. but first you must respect and help each endure. You can live, but first you We have lost something. We look other. They could still must endure. You must endure the moderate their use of for role models in all the wrong unfairness. You must endure the ha- places. We refuse to reach back in our alcohol. They could still be decent, tred. You must endure the bigotry. not too distant past for the lessons law-abiding citizens. You must endure the segregation. and values we need to carry us into I had the benefit of people who You must endure the indignities. the uncertain future. We ignore what knew they had to walk a straighter I stand before you as one who had has permitted blacks in this country line, climb a taller mountain and car- the same beginning as yourselves 10 survive the brutality of slavery and ry a heavier load. They took all that as one who has walked a little farther the bitter rejection of segregation. We segregation and prejudice would al- down the road. climbed a little higher overlook the reality of positive values low them and at the same time fought up the mountain. I come back to you, and run to the mirage of promises. to remove these awful barriers. who must now travel this road and You all have a much tougher road visions and dreams. climb this jagged, steep mountain I dare not come to this city, which to travel. Not only do you have to that hes ahead. I return as a messen- contend with the ever-present big- ger - a front-runner, a scout. What only two decades ago clung so tena- clously to segregation. bigotry and otry, you must do so with a recent lies ahead of you IS even tougher than Jim Crowism. to convince you of the tradition that almost requires you to what IS now behind you. fairness of this society. My memory wallow in excuses. You now have a That mean. callous world out there IS 100 precise. my recollection too popular national rhetoric which says IS still very much filled with discrimi- keen. to venture down that path of that you can't learn because of rac- nation. it still holds out a different life self-delusion. I am not blind to our ism. you can't raise the babies you for those who do not happen to be the history - nor do I turn a deaf ear to make because of racism. you can't right race or the right sex. It is a the pleas and cries of black Ameri- get up in the mornings because of world in which the "haves" continue cans. Often I must struggle to contain racism. You commit crimes because 10 reap more dividends than the my outrage at what has happened to of racism. Unlike me. you must not "have-nots." black Americans - what continues to only overcome the repressiveness of You will enter a world in which more than one-half of all black chil- happen - what we let happen and racism, you must also overcome the lure of excuses. You have twice the what we do to ourselves. dren are born primarily to youthful If 1 let myself go. I would rage in job I had. mothers and out of wedlock. You will the words of Frederick Douglass: Do not be lured by sirens and pur- enter a world in which the black teen- "At a time like this. scorching irony. veyors of misery who profit from age unemployment rate as always IS not convincing argument. IS needed. constantly regurgitating all that IS more than double that of white teen- Oh! Had I the ability, and could reach wrong with black Americans and agers. Any discrimination, like sharp the nation's ear. 1 would today pour blaming these problems on others. Do turns in a road. becomes critical be- out a fiery stream of biting ridicule not succumb to this temptation of cause of the tremendous speed at blasting reproach. withering sarcasm always blaming others. which we are traveling into the high- and stern rebuke. For it IS not light Do not become obsessed with all tech world of a service economy. that IS needed. but fire: It IS not the that IS wrong with our race. Rather, There IS a tendency among young, become obsessed with looking for so- upwardly mobile. intelligent minor- gentle shower. but thunder. We neec the storm. the wnirlwind and the lutions to our problems. Be tolerant of alies to lorget. we forget the sweat of all positive ideas: their number IS our forefathers. We forget the blood earthquake." much smaller than the countless of the marchers. the prayers and I often hear rosy platitudes about number of problems to be solved. We hope of our race. We forget who this country - much of which IS true. But how are we black Americans to need all the hope we can get orought us into this world. We over- feel when we have so little in a land Most importantly, draw on that 100K wno put 1000 in our mouths and clothes on our backs. We forget com- with so much? How IS black America great lesson and those positive role mitment to excellence. we procreate to respond to the celebration of the models who have gone down this road before us. He are Daogered and with pleasure and retreat from the wonders of this great nation? In 1964. when 1 entered the semi- pushed by our imenus and peers to do responsibilities of the babies we nary. I was the only black in my class unlike our parents and grandparents produce. - we are told not to be old-fashioned. We subdue. we seduce. but we don't and one of two in the school. A year later, I was the only one in the school. But they have weathered the storm. respect ourselves. our women. our babies. How do we expect a race that Not a day passed that I was not It is up to us now to learn how. Countless nours 01 research are spent has been thrown into the gutter of pricked by prejudice. But I had an advantage over black to determine why blacks fail or why socio-economic indicators to rise students and kids today. I had never we commit crimes. Why can't we above these humiliating circum- stances if we hide from responsibility heard any excuses made. Nor had I spend a few hours learning now those seen my role models take comfort in closest to us have survived and for our own destiny? helped us get this far? ahead and taken a long. hard look. I have seen two roads from my perch a few humble feet above the madding crowd. On the first, a race of people is rushing mindlessly down a highway of sweet, intoxicating destruction, with all its bright lights and grand promises constructed by social scien- tists and politicians. To the side, there is a seldom used, overgrown road leading through the valley of life with all its pitfalls and obstacles. It is the road - the old-fashioned road - traveled by those who endured slav- ery, who endured Jim Crowism, who endured hatred. It is the road that might reward hard work and disci- pline, that might reward intelligence, that might be fair and provide equal opportunity. But there are no guaran- tees. You must choose. The lure of the highway is seductive and enticing. But the destruction is certain. To travel the road of hope and opportuni- ty is hard and difficult, but there is a chance that you might somehow, some way, with the help of God, make it. 1.) 150rt AUGUST 6, 1991 Margaret Bush Wilson The NAACP Is Wrong on Thomas The young man standing at my door that Some have said that despite his chairmanship He promised he would, and Judge Thomas has summer day in 1974 looked like an African of the Equal Employment Opportunity Commis- been keeping his word ever since, looking out for prince. "Hello, I'm Clarence Thomas," be said. T sion for eight years, he has not been a champion the vulnerable and victimized on the job, in the ow," I replied. I've been expecting you." And of civil rights. Those people obviously don't know community and at the court. I know that as a began a friendship with someone I think of Judge Thomas or the real facts about his tenure Supreme Court justice Clarence Thomas will ndly as a second son. with the EEOC. His record will speak for itself continue to defend and protect the rights of the I first heard of young Thomas (then almost 26) and will impress those willing to listen and look needy. He does not permit anyone to think for from his employer-to-be, Sen. John Danforth beyond misinformed rhetoric. On a personal him, and be is intellectually honest. (R-Mo.), who was attorney general of Missouri at the time. Mr. Danforth told me he had just hired level, be knows the struggle and hardship blacks When the history of these times is written, it a bright young law graduate from Yale and asked and the impoverished of every race grapple with will be interesting to see how historians view the daily-not to mention the plight of most families, position of the National Board of the NAACP- if I knew of a place the young man could live for the summer while studying for the Missouri bar. since in my judgment the central issue of our an organization committed to advancing colored time is that some 82 percent of the families in people, which is opposed, on ideological grounds, My own son, Robert, was then a law student with plans to work that summer in Washington. I these United States have no discretionary income to this nomination of a black man to the U.S. after bills and taxes are paid. Supreme Court. invited young Clarence to stay in my son's empty room. We didn't talk much about Judge Thomas's Let the record show that the NAACP's former I don't recall seeing another young person as background that summer 17 years ago, so it is national board chair respectfully disagrees with disciplined as Clarence Thomas. First thing, only recently that I have learned about his its position. every day, be would exercise with my son's humble beginnings. The cramped house with no The writer, an attorney in St. Louis, chaired weights and then be off to his studies. I asked of plumbing in rural Georgia, his wise but not learned grandparents, the Catholic nuns and the the National Board of Directors of the him only one thing: I would prepare dinner, and be would show up on time. We would eat rest have only recently come into full view for National Association for the Advancement together every night, often with one or two me. To rise above the dual curses of poverty and of Colored People from 1975 to 1984. friends or relatives and talk about any and all of discrimination requires tremendous individual ef- the problems of the world. fort from a special kind of person, help from We didn't always agree (Clarence was "con- others and luck. All these have been present in servative" even then), but I was impressed con- Judge Thomas's career. tinually with one so young whose reasoning was Throughout the history of the U.S. Supreme so sound. I must also admit that his arguments, Court, I don't believe any other nominee can both legal and logical, forced me to rethink some claim to have come so far. In point of fact, Judge of my own views. I know I sometimes made him Thomas's unique perspective belongs not only on see things differently, too, because Clarence the Supreme Court but in the legislature, in the Thomas knew how to listen as well as talk. work place, at city hall and on our campuses. TOSS the years, I have kept in touch with No one can deny that Judge Thomas would Thomas, and to this day I respect his differ with Justice Thurgood Marshall on some grity, his legal mind and his determination. issues. I don't always agree with the justice Even when we disagree, I have found him to be a myself. I do believe that both men show a sensitive and compassionate person trying to do common, fundamental belief in the inherent what is right, working to make the world a better worth and rights of the individual. At one of his place. four previous Senate confirmation hearings. Back then I sensed that he would one day be in Judge Thomas said. "The reason I became a a position to have a larger impact, but I had no lawyer was to make sure that minorities, individ- way of knowing that this determined young man unis who did not have access to this society, might one day have the chance to tackle some of our country's problems on this nation's highest gained access. I may differ with others on how best to do that, but the objective has always court. been to include those who have been excluded." Recently, the NAACP National Board took action opposing Judge Thomas's nomination. I As young Clarence Thomas left my home at wish it had withheld judgment until after the the end of the summer, be asked how much he hearings, because the Clarence Thomas I have owed for his stay. I told him that he owed me been reading about often bears little resemblance nothing, but I did want a promise from him. I to the thoughtful and caring man I have know asked him to promise that if be were ever in a over these years. position to reach out and help others that he Judge Thomas reflects the diversity and com- would do it, just as some had done for me and as I plexity of African-American thinking, but his had done for him. views are not nearly as radical as his critics suggest. He has pushed for a new frontier in civil rights, and heaven knows we need one when one-third of African Americans are still in poverty as we approach the 21st century. He seeks a climate where African Americans and other mi- norities feel empowered to compete equally with their counterparts of other races, with rational support from government programs. THE WALL STREET JOURNAL. TUESDAY. JULY 2. 1991 Liberal Praise The Marshall Seat The choice aiso will put Democrats on the defensive: Judge Thomas draws praise even from some liberals. "He has been a Bush's Court Nominee, very good colleague." says Chief Judge Abner Mikva of the appeais court here. a former Democratic congressman. Moreo- A Black Republican, ver. Democrats specifically urged the president to consider appointing a minor- Is Deft Political Choice ity-group member to fill the vacancy that was created when Thurgood Marshall an- nounced his retirement last Thursday. Judge Thomas's association with mod- Conservatives Laud Thomas: erate Republican Sen. John Danforth of Missouri. for whom he worked after his Liberals May Be Hard Put graduation from Yale Law School in 1974. will also weigh in his favor. Mr. Danforth's To Mount a Strong Attack support will help reassure many moderate Senate Democrats and Republicans. much as New Hampshire GOP Sen. Warren Rud- Grandson of a Sharecropper man's sponsorship of David Souter did af- ter President Bush nominated him last July. By STEPHEN WERMIEL While liberals will focus on Judge And PALL M. BARRETT Thomas's legal inexperience. his record on Staff Reporters of THE WALL STREET RNAL WASHINGTON-By choosing Clarence the bench doesn't present them with the Thomas. a conservative black federal sort of target they had with the articu- judge. for the Supreme Court. President lated. sharply conservative legal views of Bush may have defused a fierce political Robert Bork. whose Supreme Court nomi- nation was defeated in 1987. battle over the high court's shift to the A number of Senate Democrats. includ- right. Judge Thomas. who has been sitting on ing Judiciary Chairman Joseph Biden of the federal appeals court in Washington for Delaware. stressed when Judge Thomas just 14 months. won't be confirmed without was confirmed for the appeals court that a fight in the Senate focusing on his inex- he would face tougher scrutiny if he were perience on the bench and his strong oppo- nominated for the Supreme Court. But that sition to affirmative action. will be a difficult position to defend in light of Mr. Thomas's success last year in de- But barring damaging unforeseen reve- lations about Judge Thomas. Democrats flecting liberal criticism. will have a hard Judge Thomas's strong opposition to af- time mounting a firmative action and the abortion debate broad-based cam- will be grist for his confirmation hearings. paign against the af- "I don't know where Judge Thomas stands fable 43-year-old. on a woman's right to choose. but I intend who is smart. tough to find out." said Democratic Sen. Howard and speaks power- Metzenbaum of Ohio. who was the lone op- fully about overcom- ponent last year in the Senate Judiciary ing racism and pov- Committee's 12-to-1 approval of his appeals erty in the deep court nomination. "Women have a right to South. know whether Judge Thomas is committed "Anybody who to protecting their fundamental rights." takes him on in the Abortion and Catholicism area of civil rights is Abortion-rights groups are also likely to taking on the grand- Clarence Thomas be concerned about the fact that Judge son of a sharecrop- Thomas is a Catholic who spent a year in a per." observes conservative Republican Missouri seminary in the 1960s pondering Sen. Orrin Hatch of Utah. the priesthood. AS other Supreme Court Judge Thomas's nomination yesterday nominees have done. however. Judge got a restrained reaction from many Sen- Thomas is likely to go to great lengths to ate Democrats. Civil rights groups. too. avoid committing himself on abortion. an said they will have to study his record. issue that is expected to come before the both in his brief tenure on the appeals court again and again. court and as chairman of the Equal Em- The reaction from civil rights groups ployment Opportunity Commission during was muted. Raiph Neas. executive director the Reagan administration. of the Leadership Conference on Civil Mr. Bush's choice IS a bold political Rights. said. With so many constitutiona! move. coming in the midst of the current nehts and personal liberties a: stake. the debate over civil rights legislation and Senate must make sure Clarence Thomas quotas. The president has nominated a cas demonstrated a commitment to equal man wno would be not merely the second opportunity and equal justice under the black to serve on the Supreme Court. but a We urge the Senate no: to rush to man who embodies the ideal of personal sucgment. achievement rather than reiiance on gov- To friends and colleagues of Judge -rnment programs for a 1-0 up. Thomas. nis own life story :S the mos: compelling thing about him. With Justice Marshall retirement. CIVI! rights advo- cates worried that there would no longer said, "I firmly insist that the Constitution be anyone on the court who had exper- be interpreted in a colorblind fashion enced racial segregation. Though Judge emphasize black self-help, as opposed to Thomas may not find favor with those racial quotas and other race-conscious le groups. the fact is that he knew nothing gal devices that only further and deepen but segregation as he grew up outside Sa- the original problem." vannah. Ga., in the 1950s. Since he has been on the federal benca Born into rural poverty. he lived in a liberal and conservative legal analysts house with no bathroom until he was seven agree. the relatively few opinions he has years old. His father left when he was written don't suggest a strong ideological young. and his mother sent him to live slant. although he has tended to rule for with his grandparents. the government in criminal cases and in The grandparents raised him with strict business regulatory matters. discipline. instilling in him a strong work One highly controversial case on which ethic. and sent him to an all-black Catholic Judge Thomas sat earlier this year has ye: school run by white nuns. Yesterday. to be decided. A three-judge panel of the speaking at a news conference at Presi- appeals court is considering the constitr- dent Bush's home in Kennebunkport. tionality of a Federal Communications Maine. Mr. Thomas choked up when he Commission policy giving preference to talked about his grandparents' influence. women for broadcast licenses. The others For a moment. it appeared that he might not be able to finish his statement. He on the panel were Judges Mikva and praised them as well as "my mother and James Buckley. a conservative. The ques- the nuns. all of whom were adamant that I tions are: Will Judge Thomas use the case to once again attack affirmative action grow up to make something of myself." and will that pour fuel on his confirmation As a child. Judge Thomas said, "I could fight? not dare dream that I would ever see the Judge Thomas is well-liked by col- Supreme Court, not to mention be nomi- leagues. both at the EEOC. where the new nated to it. Indeed. my most vivid child- headquarters building is named for hirr. hood memory of the Supreme Court was and at the appeals court. the 'Impeach Earl Warren' signs which Ricky Silberman. a close friend who IS lined Highway 17 near Savannah. I didn't vice chairman of the EEOC and whose quite understand who this Earl Warren fel- husband. Laurence. sits on the appeais low was, but I knew he was in some kind of court. says: "He is a very simple persoz trouble." who loves to say he was a farm boy and The first person in his family to attend remains a farm boy." A sometime jogger college. Judge Thomas spent a year at Lm- and weightlifter. he enjoys reading and lis- maculate Conception Seminary in Concep- tening to music ranging from classical tc tion Junction. Mo., before transferring to his favorite. country singer George Holy Cross College in Worcester, Mass. Af- Jones. ter law school. he went to work for Mr. For much of his tenure at the EEOC. Danforth. who was then Missouri's attor- Mr. Thomas was a single parent. raising a ney general. son. Jamal. Some friends have expressed concern that the bitterness of the divorce After two years in the Monsanto Co. le- from his first wife could spill over into his gal department. Judge Thomas rejoined confirmation hearings. His second wife Mr. Danforth. by then a U.S. senator. He Virginia. a deputy assistant secretary a: then served for a year as chief of the U.S. the Labor Department. is white. Education Department's civil rights office before President Reagan appointed him In light of the administration's strong attack on racial quotas in hiring. Presiden: chairman of the EEOC in 1982. Bush's selection of a black man to fill Jus- His eight-year tenure at the EEOC was marked by controversy. He changed the tice Marshall's seat brought questions about whether he was in fact observing a agency's approach to de-emphasize set- quota on the court. In his press conference. tling large numbers of cases quickly. con- Mr. Bush strongly denied the very though: centrating instead on instances in which of that. insisting that race wasn't a factor specific victims of discrimination could be in the selection of Judge Thomas. identified. In age discrimination. particu- "The fact that he is black-a minor- larly. that created case backlogs that dis- ity-has nothing to do with this." the prest- tressed advocates for senior citizens. dent said. "He is the best qualified." Liberals charged that. across-the-board. Judge Thomas. who just turned 43 last the EEOC under Mr. Thomas's leadership week. would be the youngest Supreme didn't aggressively attack civil rights vio- Court justice of the past 100 years with lations. "As chairman of the EEOC. Clar- the exception of William O. Douglas, who ence Thomas failed to demonstrate a com- joined the court when he was 40. Senate mitment to civil rights and liberties." says Judiciary Committee hearings on the Nan Aron of the liberal Alliance for Jus- Thomas nomination are expected to be tice. held in September. If they go smoothly. But Mr. Thomas had strong views and Justice Thomas could be sworn in before didn't shrink from expressing them. the new Supreme Court term begins or. Rather. he seized every opportunity-in Oct. 7. cluding writing letters to editors. op-ed page articles and book reviews-to attack affirmative action as patronizing and as an ineffective remedy for discrimination. In a 1987 letter to The Wall Street Journal. he The New Hork Times VEDNESDAY. IULY 3. !991 Influence of Nuns Lives On With Court Nominee years said today that the Clarence friend and their conviction that his SAVANNAH. Ga.. July 2 - The old St. Benedict the Moor School on East Thomas they knew is not the one-di- views on racial matters, though un- mensional conservative caricature conventional. may just be right. Gordon Street here. which Clarence that some news accounts have por- "He's a controversial figure and I Thomas attended for eight years in trayed. don't agree with all his positions, but I the 1950's and 60's. has long been think he will make a superb judge," closed. a footnote to the history of seg. 'No Knee-Jerk Conservative' Mr. Guest said. "I just pray he will be regated Savannan. Its windows are They recall a young man involved confirmed." boarded up. its swings broken. its plv- with black student protests at Holy A Conservative View wood doors padlocked: the Irish nuns Cross College, a receptive student of Mr. Douglass, a criminal defense who taught there. whom some white the writings of Malcolm X, a fledgling lawyer, predicted that Judge Thomas seminarian who gave up the possibil- townspeopie called the "nigger SIS- would rule conservatively in criminal ity of a religious vocation after a ters." have ali retired to convents law and privacy cases. "Miranda IS brush with ugly racism. not going to find much comfort in elsewhere. "It had to be hard coming up as a Clarence Thomas." he said. But he But their influence. and St. Bene- black from the South into a northeast- added: "He's going to hold himself dict's. lives on in Judge Thomas. as ern white community with a heavy spiritually accountable for his deci- he quickly and regularly acknowl- population from Boston, but he didn't sions. He's not going to rule one way edges. Fourteen months ago. three of let it throw him at all." said Father or the other because of pressure. He the nuns were present when he took John E. Brooks, President of Holy came up the rough side of the moun- his seat on the United States Court of Cross in Worcester, where Judge tain. and I know he's not going to be Thomas spent his undergraduate insensitive." Appeais for the District of Columbia years as an English major. "He's not Some who have long known Judge Circuit. He mentioned the nuns again a complainer." Thomas depict a man who has lost on Monday. as ne stood beside Presi- "He's obviously not a flaming lib- touch with his roots and grown am- dent Bush in Kennebunkport. Me. eral, but he's no knee-jerk conserva- bivalent about his racial identity, a Alo with his grandparents and tive either." Father Brooks contin- one-time black nationalist keeping m he said. the nuns had been ued. "He wants to do his own think- company with conservative Republi- at that I grow up to make ing. He's not following a crowd." cans. It is an evolution that both something of myself." Judge Thomas does represent an grieves and puzzles these people. Old and fragile though they have odd, seemingly contradictory amal- "I'd like to see if the person I knew gam of influences. He bears the mark 20 years ago IS still there lodged become. Sisters Mary Carmine and of Booker T Washington whose nh. somewhere deep inside of him. and if Virgilius and Mary Daniel and Aquin the public person he's become over will undoubtedlv be invited to Wash- losophy of self-reliance was transmit- the past 15 years IS more than a ve- ington if their former student takes ted principally through Judge neer." said Lanı Guinier. who now his place on the United States Su- Thomas's grandfather. Myers Ander- teaches at the University of Pennsyl- preme Court. son, the Savannah fuel and ice dealer vania Law School. She expressed with whom he went to live at the age Whether or not the Franciscan hope that the magnitude of the Su- of 7. The better he prepared himself, nuns attended the ceremony. their preme Court would prompt Judge Mr. Anderson told his grandson, the Thomas to reflect upon and reconnect presence would certainly be felt. less dependent he would be on the himself to his roots. Their teachings are present in the white man. In the tall of 1967. Clarence Thomas defiant. almost-Darwinian conviction "Clarence always seemed like a go- and 64 other young Catholic men en- they instilled in Clarence Thomas getter, but you didn't pay too much tered Immaculate Conception Semi- that with enough hard work and attention because his grandfather nary in the nortwestern Missouri determination he could overcome was like that." said Geraldine Wil- town of Conception with the goal of quadruple handicaps: being black. fa- liams of Savannah, a long-time becoming priests. Half the students. therless. poor and Catholic in the family friend. including Mr. Thomas, left the semi- Eisenhower-era South. Then there are his current political nary after the first year. mentors, - men like Ronald Reagan, "He and I were not close friends." But the nuns' lofty ideals about George Bush, John Sununu and the said Father Benedict Neenan, a class- race. justice and tolerance inevitably Missouri Republican Senator, John C. mate who is now a Benedictine monk collided with the harsh realities of life Danforth, - who have helped make and the prior of Conception Abbey. in Savannah. Conception. Mo., him anathema to leaders of tradi- "But in a small class you observe one Worcester. Mass.. and New Haven. tional civil rights organizations. another quite a bit and I remember To black schoolmates and friends, Conn.. and the resulting disapoint- him as a very intense person. I re- ment helped make him the complex like J. Hanson Guest. a lawyer in member him as an excellent student. Hartford. and Orian Douglass. a law- man he has become: fiercely inde- When he would speak in class he yer in Brunswick. Judge Thomas's pendent. sometimes bitter. stoic, pro- knew what he was talking about and appointment is a cause for joy. What- foundly skeptical of dogmas, conven- people respected him. ever personal differences might have tions. and panaceas. "He didn't speak out a lot in class with him are overridden by two op- In ens of interviews. Judge posing forces: their loyalty to an old but when he did he spoke with ma- The friends. teachers. class- tunty and understanding and vou ma .d colleagues from his early would say. Wow. he's been thinking about this." JEGAL LOBBYING IN THE NATION'S CAPITAL week OF JULY 8, 1991 VOL. XIV, NO. 7 $8.00 Clarence Thomas: Mind and Matter How the Supreme Court Nominee Brings His Hard Life Into the Law BY TERENCE MORAN as his lawyers argued, he was young and had endured a violent, traumatic upbring- It was just another drug appeal, just ing, even watching as his mother was another lousy, losing case brought to the thrown off a roof. U.S. Court of Appeals by a kid caught No trial-court judge, Meade noted, with cocaine. would find such a tragic history unusual. The facts before the D.C. Circuit panel "Wait a minute, interjected one of the last October were judges on the panel, bearing down on the How the choice is sadly familiar. government lawyer. "Doesn't that depend playing at the José Lopez, the on where the judge is-whether he's in U.S. Courthouse. 18-year-old de- suburban Fairfax County or Washington, Page 7 fendant, had D.C.?" pleaded guilty to For a moment, the air in the courtroom Clarence Thomas carries vivid conspiracy to was charged with tension. Judge Clarence memories of American apartheid. Thomas' 'plain distribute cocaine Thomas terse, steely demand had lifted how he brings the hard life he has led to reading' of the base, and now Lopez's case out of the realm of abstrac- the law he makes, is the focus of a bur- Constitution. sought reduction tion and into the real world. geoning battle over his nomination by Verbatim, Page 8 of the stiff, 51- **It was the only question that Thomas President George Bush to the Supreme month sentence asked during the arguments, but when he Court. meted out to him Excerpts from asked it, he cut straight to the heart of the As interest groups choose sides and under federal sen- 1984 Interview. issue,' recalls Stephen Leckar, Lopez's Senate staffers pore over the nominee's tencing guide- court-appointed lawyer, who is of counsel public and private record, the search to Page 11 lines. at D.C.'s Cohen & White. "After it hap- capture the essential character of the man, Assistant U.S. pened, I kind of smiled inwardly and to limn the mind of Clarence Thomas, has Attorney James Meade made the gov- thought, 'There's one vote for reality. begun in earnest. It won't be easy. emment's routine response that morning, Leckar was right-the panel unexpect- Willfully iconoclastic, gleefully ec- urging the judges to give great deference edly found for his client-but his com- lectic, Thomas defies categorization. He is to the guidelines. There was no need to ment resonates beyond his case. For the lessen Lopez's sentence simply because, question of Clarence Thomas' reality, of SEE THOMAS, PAGE 10 THOMAS FROM PAGE that conflict. The harsh questions that an advocate of limited government who have always been flung at Thomas-how has recommended sweeping federal power a black man could strictly construe a to punish discriminators. He is a devotee Constitution that enshrined slavery, or go of original intent in reading the Constitu- to work for Ronald Reagan, a president tion who also asserts that the open-ended whose blithe ignorance of the black concept of natural law is the basis of that American experience is legendary-are bound to come to a head when the Senate intent. He's a teetotaling Republican who drives a black Corvette. Judiciary Committee holds hearings on his Among his favorite recordings are the nomination after Labor Day. vintage sides of country music legend "These confirmation hearings are more Hank Williams and the collected speeches important than any I can remember,' says of Malcolm X. He loves the cowboy ro- Andrew Popper, a professor at American mances of Louis L'Amour and quotes University's Washington College of Law. Thomas Aquinas' Summa Theologica. He "Are we going to see the Clarence Thomas who believes the Constitution is is a private man who has lived a very pub- lic life. racially blind and who has indicated dis- "I don't fit in with whites, and I don't favor with any type of aggressive af- fit in with blacks," Thomas once told Le. firmative action, or are we going to see the Clarence Thomas who is sensitive to con- gai Times. "We're a mixed-up genera- tion, those of us who were sent out to in- cerns of race and poverty?" tegrate society." (For excerpts from the Thomas does not necessarily recognize 1984 interview, see Page 11.) a conflict in those stands, a view that Wrestling with that confusion has been puzzles and angers many civil-rights activists. the central drama of Thomas' public life. At the heart of all of his work in politics But the 43-year-old former Roman Catholic seminarian is more than a civil- and in the law is an evolving intellectual struggle to reconcile his deeply held con- rights curiosity. His views on a host of is- ve values with his firsthand experi- sues, ranging from unenumerated rights to antitrust law. reveal a social critic who poverty and injustice. ever this philosophical journey looks constantly to the verities and values Thomas, people who know him say of the past to address the pressing ques- that he will carry with him those vivid tions of the present. childhood memories of American apart- Take Thomas' approach to the problems beid. of the poor. Time and again over the Judge Clarence Thomas joins President George Bush in Maine July 1. "I grew up under state-enforced segre- years, Thomas has scathingly criticized gation, which is as close to totalitarianism government welfare programs as a kind of and 'right from wrong' were of the highest ued. "They were a way of life; they as I would like to get," Thomas said in a slow poison at work in the black commu- priority. Crime, welfare, slothfulness, and marked the path of survival: and the es- 1987 speech to the Heritage Foundation. nity, generating a culture of dependency alcohol were enemies. cape route from squalor. My household, notwithstanding the that has touched his own family. "But these were not issues to be de- For more than a decade, Thomas has myth fabricated by experts, was strong, Thomas' response to this trend has been bated by keen intellects. bellowed about been in the vanguard of a counter- stable, and conservative. God was by rousing orators, or dissected by poll- revolution in civil-rights law. and his central. School, discipline, hard work, sters and researchers,' Thomas contin- nomination has sparked a decisive bartle in SEE THOMAS, PAGE 11 THOMAS FROM PAGE 10 to advocate a return to such old-fashioned Clarence Thomas Sounds Off virtues as self-reliance and neighborliness. Many of his friends and colleagues insist that this constantly reiterated plea for Supreme Court nominee Clarence Thomas is anything but reticent. In 1984, 19 months community is not mere rhetoric; Thomas after President Ronald Reagan appointed Thomas chairman of the Equal Employment walks the walk. Opportunity Commission, Legal Times interviewed him. He sounded off-sometimes "Once or twice a week, he would come into my office and tell me about somebody quite bluntly-on a variety of topics. The following are excerpts from that interview: he had met in the elevator or out on the street, somebody he wanted us to help,' On whether he was tailoring his views on civil rights to On refusing to toe the line: recalls Pamela Talkin, a member of the win a second term at the EEOC: "I'm a Dallas Cowboys fan. I love unpopular causes." Federal Labor Relations Authority who "I'm not going to lobby for this job. This job has kicked *ked as Thomas' chief of staff during my ass, and you can quote me on that You don't just On how the media react to him: nure as chair at the Equal Employee ask for more pain." "Here's a strange black. Let's go see if he has two heads tunity Commission. "He was al- and tail." looking for the person he could pull On his political allies in Washington: up. "I don't fit in with whites, and I don't fit in with blacks. On why the government should not be the guarantor of Jill Mack knows. A 58-year-old collec- We're in a mixed-up generation-those of us who were sent civil rights: tion agent with the EEOC, Mack remem- out to integrate society. If it were not for [the] few "In order to be free, you have to be independent. bers the day Thomas struck up a conver- friends I have who do not give a damn about this stuff, this People keep trying to sell me sugar-coated dependency, and sation with her in the file room shortly af- place could drive me insane." I'm not going to buy it. The [Reagan] administration is bon- ter she arrived at the agency. Before com- est. It's about time we got some honesty [instead of] people ing to the EEOC, she had spent many On racial polarity in Washington: smiling in your face. We're playing games with our- years working on her feet in restaurants. "T've showed up in some of the nicest places in this city. selves if we think suddenly, overnight, this national gov- developing phlebitis in her legs. She was You walk in one of the top-of-the-line restaurants, people emment is going to care for us." also having some difficulty meeting other look at you like you're out of your mind. In my own demands of her new job. neighborhood, I used to get "He told me he was from Georgia," On being true to his own beliefs: stopped by the cops." "I will be me. recalls Mack. "I'm from Georgia, 100, If [William Bradford Reynolds] gets and I used to sharecrop down there. We on my nerves, I will argue with Brad. If the Civil Rights On promoting greater racial talked about working on the farm, picking Commission gets on my nerves, I will argue with them. And harmony: cotton, pulling corn, you know. He really if can't stand the heat, I'll get out of the kitchen.' "You don't see anyone trying encouraged me-he put in a good word to integrate marriages, do you? with my supervisor, stopped by my desk That would solve everything. On being black in the North vs. the South: all the time, helped me get a little training. "h was more difficult for me to live in Massachusetts than "He was always real nice," adds On civil-rights activists: it was for me to live in Savannah. In Savannah, the rules Mack, who has since been promoted. "I "They don't know what the were indeed clear. think he likes to see his people trying to bell I am. They have their ac- help themselves." cepted version of what the world On being interviewed by private law firms upon gradue- Discrimination's Impact should be like.' tion from Tale Law School in 1974: Thomas' fundamental conservatism "They would always want to talk to me about doing pro "What offends me is the civil-rights community saying bono work. stems from his well-documented upbring- Here I was, really labored over tax and I'm not black. I may disagree with [then Assistant Attorney ing in Pin Point, Georgia. The traditions they always wanted me to throw in pro bono. They've got to General William Bradford Reynolds] and the Justice De- of the rural South-which as recently as say something black to me." partment, but they don't offend me. 1910 was home to more than 90 percent of all American blacks-lend Thomas' views why he goes to church any day but Sunday: On being rick: the patina of 19th-century optimism that "I don't like people that much. God is all right. It's the "I have no doubt I'm going to be wealthy, so I don't worry endears him to conservatives and alienates people I don't like. about it. I'll write a book that will sell for $19.95." him from liberals. But it is the more immediate experience cial discrimination in his own life that fused many of Thomas' positions deep-seated bitterness. The prej- his most adventurous excursion in the law, nature that precede any social compact-is machinery. The Justice Department fought he has encountered and the respon- into the murky. metaphysical territory of deeply rooted in Roman Catholic teach- the merger, asserting that it would leave sibilities he held at the EEOC have led natural law and its relationship to the ing. Thomas found the tradition alive and the U.S. market with too few suppliers Thomas to develop an extremely tough Constitution. well in the lives and writings of such and that new competitors would find it too law-enforcement approach to anti- In the mid-1980s, as Thomas began to Americans as Abraham Lincoln and difficult to enter the market. discrimination laws, an approach that formulate more ambitious expressions of Frederick Douglass. (See "Verbatim," Thomas, in the July 1990 opinion, would probably shock many conservatives his philosophy, he turned toward the tra- Page shredded the government's case so thor- and libertarians. dition of natural law to inform his reading "For a long period of time, he read oughly that Solicitor General Kenneth During his tenure at the helm of the of American history. The ancient con- everything by or about Abe Lincoln,' Starr has decided not to file an appeal. EEOC, Thomas was fiercely criticized for cept-which holds that there are inherent, recalls Talkin, Thomas' EEOC chief of The enthusiastic manner with which de-emphasizing systemic attacks on em- immutable principles of right and wrong in staff from 1986 to 1989. "He would really Thomas has embraced his work on the ployers whose work forces were under- ponder these things-he's the kind of circuit reflects his basic enjoyment of the representative of minorities and women. person who literally loses sleep over dif- intellectual challenges of the bench. He This policy battle dominated the media ficult philosophical issues." goes out of his way to hire clerks who coverage of the EEOC, obscuring the tack Thomas' foray into natural rights en- disagree with him, and he assigns all of his Thomas tried to take. abled him to find a way of reading the cases to all of his clerks, just to watch the In rejecting most broad-based group Constitution in the light of an expanded sparks fly. remedies to discrimination, Thomas pur- version of "original intent." It also led "He likes his clerks to fight it out." sued policies that sought to investigate him, Talkin says, to wrestle with the says Clint Bolick of the Landmark Legal thoroughly and vindicate fully every gen- thomy issue of unenumerated rights in the Foundation, a friend and ideological uine, individual discrimination complaint. Constitution. soulmate of Thomas'. "He really enjoys His success on that score has been "He would try to figure out whether working with some of the best young contested. privacy is encompassed by the Constitu- minds around." Some of his proposals to carry out his tion, what uncnumerated rights are, where The intellectual combat Thomas thrives policy-such as appointing special mas- abortion fits in." says Talkin, who de- on should stand him in good stead when be ters to take over a company's personnel scribes herself as a liberal Democrat. "I faces the Senate, in what promises to be a department-are far from the laissez faire honestly believe he's still thinking about grueling confirmation. That struggle will policies that other conservatives prefer. all this, and that he recognizes his personal in part be an effort to gel Clarence Thomas "There are tougher means of deter- views and subjugates those to what the law to define himself and his beliefs to the rence. Thomas wrote in a 1987 article requires.' country. He has passionately resisted such for the Yale Law and Policy Review. "One Thomas is clearly still thinking about a efforts to pigeonhole him in the past and such approach would be for courts to im- lot of things. His tenure on the D.C. Cir- will probably put up a fight in September. pose heavy fines and even jail sentences cuit has allowed him to return to the world But Thomas' compelling personal his- on discriminators who defy court in- of business law that he left years ago to tory, which informs so much of his in- junctions against further discrimination. fight the Reagan administration's civil- tellectual questing, is certain to leave a "I am not aware of any case where a rights battles, and friends say he relishes lasting impression, no matter what hap- court has resorted to such measures, and I the change. pens to his nomination. must wonder why they are so reluctant,' Perhaps the most important decision He never forgot where he came Thomas continued. "To those of us who that Thomas, if confirmed, will leave with from," says Jill Mack, the EEOC collec- der employment discrimination not the D.C. Circuit is his careful, com- tion agent whom Thomas encouraged. nlawful but also a moral abomi- prehensive analysis of horizontal mergers "I'm not talking about Republican, and such measures are altogether in United States V. Baker Hughes. I'm not talking Democrat. He's Georgia. The case, brought by the Bush admin- just like me. That righteous note, echoed in many of Clint Bolick says Thomas enjoys istration's Justice Department, challenged -Reporters Daniel Klaidman and Anne Thomas' writings on race, is the source for having his clerks debate cases. a merger of two manufacturers of drilling Kornhauser contributed to this story. colleagues like Poldine L. Otto and Wounded by Discrimination and the college IS now coeducational. Richard Wieler have of Mr. Thomas. Some classmates were baffled by During Mr. Thomas S senior year. the only black then serving in the of. Mr. Thomas's decision to leave Con- several students protested the cam- fice of the Missouri Altorney General. ception. But Tom O'Brien. a close pus recruitment of students by Gen- It was there ne went after Yale friend whose nome in Kansas City eral Electric because of its military Law School. Between 1974 and 1977. Mr. Thomas oiten visited on week- work. When the administration ex- Mr. Thomas handled felony appeais ends. said. "I think Clarence exper- pelled some protesters. about half and represented the Revenue Depart- enced some real discrimination were black: the majority of protest- ment in tax cases. He also was the there." Mr. O'Brien. now a high ers had been white. lawyer for the Human Rights Com- school teacher of American history. Almost every black student. includ- mission. handling JOD discrimination added: "He didn't go into names or matters. ing Mr. Thomas. walked off campus specifics. but It was real and he was until the administration reinstated His most celebrated case in the torn up a little talking about it. I know those expelled. Father LaBran said. memory of the then-Attorney Gen- he was torn up about It and I was cral and now United States Senator. Stanley E. Grayson, a former shocked. I just couldn't see It. I felt Mr. Danforth, involved a dispute over like such a fool being so close and deputy mavor of New York City, was low-number license plates. distrib- a friend of Mr. Thomas at Holy Cross, being oblivious to It." uted by past Democratic Governors where they were both active in- the Mr. Thomas later told several black student union. as political favors. black friends about the incident that Mr. Danforth. a Republican. recalls "Clarence was always an independ- some believe pushed him into leaving. suggesting that Mr. Thomas acknowi- cnt thinker." Mr. Grayson said. "He On April 4. 1968, the day Rev. Dr. edge the political reality that a lot of was the type who was going to look at Martin Luther King Jr. was assassi- a set of circumstances and reach his important people. like judges. had the nated in Memphis, a group of stu- vanity plates and wanted to keep own conclusions. And I think that dents were watching television cover- them. He suggested his aide let the probably exists today." age of the event. MMr. Thomas heard case die. Mr. Grayson said that when he one white student remark. "That's Mr. Thomas refused. another Dan- started at Holy Cross there were what they should do to all the nig- forth aide recalled. saving he would about 32 black students at the college, gers." drop the case only if ordered to do so. which was going through a "time of Jerry M. Hunter. general counsel because "this IS the law." The courts heightened sensitivitv.' for the National Labor Relations agreed. finding there was no author- "II was a time of adjustment for Board. said of Mr. Thomas: "He re- ity in Missouri law for the special the school and, candidly, for many of members thinking, 'We're supposed plates. and he won. The Legislature , be people of God. If people have us." he said. "It was a predominantly has since restored vanity plates for Irish Catholic college that was in the at view here. then this is not a place drivers willing to pay a special fee. or me to be.' Mr. Hunter and Mr. midst of change. And the black stu- Alex Netchvolodoff. a long-time Thomas met as fellow lawyers in St. dent union became a useful sounding Danforth assistant who IS now vice Louis in the late 1970's. board for initiatives. The student president for government affairs of Mr. O'Brien said he was surprised union united us." Cox Enterprises in Washington. re- to hear Judge Thomas labeled as a Mr. Thomas was as involved in the called Mr. Thomas telling him of hid- protests as anyone. Mr. Grayson said. ing in the back of his classes at Holy conservative. After all. he said. this 'Clarence was always a leader. not a Cross and Yale. explaining "I didn't was the same fellow who. as a college follower." want anyone to see my blackness. I student. used to end his letters with the slogan Power to the people." Father LaBran said he was elated wanted them to judge my work." "Conservatives and liberals may at Judge Thomas appointment to Mr. Netchvolodoff tells of Mr. Dan- both be surprised if he makes It onto the High Court. "I hoped it would be forth's recruiting Mr. Thomas at the court." Mr. O'Brien said. "Clar- Clarence." he said. "This country Yale Law School. where "he was a ence Thomas IS absolute integrity. needs a man like him who, I hope. will star." Mr. Netchvolodoff said the law He's honest. he's courageous. I can't be a symbol of all people." student actually "interviewed us." In Missouri in the mid-70's a Con- asking If he would get good cases and imagine him belying his own system of beliefs for anything." federate flag was usually a redneck enough work. political statement. But on the wall Chris Brewster. another colleague Mr. Thomas transferred to Holy behind the desk of a new Assistant At- then and now a Washington attorney, Cross in Worcester, Mass. He and torney General in Jefferson City, it recalled Mr. Thomas describing the most of the handful of other black stu- was a wry declaration of individual- pay as "$11,000 a year and all the dents were housed together in Healey ity. In effect, It meant: "Don't pigeon- gruel he could eat." Dormitory, named for the a black hole me." And Mr. Brewster said his friend Roman Catholic bishop. said the Rev. That's the most vivid memory old never shared his interest in movies. Joseph J. LaBran. who IS still a resi- because "he grew UD not going to dence counselor at the college. The movies much. All the first-run movies administration thought that placing were in the white-run movie houses the students together would help and you had to sit in the balcony" if them find support in the overwhelm- you were plack in Georgia. He said ingly white school. he said. But the Mr. Thomas lust would not 20. dormitory has since been integrated Gov. John Ashcroit. who snared an office with Mr. Thomas for 16 months. called him a candid. frank individual wno was a very hard work- er." JUDICIAL THE WALL STREET JOURNAL. JULY 3, 1991 The Views of Justice Thomas, According to Judge Thoma court by giving special-interest groups- one more chance to explain its deci- The opinions on public policy he held before he joined the bench are getting a lot and occasionally even dolphins and trees- sion. (Tennessee Gas Pipeline v. FERC) standing to sue. Judge Thomas took the One case at first glance seems to raise of attention. but the best way to predict more traditional approach in a partial dis- constitutional questions, but turns out to be how Justice Clarence Thomas would rule is to review how Judge Clarence Thomas has sent when a ferry company challenged an more limited. Federal workers asked for a ruled. In his year on the federal appeals exemption from a regulation that the Inter- preliminary injunction against a recent state Commerce Commission granted to law that bars them from accepting pay- court in Washington, Judge Thomas wrote one of its competitors. ment for articles or speeches. This raises 19 opinions. His political enemies won't Judge Thomas wrote in a partial dissent free speech and property rights questions, find much grist in these rulings, which are textbook examples of judicial restraint. that the ferry company had no business in but Judge Thomas's opinion was limited to The cases deal with issues as diverse as court because it wasn't the "aggrieved" whether the trial court was right to deny a party, as required by the statute regulat- preliminary injunction. He agreed that the Rule of Law ing litigation involving the ICC. The com- plaintiffs did not risk irreparable harm by pany wanted the judges to force the ICC to waiting for the trial court to rule on the prepare an environmental impact state- case's merits. (NTEU v. U.S.) By L. Gordon Crovitz ment before granting new routes to its A pair of business cases discloses a so- competitor. "I agree that as a matter of phisticated ap- policy, it probably should," Judge Thomas proach. He ruled an airport for Toledo, searches of crack wrote. "As a matter of law, however, the against a Justice dealers and a spat over dog-food claims. Commission has no power to regulate fer- Department claim ries for environmental reasons." that a merger in the What is most important is the approach This meant the ferry company had no market for under- Judge Thomas took. In interpreting stat- utes and precedents, he used close reason- standing to sue, so judges had no right to ground drilling rigs ing and shunned any search for shadows, hear the case. "When federal jurisdiction would violate the an- titrust laws. The penumbra or emanations. does not exist, federal judges have no au- The case challenging the expansion of thority to exercise it, even if everyone- merger between a the Toledo airport asked whether the Fed- judges, parties, members of the public- Finnish company eral Aviation Authority complied with all wants the dispute resolved," he wrote. "A and a French sub- federal court may not decide cases when it sidiary of a Texas the environmental regulations before ap- proving the new plans. The plaintiffs in- cannot decide cases, and must determine firm would give the voked the broadly worded National Envi- whether it can before it may." This is an company a large ronmental Policy Act. In upholding most of important statement of separation of U.S. market share, Clarence Thomas powers-not the view of a justice who but Judge Thomas applied the Chicago the FAA's action. Judge Thomas showed a would take social questions away from the School jurisprudence that now guides the keen wit. He wrote. "Just as NEPA is not a green Magna Carta, federal judges are political branches of government. (Cross- Supreme Court. Contrary to the Justice not the barons at Runnymede." He said Sound Ferry Services v. ICC) Department's big-is-bad approach, he that judges enforce the law "by ensuring Judge Thomas also showed his judicial ruled that a large market share does not restraint in a case of ineptitude by the by itself signal barriers to entry for new that agencies comply with NEPA's proce- dures. and not by trying to coax agency Federal Energy Regulatory Commission. competitors. (U.S. v. Baker Hughes) Judges have repeatedly ruled that regula- Another case arose when two pet-food decision makers to reach certain results." tors used arbitrary calculations to deter- companies exchanged nasty accusations of (Citizens Against Burlington v. Busey) His most important constitutional ruling mine the proper rate of return for a Ten- misleading advertising-one dog food was on the doctrine of standing. which is nessee gas pipeline. Judge Thomas warned claimed it prevented hip disease, the other FERC that he was tempted to grant the claimed it was preferred by more veteri- a key limit to judicial activism. The Con- pipeline company's request for a certain narians. Judge Thomas reversed part of a stitution requires a case or controversy be- rate. But, he wrote, "legitimate concerns damage award because there was no fore judges can issue an opinion: there must be real parties with real legal issues. about judicial overreaching always mili- "finding of willfullness or bad faith." as Judicial activists often wave non-cases into tate in favor of affording the agency just required by the false-advertising statute. This emphasis on bad intent, often over- looked in securities and environmental cases, is an important limit on liability. (ALPO v. Ralston Purina) Seven of Judge Thomas's opinions were appeals from drug cases; as a justice, he will have some notion of what it is the po- lice are up against. Most of these cases were requests by defense lawyers for a judge to find some technical problem with a search, seizure or confession, which Judge Thomas refused. In one case, the de- fendants tried to throw a gym bag contain- ing crack into a sewer when the police ap- proached. Other seizures included beepers, a favorite tool of the drug trade. Judge Thomas referred to one neighborhood as "an open-air drug bazaar." His close reading of a statute led him to reverse part of a criminal conviction of a dealer named Keith Long. The police used a search warrant to find cocaine, butane torches for processing the drug and large amounts of cash. They also discovered a revolver between the cushions of a sofa. A jury convicted the defendant on the drug charges, but also under a law against using or carrying a weapon in drug traf- ficking. Judge Thomas reversed the firearm - conviction. He said the prosecution reason- ing went too far: "Long was connected to the drugs; the distribution of the drugs was facilitated by the gun; since Long thus derived benefit from the gun, he 'used' it. He rejected this view, saying it would mean "that the word 'use' has no discerni- ble boundaries." Judge Thomas is a conservative judge, if this means that he views his job as inter- preting the law and not making it up or ruling for or against parties based on who they are. A 30-year period of judicial activ- ism from the Supreme Court is now des- tined to end. Even liberals should be able. to resolve themselves to a Justice Thomas, who would know his job is the law and not politics. PAGE 101 14TH CASE of Level 1 printed in FULL format. Cross-Sound Ferry Services, Inc., petitioner V. Interstate Commerce Commission and United States of America, respondents and Viking Starship, Inc., intervenor No. 90-1053 UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT 1991 U.S. App. LEXIS 8977 November 28, 1990, Argued May 10, 1991, Decided RIOR HISTORY: [*1] etition for Review of an Order of the Interstate Commerce Commission. DUNSEL: Eugene D. Gulland for petitioner. Craig M. Keats, Attorney, Interstate Commerce Commission, with whom Robert S. ırk, General Counsel, Henri F. Rush, Deputy General Counsel and Evelyn G. itay, Attorney, Interstate Commerce Commission, and James F. Rill, Assistant :torney General, Catherine G. O'Sullivan and David Seidman, Attorneys, epartment of Justice, were on the brief, for respondents. ward D. Greenberg and Mark T. Priesing were on the brief for intervenor. IDSES: Mikva, Chief Judge, Williams and Thomas, Circuit Judges. Opinion for e Court filed by Chief Judge Mikva. Opinion concurring in part and concurring 1 the denial of the petition for review filed by Circuit Judge Clarence Thomas. 'INIONBY: MIKVA INION: In this case, we revisit the propriety of the Interstate Commerce mmission's ("ICC" or the "Commission") finding that certain water carrier rvices provided by intervenor Viking Starship, Inc. ("Viking") are ferry rvices exempt from ICC regulation. In Cross-Sound Ferry Servs., Inc. V. ICC, 3 F.2d 395 (D.C. Cir. 1989) [hereinafter Cross-Sound I], [*2] we remanded r further clarification of the Commission's views as to the scope of the ferry emption. After reviewing the Commission's decision on remand, Viking Starship, c., Common Carrier Application, 6 I.C.C.2d 228 (1989) [hereinafter Viking II], d the contentions of petitioner Cross-Sound Ferry Services, Inc. Cross-Sound"), we conclude that the Commission has not changed its policy with spect to the ferry exemption. Accordingly, we uphold the Commission's finding at Viking is an exempt ferry service, and reject Cross-Sound's procedural allenges to the Commission's decisionmaking process. In addition, we find that e Commission's decision did not trigger environmental review responsibilities der the National Environmental Policy Act or the Coastal Zone Management Act. I. Tn 1988, the Commission granted Viking temporary authority to transport gers over two routes in Long Island Sound: (1) Montauk, New York to PAGE 102 1991 U.S. App. LEXIS 8977, *2 oton/New London, Connecticut, and 2) Montauk to Block Island, Rhode Island. e Cross-Sound I, 873 F.2d at 396 (describing statutory basis for temporary tr izations). Relying on a provision of the Interstate [*3] Commerce Act a clares transportation provided "by a ferry" to be exempt from the nm.sion's jurisdiction, see 49 U.S.C. @ 10544 (a) (4) (1988), Viking osequently asked the Commission to dismiss its application for a permanent cense on the ground that its operations are exempt ferry services. >ss-Sound, which transports passengers, automobiles, and freight between ient Point, New York and New London, challenged Viking's claim, but, as :ailed in Cross-Sound I, 873 F.2d at 396-400, the Commission agreed with ting that its operations are exempt. See Viking Starship, Inc. - Common rier Application, 4 I.C.C.2d 634 (1988) [hereinafter Viking I]. Reviewing Viking I, we acknowledged the Commission's "great latitude in termining the scope of the ferry exemption,' Cross-Sound I, 873 F.2d at 398, : found ourselves unable to discern the Commission's interpretation. Id. at 1. We noted several ICC decisions asserting jurisdiction over apparently ilar Long Island Sound routes, and suggested that the discrepancy between se cases and the Viking decision were "prima facie evidence [*4] of a nge in ICC policy." Id. at 399. In addition, we expressed uncertainty about significance of various factors the Commission uses to determine whether the ry exemption applies, such as the length and directness of a carrier's route the frequency of service. Id. at 399-400. Given these perceived ambiguities, remanded "for a fuller exegesis of the Commission's views. Id. at 396. Although it acknowledged on remand that prior decisions may have misconstrued significance of certain factors flagged by the court in Cross-Sound I, see : II, 6 I.C.C.2d at 237 (referring to role of absolute distance), the ion denied changing its view of the ferry exemption, id. @t 233 n.8. It tinguished the Long Island Sound cases we cited in our panel opinion, id., explained in greater detail the factors it uses to determine what stitutes a ferry, id. at 235-40. After discussing the general contours of the ry exemption, the Commission specifically reaffirmed its earlier finding that ing's services qualify as exempt ferriage under section 10544 (a) (4). [*5] at 241-46. In addition, the Commission rejected Cross-Sound's claim that a ision exempting Viking from the Commission's jurisdiction nonetheless igated the ICC to comply with environmental review procedures under the ional Environmental Policy Act and the Coastal Zone Management Act. Id. at -49. II. In order to determine whether the Commission has complied with our mandate in ss-Sound I, we must evaluate the sufficiency of the Commission's explanations Viking II as to the scope of the ferry exemption. If we find that the ICC's :ent view of the ferry exemption "diverges from agency precedent," then, in er to uphold the new interpretation, we must also find that the Commission oplied a reasoned analysis indicating that prior policies and standards are g deliberately changed, not casually ignored.' See Hall V. McLaughlin, 864 I 868, 872 (D.C. Cir. 1989) (quoting Greater Boston Television Corp. V. FCC, F.2d 841, 852 (D.C. Cir. 1970), cert. denied, 403 U.S. 923 (1971) ) see also r Vehicle Mfrs. Ass'n V. State Farm Mutual Auto. Ins. Co., 463 U.S. 29, 57 3). [*6] If, on the other hand, we determine that the Commission "has in fact diverged from past decisions, [then] the need for a comprehensive licit statement of its current rationale is less pressing." Hall, 864 PAGE 103 1991 U.S. App. LEXIS 8977, *6 2d at 872. The agency's explanation in such a case "need not be elaborate"; we ill uphold its findings, "though of less than ideal clarity, if the agency's at ay reasonably be discerned." Id. at 872-73 (quoting Greater Boston e. sion, 444 F.2d at 851). etitioner contends that our opinion in Cross-Sound I conclusively determined at the agency had changed its policy with respect to the ferry exemption. We ecline, however, to adopt so narrow a view of our earlier holding. We remanded ne Commission's decision in Viking I precisely because we were unsure what its terpretation of the ferry exemption was, see Cross-Sound I, 873 F.2d at 400; E would be inappropriate to let our earlier expressions of puzzlement prevent a ubsequent panel from evaluating the Commission's newly tendered explanations de ovo. Reviewing the Viking II decision, we conclude that the Commission [*7] as not diverged from prior precedent. First, we believe that the Commission persuasively distinguished those cases ere it has exercised jurisdiction over water carriers operating in Long Island ound. As the Commission explained in Viking II, 6 I.C.C.2d at 233 n.8, three of he examples that we cited in Cross-Sound I as "prima facie evidence of a change a ICC policy," 873 F.2d at 398-99, involved the transportation not only of assengers but also of freight, a subject area over which the Commission has ong exercised jurisdiction. See Mascony Transport and Ferry Servs., Inc., 353 .C.C. 60, 61 (1976), petition for review denied sub nom Cross-Sound Ferry ervs., Inc. V. U.S., 573 F.2d 725 (2d Cir. 1978) (applicant sought to transport general commodities and passengers" between New London and Greenport, New ork) i Cross-Sound Ferry Servs., Inc. - Extension, ICC Docket No. W-1290 (Sept. 3, 1983) (applicant sought to transport "passengers, general commodities, obiles with passengers, and tractors, trailers, and trucks" between New = h and Montauk) and B.I. Marine Express, Inc., [*8] ICC Docket No. -1450 (Oct. 14, 1986) (applicant proposed to transport "both passengers and eneral freight" between Westerly, Rhode Island and Block Island). Indeed, the Commission has repeatedly held that "the word ferry does not enerally include the transportation of goods and merchandise," McAllister COS., Inc. - Investigation of Control, 336 I.C.C. 590, 592-93 (1970), and has efused to exempt freight carriers from regulation simply because the passenger spect of their operation, viewed in isolation, might qualify as a "ferry." Id. = 593-94 (finding that carrier authorized to transport passengers and general ommodities between Bridgeport, Connecticut and Port Jefferson, New York was not 2 exempt ferry, even though carrier had apparently never exercised its freight thority). See also B.I. Marine Express, ICC Docket No. W-1450 ("ferry service entails the transportation of passengers, their automobiles, and ccompanying baggage, but does not involve the transportation of general reight") Ann Arbor R.R. Co. Common Carrier Application, 250 I.C.C. 490, 491 L942). The Supreme Court has interpreted the [*9] term "ferry" as excluding reight services, see St. Clair County V. Interstate Sand and Car Transfer Co., 92 U.S. 454, 467 (1904) (noting that "the ferry business is confined to the :ansportation of persons with or without their property"), as have various ederal regulations. See, e.g., 46 CFR @ 171.010( (d) (2) (1990) (Coast Guard fety regulations) ; 49 CFR @ 171.8 (1989) (hazardous materials transportation). Although its efforts to distinguish the fourth example of Long Island Sound ter carrier regulation that we cited in Cross-Sound I are less persuasive, the )mmission's view that Shoreline Boating Serv., Inc., ICC Docket No. W-1294 'ed May 29, 1984), involved excursion operations (i.e., round-trip service PAGE 104 1991 U.S. App. LEXIS 8977, *9 only) instead of point-to-point passenger service can be supported. See Viking I, 6 I.C.C.2d at 233 n.8 (noting that excursion operations, like freight ;e ces, have "historically been regulated"). The administrative law judge it wing Shoreline's original request for operating authority discussed the excursion character of the proposed services in some detail. See Shoreline Boating Serv., Inc., Common Carrier Application, [*10] ICC Docket No. W-1294 (August 19, 1976) (noting that carrier sold "round-trip transportation tickets lone"; describing public support for the excursion operations; and discussing excursion services offered by carriers contesting Shoreline's request for operating authority). We also note that the Commission's decision in Viking II is consistent with it least one other decision finding water carrier services on Long Island Sound to be exempt ferriage. In North Rip Fish Harvest, Ltd., ICC Docket No. W-1325 (May 13, 1980), the Commission held that passenger service between Montauk and Block Island - one of Viking's proposed routes - was exempt from regulation under section 10544 (a) (4). See also Michigan-Wisconsin Transp. Co., ICC Docket No. W-1377 (May 15, 1984) (carrier operating across Lake Michigan is exempt under section 10544 (a) (4)). Finally, we reject Cross-Sound's suggestion that the Commission's treatment of distance in Viking II rises to the level of a change in agency policy. See 6 [.C.C.2d at 237-40 (noting that earlier cases may have "overstated" the role of absolute distance). In Cross-Sound I, we criticized the Commission for failing [*11] to explain the significance it attached to the length of a carrier's :oute. See 873 F.2d at 399. Viking II suggests that the Commission, consistent with its decision in Michigan-Wisconsin Transp. Co., ICC Docket No. W-1377, S distance as a relevant but not dispositive factor in determining whether a Icular service qualifies as a "ferry." That is, so long as the carrier ossesses the usual attributes of a ferry - such as significant time or distance savings compared to overland routes - the absolute length of the route will not revent the carrier from qualifying as a ferry. See Viking II, 6 I.C.C.2d at 240. This approach is consistent with prior Commission decisions that seemed to establish per se limits on the distances a ferry could travel. As the Commission explained, those decisions also involved services not regularly associated with ferries. See Viking II, 6 I.C.C.2d at 239-40; Pere Marquette Ry. Co., 260 I.C.C. 206 (1944) (carrier transporting not only passengers but also railroad cars and newly manufactured automobiles across Lake Michigan); Ann Arbor R.R. Co. Common Carrier Application, 250 I.C.C. 490 (1942) [*12] (carrier transporting freight cars, in addition to passengers, across Lake Michigan) Canadian Pacific RY. Co. V. U.S., 73 F.2d 831, 834-35 (9th Cir. 1934) (discussing excursion character and luxurious nature of service across Puget Sound). Moreover, the distances at issue in this case - between 15 and 30 miles, depending on the barticular route, see Cross-Sound I, 873 F.2d at 397 - are well within the 50-145 mile upper boundaries even those earlier cases established for ferry service. Thus, we conclude that the Commission did not diverge from prior precedent or olicy in evaluating Viking's services. Accordingly, there was no need for the Commission to justify a change in policy. Given the Commission's comprehensive liscussion of the ferry exemption, which responded specifically to this court's concerns about apparently inconsistent precedents and the relative importance of various criteria used to evaluate ferries, we have no difficulty PAGE 105 1991 U.S. App. LEXIS 8977, *12 iscerning the agency's path and conclude that it satisfied the standards for easoned decisionmaking. Having concluded that the Commission did not impermissibly alter its view of he ferry exemption, [*13] we may set aside the Commission's decision pplying the exemption to Viking only if it was "arbitrary, capricious, an abuse f discretion, or otherwise not in accordance with law." 5 U.S.C. @ 706 (2) (A) 1988). See Railway Labor Execs. Ass'n V. ICC, 914 F.2d 276, 280 (D.C. Cir. 990). Under section 10544 (a) (4), ferries are exempt from regulation "except to the xtent the Interstate Commerce Commission finds it necessary to exercise urisdiction to carry out" the national transportation policy. See 49 U.S.C. @ 0101 (1988) (describing national transportation policy). Applying the rinciples it enunciated earlier in its decision, the Commission reasonably etermined that Viking's Montauk-Block Island and Montauk-Groton/New London perations qualify as exempt ferries. See Viking II, 6 I.C.C.2d at 241-42 noting the "frequent and regular" character of the service; its "modest," no-frills" quality; the absence of any "freight service whatsoever" or "detours or sightseeing purposes or for intermediate stops"; and the services' ability o "substitute[ ], with a substantial reduction in overall mileage, for a road nd bridge connecting nearby points [*14] in neighboring states") We can find no error in the Commission's further determination that the ational transportation policy does not require regulation of Viking's services r der to protect Cross-Sound against potential diversion or "cream-skimming" 1 s customer base. See 49 U.S.C. @ 10101 (a) (1) (C) (national transportation olicy includes encouraging "sound economic conditions among carriers") ; Viking I, 6 I.C.C.2d at 242-46. The Commission found that the services of the two arriers differed; that even with respect to shared services - i.e., passengers ithout vehicles - the distance between Orient Point, New York and Montauk, New ork (75 "congested" highway miles) limited actual competition; and that, in any ase, there was "sufficient traffic in the area to accommodate Viking's mall-scale operation without driving Cross-Sound out of business." Viking II, 6 .C.C.2d at 243-44. Cross-Sound contends that the Commission ignored evidence that Viking ctually offers excursion and freight services inconsistent with the ferry xemption. As the Commission concedes, however, Cross-Sound may pursue these lleged violations through [*15] a properly framed request for enforcement. ee Viking II, 6 I.C.C.2d at 230 n.3; 49 CFR Part 1111 (1990) (procedures for iling complaints with the Commission). Finally, we reject Cross-Sound's claims that the Commission erred in failing O hold further hearings regarding Viking's services, or in denying the ompany's discovery requests. Although we suggested in Cross-Sound I that the ommission might "find it useful on remand to use a hearing as a vehicle to e-examine and articulate its new view of the ferry exemption," 873 F.2d at 401, hat advice was premised on our assumption that the Commission would be altering ts traditional ferry policy. Given the agency's "broad discretion in deciding hether to grant a hearing," see, e.g., Cities of Carlisle and Neola, Iowa V. FRC, 741 F.2d 429, 431 (D.C. Cir. 1984), and its view (which we uphold here) the Viking decisions do not constitute a change in policy, the Commission PAGE 106 1991 U.S. App. LEXIS 8977, *15 reasonably concluded that hearings would not be "productive" and that "additional 'evidence' would not be particularly helpful in addressing the legal issues that predominate in this case." Viking II, 6 I.C.C.2d at 233. [*16] to Cross-Sound's discovery claims, we note this circuit's position that 'the cysuct and extent of discovery in agency proceedings is a matter ordinarily entrusted to the expert agency in the first instance and will not, barring the most extraordinary circumstances, warrant the Draconian sanction of overturning a reasoned agency decision. See Trailways Lines, Inc. V. ICC, 756 7.2d 1537, 1546 (D.C. Cir. 1985). No such extraordinary circumstances exist to varrant overturning the Commission's denial of Cross-Sound's discovery requests. IV. Having approved on both substantive and procedural grounds the Commission's finding that Viking's services are exempt from regulation under section 0544 (a) (4), we next address Cross-Sound's contention that the Commission violated the National Environmental Policy Act ("NEPA"), 42 U.S.C. @@ 4321-4370b 1988 & Supp. 1990), and the Coastal Zone Management Act ("CZMA"), 16 U.S.C. @@ 451-1464 (1988), by failing to conduct any environmental review of Viking's ervices. As an initial matter, the Commission contends that Cross-Sound lacks standing o challenge its actions under either NEPA or CZMA. Standing constitutes a hreshold [*17] jurisdictional inquiry. But this court has held that "when he merits of a case are clearly against the party seeking to invoke the court's urisdiction, the jurisdictional question is especially difficult and a- reaching, and the inadequacies in the record or briefing make the case a vehicle for deciding the jurisdictional question, we may rule on the merits ithout reaching" the jurisdictional contention. Adams V. Vance, 570 F.2d 950, 54 n.7 (D.C. Cir. 1978); accord Chinese Am. Civic Council V. Attorney General, 66 F.2d 321, 325 (D.C. Cir. 1977). See Secretary of the Navy V. Avrech, 418 .S. 676, 678 (1974) (per curiam) (assuming that district court had jurisdiction nd resolving case on the merits, noting that "even the most diligent and ealous advocate could find his ardor somewhat dampened in arguing a urisdictional issue where the decision on the merits is thus foreordained") orton V. Mathews, 427 U.S. 524, 530-532 (1976) (finding it "unnecessary" to esolve "difficult and perhaps close jurisdictional arguments" where a prior upreme Court decision dictated resolution of the merits against [*18] the arty asserting jurisdiction). See also United States V. Augenblick, 393 U.S. 48, 351-52 (1969) i Southeastern Community College V. Davis, 442 U.S. 397, 404 .5 (1979). We believe that this is a rare case in which we should exercise our iscretion to proceed directly to the merits. First, as discussed more fully below, the merits of Cross-Sound's nvironmental contentions can be resolved easily, particularly in light of our arlier finding that the Commission has not altered its policy with respect to ne ferry exemption. Second, the question of Cross-Sound's standing is quite omplex, involving inquiries into difficult issues such as the prudential tanding of competitors, see, e.g., Hazardous Waste Treatment Council V. EPA, 51 F.2d 277, 282-85 (D.C. Cir. 1988), cert. denied, 490 U.S. 1106 (1989) andowner injury, see, e.g., Goos V. ICC, 911 F.2d 1283, 1289-91 (8th Cir. 990) i and the Commission's statutory authority to consider environmental ctors under the national transportation policy of 49 U.S.C. @ 10101 in mining whether to override the ferry exemption. As to the [*19] last PAGE 107 1991 U.S. App. LEXIS 8977, *19 uestion, which goes to the redressability of Cross-Sound's asserted injuries, e have serious doubts concerning the narrow construction of section 10101 urged y X. concurring colleague. See Concurring Opinion at 3-6. Although this court u efer to an agency's reasonable interpretation of a statute that Congress as entrusted it to administer, see Chevron U.S.A. Inc. V. Natural Resources efense Council, 467 U.S. 837, 843 (1984), the Commission has not definitively onstrued section 10101 as precluding consideration of environmental factors, otwithstanding the cursory footnote on which our colleague relies. See Viking I, 6 I.C.C.2d at 249 n.33; Concurring Opinion at 4-5. Whether Congress intended he agency's inquiry under section 10101 to encompass environmental onsiderations is an intricate question we need not answer on the undeveloped ecord before us. We note only that the term "efficient," which is used in ection 10101 (a) (1) (B) 's directive that the Commission promote "efficient ransportation, has classically been thought to incorporate the full range of ossible externalities, including environmental costs and benefits. [*20] Finally, the administrative record and the briefs in this case provide nsufficient factual documentation to verify or disprove Cross-Sound's nvironmental standing claims. See Avrech, 418 U.S. at 677-78 (expressing nwillingness to decide jurisdictional question without further argument, even fter ordering supplemental briefing). Our concurring colleague's view that ross-Sound's asserted injuries could not be redressed by the Commission, as to hich we have serious qualms, allows him to avoid confronting knotty factual uestions concerning Cross-Sound's injuries, see Concurring Opinion at 2, uestions that would ultimately require a remand to the Commission for further indings. Under these circumstances, we deem it appropriate to review the merits f Cross-Sound's environmental claims directly, to which we now turn. PA Section 102 (2) (C) of NEPA requires federal agencies to prepare an nvironmental impact statement ("EIS") for every "major Federal action[ ] ignificantly affecting the quality of the human environment. 42 U.S.C. @ 332 (2) (c). In Viking II, the Commission found that a "decision simply holding hat an operation is a ferry and [*21] declining to take the affirmative step ecessary to assert jurisdiction is not the type of action that triggers" NEPA eview. 6 I.C.C.2d at 248. Cross-Sound disputes this interpretation, arguing hat the Commission's change in policy with respect to section 10544 (a) (4) onstitutes a major federal action under NEPA. Our conclusion that the Commission did not change its policy with respect to he ferry exemption might well dispose of Cross-Sound's claim. Indeed, etitioner's counsel effectively conceded at oral argument that success on the olicy change question was a prerequisite to success on the NEPA claim. In any ase, the only "action" the Commission even conceivably took was in finding that iking's services are statutorily exempt. We believe that Defenders of Wildlife Andrus, 627 F.2d 1238 (D.C. Cir. 1980), in which this court held that the ecretary of the Interior's failure to prevent the state of Alaska from carrying it a wolf kill program on federal lands did not constitute a major federal ction, is controlling. There, we held that an agency must undertake some "overt it" to trigger NEPA's requirements; the agency's mere refusal [*22] to ercise its statutory authority to act would not suffice. Id. at 1245-46. Unlike an ordinary licensing decision, in which the Commission affirmatively mines that a water carrier's proposed services are required by the PAGE 108 1991 U.S. App. LEXIS 8977, *22 public convenience and necessity" under 49 U.S.C. @ 10922, the Commission here imply applied the statutory ferry exemption of section 10544 (a) (4) and declined ) ? sert jurisdiction to advance the national transportation policy of section 01 thereby placing the case squarely within the "inaction" rubric of efc ers of Wildlife. See Viking II, 6 I.C.C.2d at 247 (noting that section 0544 (a) (4) "itself exempts ferry services from our jurisdiction, and all that e agency did was to take a look at whether Viking was conducting exempt ervices"). Common sense supports our conclusion that the Commission's decision es not constitute a major federal action; as we said in Defenders of Wildlife, 10 agency could meet its NEPA obligations if it had to prepare an environmental npact statement every time the agency had power to act but did not do so." 627 2d at 1246. CZMA The Coastal Zone Management [*23] Act seeks to protect the land and water sources of the nation's coastal zone through a cooperative governmental effort 1 which states are given primary responsibility for developing coastal resource nagement programs. See, e.g., 16 U.S.C. @ 1451 (i) (congressional findings); 16 S.C. @ 1452 (2) (congressional declaration of policy). Section 307 (c) (1) of MA requires federal agencies "conducting or supporting activities directly fecting the coastal zone" to comply with the affected states' management ograms "to the maximum extent practicable." 16 U.S.C. @ 1456 (c) (1). An plementing regulation requires federal agencies to provide the affected states th so called "consistency determinations" for proposed activities at least nety days prior to final federal approval. See 15 CFR @ 930.34 (a), (b) (1990). oss-Sound contends that the Commission violated these provisions by failing to t'v the relevant states prior to deeming Viking exempt from its jurisdiction section 10544 (a) (4). We reject this claim. CZMA and the implementing regulations on which Cross-Sound relies expressly clude federal licensing or permitting activities from the definition of a ederal [*24] activity," see 15 CFR @ 930.31 (c) i instead, a separate ocedural scheme places primary compliance responsibilities for such matters on e applicant and the affected states, not the federal agency. See 16 U.S.C. @ 56 (c) (3) (A) ("any applicant for a required Federal license or permit to nduct an activity affecting land or water uses in the coastal zone" of a state st certify to the federal agency that its activity will comply with state ograms, and must furnish a copy of the certification to the affected states, ich may file objections with the federal agency) 15 CFR Part 930, Subpart D, pecially 15 CFR @ 930.54; Viking II, 6 I.C.C.2d at 248 n.30. Here, the mmission's dismissal of Viking's application for common carrier authority on risdictional grounds meant that no licensing proceeding existed sufficient to igger these regulations. See Viking I, 4 I.C.C.2d at 640 n.9; Exemption of ter Carrier Operations, 4 I.C.C.2d 656, 1988 ICC Lexis 189 (June 14, 1988) ereinafter Water Carriers] (noting that "licensing" requires an "applicant" r a license); 15 CFR @ 930.52 (defining "applicant" [*25] as "any dividual [or corporation who] files an application for a Federal license or rmit to conduct an activity affecting the coastal zone"). Thus, neither the mmission nor Viking breached any notice obligation under CZMA. We find unpersuasive Cross-Sound's analogies to an earlier decision in which e Commission concluded that its exemption of entire classes of water carriers stituted a "federal activity" requiring a CZMA consistency determination. See Carriers, 1988 ICC Lexis 189, at 11. Unlike Viking II, in which one PAGE 109 1991 U.S. App. LEXIS 8977, *25 arrier's services were held exempt, Water Carriers involved a broad, raditional rulemaking proceeding in which four classes of carriers were X6 ted. See id. at 2-10 (describing exempted classes, and recognizing that 0 sion's action had "potential for directly affecting coastal zones by llowing some additional water carrier operations"). Indeed, the rulemaking fit quarely within the definition of "federal activity," and could not qualify nder the less stringent licensing or permitting scheme discussed above. See id. t 11-12 (discussing why decision constitutes a federal activity); 15 CFR *26] @ 930.31 (a) (defining federal activity); 15 CFR @ 930.52 (requiring applicant" for federal license). Thus, we find Cross-Sound's reliance on Water arriers inapposite. V. We conclude that the Commission has not changed its policy with respect to he ferry exemption, and find that its comprehensive discussion of the exemption n Viking II satisfies this court's mandate in Cross-Sound I, as well as the ore general standards for reasoned decisionmaking. We further conclude that the ommission appropriately found Viking's operations to be exempt under section 0544 (a) (4), and we reject Cross-Sound's allegations of procedural error. inally, we conclude that the Commission's finding that it lacked jurisdiction ver Viking's services did not trigger environmental review responsibilities der either NEPA or CZMA. For the foregoing reasons, Cross-Sound's petition for eview is denied. = is so ordered. , URBY: THOMAS (In Part) [SSENTBY: THOMAS (In Part) [SSENT: CLARENCE THOMAS, Circuit Judge, concurring in part and concurring 1 the denial of the petition for review: Although I join the majority in rejecting Cross-Sound's claims under the terstate Commerce Act, I do not join the majority [*27] in reviewing toss-Sound's claims under the National Environmental Policy Act (NEPA) and the astal Zone Management Act (CZMA). Before this court may review the merits of y of Cross-Sound's claims, we must decide whether we have the authority to do . See FW/PBS, Inc. v. City of Dallas, 110 S. Ct. 596, 607 (1990) ("The federal ourts are under an independent obligation to examine their own jurisdiction, d standing 'is perhaps the most important of [the jurisdictional] doctrines.' [uoting Allen V. Wright, 468 U.S. 737, 750 (1984) )). Having examined our own risdiction over Cross-Sound's environmental claims, I conclude that we have ne: Cross-Sound does not have article III standing. This court thus has no wer to judge the merits of Cross-Sound's claims under NEPA and CZMA. I. The statute that gives this court the power to hear ICC cases limits our risdiction to petitions brought by a "party aggrieved." 28 U.S.C. @ 2344. oss-Sound has participated aggressively at every level in all of the oceedings in this case, and no one suggests that Cross-Sound has not achieved nk as a "party." See Water Transp. Ass'n V. ICC, 819 F.2d 1189, 1192-93 & n.27 cir. 1987). [*28] The question instead is whether, with respect to PAGE 110 1991 U.S. App. LEXIS 8977, *28 he Commission's decision that it did not bear certain obligations under NEPA nd CZMA, Cross-Sound has been "aggrieved." We answer this question by 'f aging in traditional standing analysis. Id. at 1193 (citation omitted). n ler to establish constitutional standing, Cross-Sound must show "that it as suffered an injury in fact traceable to the Commission's ruling and edressable by a decision in [Cross-Sound's] favor." Id. In order to establish rudential standing, Cross-Sound must show "that the interest thereby abridged as arguably within the zone protected or regulated by the constitutional or tatutory guaranty in question." Id. Cross-Sound alleges that the Commission's decision has aggrieved it both as iking's competitor and as a landowner. I acknowledge that the Commission's ecision might ultimately affect Cross-Sound's fiscal health. And though the ecord does not reveal whether Cross-Sound owns any waterfront buildings, or ulkheads, or other littoral property, I assume that the Commission's decision ill lower the value of the company's land. Cross-Sound would thus have suffered njuries-in-fact [*29] both as a competitor and as a landowner. But ross-Sound would still not have attained article III standing. Cross-Sound ould have us order the Commission to prepare an environmental impact statement nder NEPA and a consistency determination under CZMA, both of which ostensibly ould provide the Commission with information on the environmental consequences f its choices. Cross-Sound suggests that the Commission would do well to ponder he effects of its actions on the "increasingly fragile"" waters of the Long sland Sound. Brief for Petitioner at 38 (citation omitted) ; see also id. at 38 13 (citing L.I. Sound Is So Polluted It Faces Long-Term Damage, N.Y. Times, uly 6, 1990, at A1). I agree that as a matter of policy, it probably should. As matter of law, however, the Commission has no power to regulate ferries for ~onmental reasons. Therefore, neither of the alleged injuries could be ssed by a decision in Cross-Sound's favor on its NEPA and CZMA claims, and ross-Sound thus has no standing to bring them. n1 -Footnotes- n1 In its claims under the Interstate Commerce Act, in contrast, Cross-Sound eeks an order requiring the Commission to regulate Viking's ferry service. That emedy, if we were to direct it, would redress the injuries-in-fact that ross-Sound asserts. I therefore agree with the majority's implicit conclusion hat Cross-Sound has standing to bring its Interstate Commerce Act claims. -End Footnotes- *30] The Interstate Commerce Act deprives the Commission of jurisdiction over cansportation "by a ferry," "except to the extent the Commission finds it ecessary to exercise jurisdiction to carry out the [national] transportation olicy. 49 U.S.C. @ 10544 (a) (4). n2 In defining the word "ferry," the ommission properly took into account the specific transportation criteria - irectness of route, character and frequency of service - that "flow from the tatus of a ferry as a 'floating section of highway. Viking Starship, Inc., 6 .C.C.2d 228, 235 (1989) (common carrier application) (quoting J. Perry, nerican Ferryboats 171 (1957)) [hereinafter Viking II]; see ante at 4-8 endorsing Commission's definition). The Commission did not consider ironmental criteria in defining the word "ferry," and no one seriously ontends that it could have. PAGE 111 1991 U.S. App. LEXIS 8977, *30 -Footnotes- Section 10544 (a) provides: xccpt to the extent the Interstate Commerce Commission finds it necessary to xercise jurisdiction to carry out the [national] transportation policy of ection 10101 of this title, the Commission does not have jurisdiction under his subchapter over transportation by water carrier when the transportation is rovided - (4) by a ferry. 9 U.S.C. @ 10544(a). -End Footnotes *31] Nor could the Commission have taken the environment into account at the econd stage of its proceeding, when it decided whether it should regulate iking's ferry service in order to carry out the national transportation policy. he national transportation policy comprises several separate congressional oncerns, such as safety and labor conditions in the transportation industry and elations between state and federal transportation authorities. See 49 U.S.C. @ 0101 (a) (1). n3 Each is meant to further Congress's ultimate goal: "to ensure he development, coordination, and preservation of a transportation system that e S the transportation needs of the United States." Id. @ 10101 (a) (emphasis ) -Footnotes- n3 Section 10101 (a) provides: 0 ensure the development, coordination, and preservation of a transportation ystem that meets the transportation needs of the United States, ... it is the olicy of the United States Government to provide for the impartial regulation f the modes of transportation subject to this subtitle, and - (1) in regulating those modes - (A) to recognize and preserve the inherent advantage of each mode of ransportation; (B) to promote safe, adequate, economical, and efficient transportation; (C) to encourage sound economic conditions in transportation, including sound conomic conditions among carriers; (D) to encourage the establishment and maintenance of reasonable rates for ransportation, without unreasonable discrimination or unfair or destructive ompetitive practices; (E) to cooperate with each State and the officials of each State on sportation matters; and PAGE 112 1991 U.S. App. LEXIS 8977, *31 F) to encourage fair wages and working conditions in the transportation nd try. 9 s.c. @ 10101 (a). -End Footnotes *32] Conspicuous in its absence from the national transportation policy is any llusion to our nation's environmental needs, and the Commission would be hard ressed to fit environmental concerns as such within the language of the tatute. The majority suggests that the Commission might be able to squeeze the ivironment into Congress's charge that the Commission promote "efficient ransportation. 49 U.S.C. @ 10101 (a) (1) (B) i see ante at 12. This reading seems , me flawed for two reasons. First, notwithstanding the majority's advice, the ommission itself reads the national transportation policy, as I do, to exclude nvironmental matters - a point that the Commission made both in its opinion elow and in its brief to this court. See Viking II, 6 I.C.C.2d at 249 n.33 ("We bubt that we have authority to use the [national transportation policy] <ception as a basis for addressing environmental issues associated with therwise exempt ferry services, since the [policy] makes no reference to nvironmental issues. ") i Joint Brief of Respondents Interstate Commerce ommission and United States of America at 29 ("Neither section 10101 nor ection 10544 (a) mention [sic] [*33] environmental impacts. Thus, the ommission is to be guided by transportation and economic principles in deciding ether the regulation of ferriage is necessary. Environmental impacts play no 1ʳᵈ in determining whether certain transportation is ferry service, or whether ommission should exercise its authority to overide [sic] the exemption in a 1. Icular case. "). Second, it is axiomatic that in construing a statute, "the court must look to e particular statutory language at issue, as well as the language and design : the statute as a whole. " K Mart Corp. V. Cartier, Inc., 486 U.S. 281, 291 L988) (emphasis added). The majority here plucks one word, "efficient, from a omprehensive statute that in language and design deals solely with our ountry's "transportation needs,' and suggests that the word is malleable enough , cover the "environment. " But the Interstate Commerce Act includes words that e far more elastic, and the Supreme Court has rejected attempts to stretch nose words as thinly as the majority proposes the Commission do here. In New >rk Central Securities Corp. V. United States, 287 U.S. 12 (1932), [*34] or example, a unanimous Court construed a section in the Act that gives the mission the power to regulate on behalf of the "public interest.' Chief stice Hughes wrote: le term "public interest" as thus used [in the statute] is not a concept thout ascertainable criteria, but has direct relation to adequacy of ansportation service, to its essential conditions of economy and efficiency, d to appropriate provision and best use of transportation facilities, estions to which the Interstate Commerce Commission has constantly addressed self in the exercise of the authority conferred. at 25; cf. NAACP V. FPC, 425 U.S. 662 (1976) (authority to promote "public terest" does not give Federal Power Commission (now FERC) warrant to try to ly employment discrimination without regard to effects on utility rates). PAGE 113 1991 U.S. App. LEXIS 8977, *34 Then Congress wants the Commission to make decisions for environmental reasons, it explicitly tells the Commission to do so. See, e.g., 49 U.S.C. @ 10362 (c) (4) R- Services Planning Office must consider "the cost to the environment") i n4 :f 1. @ 10101a (15) (under national rail transportation policy, Congress J intends to "encourage and promote energy conservation"). When Congress ormally codified the national transportation policy, fifty-one years ago, see Transportation Act of 1940, Pub. L. No. 76-785, @ 1, 54 Stat. 899, 899, it ;urely did not mean to give the Commission license to regulate ferries in order :o promote ecological consciousness-raising - or any other "externalities" inconnected to Congress's narrow focus on fields within the Commission's raditional realm of expertise, the economics of transportation. -Footnotes- n4 Section 10362 (c) provides: ail properties are suitable for rail transportation continuation subsidies if he cost of the required subsidy to the taxpayers for the properties each year S less than - (4) the cost to the environment measured by damage caused by increased ollution. 9 U.S.C. @ 10362 (c) (emphasis added). -End Footnotes in this case, Cross-Sound wants the Commission to prepare both an nvironmental impact statement, see 42 U.S.C. @ 4332(2) 4332 (2) (C), and a consistency etermination, see [*36] 16 U.S.C. @ 1456 (c) (1) i 15 C.F.R. @ 930.4 (a), (b), ith respect to its finding first, that Viking is a ferry and second, that iking is not subject to the Commission's control. Both environmental impact tatements and consistency determinations are meant to disseminate information n the environmental consequences of government action. But as far as ross-Sound is concerned, more information is not any better than less nformation, or, for that matter, than no information at all. Neither an nvironmental impact statement nor a consistency determination can affect the ommission's decision whether Viking is or is not a ferry, and if it is, the ecision whether to regulate Viking nonetheless. In this case, the environment imply is not on the Commission's agenda. A favorable result for Cross-Sound on its environmental claims could not edress Cross-Sound's injuries-in-fact. Cross-Sound thus has no article III tanding to bring those claims, and we thus have no authority under the onstitution to hear them. See Public Citizen V. NHTSA, 848 F.2d 256, 262-63 & .27 (D.C. Cir. 1988); Natural Resources Defense Council, Inc. V. Berklund, 609 .2d 553, 558 (D.C. Cir. 1979) [*37] (per curiam). n5 I express no opinion n the majority's discussion of the merits. With respect, though, I do offer a ew words on the majority's decision to assert jurisdiction without deciding ether it has any and then to proceed to rule in this case on the merits of toss-Sound's environmental claims. -Footnotes- PAGE 114 1991 U.S. App. LEXIS 8977, *37 - Since competitors are not within the zone of interests that NEPA and CZMA 'C =, I doubt, in addition, that Cross-Sound meets the requirements of unitial standing. See Hazardous Waste Treatment Council V. EPA, 861 F.2d 277, 3-84 (D.C. Cir. 1988) (per curiam) ("When we grant standing to a party with ly an oblique relation to the statutory goal, we run the risk that the outcome uld, even assuming technical fidelity to law, in fact thwart the congressional al. Further, of course, technical fidelity to law cannot be assumed; judges r."), cert. denied, 490 U.S. 1106 (1989) cf. Churchill Truck Lines, Inc. V. ited States, 533 F.2d 411, 416 (8th Cir. 1976) (footnote and citations itted): titioners, whose sole motivation was their own economic self-interest d welfare, are singularly inappropriate parties to be entrusted with the sponsibility of asserting the public's environmental interest in proceedings incerning the issuance of operating authority to motor carriers [NEPA] S not designed to prevent loss of profits but was intended to promote vernmental awareness of and action concerning environmental problems. -End Footnotes- 38] II. Federal courts are courts of limited jurisdiction. When federal jurisdiction es not exist, federal judges have no authority to exercise it, even if one - judges, parties, members of the public - wants the dispute resolved. .g., CFTC v. Schor, 478 U.S. 833, 850-51 (1986) i Bender V. Williamsport Eu School Dist., 475 U.S. 534, 541 & n.4 (1986) i Sosna V. Iowa, 419 U.S. 393, 8 (1975) ; American Fire & Casualty Co. V. Finn, 341 U.S. 6, 17-18 & n.17 951) i Anglo Am. Provision Co. V. Davis Provision Co. No. 2, 191 U.S. 376, 377 903) (Holmes, J.) i Mansfield, Coldwater & Lake Mich. Ry. V. Swan, 111 U.S. 9, 382-84 (1884) ; People's Bank V. Calhoun, 102 U.S. 256, 260-61 (1881) ; tler V. Rae, 48 U.S. (7 How.) 765, 767 (1849) i Jackson V. Ashton, 33 U.S. (8 t.) 93, 94 (1834) (Marshall, C.J.) i Capron V. Van Noorden, 6 U.S. (2 Cranch) , 72 (1804) It follows that federal courts have a "'special obligation" to praise at the outset their own jurisdiction, even when the parties, [*39] the lower courts, have not raised any jurisdictional questions themselves. /PBS, Inc. V. City of Dallas, 110 S. Ct. 596, 607 (1990) (citation omitted). is tenet is as solid as bedrock and almost as old. See, e.g., Duquesne Light V. Barasch, 488 U.S. 299, 306 (1989) i Bender, 475 U.S. at 541 & n.4; Juidice Vail, 430 U.S. 327, 331-32 (1977) ; Liberty Mut. Ins. Co. V. Wetzel, 424 U.S. 7, 740 (1976) i Clark V. Paul Gray, Inc., 306 U.S. 583, 588 (1939) i United ates V. Corrick, 298 U.S. 435, 440 (1936) i Mitchell V. Maurer, 293 U.S. 237, 4 (1934) (Brandeis, J.) ; Louisville & Nashville R.R. V. Mottley, 211 U.S. 149, 2 (1908) ; Great Southern Fire Proof Hotel Co. V. Jones, 177 U.S. 449, 453-54 & 1 (1900) i Mansfield, 111 U.S. at 382-84; Jackson, 33 U.S. (8 Pet.) at 94; pron, 6 U.S. (2 Cranch) at 72; see also, e.g., Citizens for the Abatement of rcraft Noise, Inc. V. Metropolitan Washington Airports Auth., 917 F.2d 48, 53 .C. Cir. 1990) [*40] ("As a threshold matter, we must consider whether is case is justiciable. Although the [defendant] has not pressed the issue on peal, it is well established that a court of appeals must first satisfy itself its own jurisdiction, sua sponte if necessary, before proceeding to the s."), cert. granted on other grounds, 111 S. Ct. 750 (1991) ; Rubins PAGE 115 1991 U.S. App. LEXIS 8977, *40 ontractors, Inc. V. Lumbermens Mut. Ins. Co., 821 F.2d 671, 673 (D.C. Cir. 987) ("Before addressing the merits of this dispute we must find jurisdiction O so Although [the defendant] sought to waive the issue at oral I ent, we have an independent obligation to determine whether jurisdiction as proper. i Reynolds V. Sheet Metal Workers, Local 102, 702 F.2d 221, 223 D.C. cir. 1981) ("Federal courts are courts of limited jurisdiction, and are bliged always to ascertain whether they have subject matter jurisdiction over he litigation before them, even when the parties prefer to ignore the uestion. "). The truistic constraint on the federal judicial power, then, is this: A ederal court may not decide cases when it cannot decide cases, and must etermine [*41] whether it can, before it may. The majority here changes this undamental precept to read, in effect, that under certain circumstances a ederal court should decide cases regardless of whether it can, and need not etermine whether it can, before it does. This revision seems to me difficult to quare with the Supreme Court's regular warnings to the federal courts to ulfill their "special obligation" to inquire into their own jurisdiction at the utset. Originally stated in 1804, in Capron V. Van Noorden, 6 U.S. (2 Cranch) t 72, the rule was articulated most forcefully in Mansfield, Coldwater & Lake ichigan Railway V. Swan, 111 U.S. 379 (1884). In Mansfield, a unanimous Court xplained that this rule, "springing from the nature and limits of the judicial ower of the United States, is inflexible and without exception.' Id. at 382. he rule ... requires this court, of its own motion, to deny its own urisdiction, and, in the exercise of its appellate power, that of all the other ourts of the United States, in all cases where such jurisdiction does not matively appear in the record on which, in the exercise [*42] of that , it is called to act ... The first and fundamental question is that of 21 sdiction, first, of this court, and then of the court from which the record omes. This question the court is bound to ask and answer for itself, even when ot otherwise suggested, and without respect to the relation of the parties to :. 1. The Supreme Court reiterated this principle twice last Term. In reviewing the espondents' citizenship in Carden V. Arkoma Associates, 110 S. Ct. 1015 (1990), e Court held that "since diversity of citizenship is a jurisdictional quirement, the Court is always 'called upon to decide' it." Id. at 1021; see 1. ("'The failure of parties to urge objections [to diversity of citizenship] nnot relieve this court from the duty of ascertaining from the record whether le Circuit Court could properly take jurisdiction of this suit. (quoting 'eat Southern Fire Proof Hotel, 177 U.S. at 453)). In FW/PBS, the Court ordered smissal of a claim for lack of article III standing, even though neither the rties nor the lower courts had addressed the issue. The Court stressed that he federal [*43] courts are under an independent obligation to examine eir own jurisdiction, and standing 'is perhaps the most important of the urisdictional] doctrines. 110 S. Ct. at 607 (citation omitted). very federal appellate court has a special obligation to 'satisfy itself not ly of its own jurisdiction, but also that of the lower courts in a cause under view,' even though the parties are prepared to concede it. Mitchell V. Maurer, 3 U.S. 237, 244 (1934). See Juidice V. Vail, 430 U.S. 327, 331-32 (1977) ding). 'And if the record discloses that the lower court was without PAGE 116 1991 U.S. App. LEXIS 8977, *43 risdiction this court will notice the defect, although the parties make no ntention concerning it.' [United States V. Corrick, 298 U.S. 435, 440 9? .]" \quoting Bender, 475 U.S. at 541). To require that a court resolve jurisdictional questions before addressing n-jurisdictional ones raises the difficult question of how to distinguish the O. The rule of Mansfield might be reduced to tautology if jurisdiction were fined to encompass grounds that the court, on its own motion if necessary, 44] must establish at the threshold. The term "jurisdiction, however - "an 1-purpose word denoting adjudicatory power" - bears different meanings in fferent contexts. Szabo Food Serv., Inc. V. Canteen Corp., 823 F.2d 1073, 1077 th Cir. 1987), cert. dismissed, 485 U.S. 901 (1988). Sometimes, for example, aracterizing a provision as "jurisdictional" implies that a court cannot mper the application of the provision through otherwise available equitable ctrines such as waiver, tolling, and estoppel. See, e.g., Irwin V. Veterans min., 111 S. Ct. 453, 455-58 (1990). Other times, characterizing a provision bearing on an inferior tribunal's "jurisdiction" might signify that on peal, that tribunal's interpretation of the provision is not entitled to ference. See, e.g., Mississippi Power & Light Co. V. Mississippi ex rel. ore, 487 U.S. 354, 386-89 (1988) (Brennan, J., dissenting). Given the woolliness of the concept, it is hardly surprising that there ists a significant gray area between grounds of decision that clearly are risdictional and grounds that clearly are not. In a sense, all [*45] plicable rules limit the authority of the relevant adjudicative tribunal; for reason, proponents of deferring to reasonable agency interpretations of jurisdictional" provisions have argued that deference is necessary because intelligible distinction can be drawn between jurisdictional and n-jurisdictional provisions of statutes entrusted for their administration to e agency. See Mississippi Power, 487 U.S. at 380-82 (Scalia, J., concurring in e judgment). In contexts where distinctions between jurisdictional and n-jurisdictional provisions are made routinely, the distinctions can prove usive. Compare, e.g., Irwin, 111 S. Ct. at 457 (deeming a provision that "an ployee may file a civil action" within a certain time to be n-jurisdictional for tolling purposes) with, e.g., Soriano V. United States, shall 2 U.S. 270, 273-77 (1957) (deeming a provision that "every claim barred unless filed" within a certain time to be jurisdictional for lling purposes). To complicate matters further, some provisions - the eleventh endment, for example - can be jurisdictional in some [*46] contexts, and n-jurisdictional in others. Compare Patsy V. Board of Regents, 457 U.S. 496, 6 n.19 (1982) (stating that the eleventh amendment is not "jurisdictional in le sense that it must be raised and decided by this Court on its own motion") th Edelman V. Jordan, 415 U.S. 651, 678 (1974) ("The Eleventh Amendment fense sufficiently partakes of the nature of a jurisdictional bar so that it ed not be raised in the trial court."). Finally, and most importantly for esent purposes, it is well-settled that at some point a claim becomes fficiently frivolous on the merits as to justify a dismissal for lack of risdiction. See, e.g., Bell V. Hood, 327 U.S. 678, 682-83 (1946) (dismissal 'om district court when the claim is "wholly insubstantial and frivolous"); cht v. King, 260 U.S. 174, 176-77 (1922) (dismissal from Supreme Court when e claim is not "sufficiently substantial"). 18 PAGE 117 1991 U.S. App. LEXIS 8977, *46 e Mansfield rule is violated only if the ground passed over is dictional and the ground rested upon is non- jurisdictional, for courts 2. erlv rest on one jurisdictional ground instead of another, or [*47] on IE S ground instead of another. In cases where either ground is difficult a cerize, it is difficult to determine whether the rule has been ted. Arguably, moreover, the rule might not apply at all if the ground d over sufficiently, though not entirely, "partakes of the nature" of a ad S ground, or if the ground rested upon "sufficiently," though not entirely, akes of the nature of a jurisdictional bar, Jordan, 415 U.S. at 678. Here, er, the ground passed over - whether there exists a case or controversy it n the meaning of article III - is unambiguously jurisdictional, see, e.g., W V. Wright, 468 U.S. 737, 750-51 (1984), and the ground rested upon - ry er the Commission took "major Federal actions" or engaged in "Federal nd ity" sufficient to trigger duties under NEPA or CZMA - is unambiguously it urisdictional. In this situation, no Supreme Court case authorizes the at h of the Mansfield rule that the majority today commits. n6 17 -Footnotes- The policies of avoiding constitutional questions for non-constitutional see, e.g., Ashwander V. TVA, 297 U.S. 288, 345-48 (1936) (Brandeis, J., rring), apply with equal force to jurisdictional determinations. In this however, the constitutional questions go to jurisdiction and the onstitutional ones go to the merits, and the prudential concerns of nder cannot override a rule that is "inflexible and without exception," ield, 111 U.S. at 382. Thus, in Juidice V. Vail, 430 U.S. 327 (1977), the raised and decided a question of constitutional standing, see id. at 3, before holding that the district court erred in not abstaining under Harris, 401 U.S. 37 (1971) - a non-constitutional ground of decision 1 treated as non-jurisdictional, see, e.g., Ohio Bureau of Employment V. Hodory, 431 U.S. 471, 480 (1977) (permitting states to waive a Younger se) i Ellis V. Dyson, 421 U.S. 426, 435 (1975) (instructing district court cide on remand article III issues before reaching Younger issues). 0 End Footnotes- at y ween 1969 and 1976, the Supreme Court decided four cases that are 60 mes cited in support of assuming jurisdiction arguendo and rendering a nt on the merits: United States V. Augenblick, 393 U.S. 348 (1969) i er V. Judicial Council, 398 U.S. 74 (1970) i Secretary of the Navy V. , 418 U.S. 676 (1974) (per curiam) i and Norton V. Mathews, 427 U.S. 524 a In Augenblick, however, the ground passed over was at least arguably the risdictional, and in Chandler, Avrech, @nd Norton, the ground rested upon least arguably jurisdictional. Upon close examination, therefore, none of cases authorizes the practice undertaken by the majority. enblick involved actions for back pay brought in the Court of Claims by ius, rs challenging the constitutionality of their prior court-martial :s tions. See 393 U.S. at 348-49. The Court of Claims had "jurisdiction to judgment against the United States on any claim 'founded of upon the tution. Id. at 349 n.2 (quoting 28 U.S.C. @ 1491). Thus, one issue in in Augenblick was whether the soldiers were barred from recovery in the of Claims by the preclusive effect of their convictions in the on rtial. The Supreme Court declined to address this issue: "Assuming, PAGE 11/ 1991 U.S. App. LEXIS 8977, *46 The Mansfield rule is violated only if the ground passed over is risdictional and the ground rested upon is non- jurisdictional, for courts operly rest on one jurisdictional ground instead of another, or [*47] on e merits ground instead of another. In cases where either ground is difficult characterize, it is difficult to determine whether the rule has been , d. Arguably, moreover, the rule might not apply at all if the ground SS over sufficiently, though not entirely, "partakes of the nature" of a rits ground, or if the ground rested upon "sufficiently," though not entirely, artakes of the nature of a jurisdictional bar," Jordan, 415 U.S. at 678. Here, wever, the ground passed over - whether there exists a case or controversy thin the meaning of article III - is unambiguously jurisdictional, see, e.g., len v. Wright, 468 U.S. 737, 750-51 (1984), and the ground rested upon - ether the Commission took "major Federal actions" or engaged in "Federal tivity" sufficient to trigger duties under NEPA or CZMA - is unambiguously n-jurisdictional. In this situation, no Supreme Court case authorizes the each of the Mansfield rule that the majority today commits. n6 -Footnotes- n6 The policies of avoiding constitutional questions for non-constitutional es, see, e.g., Ashwander V. TVA, 297 U.S. 288, 345-48 (1936) (Brandeis, J., ncurring), apply with equal force to jurisdictional determinations. In this se, however, the constitutional questions go to jurisdiction and the n-constitutional ones go to the merits, and the prudential concerns of hwander cannot override a rule that is "inflexible and without exception," nsfield, 111 U.S. at 382. Thus, in Juidice V. Vail, 430 U.S. 327 (1977), the urt raised and decided a question of constitutional standing, see id. at 1-33, before holding that the district court erred in not abstaining under unger V. Harris, 401 U.S. 37 (1971) - a non-constitutional ground of decision nevally treated as non-jurisdictional, see, e.g., Ohio Bureau of Employment V. Hodory, 431 U.S. 471, 480 (1977) (permitting states to waive a Younger 1 se) Ellis V. Dyson, 421 U.S. 426, 435 (1975) (instructing district court decide on remand article III issues before reaching Younger issues). -End Footnotes- 48] Between 1969 and 1976, the Supreme Court decided four cases that are metimes cited in support of assuming jurisdiction arguendo and rendering a dgment on the merits: United States V. Augenblick, 393 U.S. 348 (1969) ; andler V. Judicial Council, 398 U.S. 74 (1970) i Secretary of the Navy V. rech, 418 U.S. 676 (1974) (per curiam); and Norton V. Mathews, 427 U.S. 524 976). In Augenblick, however, the ground passed over was at least arguably n-jurisdictional, and in Chandler, Avrech, @nd Norton, the ground rested upon S at least arguably jurisdictional. Upon close examination, therefore, none of ese cases authorizes the practice undertaken by the majority. Augenblick involved actions for back pay brought in the Court of Claims by ldiers challenging the constitutionality of their prior court-martial nvictions. See 393 U.S. at 348-49. The Court of Claims had "jurisdiction to nder judgment against the United States on any claim 'founded ... upon the nstitution. Id. at 349 n.2 (quoting 28 U.S.C. @ 1491). Thus, one issue in 49] Augenblick was whether the soldiers were barred from recovery in the urt of Claims by the preclusive effect of their convictions in the urts-martial. The Supreme Court declined to address this issue: "Assuming, 1991 U.S. App. LEXIS 8977, *49 ne rguendo, held that the attacks before it were without 351-52. that a collateral attack on a court-martial judgment" merit. See could id. be at made, A defense of claim or issue preclusion, which can be waived if not properly reserved, is almost always considered non-jurisdictional. See, e.g., Fed. R. i' ? 8 (c) (requiring res judicata to be pleaded as an affirmative defense) V. Bowen, 817 F.2d 865, 869 & n.37 (D.C. Cir. 1987) ("Failure to so plead D. onscitutes a waiver of the defense.' i see also 5 C. Wright & A. Miller, ederal Practice and Procedure @ 1278, at 481-82 & n.9 (2d ed. 1990). Although he argument for preclusion in Augenblick was statutory, the statute on which it as based gives little hint of a more jurisdictional flavor than the common-law octrine that the statute codifies. See 10 U.S.C. @ 876 (providing that military eview of court-martial convictions shall be "final [*50] and conclusive" and of the United States"). To the extent that binding upon all ugenblick bypassed a preclusion courts defense to reject the claims against which that efense was asserted, it simply rested on one merits ground as opposed to nother, and provides no basis for dodging jurisdiction to reach the merits. n7 -Footnotes- n7 Norton bypassed the question whether a statute prohibited collateral ttack in the district court upon an administrative adjudication by the ecretary of Health, Education, and Welfare. The Court correctly characterized orton was written in expressly jurisdictional terms. See 42 U.S.C. @ 405 (h), hat question as jurisdictional, because the preclusion statute at issue in [uoted in 427 U.S. at 529 n.5. -End Footnotes Despite the general rule that questions of claim or issue preclusion are jurisdictional, they are at least jurisdiction-like in two senses: first, can usually be determined as a matter of law at the outset, simply by examining the face of the [*51] new pleadings in light of the prior proceeding; second, because they touch upon the comity owed by one tribunal to the judgments and orders of another, they implicate institutional concerns that JO beyond the rights of individual litigants. It is not surprising, therefore, :hat the Supreme Court occasionally has cast preclusion questions in expressly jurisdictional terms. See District of Columbia Court of Appeals V. Feldman, 460 J.S. 462 (1983) i Rooker V. Fidelity Trust Co., 263 U.S. 413 (1923). In those cases, which involved the preclusive effect of state-court judgments in subsequent federal-court litigation, the Supreme Court reasoned that if a district court issues a judgment on a matter "inextricably intertwined" with a state-court judgment, then "the district court is in essence reviewing the state-court decision," 460 U.S. at 483-84 n.16 - "an exercise of appellate jurisdiction" unauthorized by statute, 263 U.S. at 416. Jurisdictional recasting of preclusion questions has occurred only rarely. The general rule remains that preclusion questions are non-jurisdictional. Thus, when determining the preclusive [*52] effect to which state-court judgments are entitled, the Court usually eschews the theory of Rooker-Feldman for the more conventional approach of simply applying the substantive preclusion law of the state, see 28 U.S.C. @ 1738, on the merits. See, e.g., Marrese v. American Academy of Orthopaedic Surgeons, 470 U.S. 373 (1985) i Migra V. Warren City School Dist. Bd. of Educ., 465 U.S. 75 (1984) Kremer V. Chemical Construction Corp., 456 U.S. 461 (1982). See generally P. Bator, D. Meltzer, P. Mishkin & PAGE 119 1991 U.S. App. LEXIS 8977, *52 Shapiro, Hart and Wechsler's The Federal Courts and the Federal System 615-34 (3d ed. 1988). Augenblick, the Court at times spoke in terms reminiscent of Rooker and n pating Feldman. Instead of consistently framing the issue in terms of hetner "a collateral attack on a court-martial judgment" was appropriate, 393 .s. at 351 (emphasis added), it also questioned the "jurisdiction" of the Court f Claims to "review" court-martial convictions, id. at 349. In Schlesinger V. ouncilman, 420 U.S. 738 (1975), however, another case involving [*53] the reclusive effect of a court-martial judgment, the Court returned to the more raditional, non-jurisdictional idiom. Councilman held that 10 U.S.C. @ 876, the ame preclusion statute at issue in Augenblick, merely "defines the point at hich military court judgments become final and requires that they be given res udicata effect." Id. at 749. The Court expressly rejected the argument that ection 876 divests the district courts of original jurisdiction to entertain ollateral attacks on court-martial judgments, see id. at 748-53, and it at east implicitly rejected the alternative jurisdictional theory that any istrict court so doing would effectively be engaging in direct review without a tatutory grant of appellate jurisdiction. See id. at 753 ("The district court ad subject-matter jurisdiction "). In light of this background, Augenblick cannot plausibly be read as uthorizing courts to sidestep jurisdiction. Interpreted that broadly, ugenblick would stand without precedent or progeny, breaching an otherwise ntact phalanx of Supreme Court authority spanning almost two centuries [*54] hile "offering not a single word of analysis or justification" for so doing. omment, Assuming Jurisdiction Arguendo: The Rationale and Limits of ypothetical Jurisdiction, 127 U. Pa. L. Rev. 712, 713 (1979). To save blick from that dubious distinction, one need only posit that the Court, te occasional rhetoric to the contrary, viewed the preclusion question in ustomary, non-jurisdictional terms, presaging its later, express holding in ouncilman. n8 -Footnotes- n8 Avrech probably can be explained in terms similar to Augenblick. In wrech, the court bypassed the question, which it cast in jurisdictional terms, ether a district-court plaintiff seeking back pay could collaterally attack a ourt-martial conviction. See 418 U.S. at 676-77. The Court's characterization E the bypassed preclusion question as jurisdictional was perhaps more plausible n Avrech than in Augenblick, however, for the plaintiff in Avrech (like the laintiffs in Rooker and Feldman, but unlike the plaintiffs in Augenblick) ought an actual declaration that another tribunal's judgment was invalid. See 1. at 677. But since Avrech rested on jurisdictional grounds in any event, see fra pp. 17-19, it matters little whether the bypassed preclusion question ere is considered jurisdictional or not. -End Footnotes *55] The other Supreme Court cases passed over grounds that are clearly urisdictional, but rested on alternative grounds that are at least arguably risdictional. Thus, in Chandler, the Supreme Court avoided deciding whether it d jurisdiction to issue writs of prohibition or mandamus against the judicial ncil of the Tenth Circuit, holding instead that the petitioner was not PAGE 119 1991 U.S. App. LEXIS 8977, *52 Shapiro, Hart and Wechsler's The Federal Courts and the Federal System 15-34 (3d ed. 1988). \ugenblick, the Court at times spoke in terms reminiscent of Rooker and t. .pating Feldman. Instead of consistently framing the issue in terms of ether "a collateral attack on a court-martial judgment" was appropriate, 393 S. at 351 (emphasis added), it also questioned the "jurisdiction" of the Court Claims to "review" court-martial convictions, id. at 349. In Schlesinger V. uncilman, 420 U.S. 738 (1975), however, another case involving [*53] the eclusive effect of a court-martial judgment, the Court returned to the more aditional, non-jurisdictional idiom. Councilman held that 10 U.S.C. @ 876, the me preclusion statute at issue in Augenblick, merely "defines the point at ich military court judgments become final and requires that they be given res dicata effect." Id. at 749. The Court expressly rejected the argument that ction 876 divests the district courts of original jurisdiction to entertain llateral attacks on court-martial judgments, see id. at 748-53, and it at ast implicitly rejected the alternative jurisdictional theory that any strict court so doing would effectively be engaging in direct review without a atutory grant of appellate jurisdiction. See id. at 753 ("The district court d subject-matter jurisdiction "). In light of this background, Augenblick cannot plausibly be read as thorizing courts to sidestep jurisdiction. Interpreted that broadly, genblick would stand without precedent or progeny, breaching an otherwise tact phalanx of Supreme Court authority spanning almost two centuries [*54] ile "offering not a single word of analysis or justification" for so doing. mment, Assuming Jurisdiction Arguendo: The Rationale and Limits of hetical Jurisdiction, 127 U. Pa. L. Rev. 712, 713 (1979). To save lick from that dubious distinction, one need only posit that the Court, brite occasional rhetoric to the contrary, viewed the preclusion question in stomary, non-jurisdictional terms, presaging its later, express holding in uncilman. n8 -Footnotes- n8 Avrech probably can be explained in terms similar to Augenblick. In rech, the court bypassed the question, which it cast in jurisdictional terms, ether a district-court plaintiff seeking back pay could collaterally attack a urt-martial conviction. See 418 U.S. at 676-77. The Court's characterization the bypassed preclusion question as jurisdictional was perhaps more plausible Avrech than in Augenblick, however, for the plaintiff in Avrech (like the aintiffs in Rooker and Feldman, but unlike the plaintiffs in Augenblick) ight an actual declaration that another tribunal's judgment was invalid. See at 677. But since Avrech rested on jurisdictional grounds in any event, see fra pp. 17-19, it matters little whether the bypassed preclusion question ere is considered jurisdictional or not. -End Footnotes- 55] The other Supreme Court cases passed over grounds that are clearly risdictional, but rested on alternative grounds that are at least arguably risdictional. Thus, in Chandler, the Supreme Court avoided deciding whether it 1 jurisdiction to issue writs of prohibition or mandamus against the judicial il of the Tenth Circuit, holding instead that the petitioner was not PAGE 120 1991 U.S. App. LEXIS 8977, *55 titled to so extraordinary a remedy because he had failed to exhaust the other venues of relief available to him. See 398 U.S. at 86-89; see also Coalition or the Preservation of Hispanic Broadcasting V. FCC, No. 87-1285, slip op. at D.C. Cir. Apr. 23, 1991) (en banc) (avoiding standing question and is ssing petitioners' claim for failure to exhaust administrative remedies) ampagne V. Schlesinger, 506 F.2d 979, 982 (7th Cir. 1974) ("Exhaustion is a uasi-jurisdictional problem "). Similarly, in Avrech and Norton, the Court rested on essentially risdictional grounds - "the inability of the federal judiciary 'to review moot ses, DeFunis V. Odegaard, 416 U.S. 312, 316 (1974) (per curiam) (citation nitted). On [*56] the merits, Avrech and Norton involved constitutional allenges to, respectively, a court-martial conviction and an administrative ijudication denying entitlement to certain benefits. In addition, each case resented a threshold question, cast in jurisdictional terms, n9 whether the :ior judgment could be collaterally attacked in the district court. While rech was pending, the Supreme Court decided another case presenting the ientical merits issue, rejecting the position advocated by the plaintiff in rech. The same thing happened in Norton. In both cases, the Court refused to ecide the pending jurisdictional question, but issued a conforming merits ecision nonetheless. -Footnotes- n9 See supra notes 7, 8. -End Footnotes Avrech, the Court decided that the intervening decision had rendered the question so insubstantial that it effectively prevented the Court from eceiving the requisite adversary presentation on the threshold, jurisdictional lestion. Faithful to the Mansfield rule, the Court [*57] had ordered ipplemental briefing on the jurisdictional question, but had yet to hear oral :gument on it. The Court reasoned that deciding the jurisdictional question ould be inappropriate under the circumstances, because "even the most diligent d zealous advocate could find his ardor somewhat dampened in arguing a risdictional issue where the decision on the merits is thus foreordained." 418 S. at 678. n10 -Footnotes- n10 Since the jurisdictional issue was under consideration only because the urt raised it on its own initiative after hearing oral argument on the merits, is especially ironic that Avrech has come to be cited in support of destepping jurisdiction altogether. -End Footnotes Norton involved a similar situation, except that the jurisdictional question d been fully briefed and argued before the intervening decision was handed wn. Nonetheless, the Court made clear that the effect of the intervening cision was to render the merits issues so "insubstantial" as "not even to pport the jurisdiction [*58] of a three-judge district court to consider hem] on remand. 427 U.S. at 531 (emphasis added); see id. at 530-31 ("The osition [in the intervening case] renders the merits in the present case a PAGE 121 1991 U.S. App. LEXIS 8977, *58 cided issue" - foreordained - "and thus no longer substantial in the risdictional sense."). en the mooting effect of the intervening decision in both Avrech and 12 11, a more fastidious Court might have either dismissed the appeals or cated the lower court judgments and remanded with instructions to dismiss, ternative dispositions that would have left the pending jurisdictional estions undecided by the Court. Cf. United States V. Munsingwear, 340 U.S. 36, (1950) (generally endorsing the latter course when a civil case becomes moot nding appeal). Instead, without deciding the jurisdictional questions, the urt reversed on the merits in Avrech and affirmed on the merits in Norton, asoning that "whichever disposition we undertake, the effect is the same. 427 S. at 532. Notwithstanding the Court's merits dispositions, it is clear from e supporting reasoning that Avrech [*59] and Norton permit this approach ly when an intervening decision renders a pending claim so "foreordained" or nsubstantial" that under cases like Bell V. Hood or Zucht V. King, the claim uld not even have supported federal jurisdiction had the intervening decision en decided beforehand. The majority might well be correct that the vironmental questions in this case are easier to resolve than are the standing estions, but the majority's answer is hardly so "foreordained" as to make the aims insubstantial in a jurisdictional sense. In sum, not a single Supreme Court case authorizes federal courts to shuffle ound unambiguously jurisdictional problems in order to issue judgments ambiguously on the merits. As one defender of this approach candidly admits, here is no Supreme Court opinion unequivocally holding that it is rmissible to assume justiciability and rule on the substantive merits." ent, supra, 127 U. Pa. L. Rev. at 745. recognize, of course, that the majority's approach finds support in the ecedents of this court decided after Augenblick. See, e.g., Adams V. Vance, 0 F.2d 950, 953-55 & n.7 (D.C. Cir. 1978) [*60] Chinese Am. Civic Council Attorney Gen., 566 F.2d 321, 325-26 & n.9 (D.C. Cir. 1977). Given only those cisions, I would of course be bound to accept this court's judgment that cases ch as Augenblick implicitly overruled cases such as Capron and Mansfield and a st of others. n11 But if such venerable precedent can be implicitly overruled ith not a single word of analysis or justification," Comment, supra, 127 U. L. Rev. at 713, it can also be revivified through express reaffirmation - as ppened twice last Term. However valid this circuit's cases once might have en, in my view they do not survive the Supreme Court's most recent onouncements in FW/PBS and Carden. Since FW/PBS and Carden were decided, the ly precedent from this court even arguably bypassing jurisdiction is Coker V. llivan, 902 F.2d 84 (D.C. Cir. 1990). In Coker, we assumed article III anding arguendo, resting instead on the ground that the challenge to the ency's enforcement decision was unreviewable under Heckler V. Chaney, 470 U.S. L (1985). See Coker, 902 F.2d at 90. [*61] Coker provides at best weak oport for the majority's approach, however; there, we explained that "the ternative rationale on which we rely is also a jurisdictional limitation." Id. 88 (emphasis added) ; see also Hispanic Broadcasting, No. 87-1285, slip op. at (citing Coker as having "dismissed case on non-constitutional jurisdictional unds to avoid problematic Article III inquiry"). -Footnotes- PAGE 122 1991 U.S. App. LEXIS 8977, *61 nll That concession, of course, would still not oblige me to endorse the ajority's approach in this case: = colleague - apparently of the view that the standing issue is too li. cult to resolve - believes we should pass on to the merits without deciding hether we have the constitutional authority to hear the case. To be sure, this ourt has on occasion followed that course, although not often in recent times, ut we are unaware of any case where a panel was criticized for not employing hat technique; in other words, for assuming its constitutional obligation. Here he parties have briefed the standing issue and we have done our best to answer he jurisdictional question raised. It is hard to understand why, under these ircumstances, it could be thought a judicial virtue not to do so. nited Transp. Union V. ICC, 891 F.2d 908, 911 (D.C. Cir. 1989), cert. denied, 10 S. Ct. 3271 (1990). -End Footnotes *62] Read in light of one hundred and eighty-seven years of other precedents, the upreme Court's opinions in FW/PBS and Carden confirm that federal courts must irst assure themselves that they have the authority to hear a dispute before hey may decide the dispute on the merits. See FW/PBS, 110 S. Ct. at 607-08; arden, 110 S. Ct. at 1021. Federal courts simply may not assume jurisdiction ypothetically. Some cases might cry out for decision on the merits; some might ose difficult jurisdictional problems. Our threshold duty to examine our own urisdiction is no less obligatory in either instance. II. "If there were no jurisdiction, there was no power to do anything but strike he case from the docket. In that view of the subject the matter was as much oram non judice as anything else could be " The Mayor V. Cooper, 73 U.S. 6 Wall.) 247, 250 (1868). In my view, this court has no jurisdiction to hear ross-Sound's environmental claims. I would therefore strike those claims from he docket and stop before reaching the merits. Because the majority here goes urther, I respectfully decline to join parts IV [*63] and V of the ajority's opinion and join only parts I, II, and III. EDERAL REPORTER, 2d SERIES U.S. V. BAKER HUGHES INC. 981 Cite as 908 F.2d 981 (D.C. Clr. 1990) 3. Monopolies 24(13) NITED STATES COURT OF APPEALS UNITED STATES of America, Rebuttal of prima facie case that ac- Appellant, quisition or merger will lessen competition in relevant market does not require clear V. Eleventh Circuit showing that entry into market by competi- BAKER HUGHES INC., Eimco Secoma, tors will be "quick and effective," rather, S.A., and Oy Tampella AB, Appellees. evidence on variety of factors can rebut No. 90-5060. prima facie case. Clayton Act, § 7, 15 U.S. DENIALS OF REHEARING EN BANC C.A. § 18. United States Court of Appeals, deral Rules of Appellate Procedure; Local Eleventh Circuit Rule 35) District of Columbia Circuit. 4. Monopolies 24(13) Denials where no member of the panel nor Judge in regular active Argued May 16, 1990. Misleading nature of statistics underly- ervice on the Court requested that the Court be polled on rehearing ing Government's prima facie case that Decided July 6, 1990. 11 banc. merger or acquisition would have effect of Denials after a poll requested by a member of the panel or a Circuit lessening competition, and sophistication of United States brought action to enjoin consumers purchasing hardrock hydraulic udge in regular active service. Denials on the Court's own motion after a poll requested by a member Finnish manufacturer's proposed acquisi- underground drilling rigs, provided support tion of French manufacturer of hardrock for district court's conclusion that Govern- of the panel or a Circuit Judge in regular active service. hydraulic underground drilling rigs. The ment's prima facie case of lessening of United States District Court for the Dis- competition was rebutted; market for such Docket Date of Citation of trict of Columbia, Gerhard A. Gesell, J., drilling rigs was so minuscule that every Number Denial Panel Decision 731 F.Supp. 3, denied injunction, and appeal sale of rig increased seller's market share GROUP 1 89-8359 6/20/90 M.D.Ga., 899 was taken. The Court of Appeals, Clar- by two to five percent, and consumers who ence Thomas, Circuit Judge, held that evi- generally purchased such rigs, for thou- F.2d 1136 ing 89-8407 6/19/90 N.D.Ga., 900 dence justified district court's conclusion sands of dollars, closely examined available F.2d 266 that acquisition would not substantially options and typically insisted on receiving rmers Home Admin 89-8359 6/20/90 M.D.Ga., 899 lessen competition in United States. multiple, confidential bids for each order. F.2d 1136 Clayton Act, § 7, 15 U.S.C.A. § 18. Affirmed. 5. Monopolies 24(13) District court's determination that en- 1. Monopolies 24(12) try into United States hardrock hydraulic When Government presents evidence underground drilling rig market would like- showing that transaction involving merger ly avert any anticompetitive effects of ac- or acquisition will lead to undue concentra- tion in market for particular product in quisition of one drilling rig manufacturer by second manufacturer, together with de- particular geographic area, Government es- termination that market share statistics tablishes presumption that transaction will were misleading and sophistication of con- substantially lessen competition in violation sumers was likely to foster competition, of Clayton Act, and burden then shifts to was sufficient to rebut Government's pri- party seeking acquisition or merger to re- ma facie case that acquisition would lessen but such presumption. Clayton Act, § 7, competition. Clayton Act, § 7, 15 U.S.C.A. 15 U.S.C.A. § 18. § 18. 2. Monopolies 24(12) If party seeking merger or acquisition 6. Monopolies 24(13) rebuts presumption that transaction will Antitrust defendant seeking to rebut substantially lessen competition, burden of presumption of anticompetitive effect of producing additional evidence of anticom- acquisition or merger must show that pri- petitive effect shifts to Government, and ma facie case inaccurately predicts relevant merges with ultimate burden of persuasion, transaction's probable effect on future which remains with Government at all competition. Clayton Act, § 7, 15 U.S.C.A. times. Clavton Act, § 7, 15 U.S.C.A. § 18. § 18. 982 908 FEDERAL REPORTER, 2d SERIES U.S. V. BAKER HUGHES INC. 983 Cite as 908 F.2d 981 (D.C. Clr. 1990) Appeal from the United States District United States HHUDR market in violation United States v. General Dynamics did not expressly state the legal standard Court for the District of Columbia (Civil of section 7 of the Clayton Act, 15 U.S.C. Corp., 415 U.S. 486, 496-504, 94 S.Ct. 1186, that it applied in its analysis of rebuttal Action No. 89-03333). § 18.¹ In December 1989, the government 1193-97, 39 L.Ed.2d 530 (1974); Philadel- evidence, failed to apply a sufficiently David Seidman, Atty., Dept. of Justice, sought and obtained a temporary restrain- phia Bank, 374 U.S. at 363, 83 S.Ct. at stringent standard. The government ar- with whom James F. Rill, Asst. Atty. Gen., ing order blocking the transaction. See 1741. If the defendant successfully rebuts gues that, as a matter of law, section 7 Michael Boudin and Judy L. Whalley, Dep- Temporary Restraining Order, United the presumption, the burden of producing defendants can rebut a prima facie case uty Asst. Attys. Gen., and Catherine G. States v. Baker Hughes Inc., No. 89-03333 additional evidence of anticompetitive ef- only by a clear showing that entry into O'Sullivan, Robert B. Nicholson and An- (D.D.C. Dec. 15, 1989). In February 1990, fect shifts to the government, and merges the market by competitors would be quick drea Limmer, Attys., Dept. of Justice, were the district court held a bench trial and with the ultimate burden of persuasion, and effective. Because the district court on the brief, for appellant. issued a decision rejecting the govern- which remains with the government at all failed to apply this standard, the govern- David Marx, Jr., with whom Ronald A. ment's request for a permanent injunction times. See Kaiser Aluminum & Chem. ment submits, the court erred in concluding and dismissing the section 7 claim. See Corp. v. FTC, 652 F.2d 1324, 1340 & n. 12 that the proposed acquisition would not Bloch, Lizbeth R. Levinson and Amy E. (ith Cir.1981). substantially lessen future competition in Hancock, for Oy Tampella AB and Eimco United States v. Baker Hughes Inc., 731 Secoma, S.A., and William J. Baer, with F.Supp. 3 (D.D.C.1990). The government By presenting statistics showing that the United States HHUDR market. whom Randal M. Shaheen for Baker immediately appealed to this court, re- combining the market shares of Tamrock We find no merit in the legal standard questing expedited proceedings and an in- and Secoma would significantly increase propounded by the government. It is de- Hughes Inc., were on the joint brief, for junction pending appeal. We granted the concentration in the already highly concen- void of support in the statute, in the case appellees. motion for expedited briefing and argu- trated United States HHUDR market, the law, and in the government's own Merger Before RUTH B. GINSBURG, ment, but denied the motion for an injune- government established a prima facie case Guidelines. Moreover, it is flawed on its SENTELLE, and THOMAS, Circuit tion pending appeal. The appellees con- of anticompotitivo offect. The district morits in three fundamental respects. summated the acquisition shortly there- court, however, found sufficient evidence First, it assumes that ease of entry by Judges. after. that the merger would not substantially competitors is the only consideration rele- Opinion for the Court filed by Circuit lessen competition to conclude that the de- vant to a section 7 defendant's rebuttal. [1,2] The basic outline of a section 7 fendants had rebutted this prima facie Second, it requires that a defendant who Judge CLARENCE THOMAS. horizontal acquisition case is familiar. By case. The government did not produce any seeks to show ease of entry bear the oner- CLARENCE THOMAS, Circuit Judge: showing that a transaction will lead to un- additional evidence showing a probability ous burden of proving that entry will be Appellee Oy Tampella AB, a Finnish cor- due concentration in the market for a par- of substantially lessened competition, and "quick and effective." Finally, by stating that the defendant can rebut a prima facie poration, through its subsidiary Tamrock ticular product in a particular geographic thus failed to carry its ultimate burden of AG, manufactures and sells hardrock hy- area,2 the government establishes a pre- persuasion. case only by a clear showing, the standard draulic underground drilling rigs sumption that the transaction will substan- [3] In this appeal, the government as- in effect shifts the government's ultimate (HHUDRs) in the United States and tially lessen competition. See United sails the court's conclusion that the defen- burden of persuasion to the defendant. Al- throughout the world. Appellee Baker States v. Citizens & Southern Nat'l Bank, dants rebutted the prima facie case. though the district court in this case did Hughes Inc., a corporation based in Hous- 422 U.S. 86, 120-22, 95 S.Ct. 2099, 2118-19, Doubtless aware that this court will set not expressly set forth a legal standard ton, Texas, owned a French subsidiary, aside the district court's findings of fact when it evaluated the defendants' rebuttal, 45 L.Ed.2d 41 (1975); United States v. Eimco Secoma, S.A. (Secoma), that was only if they are clearly erroneous, see Fed. we have carefully reviewed the court's Philadelphia Nat'l Bank, 374 U.S. 321, similarly involved in the HHUDR industry. 363, 83 S.Ct. 1715, 1741, 10 L.Ed.2d 915 R.Civ.P. 52(a), the government frames the thorough analysis of competitive conditions In 1989, Tamrock proposed to acquire Seco- (1963). The burden of producing evidence issue as a pure question of law, which we in the United States HHUDR market, and ma. to rebut this presumption then shifts to the review de novo. The government's key we are satisfied that the court effectively The United States challenged the pro- defendant. See, e.g., United States v. Ma- contention is that the district court, which applied a standard faithful to section 7.4 posed acquisition, charging that it would rine Bancorporation, 418 U.S. 602, 631, 94 3. From 1986 through 1988, Tamrock had an reprinted in 4 Trade Reg.Rep. (CCH) 11 13,103, at substantially lessen competition in the S.Ct. 2856, 2874-75, 41 L.Ed.2d 978 (1974); average 40.8% share of the United States 20,561-64 (1988). This acquisition has in- HHUDR market, while Secoma's share averaged creased the HHI in this market from 2878 to 1. Section 7 prohibits mergers and acquisitions Although the appellees quibble with the 17.5%. 731 F.Supp. at 6. In 1988 alone, the 4303. Brief for Appellant at 5 n. 3, 12 (calculat- the effect of which "may be substantially to court's product market definition, they conclude two firms enjoyed a combined share of 76% of ed from 1986-1988 figures; see 731 F.Supp. at lessen competition, or to tend to create a mo- that "the [district] court's product market defini- the market. (The district court inaccurately cal- 6). nopoly." 15 U.S.C. § 18. tion presages its finding that the extent of culated this figure as 66%. See id. at 10; Brief 4. Even if we found more impressive the argu- 2. The parties in this case do not seriously con- present competition and ease of entry preclude for Appellant at 10 n. 10; Brief for Appellees ment that the district court did not clearly artic- test the district court's definition of the relevant finding a violation of Section 7." Brief for app. A.) The acquisition thus has brought about ulate the legal standard applicable to a section 7 markets. The court defined the geographic Appellees at 10 (emphasis added). If the appel- a dramatic increase in the Herfindahl-Hirsch- rebuttal, it would remain open to us to affirm market as the entire United States, see 731 lees believe that the court's product market defi- man Index (HHI)-a yardstick of concentra- that court's judgment. Cf. Nelson v. United F.Supp. at 5-6, and the relevant product as three nition contributed to their victory, we see no lion-for this market. The Department of Jus- States, 838 F.2d 1280, 1285 (D.C.Cir.1988) types of HHUDRs: face drills ("jumbos"), long. reason to address their halfhearted and contra- lice's Merger Guidelines characterize as "highly ("[W]e may affirm a trial court's decision on a hole drills, and roof-bolting drills, as well as dictory challenges to that definition. concentrated" any market in which the HHI basis not relied on by the district court where associated spare parts, components, and acces- exceeds 1800. See United States Dep't of Jus- that ground finds support in the record.") (cita- sories, and used drills. See id. at 4, 6-8. lice, Merger Guidelines § 3.1 (June 14, 1984), tion omitted). 984 908 FEDERAL REPORTER, 2d SERIES U.S. v. BAKER HUGHES INC. 985 Cite as 908 F.2d 981 (D.C. Clr. 1990) Concluding that the court applied this legal quiry into future competitiveness; the So- prer, the Court stressed that a transaction ny made substantial lessening of competi- standard to factual findings that are not preme Court has never indicated that a must tion unlikely); United States v. Interna- clearly erroneous, we affirm the court's defendant seeking to rebut a prima facie be functionally viewed, in the context of tional Harvester Co., 564 F.2d 769, 773-79 denial of a permanent injunction and its case is restricted to producing evidence of its particular industry. That is, whether (7th Cir.1977) (company successfully rebut- dismissal of the government's section 7 ease of entry. Indeed, in numerous cases, the consolidation was to take place in an ted prima facie case by showing, among claim. defendants have relied entirely on non-en- industry that was fragmented rather other things, financial weakness of ac- try factors in successfully rebutting a pri- than concentrated, that had seen a recent quired company, de facto independence of I. ma facie case. trend toward domination by a few lead- acquired company from acquiring company, It is a foundation of section 7 doctrine, In United States v. General Dynamics ers or had remained fairly consistent in strong level of competition in relevant mar- disputed by no authority cited by the Corp., 415 U.S. 486, 94 S.Ct. 1186, 39 its distribution of market shares among ket, and tendency of the market toward government, that evidence on a variety of L.Ed.2d 530 (1974). for instance, the Su- the participating companies, that had ex- even stronger levels of competition). factors can rebut a prima facio case. preme Court rejected the government's an perienced easy access to markets by sup- Indeed, that a variety of factors other These factors include, but are not limited gument that a merger between two leading pliers and easy access to suppliers by than ease of entry can rebut a prima facie to, the absence of significant entry barriers coal producers would violate section 7. At buyers or had witnessed foreclosure of case has become hornbook law. See, e.g., in the relevant market. In this appeal, though the transaction would result in the business, that had witnessed the ready P. Areeda & H. Hovenkamp, Antitrust however, the government inexplicably im- two largest firms controlling about half of entry of new competition or the erection Law 919', 920.1, 921', 925', 934', 935', bues the entry factor with talismanic sig- all sales in an industry that was already of barriers to prospective entrants, all 939', at 813-23 (Supp.1989) (other factors nificance. If, to successfully rebut a prima highly concentrated because of a rapid de- were aspects, varying in importance with include significance of market shares and facie case, a defendant must show that cline in the number of competitors, the the merger under consideration, which concentration, likelihood of express collu- entry by competitors will be quick and ef- defendants produced considerable evidence would properly be taken into account. sion or tacit coordination, and prospect of fective, then other factors bearing on fu- that the merger would not substantially 370 U.S. at 321-22, 82 S.Ct. at 1521-22 efficiencies from merger); H. Hovenkamp, ture competitiveness are all but irrelevant. lessen competition. One of the parties to (footnote omitted).6 All these factors are Economics and Federal Antitrust Law The district court in this case considered at the merger owned only minimal reserves of relevant in determining whether a transac- § 11.6, at 307-11 (1985) (other factors in- least two factors in addition to entry: the coal, an irreplaceable raw material, and had tion is likely to lessen competition substan- clude supply of irreplaceable raw materials, misleading nature of the statistics underly- already committed these reserves through tially, but none is invariably dispositive. excess capacity, degree of product homo- ing the government's prima facie case and long-term contracts. This evidence led the See Note, Horizontal Mergers After Unit- geneity, marketing and sales methods, and the sophistication of HHUDR consumers. Court to conclude that the government's ed States V. General Dynamics Corp., 92 absence of a trend toward concentration); These non-entry factors provide compelling statistics regarding concentration in the Harv.L.Rev. 491, 500 (1978). L. Sullivan, Handbook of the Law of Anti- support for the court's holding that Tam- wake of the merger inaccurately portrayed In the wake of General Dynamics, the trust § 204, at 622-25 (1977) (other factors rock's acquisition of Secoma was not likely the post-merger company's weak competi- Supreme Court and lower courts have include industry structure, weakness of to lessen competition substantially. We tive stature, and that the defendants had found section 7 defendants to have success- data underlying prima facie case, elasticity have concluded that the court's considera- therefore rebutted the prima facie case. fully rebutted the government's prima fa- of industry demand, inter-industry cross- tion of these factors was crucial, and that Id. at 503-04, 94 S.Ct. at 1196-97. No- cie case by presenting evidence on a variety elasticities of demand and supply, product the government's fixation on ease of entry where did the Court consider barriers to of factors other than ease of entry. See, differentiation, and efficiency). See gener- is misplaced. entry. e.g., Citizens & Southern, 422 U.S. at 121- ally Antitrust Section, ABA, Horizontal Section 7 involves probabilities, not cer- Indeed, the Court in General Dynamics 23, 95 S.Ct. at 2119-20 (no lessening of Mergers: Law and Policy 162-75, 201-04, tainties or possibilities.⁵ The Supreme emphasized the comprehensive nature of a competition, and thus no violation of sec- 219-63 (Monograph No. 12, 1986). Court has adopted a totality-of-the-circum- section 7 inquiry, quoting at length from tion 7, where acquired banks were already It is not surprising, then, that the De- stances approach to the statute, weighing a its decision a decade earlier in Brown Shoe associated with acquiring bank; no discus- partment of Justice's own Merger Guide- variety of factors to determine the effects Co. v. United States, 370 U.S. 294, 82 S.Ct. sion of ease of entry); Lektro-Vend Corp. lines contain a detailed discussion of non- of particular transactions on competition. 1502, 8 L.Ed.2d 510 (1962). See General r. Vendo Co., 660 F.2d 255, 276 (7th Cir. entry factors that can overcome a presump- That the government can establish a prima Dynamics, 415 U.S. at 498, 94 S.Ct. at 1981) (acquired company's deteriorating tion of illegality established by market facie case through evidence on only one 1194. In Brown Shoe, the Court applied market position both before and after ac- share statistics. See United States Dep't factor, market concentration, does not ne- section 7 stringently, holding that a merger quisition rebutted prima facie case), cert. of Justice, Merger Guidelines (June 14, gate the breadth of this analysis. Evidence that created a company with a 5% share of denied, 455 U.S. 921, 102 S.Ct. 1277, 71 1984) [hereinafter Guidelines], reprinted in of market concentration simply provides a a highly fragmented market violated the L.Ed.2d 461 (1982); FTC v. National Tea 4 Trade Reg.Rep. (CCH) 13,103, at 20,- convenient starting point for a broader in- statute. In arriving at this result, how- Co., 603 F.2d 694, 699-700 (8th Cir.1979) 561-64 (1988). According to the Guide- (weak market position of acquiring compa- lines, these factors include changing mar- 5. See Brown Shoe Co. V. United States, 370 U.S. for dealing with clear-cut menaces to competi- 294, 323, 82 S.Ct. 1502, 1522-23, 8 L.Ed.2d 510 tion; no statute was sought for dealing with 6. See also id. at 322 n. 38, 82 S.Ct. at 1522 n. 38 amination of the particular market-its struc- (1962) ("Congress used the words 'may be sub- ephemeral possibilities. Mergers with a proba- ("Statistics reflecting the shares of the market ture, history and probable future-can provide stantially to lessen competition' (emphasis sup- ble anticompetitive effect were to be proscribed controlled by the industry leaders and the par- the appropriate setting for judging the probable plied). to indicate that its concern was with by this Act.") (footnote omitted) (emphasis add- ties to the merger are, of course, the primary anticompetitive effect of the merger."). probabilities, not certainties. Statutes existed ed). index of market power; but only a further ex- 986 908 FEDERAL REPORTER, 2d SERIES U.S. V. BAKER HUGHES INC. 987 Cite as 908 F.2d 981 (D.C. Clr. 1990) ket conditions (§ 3.21), the financial condi- leading. Because the United States The government has not provided us court's conclusion that the defendants suc- tion of firms in the relevant market HHUDR market is minuscule, market with any reason to suppose that these find- cessfully rebutted the government's prima (§ 3.22), special factors affecting foreign share statistics are "volatile and shifting," ings of fact are unsupported in the record facie case. firms (§ 3.23), the nature of the product 731 F.Supp. at 11, and easily skewed. In or clearly erroneous, see Fed.R.Civ.P. 52(a). and the terms of sale (§ 3.41), information Ля authority for its "quick and effective" 1986, for instance, only 22 HHUDRs were We thus accept them as correct. These about specific transactions and buyer mar- sold in the United States. In 1987, the findings provide considerable support for entry test, the government relies primarily ket characteristics (§ 3.42), the conduct of the district court's conclusion that the de- on United States v. Waste Management, number rose to 43, and in 1988 it fell to 38. firms in the market (§ 3.44), market per- Inc., 743 F.2d 976, 981-84 (2d Cir.1984). Every HHUDR sold during this period, fendants successfully rebutted the govern- formance (§ 3.45), and efficiencies (§ 3.5). This reliance is misplaced. Neither Waste thus, increased the seller's market share by ment's prima facie case. Because the de- Given this acknowledged multiplicity of two to five percent. A contract to provide fendants also provided compelling evidence Management nor any other case purports relevant factors, we are at a loss to under- on ease of entry into this market, we need to establish a categorical "quick and effec- multiple HHUDRs could catapult a firm stand on what basis the government has not decide whether these findings, without tive" entry requirement. The Second Cir- from last to first place. The district court decided that "[t]o rebut the government's found that, in this unusual market, "at any more, are sufficient to rebut the govern- cuit in Waste Management simply noted prima facie case, the defendants were re- ment's prima facie case. The foregoing that the defendant had successfully rebut- given point in time an individual seller's quired to show that entry would be both future competitive strength may not be analysis of non-entry factors is intended ted the government's prima facie case by showing that entry into the Dallas/Fort quick and effective in preventing supra- accurately reflected." Id. at 9. While ac- merely to underscore that, contrary to the competitive prices." Brief for Appellants knowledging that the HHUDR market government's assumption, these factors are Worth trash collection market was "easy." at 11-12 (emphasis added). If the district would be highly concentrated after Tam- relevant, and can even be dispositive, in a Id. at 983. That a defendant may success- rock acquired Secoma, the court found that section 7 rebuttal analysis. fully rebut a prima facie case by showing court in this case had focused exclusively quick and effective entry does not mean on entry, it might be understandable that such concentration in and of itself would the government would mirror that focus in II. that successful rebuttal requires such a not doom competition. High concentration showing. We are at a loss to understand attacking the court's conclusion. The dis- has long been the norm in this market. The existence and significance of barri- how the government derived from Waste trict court, however, canvassed a number For example, only four firms sold ers to entry are frequently, of course, cru- Management (where, lest the irony be of non-entry factors that contributed to its conclusion that the defendants had rebut- HHUDRs in the United States between cial considerations in a rebuttal analysis. missed, the government lost) the proposi- In the absence of significant barriers, a 1986 and 1989. Id. at 5-6.⁷ Nor is concen- tion that "a defendant arguing supposed ted the prima facie case. By ignoring company probably cannot maintain supra- tration surprising where, as here, a product ease of entry can rebut the government's these factors, the government's arguments competitive pricing for any length of time. against that conclusion fall wide of the is esoteric and its market small. Indeed, See, e.g., United States v. Falstaff Brew- prima facie case only by clearly showing mark. the trial judge found that "[c]oncentration that entry will be both quick and effective ing Corp., 410 U.S. 526, 532-33, 93 S.Ct. has existed for some time [in the United [4] The district court's analysis of this 1096, 1100-01, 35 L.Ed.2d 475 (1973); Unit- at preventing supracompetitive pricing." States HHUDR market] but there is no case is fully consonant with precedent and ed States v. Syufy Enters., 903 F.2d 659, Brief for Appellant at 14 (emphasis added). proof of overpricing, excessive profit or logic. The court reviewed the evidence 664 (9th Cir.1990); California v. American That the "quick and effective" standard any decline in quality, service or diminish- proffered by the defendants as part of its Stores Co., 872 F.2d 837, 842 (9th Cir.1989), lacks support in precedent is not surpris- ing innovation." Id. at 12. overall assessment of future competitive- rev'd on other grounds, - U.S. 110 ing, for it would require of defendants a ness in the United States HHUDR market. The second non-entry factor that the dis- S.Ct. 1853, 109 L.Ed.2d 240 (1990); Ball degree of clairvoyance alien to section 7, As noted above, the court gave particular trict court considered was the sophistica- Memorial Hosp., Inc. v. Mutual Hosp. which, as noted above, deals with probabili- weight to two non-entry factors: the tion of HHUDR consumers. HHUDRs Ins., 784 F.2d 1325, 1335-36 (7th Cir.1986). ties, not certainties. Although the govern- flawed underpinnings of the government's currently cost hundreds of thousands of The district court in this case reviewed the ment disclaims any attempt to impose upon prima facie case and the sophistication of dollars, and orders can exceed $1 million. prospects for future entry into the United defendants the burden of proving that en- HHUDR consumers. The court's consider- Id. at 8. These products are hardly trink- States HHUDR market and concluded that, try actually will occur, see Reply Brief for ation of these factors was not only appro- ets sold to small consumers who may pos- overall, entry was likely, particularly if Appellant at 13 n. 13, we believe that an priate, but imperative, because in this case sess imperfect information and limited bar Tamrock's acquisition of Secoma were to inflexible "quick and effective" entry re- these factors significantly affected the gaining power. HHUDR buyers closely lead to supracompetitive pricing. The quirement would tend to impose precisely probability that the acquisition would have examine available options and typically in- government attacks this conclusion, assert- such a burden. A defendant cannot real- anticompetitive effects. sist on receiving multiple, confidential bids ing that, as a matter of law, the court istically be expected to prove that new com- With respect to the first factor, the sta- for each order. Id. This sophistication. should have required the defendants to petitors will "quickly" or "effectively" en- show clearly that entry would be "quick ter unless it produces evidence regarding tistical basis of the prima facie case, the the court found, was likely to promote com- and effective." We reject this novel and specific competitors and their plans. Such court accepted the defendants' argument petition even in a highly concentrated mar unduly onerous standard. The district evidence is rarely available; potential com- that the government's statistics were mis- ket. Id. at 11. court's factual findings amply support its petitors have a strong interest in downplay- 7. See also supra note 3 (HHI of United States which HHI exceeds 1800 as "highly concentral. determination that future entry into the ing the likelihood that they will enter a HHUDR market before merger was 2878; De- ed"). United States HHUDR market is likely. given market. When the government sar- partment of Justice regards any market in This determination, in turn, supports the castically "wonders how slow and ineffec- 988 908 FEDERAL REPORTER, 2d SERIES U.S. V. BAKER HUGHES INC. 989 Cite 908 F.2d 981 (D.C. Clr. 1990) tive entry rebuts a prima facie case," id. at time, the Department is unlikely to chal 12, it misses a crucial point. If the totality lenge mergers in that market for future expansion.⁸ 731 F.Supp. at 9, IIL La of a defendant's evidence suggests that assessing the ease of entry into a mar 10. 11. Second, the court stressed that a entry will be slow and ineffective, then the ket, the Department will consider the number of firms competing in Canada and Finally, we consider the strength of the district court is unlikely to find the prima likelihood and probable magnitude of en- other countries had not penetrated the showing that a section 7 defendant must try in response to a "small but signift l'nited States market, but could be expect- make to rebut a prima facie case. The facie case rebutted. This is a far cry, cant and nontransitory" increase in price. ed to do so if Tamrock's acquisition of district court simply reviewed the evidence however, from insisting that the defendant must invariably show that new competi- Secoma led to higher prices. Id. at 10-11.' that the defendants presented and conclud- tors will enter quickly and effectively. Guidelines § 3.3, reprinted in 4 Trade Because the market is small, "[i]t is inex- ed that the acquisition was not likely to Reg.Rep. (CCH) at 20,562. In its brief, Furthermore, the supposed "quick and pensive to develop a separate sales and substantially lessen competition. The moreover, the government fails to state its effective" entry requirement overlooks the service network in the United States." Id. government argues that the court erred by own standard consistently, insisting at one at 8. Third, these firms would exert com- failing to require the defendants to make a point that 11 firm that never enters is given point that a defendant show that entry will petitive pressure on the United States "clear" showing. See Brief for Appellant market can nevertheless exert competitive be "sure, swift, and substantial." Brief for at 13. The relevant precedents, however, pressure on that market. If barriers to HHUDR market even if they never actual- Appellant at 16. Our uncertainty over the ly entered the market. Id. at 10-11. Final- suggest that this formulation overstates entry are insignificant, the threat of entry meaning and implications of "quick and can stimulate competition in a concentrated Iv. the court noted that there had been the defendants' burden. We conclude that effective" entry makes us all the more tremendous turnover in the United States a "clear" showing is unnecessary, and we market, regardless of whether entry ever resistant to the imposition of such a re- occurs. See Falstaff Brewing, 410 U.S. at HHUDR market in the 1980s. Secoma, for are satisfied that the district court required quirement. Nor has the government 532-33, 93 S.Ct. at 1100-01 (potential for example, did not sell a single HHUDR in the defendants to produce sufficient evi- shown that current section 7 law is so the United States in 1983 or 1984, but then dence. defendant Falstaff to enter the market confused as to warrant the invention of a might induce brewers in the Northeast to lowered its price and improved its service, The government's "clear showing" lan- new standard. maintain competitive prices); FTC v. Proc- becoming market leader by 1989. Id. at 9, guage is by no means unsupported in the ter & Gamble Co., 386 U.S. 568, 581, 87 The government's insistence on a "quick 10. Secoma's growth suggests that com- case law. In the mid-1960s, the Supreme S.Ct. 1224, 1231-32, 18 L.Ed.2d 303 (1967) and effective" entry standard only reaf- petitors not only can, but probably will, Court construed section 7 to prohibit virtu- ("It is clear that the existence of Procter at firms our doubts, raised in section I of this enter or expand if this acquisition leads to ally any horizontal merger or acquisition. the edge of the industry exerted considera- opinion, about the government's approach higher prices. The district court, to be At the time, the Court envisioned an ideal ble influence on the market [The] in- to section 7 analysis. Predicting future sure, also found some facts suggesting dif- market as one composed of many small dustry was influenced by each firm's pre- competitive conditions in a given market, as ficulty of entry,¹⁰ but these findings do not competitors, each enjoying only a small dictions of the market behavior of its com- the statute and precedents require, calls negate its ultimate finding to the contrary. market share; the more closely a given petitors, actual and potential.") (emphasis for a comprehensive inquiry. The govern- In sum, we see no error-legal or factu- market approximated this ideal, the more added); cf. Byars v. Bluff City News Co., ment's standard would improperly narrow al-in the district court's determination competitive it was presumed to be. See 609 F.2d 843, 851 n. 19 (6th Cir.1979) ("If the section 7 inquiry, channelling what that entry into the United States HHUDR United States v. Aluminum Co. of Am., entry barriers are low, the threat of poten- should be an overall analysis of competi- market would likely avert anticompetitive 377 U.S. 271, 280, 84 S.Ct. 1283, 1289, 12 tial competition operates as a significant tiveness into a determination of whether a effects from Tamrock's acquisition of Seco- L.Ed.2d 314 (1964) ("It is the basic premise check on monopoly power since competitors defendant has shown particular facts. ma. The court's determination on entry, of [section 7] that competition will be most will quickly enter the market if prices are considered along with the findings dis- vital 'when there are many sellers, none of raised significantly."). If a firm that never [5] Having rejected the "quick and ef- cussed in section I of this opinion, suffices which has any significant market share.'') enters a market can keep that market com- fective" entry standard itself, we turn to rebut the government's prima facie case. (quoting United States v. Philadelphia petitive, a defendant seeking to rebut a briefly to the government's more general prima facie case certainly need not show argument that the district court's findings 8. As the Guidelines note, "'Entry' may occur as ers would exist after the merged firm had elimi- firms outside the market enter for the first time nated some of its rivals, because at that point that any firm will enter the relevant mar- regarding ease of entry failed to support or as fringe firms currently in the market greatly the remaining firms would begin to charge su- ket. its conclusion that the defendants had re- expand their current capacity." Guidelines pracompetitive prices, and the barriers that ex- The final flaw in the proposed "quick and butted the prima facie case. The district § 3.3, reprinted in 4 Trade Reg.Rep. (CCH) at isted during competitive conditions might well court in this case discussed a number of 20,562 n. 20 (emphasis added). prove insignificant."). effective" standard is its manipulability. The adjectives "quick" and "effective" are considerations that led it to conclude that 9. Some of these firms have already tried, but not self-defining, and have not traditionally entry barriers to the United States failed, to penetrate the United States HHUDR 10. The court, for instance, noted that HHUDRs HHUDR market were not high enough to market. As the district court correctly noted, are custom-made, and thus are not readily inter- been used in the section 7 context. The however, failed entry in the past does not neces- changeable or replaceable. Buyers, therefore, government's Merger Guidelines do not use impede future entry should Tamrock's ac- sarily imply failed entry in the future: if prices tend to return to sellers from whom they have the words when discussing entry, noting quisition of Secoma lead to supracompeti- reach supracompetitive levels, a company that purchased in the past. 731 F.Supp. at 8. The tive pricing. First, the court noted that at has failed to enter in the past could become court also found that HHUDR customers typi- only that least two companies, Cannon and Inger competitive. See 731 F.Supp. at 11; cf. Cargill, cally place great importance on assurances of [i]f entry into a market is so easy that Inc. v. Monfort of Colo., Inc., 479 U.S. 104, 119 product quality and reliable future service- existing competitors could not succeed in soll-Rand, had entered the United States n. 15, 107 S.Ct. 484, 494 n. 15, 93 L.Ed.2d 427 considerations that may handicap new entrants. raising price for any significant period of HHUDR market in 1989, and were poised (1986) ("In evaluating entry barriers a court Id. It also noted the significant economies of should focus on whether significant entry barri- scale involved in manufacturing HHUDRs. Id. 990 908 FEDERAL REPORTER, 2d SERIES U.S. v. BAKER HUGHES INC. 991 Cite as 908 F.2d 981 (D.C. Clr. 1990) Nat'l Bank, 374 U.S. 321, 363, 83 S.Ct. dismissed the defendants' contention that carded Philadelphia Bank's insistence fects") (emphasis added). The more com- 1715, 1741, 10 L.Ed.2d 915 (1963)). the post-merger market was highly compet- that a defendant "clearly" disprove anti- pelling the prima facie case, the more evi- This perspective animated a series of de- itive. Id. at 277-78, 86 S.Ct. at 1482" competitive effect, and instead described dence the defendant must present to rebut cisions in which the Court stated that a Noting that the market was "marked at the the rebuttal burden simply in terms of a it successfully. A defendant can make the section 7 defendant's market share mea- same time by both a continuous decline in "showing." See, e.g., United States v. Ma- required showing by affirmatively showing sures its market power, that statistics the number of small businesses and a large rine Bancorporation, 418 U.S. 602, 631, 94 why a given transaction is unlikely to sub- alone establish a prima facie case, and that number of mergers," the Von's Grocery S.Ct. 2856, 2874-75, 41 L.Ed.2d 978 (1974) stantially lessen competition, or by discred- a defendant carries a heavy burden in seek- Court predicted that, if the merger were lafter government established prima facie iting the data underlying the initial pre- ing to rebut the presumption established by not undone, the market "would slowly but case, "the burden was then upon appellees sumption in the government's favor. such a prima facie case. The Court most inevitably gravitate from a market of many to show that the concentration ratios, clearly articulated this approach in Phila- small competitors to one dominated by one which can be unreliable indicators of actual By focusing on the future, section 7 delphia Bank: market behavior, did not accurately depict gives a court the uncertain task of assess- or a few giants, and competition would Th[e] intense congressional concern with the economic characteristics of the [rele- ing probabilities. In this setting, allocation thereby be destroyed." Id. at 278, 86 S.Ct. of the burdens of proof assumes particular the trend toward concentration [underly- at 1482; see also United States v. Pabst vant] market") (citation omitted) (emphasis ing section 7] warrants dispensing, in added); United States v. Citizens & importance. By shifting the burden of pro- Brewing Co., 384 U.S. 546, 550-52, 86 S.CL certain cases, with elaborate proof of 1665, 1668-69, 16 L.Ed.2d 765 (1966) (acqui- Southern Nat'l Bank, 422 U.S. 86, 120, 95 ducing evidence, present law allows both market structure, market behavior, or S.Ct. 2099, 2118, 45 L.Ed.2d 41 (1975) (after sides to make competing predictions about sition producing brewer accounting for probable anticompetitive effects. Specif- 4.49% of nationwide beer sales violates sec- government established prima facie case, a transaction's effects. If the burden of "[i]t was incumbent upon [the defen- production imposed on a defendant is un- ically, we think that a merger which pro- tion 7; brewer's rebuttal evidence virtually dant] to show that the market-share statis- duly onerous, the distinction between that duces a firm controlling an undue per- ignored). tics gave an inaccurate account of the ac- burden and the ultimate burden of persua- centage share of the relevant market, Although the Supreme Court has not and results in a significant increase in quisitions' probable effects on competi- sion-always an elusive distinction in prac- overruled these section 7 precedents, it has tion") (emphasis added). Without overrul- tice-disintegrates completely. A defen- the concentration of firms in that mar- cut them back sharply. In General Dy- ing Philadelphia Bank, then, the Supreme dant required to produce evidence "clearly" ket, is so inherently likely to lessen com- namics, 415 U.S. at 498-504, 94 S.Ct. at Court has at the very least lightened the disproving future anticompetitive effects petition substantially that it must be en- 1194-97, the Court affirmed a district court evidentiary burden on a section 7 defen- must essentially persuade the trier of fact joined in the absence of evidence clearly determination that, by presenting evidence dant. See generally Note, 92 Harv.L.Rev. on the ultimate issue in the case-whether showing that the merger is not likely to at 491 (describing impact of General Dy- have such anticompetitive effects. that undermined the government's statis- a transaction is likely to lessen competition tics, section 7 defendants had successfully namics on section 7 jurisprudence). substantially. Absent express instructions 374 U.S. at 363, 83 S.Ct. at 1741 (emphasis rebutted a prima facie case. In so holding, added). Philadelphia Bank involved a [6] In the aftermath of General Dy- to the contrary, we are loath to depart the Court did not expressly reaffirm or namics and its progeny, a defendant seek- from settled principles and impose such a proposed merger that would have created a disavow Philadelphia Bank's statement bank commanding over 30% of a highly ing to rebut a presumption of anticompeti- heavy burden. Sce Kaiser Aluminum & that a company must "clearly" show that a concentrated market. While acknowl- tive effect must show that the prima facie Chem. Corp. v. FTC, 652 F.2d 1324, 1340 & transaction is not likely to have substantial case inaccurately predicts the relevant n. 12 (7th Cir.1981); cf. Texas Dep't of edging that the banks could in principle anticompetitive effects. The Court simply transaction's probable effect on future Community Affairs v. Burdine, 450 U.S. rebut the government's prima facie case, held that the district court was justified, the Court found unpersuasive the banks' competition. See American Stores, 872 248, 253-56, 101 S.Ct. 1089, 1093-95, 67 based on all the evidence, in finding that evidence challenging the alleged anticom- F.2d at 842 (defendant can rebut prima L.Ed.2d 207 (1981) (applying similar pro- "no substantial lessening of competition oc- petitive effect of the merger. See id. at facie case "through evidence demonstrat- duction-burden-shifting analysis to employ- curred or was threatened by the acquisi- 366-72, 83 S.Ct. at 1743-46. ing that statistics on market share, market ment discrimination suits under title VII, tion." General Dynamics, 415 U.S. at 498, concentration, and market concentration and noting that "[t]he ultimate burden of In United States v. Von's Grocery Co., 94 S.Ct. at 1194. trends portray inaccurately the merger's persuading the trier of fact remains 384 U.S. 270, 86 S.Ct. 1478, 16 L.Ed.2d 555 probable effects on competition") (empha- at all times with the plaintiff," id. at 253, (1966), the Court further emphasized the General Dynamics began a line of deci- weight of a defendant's burden. Despite sions differing markedly in emphasis from sis added); cf. Waste Management, 743 101 S.Ct. at 1093); 9 J. Wigmore, Evidence the Court's antitrust cases of the 1960s. F.2d at 981 (defendant can rebut prima § 2489, at 300 (J. Chadbourn rev.ed. 1981) evidence that a post-merger company had only a 7.5% share of the Los Angeles retail Instead of accepting a firm's market share facie case "by a demonstration that the (burden of persuasion "never shifts" away as virtually conclusive proof of its market merger will not have anticompetitive ef- from plaintiff). grocery market, the Court, citing anticom- petitive "trends" in that market, ordered power, the Court carefully analyzed defen- the lower courts, has said repeatedly that the ment whether the challenged acquisition is the merger undone. The Court summarily dants' rebuttal evidence.¹² These cases dis- economic concept of competition, rather than likely to hurt consumers, as by making it any desire to preserve rivals as such, is the easier for the firms in the market to collude, 11. Justice Stewart, in dissent, emphasized the 12. Judge Posner has elucidated this point: lodestar that shall guide the contemporary expressly or tacitly, and thereby force price considerable amount of evidence in the record The most important developments that cast application of the antitrust laws, not exclud- above or farther above the competitive level. indicating the market's competitiveness. 384 doubt on the continued vitality of such cases ing the Clayton Act Applied to cases Hospital Corp. of Am. V. FTC, 807 F.2d 1381, U.S. at 290-301, 86 S.Ct. at 1489-95 (Stewart, J., as Brown Shoe and Von's are found in other brought under Section 7. this principle re- 1386 (7th Cir. 1986), cert. denied, 481 U.S. 1038, cases, where the Supreme Court, echoed by quires the district court to make a judg. 107 S.Ct. 1975, 95 L.Ed.2d 815 (1987). dissenting). 992 908 FEDERAL REPORTER, 2d SERIES COMMI Imposing a heavy burden of production on a defendant would be particularly ano- F.Supp. at 12. The government has given sculpture failed to ac us no reason to reverse that conclusion. malous where, as here, it is easy to estab- theme and format; (: For the foregoing reasons, the judgment decisionmaker was " lish a prima facie case. The government, of the district court is Park Service's nubmi after all, can carry its initial burden of production simply by presenting market Affirmed. davits did not justify to be taken from the concentration statistics. To allow the Affirmed. government virtually to rest its case at KEY NUMBER SYSTEM that point, leaving the defendant to prove the core of the dispute, would grossly in- 1. United States - flate the role of statistics in actions The National P: brought under section 7. The Herfindahl- abuse its discretion or Hirschman Index cannot guarantee litiga- capricious fashion " tion victories." Cf. Ball Memorial Hosp., COMMUNITY FOR CREATIVE without regard to the 784 F.2d at 1336 (explaining that "[m]arket NON-VIOLENCE, et al., ture, that sculpture share is just a way of estimating market Appellants, family was not a power, which is the ultimate considera- v. symbol that accorded tion," and noting that "[w]hen there are format of the Christn better ways to estimate market power, the Manuel LUJAN, Jr., Secretary of the on the ellipse, behind court should use them"). Requiring a Interior, et al. thus refused to include "clear showing" in this setting would move No. 89-5218. pageant. 5 U.S.C.A. far toward forcing a defendant to rebut a probability with a certainty. United States Court of Appeals, 2. Administrative La District of Columbia Circuit. -507 United States 0-57 Argued May 16, 1990. The National Parl The appellees in this case presented the Decided July 17, 1990. district court with considerable evidence re- explained the basis of garding the United States HHUDR market. sculpture of homeless The court credited the evidence concerning Action was brought challenging denial of Christmas pageant the sophistication of HHUDR consumers by the National Park Service of request for lipse, behind the Whit and the insignificance of entry barriers, as inclusion of a sculpture of a homeless fami- that it did not depict a well as the argument that the statistics ly in Christmas pageant of peace on the Christmas symbol. underlying the government's prima facie ellipse, behind the White House. Plain- seq. case were misleading. This evidence amply tiff's motion for preliminary injunction was 3. Federal Civil Proc. justified the court's conclusion that the pri- denied, and Park Service's motions for pro- In litigation cone ma facie case inaccurately depicted the tective order and summary judgment were the National Park Ser\ probable anticompetitive effect of Tam- granted by the United States District Court trative Procedure Act rock's acquisition of Secoma. Because the for the District of Columbia, Louis F. Ober- tain sculpture to be di government did not produce sufficient evi- dorfer, J., and plaintiff appealed. The pageant, submission by dence to overcome this successful rebuttal, Court of Appeals, Sentelle, Circuit Judge, inappropriate litigation the district court concluded that "it is not held that: (1) the Park Service did not justify allowing a de₁ likely that the acquisition will substantially abuse its discretion or act in an arbitrary from the regional dires lessen competition in the United States ei- and capricious fashion; (2) the Park Service Service adequately ju ther immediately or long-term." 731 adequately explained its conclusion that the the record materials. 13. We refer the government to its own Merger that the Department of Justice has ignored its seq., 706(2)(A). Guidelines, which recognize that "[i]n a variety own admonition. The government does not 4. Federal Civil Proc of situations, market share and market concen- maximize its scarce resources when it allows tration data may either understate or overstate statistics alone to trigger its ponderous enforce- Discovery of ag. the likely future competitive significance of a ment machinery. Cf. Syufy Enters., 903 F.2d at process is allowed in firm or firms in the market." Guidelines § 3.2, 672 ("It is a tribute to the state of competition in America that the Antitrust Division of the De- es: where there has b. reprinted in 4 Trade Reg.Rep. (CCH) at 20,561. Although the Guidelines disclaim "slavish[ ad- partment of Justice has found no worthier tar- of bad faith or improp here[nce]" to such data, id., statement, reprinted get than this paper tiger on which to expend examination of decision in 4 Trade Reg.Rep. (CCH) at 20,552, we fear limited taxpayer resources."). only possibility for eft THE WALL STREET JOURNAL. On Brown V. Board of Education, Call Him Thurgood Thomas The NAACP board is scheduled to de- There are nearly identical arguments the Fourteenth Amendment, separate but cide today whether to join the interest about what the Brown opinion should have equal could have been invalidated without groups that oppose a black Supreme Court said in Mr. Marshall's legal briefs in the citing "Kenneth Clark's controversial doll nominee. Benjamin Hooks has said his case and Judge Thomas's recent speeches studies, which could just as easily have group would have preferred another Thur- and law-review articles. They agreed that been used in support of segregation as good Marshall. The NAACP should know the court should have based its decision against It." that when it comes to the Supreme Court's on legal and constitutional sources. not so- The court missed the forest for the ciologists. They both referred to the Decla- trees. "The Brown focus on environment Rule of Law ration of Independence's self-evident truth overlooks the real problem with segrega- that "all men are created equal." which fi- tion, its origin in slavery. which was at nally applied to blacks after the Civil War fundamental odds with the founding princi- By L. Gordon Crovitz through the Fourteenth Amendment. ples. Had Brown done so. it would have Mr. Marshall's brief and Judge been forced to talk about slavery. which it Thomas's writings both cited Justice Har- never mentions," Judge Thomas wrote. He most important civil-rights case, Clarence Thomas is another Thurgood Marshall. With all the smoke cooked up by Judge No Disagreement Hero Thomas's critics. no one seems to have no- Thorgood Marshall Clarence Themas ticed that he takes precisely the same (As the NAACP lawyer in Brown V. Board of (Writing in the Howard Law Journal in 1987): broad view of the constitutional promise of Education in 1954 arguing for a broad constitu- The great flaw of Brown is that it did not rely equality that Mr. Marshall as the lawyer tional rejection or the separate-but-equal doctrine): on Justice Hartan's dissent in Pleasy. which arguing Brown l'. Board of Education While the majority opinion sought to understood well that the fundamental issue of tried-unsuccessfully-to persuade the Su- rationalize its holding on the basis of the state's guidance by the Founders' constitutional preme Court to adopt. judgment that separation of races was principles tay at the heart of the segregation The 1954 case was a great victory for conducive to public peace and order. Justice issue Justice Hartan's Plessy opinion is a the civil-rights movement and especially Harlan knew all too well that the seeds for good example of thinking in the spirit of the for the NAACP where Mr. Marshall continuing racial animosities had been Founding. His arguments can be fully worked. The justices finally declared that planted. "Our Constitution," said Justice appreciated only in light of the Founders' rate but equal facilities were unconsti- Hartan, "is colorblind, and neither knows nor intentions. Largely as a result of the dubious al. A filibuster in the Senate perpetu- tolerates classes among citizens." n is the reasoning of the post-Plessy Court. and a Jim Crow segregation. so it was ap- dissenting opinion of Justice Hartan, rather national indifference to the rights of all propriate that the court struck down these than the majority opinion in Plessy K Ferguson, Americans. Justice Harlen's argument that racist laws. that is in keeping with the scope and meaning the Constitution is "colorblind" did not rally of the Fourteenth Amendment. supporters. The problem is that Brown is a classic example of a correct result reached by lousy reasoning. The opinion by Chief Jus- lan's dissent from the 1896 case that estab- said that a better understanding of the tice Earl Warren was based almost en- lished the doctrine of separate but equal, "first principles of equality and liberty" tirely on dubious sociological data on how Plessy v. Ferguson (see excerpts nearby) would "lead us above petty squabbling much better black students supposedly Justice Harian would instead have given over 'quotas,' 'affirmative action' and learn when they study in the same class- the Fourteenth Amendment its common- race-conscious remedies of social ills." rooms as whites. A famous footnote cites sense reading, which is that it was in- Once on the Supreme Court, Mr. Mar- behavior studies in publications such as tended to replace slavery with equality by shall supported quotas, but be made some the International Journal of Opinion and forbidding the government from treating of the same points about a colorblind Con- Attitude Research. It's now clear that this people differently by race. The amend- stitution in his brief in Brown. "The roots case was the beginning of an era of judi- ment promised blacks all the privileges of our American egalitarian ideal extend cial activism that substituted shadows, and immunities of citizenship and equal deep into the history of the Western penumbras and judicial social engineering protection of the laws. world." the brief said. "Philosophers of the for adherence to constitutional text and Judge Thomas wrote that if the opinion seventeenth and eighteenth centuries pro- original intent. in Brown had adopted this broader view of duced an intellectual climate in which the JULY 31, 1991 equality of man was a central concept. Their beliefs rested upon the basic proposi- tion that all man are endowed with certain natural rights." Mr. Marshall's reference to natural rights is important because Judge Thomas's critics accuse him of weirdness for using similar terms. For different rea- sons, it's important reassurance for both liberals and conservatives to understand why Judge Thomas wrote about natural rights. The reason was his search as head of the Equal Employment Opportunity Commission for a more enduring guaran- tee of equality than the fleeting legal stan- dards in Brown. Liberals should know that Judge Thomas is not on a goose chase for penum- bras or emanations from the Constitution into which he can insert his conservative policy preferences-as Justice Marshall too often did to enact his liberal views. Conservatives should know that he invokes natural rights in the service of original-in- tent jurisprudence. His law review article, "Toward a 'Plain Reading' of the Constitu- tion-The Declaration of Independence in Constitutional Interpretation," stressed that terms must be read according to their original meaning. Individual liberty is con- stitutionally protected, but group rights are not: discrimination must be punished, but not by mandating quotas. The NAACP's Mr. Hooks recently noted this distinction. Judge Thomas is "not without some good points." he said, adding that "if a black or a woman has been indi- vidually discriminated against or mis- treated he'll go to the ends of the earth to correct it." Now it turns out there's not much dif- ference between Justice Marshall and Judge Thomas on the broadest issues of civil rights. It will be fascinating to see if the NAACP has the courage to abandon its usual liberal allies who hope to do to Judge Thomas what they did to Robert Bork. The Washington Post JULY 19, 1991 Charles Krauthammer The greater curiosity is the charge of judicial activism. Coming from The history of the liberal jurispru- Tribe, this is hilarious. Tribe is one of dence he has spent his career justify- Look Who's the great defenders of the idea of ing is the history of one judicial usur- reading the Constitution, shall we say, pation after another, each made over expansively. When the liberal court of and above and against "the power of Discovered the '60s and '70s-that Edison of the Congress and of every state and local legislature." For liberais now to rights industry-minted new rights, year in, year out, with Menlo Park champion the power of every state efficiency, he applauded. When, for and local legislature, after having spent 40 years championing the right Judicial example, Roe a Wade purported to find the right to abortion in the Con- of the unelected judiciary to force states and localities to raise taxes, stitution-or, to be more precise, in the penumbral emanations of the Con- reform prisons, bus children, hire by race and permit abortion is world Restraint stitution-that was good constitution- class chutzpah. alism because it fit nicely with Tribe's And what exactly is Thomas's of- view that "to conscript a woman to The life of a columnist is a feast of carry a fetus to term within her fense? Whether a judge calls what he is believes natural law or something ironies, but rarely is one served a a unique and most fundamental inva- meal quite as sumptuous as the one sion of her constitutional liberty." else, every justice brings a certain intellectual structure and understand- just cooked up by Laurence Tribe, As Judge Richard Posner writes, ing of rights to his interpretation of Harvard Law School professor and Tribe's "method is to use the skills of the Constitution. Thomas is simply leading liberal constitutional scholar. a lawyer to make political choices for more ingeauous than most: He spells On Monday, Tribe took to the New society in the name of a fictive consti- out what it is he appeals to-the York Times to share with us his tution, as if the Supreme Court really classical tradition of natural law and anxieties about Supreme Court nomi- were a superlegislature and govern- the explicit words of the Declaration nee Clarence Thomas. ment by lawyers had, at last, arrived." of Independence. The nation is far Thomas, it seems, is not a tradi- Liberal lawyers, that is. Now that safer entrusting its future to such a tional conservative, meaning a judi- liberals have lost control of the court justice than to the kind that pulls new cially restrained one who believes they are shocked-shocked!-that rights out of a hat and declares them hat a judge's job is to interpret the judges might go beyond the letter of penumbral emanations. N, not make it. It seems that Thom- the Constitution and apply concepts & is a more radical kind of conserva- like natural law through which they tive. Instead of just sticking to the might legislate. Now that the tables Constitution and nothing but, Thomas are turned, liberals would like us to ves in "natural law" as another believe that only constitutional liter- of rights beyond the Constitu- alism is permitted. And as a guide to understanding It gets funnier. Tribe's concern is natural law, Thomas invokes the Dec- that Thomas "might seek to replace laration of Independence, which, for Roe not with a system that strength- example, speaks of life, liberty and ens states' rights," but one that de- the pursuit of happiness as inalienable nies the states' right to permit a legal rights. Under such a theory of natural abortion. Tribe is terribly concerned rights, Tribe warns, a judge could ban that "Thomas has already dismissed everything from abortion counseling talk of states' rights as a 'constitu- to anal sex to minimum wage laws. tional sideshow.' Nothing less than the "fate of self- It has been a while since a champi- government in the U.S.," it seems, is on of liberal jurisprudence stood up threatened by Thomas's kind of judi- for the notion of states' rights, the old cial activism. segregationist cry, but it is refresh- The first oddity of this critique is ing. And late. Where was Tribe's that today, for the purposes of the concern for states' rights under Roe, Thomas nomination, a traditional con- which effectively deprived the 50 servative seems to be a good conser- states of any say in the matter of vative. Of course, the last time a abortion? principled judicial restraint conserva- Tribe, born again defender of tive, Robert Bork, was nominated for states' rights, warns darkly that with the court, Tribe led the pack that the Thomas nomination "the power of savaged him. But never mind. Congress and of every state and local legislature [is] hanging in the bal- ance." It is touching that Tribe should be so concerned with judicial en- croachment on legislative powers. Only four years ago he was ridiculing the idea of "judicial restraint" as a "political buzzword." 572 905 FEDERAL REPORTER, 2d SERIES U.S. v. LONG as 909 F2d 1972 (D.C. Clr. 1990) 1573 ceptional AFL-CIO's plea to be heard on 1. Criminal Law 1081(6) 6. Weapons is the merits in this case. For failure to meet District court's ministerial act of dock- Although defendant can use a firearm proceedings and thus favors joint trial of codefendants. a mandatory time limit, one our precedent eting tardy notice of appeal was not an without actively employing it, Government. impels us to apply on our own initiative, see implicit grant by the district court of an at a minimum, must show that a particular 12. Criminal Law >622.2(11) Microwave Communications, 515 F.2d at extension of time to file the notice of ap- defendant has actually or constructively Interest in efficient and expeditious 390 n. 25, AFL-CIO's petition for review is peal. F.R.A.P.Rule 4(b), 28 U.S.C.A. possessed a firearm in order to prove that proceedings must never be allowed to he has used it in connection with drug eclipse the defendant's right to a fair trial, Dismissed. 2. Criminal Law -1181.5(3) transaction. 18 U.S.C.A. § 924(c)(1). and a joint trial is inappropriate when the Where notice of appeal was untimely, 7. Conspiracy -41 evidence against one defendant is far more KEY NUMBER SYSTEM court would remand case to district court Defendant involved in conspiracy can damaging than the evidence against the other. for determination of whether defendant be punished as a principal of the offense of should be granted 30-day extension of peri- use of a firearm in connection with a drug 13. Criminal Law -1166(6) od for filing notice of appeal. F.R.A.P. offense, regardless of whether he has pos- In view of abundant evidence implicat- Rule 4(b), 28 U.S.C.A. sessed firearm, based on the rule of vica- ing defendant, such as the fact that he was rious liability for coconspirators. 18 U.S. surrounded by narcotics and related para- UNITED STATES of America 3. Criminal Law -1144.13(3), 1159.2(1, 7) C.A. § 924(c)(1). phernalia when he was arrested, he was Overturning a jury's determination of 8. Weapons 1 v. not prejudiced by joint trial on theory that guilt on the ground of insufficient evidence Where Government proves that defen- evidence against codefendant was much Keith D. LONG, Appellant. is not a task which court will undertake dant has aided or abetted another person's greater. lightly; appellate court owes tremendous UNITED STATES of America use of firearm in connection with drug deference to jury verdict, and must consid- offense, defendant may be punished as a v. er the evidence in the light most favorable principal regardless of whether the defen- Appeal from the United States District Sonia E. MAYFIELD. Appellant. to the Government and affirm the judg. dant has himself actually or constructively Court for the District of Columbia (Crimi- ment if any rational trier of fact could have possessed the firearm. 18 U.S.C.A. §§ 2, nal Nos. 88-00444-02 and 88-00444-01). Nos. 89-3096, 89-3105. found the essential elements of the crime 924(c)(1). Nicholas G. Karambelas with whom Ste- United States Court of Appeals, beyond a reasonable doubt. 9. Criminal Law =419(2.10) ven R. Kiersh was on the brief, for appel- District of Columbia Circuit. lunt in 89-3096. 4. Weapons 17(4) Evidence that person who called upart. Argued April 16, 1990. Defendant's conviction for using a ment while officers were conducting search Ronny E. Jones, for appellant in 89-3105. weapon in connection with drug offense and making arrests asked whether a partic- Decided June 22, 1990. Eric M. Acker, Asst. U.S. Atty., with ular person "still had any stuff" and stated was not supported by evidence that defen- whom Jay B. Stephens, U.S. Atty., John R. that she was looking for "a fifty" was not dant was arrested in room in which drugs Fixher, Helen M. Bollwerk, Elizabeth Tros- evidence of an assertion, 80 that evidence Defendants were convicted in the Unit- were found and in which a revolver was man, and Geoffrey Bestor, Asst. U.S. At- ed States District Court for the District of found some 10 to 15 feet away from him, in of that telephone call was not hoursay. lyn., were on the brief, for appellee. Fed.Rules Evid.Rule 801(c), 28 U.S.C.A. Columbia, Stanley S. Harris, J., of drug the absence of evidence that defendant offenses and they appealed. The Court of owned the gun or knew of its existence or 10. Criminal Law 1169.1(9) Before SILBERMAN, SENTELLE, and that he leased or lived at the premises. 18 Officer's testimony regarding tele- THOMAS, Circuit Judges. Appeals, Clarence Thomas, Circuit Judge, held that: (1) ministerial act of docketing U.S.C.A. § 924(c)(1). phone call which was received at apartment while officers were searching it and muk- Opinion for the court filed by Circuit defendant's tardy notice of appeal was not Judge THOMAS. an implicit grant of extension of time by 5. Weapons 17(4) ing arrests was not unfairly prejudicial on the district court for taking the appeal; (2) Defendant's conviction for use of a theory that it was unreliable because the Concurring opinion filed by Circuit evidence was insufficient to sustain convic- gun in connection with a drug transaction officer testified from memory and because Judge SENTELLE. tion for use of a weapon in connection with could not be supported on evidence which the declarant was unavailable for crome-ex- a drug offense; and (3) testimony concern- connected defendant to the drugs and amination. Fed.Rules Evid.Rule 40%, 28 CLARENCE THOMAS, Circuit Judge: showed that the distribution of the drugs U.S.C.A. ing telephone call received by officers at Sonia Mayfield and Keith Long appeal apartment while arrests were being made was facilitated by the gun, on theory that 11. Criminal Law 622 their convictions for possessing in excess was not hearsay. defendant derived benefit from the gun Judicial system has strong and legit- of five grams of cocaine base with intent to and thus "used" it. 18 U.S.C.A. distribute, 21 Affirmed in part, reversed in part, and imate interest in efficient and expeditious 241(b)(1)(B)(ii),' and using or carrying 841(a), a U.S.C. §§ remanded. § 924(c)(1). See publication Words and Phrases 1. Both Mayfield and Long were charged with Sentelle, Circuit Judge, filed a concur- for other judicial constructions and possessing in excess of fifty grams of URSINE , 841(b)(1)(A)(iii). The jury, however, convict. base with intent to distribute, 21 U.S.C. ed them of the lesser included offense of pos- ring opinion. definitions. /4 905 FEDERAL REPORTER, 2d SERIES U.S. V. LONG firearm during and in relation to a drug Cite as 905 F.2d 1572 (D.C. Ctr. 1990) 1575 As Mayfield correctly notes, however, trafficking crime, 18 U.S.C. § 924(c)(1). In serve vital interests of efficiency and finali- rule 4(b) does not absolutely bar criminal ty in the administration of justice, and are by sufficient evidence, requires some elabo- addition, Mayfield appeals her conviction appeals in which the required notice is filed not designed merely to ensnare hapless liti- ration of the pertinent facts. On the eve- for knowingly opening or maintaining a more than ten days after entry of the judg- gants. As this court has noted when con- ning of November 16, 1988, pursuant to a place for the purpose of distributing or ment. The rule allows the district court, sidering a civil appeal time-barred by rule valid search warrant, several officers of using a controlled substance, 21 U.S.C. with or without motion and notice, to ex- 4(a): "The Federal Rules of Appellate Pro- the D.C. Metropolitan Police Department § 856(a)(1). Mayfield's appeal is not prop- tend the period for filing a notice of appeal cedure impose strict requirements for the forced their way into a one-room basement erly before this court. Thus, we do not for an additional thirty days "[u]pon a timely filing of appeals [W]e decline apartment where Mayfield lived. They consider the merits of her arguments, and showing of excusable neglect." to ... subvert the plain words and meaning found Long emerging from behind a cur- remand her case to the district court. Mayfield concedes that the district court of the federal rules. This court has never tain that separated the back of the room Long raises three challenges to his convic- did not explicitly grant her a thirty-day had the authority to revamp these rules." from the front. Tr. I at 23-24, 25, 68; Tr. tions. First, he asserts that there is insuf- extension to file her notice of appeal. She Polylok Corp. v. Manning, 793 F.2d 1318, II at 8. The police arrested Long and three ficient evidence to support his conviction urges us, however, to hold that the district 1322 (D.C.Cir.1986). other individuals, including Mayfield," and for using or carrying a firearm in relation court implicitly granted the extension by [2] We therefore remand this case to began a search for evidence of drug-related to a drug trafficking crime. Second, he "accepting" her untimely notice of appeal. the district court for a determination of activity. contends that the trial judge erred in ad- She notes that the Eighth Circuit has, on whether Mayfield should be granted the mitting into evidence the substance of an occasion, followed this approach. See thirty-day extension permitted by rule 4(b). The search was hardly arduous; the one- incriminating telephone conversation. Fi- United States v. Williams, 508 F.2d 410, Mayfield will thus have an opportunity to room apartment brimmed with evidence. nally, he asserts that the trial judge abused 410 (8th Cir.1974) (per curiam) ("We con- present to the district court whatever evi- In the front part of the apartment, the his discretion by declining to sever Long's strue the district court's acceptance of the dence of excusable neglect she can muster. police found rock cocaine, a razor blade, trial from Mayfield's. We are persuaded notice of appeal as a grant of additional This resolution places us squarely in line and a butane torch lying on a table. They by Long's first argument and reverse his time to file pursuant to Fed.R.App.P. 4(b) with the majority of appellate courts that found more rock cocaine and a scale on a even though no formal order is entered to firearms conviction. Finding no merit in have considered this issue. See, e.g., Unit- table behind the curtain. The search also that effect."); United States v. Mills, 430 his second and third contentions, however, ed States v. Golding, 739 F.2d 183, 184 (5th yielded a large amount of cash, cocaine in F.2d 526, 528 (8th Cir.1970) (same), cert. we affirm his narcotics conviction. Cir.1984) (per curiam); United States v. denied, 400 U.S. 1023, 91 S.Ct. 589, 27 powder form, several pipes, a number of Lucas, 597 F.2d 243, 245-46 (10th Cir.1979) L.Ed.2d 636 (1971). butane torches, packaging materials, and a (per curiam); United States v. Stolarz, 547 I. F.2d 108, 111-12 (9th Cir.1976), cert. de- significant supply of dextrose, a cutting [1] We decline Mayfield's invitation to equate the ministerial act of docketing a nied, 434 U.S. 851, 98 S.Ct. 162, 54 L.Ed.2d agent. Finally, the police found a function- The Federal Rules of Appellate Proce- 119 (1977).4 Even the Eighth Circuit has al but unloaded .22 caliber revolver be- dure require that parties wishing to appeal tardy notice of appeal with an implicit grant of an extension of time by the dis- cut back significantly on its earlier, permis- tween the cushions of a sofa in the front in criminal cases file a notice "in the dis- trict court. Docketing a notice of appeal is sive attitude toward rule 4(b). See United part of the room. Although the barrel of trict court within 10 days after the entry of a clerical task, and does not require the States v. Anna, 843 F.2d 1146, 1147 (8th the gun was hidden, the handle protruded the judgment or order appealed from." approbation of the trial judge. It thus Cir.1988) (terming the Circuit's earlier prac- from the cushions. The police found no Fed.R.App.P. 4(b). The district court dock- presents no occasion for a party to make a tice "discretionary" and declining to follow other firearms or any ammunition in the eted the judgment against Mayfield on showing of excusable neglect, which is a it, instead remanding case to district court apartment. June 5, 1989; she filed notice of this appeal prerequisite for obtaining the thirty-day ex- for decision on excusable neglect). on June 16, 1989, eleven days later. Citing In addition to his narcotics conviction, tension contemplated by rule 4(b). Adopt- rule 4(b), and stressing that it is "mandato- II. Long was convicted of violating 18 U.S.C. ing the fiction that the district court implie- ry and jurisdictional," United States v. itly granted the extension of time would Consideration of Long's first claim, that § 924(c)(1). This statute, in pertinent part, Robinson, 361 U.S. 220, 226, 80 S.Ct. 282, undoubtedly expedite the final adjudication his firearms conviction was not supported provides that "[w]hoever, during and in 287, 4 L.Ed.2d 259 (1960), the government of Mayfield's case. But the unambiguous relation to any drug trafficking crime urges us to dismiss Mayfield's appeal out- language of the rule forecloses this short- 3. But cf. United States v. Hoye, 548 F.2d 1271, right. cut.2 The time limits specified in the rules 1273 (6th Cir.1977) (per curiam) ("[W]here a glect, the court concluded that "based on the document is filed within the 40-day period facts present here the district court would find sessing in excess of five grams with intent to which represents a clear assertion of an intent excusable neglect," and proceeded to consider v. Gibson, 568 F.2d 111, 112 (8th Cir.1978) (per distribute. to appeal, courts of appeals have the power to the merits of the case. See United States v. curiam) (concluding that trial judge implicitly found excusable neglect when he granted mo- overlook irregularities where fairness and jus- Reyes, 759 F.2d 351, 354 (4th Cir.), cert. denied, 2. There may be cases in which an implicit find- tice so require."). Having no idea of the source 474 U.S. 857, 106 S.Ct. 164, 88 L.Ed.2d 136 ing of excusable neglect would be less of a tion for leave to appeal in forma pauperis dur- of this alleged "power to overlook" the clear (1985). Because Mayfield has proffered no ex- fiction than here. When a trial judge takes ing thirty-day discretionary period). Because some explicit action with respect to a tardy Mayfield has not specified any action taken by language proach. of rule 4(b), we reject the Hoye ap- cuse for her delay, the Reyes approach, even assuming that it can be squared with the lan- appeal, the judge at a minimum is aware of the the district judge in her case that might consti- appeal; under these circumstances, his action tute an implicit extension of time, we need not 4. The Fourth Circuit, in one case, took a novel guage of rule 4(b), is not available to us here. could arguably be construed as an implicit find. consider the merits of the Gibson approach. approach to this question. After noting the op- ing of excusable neglect. See, e.g., United States tion of remanding an untimely appeal to the 5. The other two individuals, indicted with Long district court for a decision on excusable ne- and Mayfield, pleaded guilty to possession of a controlled substance, 21 U.S.C. § 844(a). 905 FEDERAL REPORTER, 2d SERIES U.S. v. LONG 1577 Cite - 905 F.2d 1572 (D.C. Clr. 1990) uses or carries a firearm, shall, in There is no evidence suggesting that Long prove that he has "used" it." Cf. United addition to the punishment provided for viction of a defendant in the absence of any was headed for the gun, or that he even States v. Joseph, 892 F.2d 118, 126 (D.C. such crime be sentenced to imprison- indicia of possession would stretch the knew of its existence. The gun itself was Cir.1989) (violation of section 924(c)(1) pos- ment for five years." Id. (emphasis add- unregistered, and yielded no fingerprints. sible "[w]hen a person 'has a present abili- meaning of "use" beyond the breaking ed). Long argues that the evidence ad- Nor did Long own, lease, or live at the ty to exercise dominion and control over' point. We readily acknowledge that the duced at trial was insufficient to support a a firearm") (emphasis added) (quoting word "use" is expansive, but the difficulty jury finding that he "use[d] or carrie[d]" a premises on which the gun was found.¹ United States v. Evans, 888 F.2d 891, 895 of pinpointing the outer limits of its mean- firearm within the meaning of section There was no evidence, in short, that the 924(c)(1). We agree. firearm was ever either actually or con- (D.C.Cir.1989), cert. denied, - U.S. ing does not imply that no such limits exist. structively in Long's possession. Although 110 S.Ct. 1325, 108 L.Ed.2d 500 (1990)); To affirm Long's conviction for "using" the (3) Overturning a jury's determination United States v. Henry, 878 F.2d 937, 944 revolver in the sofa would be to concede the gun was partially visible between the of guilt on the ground of insufficient evi- (6th Cir.1989) (violation of section 924(c)(1) that the word "use" has no discernible dence is not a task that we undertake light- sofa cushions, its visibility, without more, possible "if it reasonably appears that the boundaries. That prospect is particularly ly. As an appellate court, we owe tremen- does not establish that any particular per- firearms found on the premises controlled troubling where, as here, we are constru- ing a criminal statute. dous deference to a jury verdict; we must son either actually or constructively pos- or owned by a defendant and in his actual consider the pri lence in the light most fa- sessed the gun. or constructive possession are to be used The government has cited numerous vorable to the government, see Glasser ". to protect the drugs or otherwise facilitate cases in which this court and its sister United States, 315 U.S. 60, 80, 62 S.Ct. [5] The government argues that Long a drug transaction") (emphasis added); circuits have upheld the firearms convic- 457, 469, 86 L.Ed. 680 (1942), and affirm "used" the gun because he committed a United States v. Meggett, 875 F.2d 24, 29 tions of defendants found to have "used" the judgment if "any rational trier of fact drug offense facilitated by the gun. The (2d Cir.) ("Possession of a gun, even if it is guns in a vast array of circumstances. could have found the essential elements of logic, in essence, is this: Long was connect- concealed, constitutes 'use' if such posses- These cases are inapposite. Our problem the crime beyond a reasonable doubt," ed to the drugs; the distribution of the sion is an integral part of the predicate here is not with the notion that there are Jackson v. Virginia, 443 U.S. 307, 319, 99 drugs was facilitated by the gun; since offense and facilitates the commission of S.Ct. 2781, 2789, 61 L.Ed.2d 560 (1979). Long thus derived benefit from the gun, he that offense.") (emphasis added), cert. de- many ways in which a defendant can "use" We do not, however, fulfill our duty "used" it. We reject the notion that a nied, - U.S. 110 S.Ct. 166, 107 a firearm in relation to a drug trafficking through rote incantation of these principles loose, transitive relationship of this type is L.Ed.2d 123 (1989); United States v. Ma- crime, but rather with the notion that in sufficient to show that a person "used" a tra, 841 F.2d 837, 840-41 (8th Cir.1988) order to prove such "use," the government followed by summary affirmance. We gun. This approach would obliterate any ("[N]one of the guns was in the actual need not show any nexus at all between a must ensure that the evidence adduced at possession of the defendant, but all were particular drug offender and the firearm trial is sufficient to support a verdict as a remaining limits on the meaning of the matter of law. A jury is entitled to draw a under his control.") (emphasis added); that he allegedly "used." As noted above, word "use" in section 924(c)(1). vast range of reasonable inferences from United States v. Stewart, 779 F.2d 538, the record in this case is devoid of any [6-8] The word has been losing its con- 540 (9th Cir.1985) (violation of section evidence linking Long to the revolver found evidence, but may not base a verdict on mere speculation. ventional, active connotation for some time, 924(c)(1) possible "[if the firearm is with- in the sofa, other than his presence in the as courts have held that narcotics offend- in the possession or control of a person apartment and involvement with the nar- [4] Having carefully reviewed the who commits an underlying crime as de- cotics. In all the cases cited by the govern- record in this case, we conclude that the ers can "uno" guns simply by possessing fined by the statute") (emphasis added); ment, some nexum was established through government failed to provide any evidence them in the vicinity of drugs. Although a United States v. LaGuardia, 774 F.2d 317, an explicit or implicit showing of actual or to support a reasonable inference that defendant can "use" a firearm without ac- 321 (8th Cir.1985) ("Section 924(c)(1) reach- constructive possession. Long "used" the revolver. When arrest- tively employing it, the government, at a es the possession of a firearm which in any ed, Long was ten to fifteen feet away from minimum, must show that a particular de- In United States v. Anderson, 881 F.2d manner facilitates the execution of a felo- the revolver, and was emerging from be- fendant has actually or constructively pos- 1128 (D.C.Cir.1989), for example, we upheld ny.") (emphasis added). Upholding the con- hind the curtain that divided the room. sessed a particular firearm in order to the firearms conviction of appellant Green- 8. This analysis assumes a situation in which the 6. There is no evidence that Long ever actually government prosecutes a defendant for violat- U.S. 110 S.Ct. 117, 107 L.Ed.2d 79 (1989): 7. Mayfield testified at trial that Long visited her or constructively "carried" the revolver, and apartment two to three times per week. Tr. II ing the statute as a principal. A defendant who see also Pinkerton v. United States, 328 U.S. 640, hence we are not called upon to construe that has not actually or constructively possessed a 646-48, 66 S.Ct. 1180, 1183-85, 90 L.Ed. 1489 at 92. Long did not live there, however. Even word. Instead, we focus exclusively on the stat- assuming that he visited the apartment to carry firearm, of course, might nevertheless be pun- (1946) (coconspirator liable for all foreseeable utory term "use," which we believe is properly ished as a principal if the government can prove substantive offenses committed in furtherance out drug transactions, there was no evidence susceptible of a broader interpretation than that he exercised the degree of dominion and that he has conspired in or aided or abetted a of the conspiracy). "carry." Cf. United States v. Feliz-Cordero, 859 control over the premises that would support an section 924(c)(1) offense. Similarly, where the government proves that F.2d 250, 253-54 (2d Cir.1988) (legislative histo- ry of section 924(c)(1) does not suggest that inference of constructive possession over their Thus, a defendant involved in a conspiracy, a defendant has aided or abetted another per- "carry" should be construed as having any contents. This court has emphasized that con- regardless of whether he has possessed a fire- son's "use" of a firearm, the defendant may be meaning beyond its literal meaning. and structive possession "should not be lightly im- arm, can be punished as a principal based on punished as a principal regardless of whether "[therefore, a person cannot be said to 'carry' a puted to one found In another's apartment or the rule of vicarious liability for coconspirators. the defendant himself has actually or construc. firearm without at least a showing that the gun home." United States v. Holland, 445 F.2d 701, See United States v. Rosado, 866 F.2d 967, 968 n. lively possessed the firearm. 18 U.S.C. 5 2. is within reach during the commission of the 703 (D.C.Cir.1971). 1. 970 (7th Cir.) (defendant liable under section In this case, the government has not proved a drug offense"). 924(c)(1) where coconspirator used firearm dur- conspiracy or aiding or abetting. Long's poten- ing drug trafficking offense), cert. denied, - tial liability for using the gun is based entirely on his own actions. 78 905 FEDERAL REPORTER, 2d SERIES U.S. V. LONG 1579 Cite M 905 F.2d 1572 (D.C. Clr. 1990) wood, who was arrested inside the closet of had kept them overnight in an apartment, tion that an individual can be convicted for come around to pick up the "fifty." Again, a room adjoining a second room where "within reach and available to protect him "using" a gun that he neither actually nor the officer answered yes. Tr. I at 80-81. guns were found. Our holding, however, during his ongoing crime of possession constructively possessed. Evidence of pos- was premised on our conclusion that "there with intent to distribute cocaine." Id. at session, or evidence from which possession Before trial, Long's counsel moved in was substantial evidence connecting Green- can reasonably be inferred, is a prerequi- limine to exclude evidence of this telephone 895 (emphasis added). This evidence al- wood to the bedroom in which the guns site to a conviction for "use" under section conversation as inadmissible hearsay. The lowed the jury to infer constructive posses- were found." Id. at 1141. Of paramount sion: "An object is 'accessible' or 'within 924(c)(1). trial judge denied the motion. See Tran- importance, the government had introduced script of Suppression Hearing (Tr. Supp. reach,' as commonly understood, if a party We decline to decide the case so narrow- evidence that Greenwood lived in the apart- Hrg.) at 11. At trial, the police officer who is not just near it, but has a present ability ly, however, as to reveal no principle appli- ment; this evidence justified an inference had taken the call testified about the con- to exercise dominion and control over it cable beyond these facts. The concurrence that Greenwood constructively possessed versation. Tr. I at 80-81. In this appeal, [T]here was sufficient evidence from which argues that we should hold only that "[o]n the apartment's contents. In addition, Long renews his hearsay challenge to the the jury could conclude that [the appellant] the present facts, the government did not there was testimony that Greenwood had introduction of the officer's testimony. had something approaching actual роввея. offer evidence of possession or any other the keys to the particular bedroom in which sion of the gun during the commission of evidence that Long had used the firearm." Although Long concedes that the caller the guns were found, and that the police the predicate drug offense." Id. at 895. Conc. op. at 1582 (emphasis modified). did not expressly assert that he was in- found Greenwood's wallet and photographs This analysis, however, begs the central volved in drug distribution, he argues that in that bedroom. See id. at 1141. Other courts have upheld section 924(c)(1) convictions where the nexus was question in the case: was there sufficient her questions contain implicit assertions Anderson, thus, stands for the unexcep- tional proposition that a jury can reason- established in a variety of ways. See, e.g., evidence to show that Long "used" the about his involvement. Long contends that gun? The government obviously thought it is irrelevant that these alleged assertions ably infer that a person who exercises do- United States v. Munoz-Fabela, 896 F.2d there was. It argued strenuously in this were couched in question form, since the minion and control over given premises 908, 911 (5th Cir.1990) (firearm, registered in another person's name, was on floor- appeal that Long's connection to the drugs questions plainly revealed assumptions that constructively possesses contraband found board of defendant's car, within view and and his presence in the room with the gun are the functional equivalent of direct as- on those premises. See also United States reach of defendant); United States v. amounted to "use" of the gun. Deciding sertions. Long maintains that the caller, v. Alvarado, 882 F.2d 645, 654 (2d Cir.1989) (affirming section 924(c)(1) conviction Grant, 545 F.2d 1309, 1311-12 (2d Cir.1976) whether there was sufficient evidence to through her questions, in effect asserted where guns were found in defendant's resi- support Long's conviction for "using" a that "Keith has crack and sells it out of (firearms were found in rooms of social Mayfield's apartment." He argues that dence), cert. denied, - U.S. 110 club; defendant lived there, managed the gun necessarily entails some decision about S.Ct. 1114, 107 L.Ed.2d 1021 (1990); Unit- club, and had keys to the rooms), cert. what it means to "use" a gun. Despite the the government introduced this testimony ed States v. Robinson, 857 F.2d 1006, 1010 denied, 429 U.S. 1103, 97 S.Ct. 1130, 51 concurrence's qualms about setting a mini- to prove the truth of precisely these asser- (5th Cir.1988) (same); United States v. Ma- L.Ed.2d 554 (1977). A common theme mum threshold for finding "use" within the tions, and that the testimony, thus, should tra, 841 F.2d 837, 840-41 (8th Cir.1988) unites these cases and distinguishes them meaning of section 924(c)(1), this case have been excluded as hearsay. (same). from the present one. In each case, the forces us to set such a threshold, either Hearsay is an out-of-court statement of- Similarly, we have held that evidence re- defendant's actual or constructive posses- explicitly (as we have done) or implicitly. fered to prove the truth of the matter sion of a firearm was indicated by one or asserted in the statement. Fed.R.Evid. garding a past connection between a defen- III. dant and a firearm establishes a sufficient more of several factors: close physical 801(c). As a threshold matter, then, Long proximity to the firearm, possessory inter- Having reversed Keith Long's conviction must show that the evidence he seeks to nexus to support a conviction under section est in the firearm, or dominion and control on the firearms charge, we now consider 924(c)(1). In United States v. Evans, 888 exclude as hearsay is a "statement," which over the premises on which the firearm his two remaining challenges, which per- the rule defines as "an oral or written F.2d 891 (D.C.Cir.1989), cert. denied, - U.S. 110 S.Ct. 1325, 108 L.Ed.2d 500 was located. tain to the narcotics charge. assertion." Fed.R.Evid. 801(a)(1). Al- (1990), we upheld the firearms conviction of [9] During the search of Mayfield's though the rule does not define "asser- Lest this opinion foster confusion in an a drug trafficker arrested across town already unsettled area, we emphasize its apartment, the telephone rang, and a police tion," the accompanying advisory commit- from the apartment where the relevant narrowness: we reverse Long's conviction officer answered it. An unidentified fe- tee note stresses that "nothing is an asser- guns were found.' In that case, however, because the government failed to adduce male voice asked to speak with "Keith." tion unless intended to be one." Fed.R. the government introduced testimony that any evidence suggesting that Long actual- The officer replied that Keith was busy. Evid. 801 advisory committee note (empha- the defendant had brought the guns and ly or constructively possessed the revolv- The caller then asked if Keith "still had sis added). drugs to Washington from New York and er.¹⁰ We simply cannot accept the proposi- any stuff." The officer asked the caller The caller's words, thus, cannot be char- what she meant, and the caller responded 9. Although Evans construed the "carry" compo- acterized as an "assertion," even an implied the firearm (2) during and in relation to a drug nent of the "usel ] or carr(y)" requirement, its "a fifty." = The officer said "yeah." The trafficking crime. A person can possess a gun one, unless the caller intended to make analysis applies equally to the term "use." without either "using" It or using it "during and caller then asked whether "Mike" could such an assertion." While Long's criticism 10. We do not mean to imply that possession of a in relation 10" a given crime. See, E.g., United States v. Feliz-Cordero, 859 F.2d 250, 254 (2d not used during or in relation to drug traffick. firearm by a drug trafficker is invariably suffi- ing offense). 12. The advisory committee note's discussion of cient for a conviction under section 924(c)(1). Cir.1988) (firearm found in dresser drawer was the intent requirement focuses on situations in The statute requires that the defendant (1) use not accessible to drug traffickers and thus was 11. A "fifty" refers to a bag of crack worth fifty which an Implied assertion arises from conduct, dollars. See Tr. I at 90; Tr. II at 50, 56. as opposed to words. The note appears to as- 80 905 FEDERAL REPORTER, 2d SERIES U.S. v. LONG Cite as 905 F.2d 1572 (D.C. Ctr. 1990) 1581 of a rigid dichotomy between express and dence to suggest that the caller, through [11, The judicial system has a implied assertions is not without merit, it her questions, intended to assert that he strong and legitimate interest in efficient no dearth of evidence against Mayfield. misses the point that the crucial distinction was involved in drug dealing. The caller and expeditious proceedings. and hence the She lived in the apartment where the drugs under rule 801 is between intentional and may indeed have conveyed messages about system favors the joint trial of codefend- were found, which at a minimum suggests unintentional messages, regardless of Long through her questions, but any such ants. See United States 1. Manner, 887 some connection to the drugs and the fire- whether they are express or implied. It is F.2d 317, 324 (D.C.Cir.1989). cert. denied, arm discovered there. There was, how. messages were merely incidental and not difficult to imagine any question, or for intentional. See United States v. Zenni, - U.S. 110 S.Ct. 879. 107 L.Ed.2d ever, abundant evidence implicating Long that matter any act, that does not in some 492 F.Supp. 464, 469 (E.D.Ky.1980) (phone 962 (1990); United States 1. Hines, 455 as well: when arrested, he was surrounded way convey an implicit message. One of calls from bettors, answered by police dur- F.2d 1317, 1334 (D.C.Cir.1971), cert. de- by narcotics and related paraphernalia. the principal goals of the hearsay rule is to ing raid of illegal gambling establishment, nied, 406 U.S. 975, 92 S.Ct. 2427, 32 This case involves nowhere near the "gross exclude declarations when their veracity L.Ed.2d 675 (1972). Of course. this interest disparity" of evidence required before we were not assertions and therefore were cannot be tested through cross-examina- must never be allowed to eclipse a defen- will hold that a district court has abused its outside scope of hearsay rule). Long thus fails to satisfy the intent component of run dant's right to a fair trial. ^ joint trial is discretion in denying a motion to sever. tion. When a declarant does not intend to Haldeman, 559 F.2d at 72. communicate anything, however, his sincer- 801, which "place[s] the burden upon the inappropriate "when the evidence against ity is not in question and the need for party claiming that the intention existed." one defendant is 'far more damaging' than cross-examination is sharply diminished. Fed.R.Evid. 801 advisory committee note; the evidence against the moving party." For the foregoing reasons, we remand Thus, an unintentional message is pre- accord United States v. Hensel, 699 F.2d United States v. Bruner, 657 F.2d 1278, Sonia Mayfield's case to the district court sumptively more reliable. See United 18, 31 (1st Cir.), cert. denied, 461 U.S. 958, 1290 (D.C.Cir.1981) (quoting United States to determine whether her tardiness in filing States v. Groce, 682 F.2d 1359, 1364 (11th 103 S.Ct. 2431, 77 L.Ed.2d 1317 (1983). Be- v. Mardian, 546 F.2d 973, 977 (D.C.Cir. a notice of appeal resulted from excusable Cir.1982); 4 J. Weinstein & M. Berger, cause the caller's questions were nonasser- 1976) (en banc)); see also United States v. neglect and, if so, whether to accept her Weinstein's Evidence 1801(a)[01] (1988). tive, they fall outside the scope of the Slade, 627 F.2d 293, 309-10 (1).C.Cir.), cert. notice of appeal, which was filed within the Evidence of unintended implicit assertions hearsay rule, and the trial judge did not err denied, 449 U.S. 1034, 101 S.Ct. 608, 66 thirty-day discretionary period. We re- is "[a]dmittedly ... untested with respect in admitting the testimony concerning the L.Ed.2d 495 (1980). In such rituations, the verse Keith Long's conviction for using or to the perception, memory, and narration questions." jury may not be able to compartmentalize carrying a firearm during and in relation to (or their equivalents) of the actor," but the evidence introduced against each defen- a drug trafficking crime, 18 U.S.C. "these dangers are minimal in the absence IV. dant, and the spillover may jeopardize one § 924(c)(1), but affirm his conviction for of an intent to assert and do not justify the defendant's right to a fair trial. See Unit- possessing in excess of five grams of co- Long and Mayfield were tried jointly. loss of the evidence on hearsay grounds." ed States v. Sampol, 636 F.2d 621, 647 caine base with intent to distribute, 21 Asserting that the evidence against May- Fed.R.Evid. 801 advisory committee note. (D.C.Cir.1980) (per curiam); Mardian, 546 U.S.C. §§ 841(a), 841(b)(1)(B)(iii). field was far more damning than that F.2d at 979. It is so ordered. [10] With our inquiry focused on the against him, Long argues that the district intent of the caller, we have little trouble court abused its discretion in denying his [13] Striking the balance between the disposing of Long's theory about implied motion to sever his trial from hers.¹⁴ We SENTELLE, Circuit Judge, concurring: system's interest in joint trialn and a defen- assertions. Long has not provided any evi- find no merit in this claim. dant's right to a fair proceeding is peculiar- While I am in total agreement with the sume, In circular terms, that any communica. ly within the province of the trial court, conclusion of the Court and in substantial she testified from memory, and because the tion made in words is an assertion: "It can declarant was unavailable for cross-examina- and we will not reverse the balance that agreement with the reasoning of Judge scarcely be doubted that an assertion made in tion. But this is invariably true whenever a court strikes absent a clear abuse of discre- Thomas' careful opinion, I write separately, words is intended by the declarant to be an witness testifies about words spoken outside the tion. United States v. Hernandez, 780 if briefly, for a distinct, finite purpose. I assertion. Hence verbal assertions readily fall courtroom; Long has not explained why the into the category of "statement." Fed.R.Evid. prejudice inherent in this testimony is unfair. F.2d 113, 119 (D.C.Cir.1986); United States find the opinion entirely correct as to the 801 advisory committee note. The note also In no way has Long shown the "grave abuse" of acknowledges the possibility of "nonassertive v. Haldeman, 559 F.2d 31, 72 (D.C.Cir. facts of this case and the law applied there- discretion that is required before we will disturb 1976) (en banc) (per curium), cert. denied, to. But, by stating that in the general case verbal conduct," however, and suggests that In- the delicate balance struck by the trial court tent determines whether such "verbal conduct" 481 U.S. 933, 97 S.Ct. 2641, 528 L.Ed.2d 250 charging "use" of a firearm in violation of under rule 403. See United States v. Payne, 805 is hearsay. We are persuaded that the note's F.2d 1062, 1066 (D.C.Cir.1986). (1977). In this case, to be sure, there was Title 18 U.S.C. & 924(c)(1), "the govern- intent analysis applies with equal force to mes- ment, at a minimum, must show that a sages implied from words and to messages im- 14. The government contends that Long did not with respect to that codefendant. but noted that plied from conduct. present this argument to the district court, and he "would just like to preserve (the motion) in was overwhelming. See Tr. II at 114-15 ("[H]ad 13. Long further argues that, even if testimony that consequently he has waived it on appeal. the event that disparity issues present them- there been a separate trial, none of this evidence about the telephone call is not hearsay, it should The record, however, shows otherwise. In ad- selves at trial with respect 11, the remaining with respect to Mr. Long on trial would have have been excluded as unfairly prejudicial. vance of trial, Long filed a motion to sever his defendants." Tr. Supp. Hrg. at : Long thus come in against him It's a spillover; the Rule 403. in pertinent part, provides that "evi- trial from that of his (then three) codefendants, complied with Fed.R.Crim.P. 12(h)(5). which re- prejudice is overwhelming: coupled with the dence may be excluded if its probative value is on the ground that the evidence against him was trial. quires that severance motions be raised before fact that this would not have come in had there substantially outweighed by the danger of un- much weaker than the evidence against them. been a separate trial."). The court denied fair prejudice." Fed.R.Evid. 403 (emphasis add- The government opposed this motion, and both At the close of all the evidence at trial, Long's Long's severance motion. Id. at 116. It is disin- ed). sides filed briefs. When one of the codefend. attorney renewed his call for . argu- genuous, at best, for the government now to Long argues that the officer's testimony re- ants pleaded guilty. Long's attorney conceded ing that the disparity between the evidence contend that Long "did not argue this ground to garding the phone call was unreliable because that the severance motion had become moot against Long and the evider.". against Mayfield the District Court." Brief for Appellee at 26. 905 F 20-36 1582 905 FEDERAL REPORTER, 2d SERIES particular defendant has actually or con- acting in concert possibilities, and there structively possessed a particular firearm may be other ways in which a defendant in order to prove that he has 'used' it." engaged in a drug transaction can "use" a Maj. op. at 8, the Court has gone beyond firearm possessed by some other person to the holding necessary to determine this protect the defendant's own drug enter- case. On the present facts, the govern- prise. What the quantum of evidence nec- ment did not offer evidence of possession essary for such other concept of use might or any other evidence that Long had used be, I would leave for the case that presents the firearm, as the Court's opinion well the question. ACCORD AND establishes. That, however, is all that is 2(2). Matters cover necessary to decide the controversy before celpt. E KEY NUMBER SYSTEM C.A.10 (Okl.) 1990. I us. There may be other cases in which contractor's agreement evidence sufficient to support a jury verdict accord and satisfaction claims against owner 1.. of "use" would appear without fitting the late supply deliveries technical rubric of possession. The majori- by evidence that partic order to discharge any ty's opinion at footnote 8 points out the spower Constructors. a Corp. v. Grand River 1413. ACCOU Performanc and liabilities. C.A.D.C. 1990. No between alleged deficion auditor's annual audits nancial problems: alth. auditor failed to specifical failure to pass on will stated value of certain ing concern" qualificati corporation was in ver and corporation's direct that condition.-Drabk Co., 905 F.2d 453. -9. Dutles and llabi C.A.10 (Utah) 1990. I tive negligence defense tor's malpractice action ness in absence of evider conduct contributed to form his work or to fur information: allegation have discovered precar business and would h many of their losses proper attention and th: actions with business manner did not estable defense.-Fullmer v. We 1394. Under Utah law, audit the negligent preparatic cial statements to third., corporation, inasmuch those who could reason. audited statements.-I.I -10. Actions. C.A.10 (Utah) 1990. sufficient evidence th. with business in relatio were loans, rather than ests, that investors rel prepared by auditor in and that such reliance awarding damages to in transactions for auditor financial statements.— Beck, 905 F.2d 1394. Praised for Demeanor, Scholarship on Bench By RICHARD CARELLI, Associated Press Writer WASHINGTON (AP) Lawyers who appeared before Clarence Thomas in his brief federal appeals-court tenure praised on Tuesday his judicial demeanor, "good, probing questions" from the bench and his scholarship. "He looks, sounds and acts like a judge," said Washington lawyer Richard J. Leighton of the man President Bush wants on the Supreme Court to replace the retiring Thurgood Marshall. None of the lawyers contacted used words such as "brilliant" or "erudite" often-cited adjectives when Supreme Court nominees are discussed but all said he was, in their cases, well-prepared, a good listener or fair. Leighton was involved in one of the 18 cases in which Thomas wrote an opinion during his 15 months on the U.S. Circuit Court of Appeals here. Leighton, who represented Alpo Petfoods in a false-advertising dispute with competitor Ralston Purina, remembers being impressed with Thomas when the case was argued in April 1990. "He asked good, probing questions, and from his follow-ups I could tell the questions weren't just coming from some law clerk's memo, Leighton said. "He really ran me through my tricks." = The ruling went against Alpo on a key point, and against Ralston Purina on another. "Judge Thomas' decision in the case has been cited often, and is being discussed in all the seminars on the Lanham Act (a federal law on false advertising), Leighton said. "It's an extraordinarily clear opinion that's written in a scholarly fashion. This was a weighty decision, no piece of fluff." Michael Olshonsky, a Washington criminal defense lawyer, remembers being favorably impressed with Thomas when Olshonsky represented a client whose drug conviction was upheld by a Thomas-authored decision. A three-judge panel ruled that forcing three defendants to stand trial together did not violate their rights, and that all three correctly were convicted of possessing a weapon found on one of them. "My impression during arguments was that the judge was thoroughly prepared," Olshonsky said. "The decision itself was consistent with the general trend in this circuit." George Davies, a Birmingham, Ala., lawyer who represented the United Mine Workers union before Thomas and two other judges in a mine-safety dispute earlier this year, has one standout memory of oral arguments in the case "He didn't like our position very - much." = Davies said Thomas' questions focused on the "highly technical points" of the relevant federal law. "It was evident he had read the briefs and been through the record. Although I was disappointed with the decision," said Davies, "I do think he did look hard at the case. He did his homework." When Washington lawyer James Davenport heard of Thomas' selection for the Supreme Court, he had trouble remembering that Thomas was on a three-judge panel that upheld a client's criminal conviction last August. "To the best of my recollection, he didn't ask a single question during arguments." But Thomas wrote the decision in the case. Davenport's assessment: "I obviously was not pleased by the result, but it was a reasoned opinion." AP-DS-07-02-91 1714EDT EEOC How EEOC Thrived Why would the During Thomas's Republican chairman of the EEOC ask me, a Tenure as Chairman Democrat and a career The nomination of Clarence Thomas to the Supreme Court has evoked a great deal federal employee, to of productive and enlightened discussion. be his chief of staff? Unfortunately, it has also resulted in the repetition, however innocent, of un- founded criticisms of his record as chair- question me as to my philosophical views; man of the Equal Employment Opportunity my strict and single mandate from him was Commission. to help make the EEOC effective. Clarence Thomas vigorously and effec- During his tenure as chairman, the EEOC tively enforced the laws against employ- went to court on behalf of workers 60 ment discrimination. I marvel at the will- percent more often than in previous years ingness with which generally intelligent and collected more than $1 billion on be- and skeptical individuals have accepted half of American workers, more than dur- bare assertions to the contrary. The record ing any other comparable period. establishes that the EEOC came of age For the first time, policies were adopted under the leadership of Judge Thomas. As requiring thorough investigation of all his chief of staff, I witnessed it. charges of discrimination and full redress Why would the Republican chairman of for its victims. Workers unlawfully de- the EEOC ask me, a Democrat and a career prived of a livelihood were to receive a job federal employee, to be his chief of staff? and full backpay. Those who discriminated And why would a "politically correct" civil had to take such additional affirmative servant accept the position? Because we steps as discharging offending supervisors shared a commitment to equal employment and posting notices to employees to assure opportunity and the full protection and them that their rights would not again be vindication of the rights of women, minori- violated. ties, older Americans, and workers with In the past, field offices-made unreview- disabilities. able determinations to litigate only a few of We were dedicated to the goal of making the many cases found to have merit. Under the EEOC a credible and aggressive law Thomas, all meritorious cases were submit- enforcement agency. Thomas concentrated ted to the Commission for litigation. on my law enforcement experience, ig- Some have mistakenly assumed that the nored my party affiliation, and did not increased efforts on behalf of individual workers constituted a shift away from concern about the existence of broad-based discrimination stemming from employ- ment patterns and practices. Roll Call - August 1, 1991 To the contrary. In 1981 the EEOC had only one broad systemic pattern and prac- tice case in litigation; in 1988 the Commis- sion had 16 such cases in active litigation. Pamela Talkin is a member of the Federal Labor Relations Authority. Thursday, August 1, 1991 ROLL CALL Page 5 Guest Observer By Pamela Talkin Moreover, the EEOC, on its own initiative, the laws ensuring equal opportunity and ture, but he also succeeded in transforming actively prosecuted as broad, pattern and prohibiting discrimination. the EEOC into a respected and highly pro- practice actions hundreds of cases that had Judge Thomas was,committed to identi- fessional agency. been filed as individual claims. fying and eliminating all arbitrary ob- No one was more dismayed than Clar- In accordance with precedent, Thomas stacles to equal opportunity. Employers ence Thomas when the evolving EEOC did voted to approve settlements involving the were required to recruit actively minerities not, on occasion, live up to its own en- use of goals and timetables, despite his now and women and to setaside millions for the hanced expectations. As he often stated, we well-publicized personal views on the effi- training of minority and woman employees built our wagon while we were riding in it cacy of such measures. and the establishment of scholarship funds and, with 50 offices and 3,000 employees, Reasonable people can and do differ with for minority students. mistakes occurred. Thomas took full re- his views on this matter. However, the Federal agencies were required to submit sponsibility for any shortcomings and re- potential use of goals and timetables was affirmative action plans identifying barri- doubled his efforts to make the EEOC a involved in less than one-half of one per- ers to the full employment of all employees formidable opponent of those who would cent of the more than 60,000 cases filed and detailing the steps to be taken to re- violate the laws prohibiting discrimination. annually. A difference of opinion over the move those obstacles. Today's EEOC is a fitting and lasting utility of thisone form of affirmative action When he became chairman in 1982; tribute to Clarence Thomas's vision and his cannot serve as a legitimate basis for cava- Thomas found an EEOC in disarray. Clar- unwavering commitment to upholding the lier assertions that Thomas did not enforce ence Thomas not only built the infrastruc- laws protecting American workers. LOS Angeles Times SUNDAY, JULY 7, 1991 He Is Nothing If Not an Independent Thinker' There were cheers that day as well PERSONAL Clarence loves to tell the story of the PERSPECTIVE day be arrived at the EEOC. His prede. cessor had left him the title of "chair." but when he finally gained admittance to his office-he had trouble convincing the. By R. Goull Sliberman guard that be. Clarence Thomas. was the WASHINGTON new chairman of the EEOC chair mL W ben Clarence Thomas stepped behind his desk. Neither chair. systems onto the national stage last or.sembiance of organization was to be Monday in Kennebunkport. found. Clarence got himself a chair and & Ma. cheers erupted at the Equal Emoloy- Classic Coke put his grandfather's and his, ment Opportunity Commission. the -gen- son's pictures on his desk (It at least cy be headed for eight years. That remained) and went to work. longtime employees of the often beles- Much has been written about Myers. guared commission cheered Thomas' Anderson, Clarence's grandfather. the nomination to the Supreme Court is a most profound influence on his life. When story to itself. I first came to the commission in late. Immediately after President George 1984. Anderson had only died recently, Bush introduced Thomas. members of the When Clarence talked about him. his eyes: prem started calling the commission welled up. Anderson's injunctions to his "Who is this Clarence Thomas!" grandson to "make something of your- For those of - who were his col- self." that "Mr. Can't is dead. I helped: leagues. the answer is quite simple He is bury him" became the railying cries for dignified. reflective. direct. careful. cou- an agency in which "Mr. Can't" had been regeous-a friendly. funny man with a very much ative. hearty laugh. The Clarence Thomas you The men and see is the Clarence Thomas you get women of the Everyone at the EDOC remembers that EEOC love Clar- his arrival in May. 1982. aroused a good ence because. in measure of skepticism from a staff weary a real sense. be: of uncertainty and leary of this Reagan- is one of them. appointed black man. They, too, asked. In the earty "Who is this Clarence Thomas!" days of his This past week. I've been reminiscing chairmanship, with some of the men and women of the he would " EEOC about then-Chairman Thomas. One down to the fl- theme stands out Thomas profoundly nance section so influenced the commission and the men often that be and women who work for IL AL his had his own chair there. The supervisors renomination hearings in 1987. the line to were not sure that the chairman's tree for into the committee room wound quest. unannounced visits were Decear around the corridors of the Dirkson sartly a good thing. But as staffer Mary Building, so many commission employees Stringer remembered this week. "We had taken annual leave to go down and closed the books on Sept. 30th and и we support their leader. were here 'til two in the morning, Clar. And lead he did. Clarence challenged ence was here." his staff to do better. convinced them that "Pop" Tate. once janitor. now roving be and the agency needed their best. He EEOC jack-of-all-trades. is keeping a told them that tough times were ahead scrapbook of everything that's being (be was right). that they were going to written about his friend. Judge Thomas have to break some crockery but. togeth- "Pop" never quite understood how any. er. they would pick up the pieces and one who lived in Washington could root create a revitalized agency of which they for the Dallas Cowboys. but Clarence M. could all be proud. And be did just nothing of not an independent thinker. that-when be left the commission. the Clarence does not uncritically accept new building for which be had fought so orthodaxy of any stripe. He questions hard was named the Thomas Building. cliches like "color-blind society." know. ing full well that color and race are facts' of life. factors in life. You can make them a plus. make them a minus. but you can't erase them. Clarence publicly questioned the Rea- gan Administration's seeming reluctance to broaden the Republican Party. He instated that his party had room for people of all colors. faiths. conditions and classes. That's why he was an inspering bodd of the EEOC. His liberating message to all who know him - You count because of who you are and what you do. not because of what goods you possess or to what race (or religion) you belong. And that's the signaficance of his ap- pointment. Clarence Thomas' confirma- Lion hearings present a historic oppor- tunity to reasoure the people of this country that the American dream lives. The men and women of the United States Equal Employment Opportunity Commis- sion are getung ready to cheer again. Initiatives of Judge Clarence Thomas at the U.S. Equal Employment Opportunity Commission (Tenure: May 1982 to March 1990) "Overall, it seems clear that he left the [EEOC] in better condition than he found it.' (U.S. News and World Report, July 15, 1991). ENFORCEMENT Charge Processing Before Thomas In April 1981, the General Accounting Office found, "The rapid charge process has over-emphasized obtaining settlement agreements with the result that EEOC has obtained negotiated settlements for some charges on which GAO believes there was no reasonable cause to believe that the charges were true. The settlement agreements for these charges have little substance and they distort the results of the rapid charge process by inflating the number of settlements." The GAO report found that these negotiated settlements "undermine EEOC's credibility because charging parties and employers said they were pressured into settlements they disagreed with [and] charging parties were led to believe that, since the charges were resolved with settlement agreements, their charges had merit but EEOC handled them ineffectively.' (GAO, Further Improvements Needed in EEOC Enforcement Activities, (April 9, 1981). Thomas Initiative Under Judge Thomas' leadership in 1983, the Commission unanimously adopted a resolution to shift its presumption in favor of rapid charge processing to one of case-by-case decisions on appropriate methods for resolving administrative charges, so that adequate evidence could be obtained to ensure strong cases for conciliation and litigation. This resulted in more full investigations and ultimately, in more cases being considered by the Commission for litigation. (EEOC). The Thomas Commission adopted a remedies policy which calls for a full remedy to be sought in every case where discrimination is found, including elimination of the discriminatory practices. (EEOC, Policy Statement on Remedies and Relief for Individual Cases of Unlawful Discrimination, Feb. 5, 1985). Thomas at EEOC Page 2 Litigation Before Thomas Cases were selectively litigated. (EEOC). Thomas Initiative An enforcement policy was adopted which called for every case of discrimination which fails conciliation to be presented to the Commission for litigation consideration. (EEOC, Statement of Enforcement Policy, Sept. 11, 1984. This resulted in a Statistics). dramatic increase in the number of lawsuits filed by EEOC. (EEOC Systemic Cases Before Thomas Before Clarence Thomas arrived at EEOC, the agency had no viable systemic program. Many systemic charges were never investigated or resolved. (EEOC). Thomas Initiative In 1985, Judge Thomas reorganized the systemic function so that investigations and litigation of systemic cases were placed respectively into the two offices best equipped to conduct these specialized functions. (EEOC). In 1988, 103 systemic cases were investigated and 16 were in active litigation. of the $131 million in relief obtained in FY 1988, over $48 million was awarded in large class action/pattern and practices cases. (Vice Chairman R. Gaull Silberman, EEOC). Lawsuits Before Thomas In 1981, EEOC filed 444 lawsuits on behalf of discrimination victims. (EEOC Enforcement Statistics). Thomas Initiative By 1986, the agency was routinely, filing more than 500 lawsuits each year. Altogether during Thomas' tenure, EEOC filed more than 3,300 lawsuits and obtained nearly $1 billion in monetary benefits for victims of discrimination. (EEOC Enforcement Statistics). FEDERAL SECTOR ENFORCEMENT Federal EEO Appeals Before Thomas EEOC's Office of Review and Appeals, which reviews federal agency decisions on employee EEO complaints, in 1982 was understaffed and ineffectively managed. Unassigned cases were placed in cardboard boxes stacked in a room from floor to ceiling; most were 2 or 3 years old before being assigned to an attorney, some were 6 to 8 years old before being completed. ORA decisions were not indexed or recorded for attorneys; GAO in 1982 reported that ORA decisions were inconsistent, even on separate appeals filed on the same case. (EEOC). Thomas Initiative EEOC under Clarence Thomas established a viable case filing system for federal appeals, assigned more attorneys to ORA, computerized case indices and a tracking system, a library was established for the staff and the average case processing was reduced to 130 days by 1989. (EEOC). In 1982, ORA completed 3,488 cases. In 1988, it completed 6,380. (EEOC, EEOC: 1982 to the Present, Dec. 1988). Federal EEO Before Thomas When Clarence Thomas arrived at EEOC, no "management directives" to federal agencies had been issued on the employment of minorities and women, no information or statistics existed on the status of minorities, women and disabled individuals employed by the federal government, mail was backlogged and paperwork was in boxes. (EEOC). Thomas Response Under Thomas, Management Directives 707 and 707A, for minorities and women, were issued for 1982 - 1987; Management Directive 714 for minorities and women and 713 for persons with disabilities were issued for 1988 - 1992. Reports on the employment of minorities, women and disabled individuals were issued on an annual basis since 1982 and the agency became a model employer of persons with disabilities. By the end of Chairman Thomas' tenure, all mail was answered within 30 days and all files were organized and computerized. Thomas at EEOC Page 4 FINANCIAL MANAGEMENT Before Thomas In May 1982, GAO reported to Congress that EEOC had not maintained accurate and up-to-date financial records, had not implemented adequate audit controls, had engaged in a questionable "loan" program to finance private Title VII discrimination suits and that the financial disarray of EEOC forced senior staff to make unsupported and improper manual adjustments to the year-end reports for fiscal years 1980-81. (GAO, Continuing Financial Management Problems at the Equal Employment Opportunity Commission, May 17, 1982). More than $1 million in outstanding employee travel debts remained uncollected and in fiscal 1981, the agency underwent a reduction in force, which according to a former budget official was directly related to the agency having returned to the Department of Treasury unspent more than $10 million of its $140 million appropriation due to poor financial management. (EEOC Fact Sheet). Thomas Initiative As Chairman, Judge Thomas improved the agency's financial management. By the time he left EEOC, the agency was regularly obligating more than 99 percent of its appropriation and is able to monitor all funds in its various offices. In 1984, for the first time, EEOC's financial accounting systems met GAO standards. (EEOC Fact Sheet). PERSONNEL Before Thomas In 1982, the Office of Personnel Management described the EEOC work environment as "beset by acrimony, improper employee conduct, poor performance and favoritism." (The Washington Times, July 5, 1991). In 1982, 60 jobs at EEOC were audited -- 53 were subsequently downgraded (of those, 42% were found to be overgraded by three or more grades) ; there was no accurate count of agency employees; employee pay records frequently contained errors. (EEOC Fact Sheet). Thomas at EEOC Page 5 Thomas Initiative Chairman Thomas implemented employee training and recruitment programs to upgrade and train the existing work force and to recruit and attract high quality employees. For the first time in 1987, virtually all investigators received comprehensive investigative training. Equal Opportunity Specialist positions were converted to Investigators in 1988, reflecting EEOC's commitment to more full investigations. Federal sector Hearing Examiner positions were upgraded to Administrative Judges and given more authority. Incentive programs were implemented. (EEOC Fact Sheets). Without additional resources, the personnel system was centralized and linked to the payroll system; by the end of Clarence Thomas' tenure the error rate was .01 percent. By the time Thomas left the agency, EEOC 's personnel organization was routinely commended and consulted by other small agencies and the Office of Personnel Management for its excellent personnel practices. In 1988, EEOC received the Office of Management and Budget's Productivity Improvement Award for quality, effectiveness and efficiency. (EEOC News Release, July 1, 1988). After a July 1991 visit to EEOC, Senator John C. Danforth said, "While at the headquarters, I had the opportunity to speak with a wide variety of individuals The clear message of those I visited was that Clarence Thomas had transformed the EEOC from the dregs of the federal bureaucracy to an efficiently operating agency which was effectively performing the duties Congress had assigned to it.' (Sen. John C. Danforth, July 16, 1991, Floor Statement). COMPUTERIZATION Before Thomas When Clarence Thomas arrived at EEOC, the only automated equipment for case management was two outdated mainframe computers with keypunch equipment. There were outmoded and incompatible word processors; the agency did not own even one personal computer. (EEOC Fact Sheet). Thomas at EEOC Page 6 Thomas Initiative Under Judge Thomas' guidance, EEOC began to automate by purchasing its first personal computer in 1983. The agency was computerized without any additional funding from Congress. As a result of Thomas' initiatives, an integrated charge data system was installed in all 50 field office which connected to a national database containing nationwide enforcement data on more than a million cases by the end of Thomas' tenure, more than 1,000 compatible personal computers were installed throughout EEOC and virtually every program at EEOC was computerized, including financial management, personnel, and federal sector appeals, in addition to enforcement. (EEOC Fact Sheets). ### PRESS The New York Times What Clarence Thomas Knows By Guido Calabresi especially not on African-Americans. ant is served by a lousy lawyer, they If he had, he would be unworthy to sit sound like what they are: people who on the Supreme Court. What he has neither through personal experience NEW HAVEN done is to conclude, with many others nor academic thought could ever am a Democrat. Since the and probably wrongly, that certain imagine themselves erroneously I President and others have measures have done more harm than crushed by the power of the state. started to throw mud on liber- good. I wish I could convince him Clarence Thomas, at least, knows als, I have proudly asserted otherwise. Maybe some day someone better, and someday, in some case, that I am a liberal. I despise will. that knowledge will make itself felt. the current Supreme Court What matters most, though, is that, Of course, there are others as able and find its aggressive, willful, statist unlike many on the Court, he does as Clarence Thomas who also know behavior disgusting - the very oppo- know the deep need of the poor and this. And if I were President I would site of what a judicious moderate, or especially of poor blacks, and wants name someone like that who also even conservative, judicial body to help. That will keep him open to shared my views. But it is a gross should do. argument as a Justice should be. illusion to think that this Administra- I think it strange that these strict The second reason I support him tion will do anything like that any destructionists should be allowed to derives from this direct knowledge of more than the Reagan White House get away with the claim that they are what it is like to be in need. This Court did when Robert Bork was cruelly following the Constitution when, in- caricatured and defeated. What we stead, they persistently reach well got then, what we would get now, is beyond the issues before them to Im- someone less able, with less life expe- pose their misguided values on the He may stand up rience, a gray follower of all that is Great Charter and on all of us. worst in the Court today. Yet I support the nomination of against a willful, And now, as then, The New York Clarence Thomas to that Court. Why? Times and eminent scholars who de- First, because I know him and statist Court. feated the nominee will join the band- know he is a decent human being who wagon of support for the nonentity. cares profoundly for his fellows. He is For in such a person the "offending" not the caricature that some of his views will not stand out against the opponents have put forth. It is true grayness of his background. that he has come to believe that some is outrageously homogeneous. It is No, I would much rather have things we liberals have espoused to overwhelmingly made up of gray Re- someone who does stand out, who help African-Americans (and many publican political hangers-on of virtu- holds his or her own views, with other people, too) are counterproduc- ally identical backgrounds. They all which I deeply disagree but who has tive. I think that on the whole he is bring to the Court the same life expe- somewhere, same time, experienced wrong. rience and lack thereof. life and has been willing to stand up But his conclusion is not so impor- How can they know what discrimi- against the pack. Better such a one tant as the fact that he does not deny nation really means? How can they than someone who will readily blend that such measures helped him or understand what fear of police, prose- in and be another anonymous vote for that the people whom these remedies cutorial or state abuse and brutality the activist and virulent views now so seek to help are deserving and often is? When they babble that coerced dominant on the Court. desperately need help. He has not confessions need not make trials un- For there is just a chance that such turned his back on those in need, and fair; that discrimination must be a one may stand up to the pack again, proved in individual cases and not and remind us all of what it is like to Guido Calabresi is dean of Yale Law through statistics, or that a single be poor and friendless and to be fac- School. appeal is adequate even if a defend- ing a hostile state. JULY 28, 1991 emcago Cribune JULY 18, 1991 Far from being eccentric, this general belief is Is Thomas' belief widely accepted. Says Randy Barnett, a professor at IIT-Kent College of Law: "Americans believe they have rights that the government didn't create and in natural law can't take away. Thomas is right in the mainstream of what Americans think." Thomas is also in harmony with one Joseph Biden, chairman of the Judiciary Committee, who during unnaturally odd? Robert Bork's confirmation hearings said of constitutionally protected rights: "What has been protected [are] important and fundamental liberties that, in my view, predate the Constitution. I Opponents of Clarence Thomas have discovered have them because I exist. that on occasion be has invoked something known as In fact, liberal interpreters take a similar approach "natural law." From their reaction you would think to the Constitution, arguing that certain transcendent they had found him at the airport in a Hare Krishna values and moral principles, like human dignity and robe. equal respect for all, deserve protection even though Harvard law professor Laurence Tribe depicts him they aren't mentioned in the text. Tribe himself as a scary medieval relic, "the first Supreme Court thinks it should be read imaginatively to guarantee nominee in 50 years" to draw on natural law. the right to "a decent level of affirmative Thomas, be suggests, may return us to the time when governmental protection in meeting the basic human the Supreme Court said women could be prohibited needs of physical survival and security, health and from becoming attorneys because the law of nature housing, work and schooling." consigned them to the job of wife and mother. Yes, that's hypocrisy you smell. "There is not a He was seconded by Robert Alley, an adviser to fundamental or significant difference between using Americans United for Separation of Church and natural law and using moral principles to interpret State: "If be develops an agenda of declaring the Constitution," says University of Minnesota law professor Suzanna Sherry, a self-described liberal. Stephen Chapman The critics suggest that Thomas will analyze the Constitution by trying to make it conform to Aquinas' Summa Theologica. They might be forgiven 'unnatural' things as immoral, I'm frightened." if he hadn't taken such trouble to specify what he The logic is that since natural law has been used to means when be refers to natural law. defend oppressive practices, it can be used only to What he means is the ideals of the Declaration of defend oppressive practices. This is like saying that Independence, which says, "We hold these truths to since (a) the Nazis had moral principles, and (b) the be self-evident, that all men are created equal, that Nazis were bad, (c) moral principles are bad. Tribe they are endowed by their creator with certain doesn't mention one modern proponent of natural unalienable rights, that among these are life, liberty law, Martin Luther King Jr., who wrote that "an and the pursuit of happiness.' It is impcasible to unjust law is a human law that is not rooted in make sense of the Constitution, Thomas argues, eternal law and natural law." without understanding that its authors intended it as Natural law is essentially the broad idea, which an expression of these "self-evident truths." traces back to Thomas Aquinas, that human nature Referring to the Declaration, Thomas has written: defines how people should live, and that some "Here, as Lincoln put it, bies 'the father of all moral actions are wrong regardless of law or custom. The principle' in Americans. Equality means equality of term is also sometimes used to refer to the belief that individual rights, an equality resting on the laws of people have inherent ("natural") rights that others nature and of nature's God. Because no man is have a duty to respect. Sometimes these are viewed the natural ruler of another, government must as God-given, but not always: Novelist and proceed by consent. And that, in turn, requires philosopher Ayn Rand, a vociferous atheist, fervently representation, elections and the separation of believed in natural rights. powers. These are the requirements of free government, and they rest on a moral conception of human worth, based on human nature." Thomas agrees with the Framers that rights don't exist because the Constitution protects them; the Constitution protects them because they exist. He shares the view of most Americans that liberties are not something created by government that can be repealed by government, but the undeniable birthright of every individual. If Thomas' crities want to turn his confirmation hearings into a debute over those propositions, it isn't Thomas who will end up looking scary. EDITORIAL BY DAVID GERGEN EDITOR AT LARGE THE BRIEF ON CLARENCE THOMAS T he more one learns about Clarence Thomas, the the game over. ensuring that it is now played with abso- more compelling he becomes as a nominee to lute fairness. To insist upon preferences or quotas for the Supreme Court-and as a fresh hope in blacks may grant them temporary gain but cost them breaking America's paralyzing deadlock over race. In their own self-confidence and white respect. Stop rob- recent days, his life story has already been turned into bing us of our manhood. he says angrily. the stuff of legend: a young man whip lifted himself Thomas does not walk away from disadvantaged from the hardscrabble of rural Georgia, so dark- blacks: indeed. he has invested years trying to help them. skinned that other blacks in Savannah called him ABC But he thinks the proper role for government is to clear ("America's Blackest Child"); nurtured by a grandfa- away the hurdles of all poor people - the drugs, crime ther who could barely read, but knew enough to instill and malnutrition that plague inner cities-without re- the old values of hard work. self-reliance and religious gard to race. Nor is he a lackey for white bigots. At the faith: taught by nuns, but taunted by classmates in an EEOC, he sought much tougher penalties against all-white high school: persevering up whites ho discriminate: He wanted to the ladder through Yale Law School, fine them heavily and toss them in jail. onto the staff of, John Danforth in As a Reagan appointee. he attacked Missouri, then to Washington. and al- 'He believes the administration for dragging its feet ways. always. a lonely. personal strug- gle to be his own man. government's role on voting rights. for granting a tax ex- empti- to all-white Bob Jones Uni- Yet Thomas offers far more than is to protect the versity and for failing to offer a positive inspiring biography. "What Clarence individual, not to vision to blacks. He is not even certain is all about," says his friend, Republi- advance the about the merits of integration. Just to can Senator Danforth. "is that in this sit next to a white child in school solves country you should have the freedom interests of any nothing. he believes. First. the black to think what you want to think. child must learn to believe in himself. whether you're black. white. or any- one group. In donning judicial robes, Thomas thing else." Just as he has cut his own has pledged that his personal views career path, he has plowed his own will not matter. So strong is his alle- mental furrow, catching hell from all giance to law and precedent that his sides. Many civil-rights groups believe closest admirers believe he is more he betrays blacks because he refuses to march in lock- likely to fit the Felix Frankfurter than the William step with their agenda. From his days running the Equal Rehnquist mold. refusing to join conservative activists Employment Opportunity Commission, when he op- eager to strike down rulings from the Warren court. We posed racial quotas, they dismiss him as a black conser- won't know for sure how he will come out on abortion, vative doing the white man's bidding. In truth, Thomas school prayer or crime until he actually sits on the court. doesn't fit into any political box; he is, as Washington What we do know is that, as George Bush said. this political writer Juan Williams described him four years new nominee is "fiercely independent," and in today's ago in The Atlantic, "ideologically sui generis." climate, his voice is welcome. America has wound up Drawing heavily upon his life and his readings, in a terrible cul-de-sac over race: Most whites, blacks Thomas believes that under natural law (and America's and browns now believe in equality, but we are hung Declaration of Independence). all men and women are up in arguments and in government programs that created equal, and that the U.S. Constitution provides aren't working to bring it about. Too many black activ- legal guarantees. Government's role is to protect the ists insist that all blacks are victims and need special rights of the individual but not to advance the interests preferences throughout life: too many whites have giv- of any group. black or white; it is up to the individual to en up trying to find answers and suspect a black under- make it on his own. Yes. whites tilted the game unfairly class will be with us forever. Now comes Clarence in their direction for generations. but rather than com- Thomas insisting that if both races shape up, blacks pensating blacks for past sins. government should start can still make it on their own. He should know. 84 U.S.NEWS & WORLD REPORT. JULY 15. 1991 The Detroit News SUNDAY. JULY 7, 1991 A Man for This Season In politics, timing is almost as important as sub- rather than laying burdensome new rules on em- stance. ployers. Without the legacy of retiring Supreme Court As a result, court actions filed on behalf of plain- Justice Thurgood Marshall, Clarence Thomas tiffs rose from less than 250,000 in 1982 to more might not be the likely next justice of the Supreme than 560,000 a year under Mr. Thomas. From Court. But just as Thurgood Marshall was a man 1980-82, EEOC collected $320 million in fines for his time, leading the charge from employers. From 1984 for the basic civil rights of black through 1986, EEOC collected $381 million. That hardly strikes Americans, 80 Judge Thomas us as the actions of a man who may be the right man for this lacks "sensitivity" to employ- time, keeping the pendulum ment discrimination. Moreover, from swinging too far in the di- the Thomas rules have contin- rection of policies of racial pref- erence that could threaten the ued in force to this day, another indication that he was hardly a social fabric. Sadly, many black leaders see rogue ideologue when it came to fair play in the workplace. Judge Thomas as a threat to The one area in which Mr. their turf. A campaign of disin- formation about him has already Thomas' performance has been most severely questioned is in begun similar to that waged against Judge Robert Bork. age discrimination cases. The backlog of these cases reached a There appear to be three main new high in 1987, and many were areas of criticism: his conserva- allowed to lapse. This precipitat- tive "ideology," his record as ed an investigation by a Senate chairman of the Equal Employ- subcommittee. But at least part ment Opportunities Commission of that backlog was found attrib- and his apparent opposition to Clarence Thomas utable to the fact that Congress abortion. We don't know how Mr. Thomas would.vote on itself repeatedly appropriated less for EEOC opera- the matter of Roe VS. Wade. We do know the prem- tions than even the Reagan administration re- ise on which abortion rights folks are now attack- quested. ing him is false, namely that he is, as Virginia Gov. How about the charge that Judge Thomas is a Douglas Wilder said the other day, "a devout Ro-. hardline conservative who is "out of touch" with the American mainstream? man Catholic." It is true that Judge Thomas was schooled by That charge should have been laid to rest by Roman Catholic nuns and attended Holy Cross Mark Gitenstein, a liberal former Senate Judiciary University. Now, it is worth noting that some of counsel, who now heads the Foundation for the strongest pro-choice voices in America are Change, a Washington think tank. He told the Le- Catholic, including Sen. Joseph Biden, chairman gal Times in October 1989, during Mr. Thomas' of the Judiciary Committee which will sit in judg- confirmation as an Appeals Court judge, "In my ment on Judge Thomas. But the fact is, as Judge view, in the context of this administration Mr. Thomas pointed out in an interview last week, he Thomas is a moderate, pragmatic, reasonable nom- is not a Catholic. "Currently I am attending the inee." Episcopal Church," he said, which tends to leave And as Detroit Judge Damon Keith, a Carter questions of abortion to individual conscience. appointee to the 6th Circuit Court of Appeals, said at the time of Judge Thomas' nomination to the That does not settle the question of how he D.C. Court of Appeals: "IfI or a member of my might rule on abortion as a judge, but it does un- family were in trouble, he is the kind of person rd derline the fact that his opponents are likely to like to appear before." For making this statement, show no great regard for the truth in their cam- repeated in a Wall Street Journal article last week, paign against him. And the fact that "liberals," who Judge Keith says he has been the target of some not so long ago had to defend John F. Kennedy angry phone calls from other civil rights leaders. from anti-Catholic bigotry, would seek to hold a But he says he stands by his earlier statement. man's religion against him is a sign of the extent to which liberalism has degenerated as a principled One of the ironies of this line of attack is that political creed. Mr. Thomas was accused of being too "moderate" Mr. Thomas also is being attacked for his alleg- by members of the Reagan administration. The edly "insensitive and questionable enforcement re- main reason: He opposed race-based remedies such cord" at the Equal Employment Opportunity Com- as quotas, but he deeply believed in affirmative ac- mission. What is overlooked here is that when tion for qualified individual minorities. There are Clarence Thomas took over this agency, it was in ambiguities in such a position, but polls consis- chaos. It's no accident that one of Mr. Thomas' tently show that this is where the American people most strident critics is D.C. Delegate Eleanor are, too. Holmes Norton, who was his predecessor at the Judge Thomas stands as living proof that even EEOC. The nonpartisan General Accounting Of- the poorest black American can rise out of a Geor- fice in 1982 concluded that the internal record- gia sharecropper background to the highest court keeping of that agency under Ms. Norton was so in the land. That should be taken not as a rejection bad that "EEOC faces a formidable task in correct- of the vision of a Justice Marshall, but as affirma- ing the operational deficiencies that allowed the tion of the courageous struggle for equality before unreliable records to develop." the law in which Thurgood Marshall played such a Under Mr. Thomas the EEOC was for the first formative role. time fully computerized. Management also was Just as Thurgood Marshall was a man for his streamlined. And Mr. Thomas put the emphasis on time, Clarence Thomas appears to be a man for prosecuting individual cases of discrimination this season. The Atlanta Zournal THE ATLANTA CONSTITUTION SUNDAY. JULY 7. 1991 munity. Wouldn't it be ironic if, Thomas in your haste to conquer the trained and capable black pro- world, you lost those closest to fessionals and business people you? Or, in looking beyond the who were frustrated because horizons, you fell down a mine they were viewed only as mem- an asset shaft?" bers of a group who got their po- sitions through quotas rather These observations of Judge than because of their qualifica- to bench Thomas as a lawyer of keen intel- tions as individuals. Their true lect with strong values are all achievements were being deval- part of my simple response to ued and masked. questions regarding his confir- mation. Yet, many black leaders con- He offers strong values, tinued to advocate more govern- But, there is another, more intellect to court ment and private programs complex reason why I believe he based on racial quotas. should be confirmed. Judge By Larry D. Thompson Thomas, who is black, has said Ostracized by black liberals that we cannot simply dismiss B ecause I practiced law with Judge race as a factor in our society. Judge Thomas was an early, Clarence Thomas some 14 years His confirmation, I believe, may courageous advocate of so-called ago, many people have asked me, conservative positions. He was "Do you think he will be confirmed?" The signal the beginung of the ac- ostracized, often quite bitterly, simple answer is a resounding yes. ceptance of new ideas and values by many black liberal leaders. While some may disagree with Judge for a generation of black Amer- Thomas's views on several issues, I do icans. not believe that many who may differ Judge Thomas was never ob- with him on these issues, but who have sequious. He was always his own The wrong approach had an opportunity to know him, will op- person and was never a shill for pose his nomination. anyone or any cause. He has crit- Judge Thomas, who is almost A graduate of Yale Law School. Judge icized the national Rep half the age of Justice Marshall, Thomas is a legal scholar with valuable Party for what he saw as has, through intellect and hard hands-on experience in the public policy tant indifference" towar work, been able to take advan- arena. As chairman of the Equal Employ- voters and criticized the tage of the opportunities made ment Opportunity Commission, he led possible for our generation by administration for its po: the agency in removing a backlog of dis- the work of Justice Marshall and the Bob Jones University crimination cases that served to unfairly other black leaders. Yet, obvious when it tried to grant tax deny relief to individuals who suffered problems remain. status to that institution employment discrimination. The EEOC charges that it practic under his leadership became a more ef- When we were working to- crimination. fective advocate for individuals who gether, Judge Thomas and I In a speech at Suffolk were victims of discrimination, and it would once a week leave our cor- sity, he expressed the fru av dehumanizing litigation and pol- porate law offices and go to our of many black conservat. ici at led to minorities simply being favorite Chinese restaurant and "It often seemed that to be ac- treated as numbers. For example, the cepted within the conservative number of discrimination charges con- talk about the problems of the ranks and to be treated with sidered for litigation authorization by the EEOC rose from 401 in 1982, when Judge day. We would discuss the prob- some degree of acceptance, a lems black people were experi- Thomas became chairman, to 764 in 1988 encing and our dismay over and approximately 800 in 1989. black was required to become a some black leaders who contin- caricature of sorts, providing An outstanding role model ued to preach the "politics of despair." side shows of anti-black quips Judge Thomas is a warm and engag- and attacks. But there was more ing person. He is, as they say, down to These leaders stressed the much more to our concerns earth. He is also very wise and, because status of black people as victims than merely attacking previous of his background, will serve as an out- and advocated more government policies and so-called black lead- standing role model for our nation's assistance as the only way of ers. The future, not the past, youth, especially those who are poor or overcoming our problems. They could be influenced." black. ignored other problems facing While genuinely appreciative Over the years, we have exchanged the black community: drug use, and respectful of the important speeches and articles each of us wrote lack of respect for the law, kids contributions and sacrifices of and, quite frankly, I benefited more from having children too soon and fa- leaders of the past, many believe this practice than did Judge Thomas. thers who were not taking their that a new generation of black Judge Thomas is a prolific and insightful responsibilities seriously. leaders with new ideas will ad- writer. In a commencement address at We noted the pernicious ef- vance black Americans and this Syracuse University Law School this fects of group politics. We each nation even more. With this in year, Judge Thomas offered the follow- knew many outstanding, highly mind, Judge Thomas once told ing advice to the graduates: me, "Our day will come." With "I encourage you to focus first on his nomination to the United those who are nearest you, your parents, has. States Supreme Court, perhaps it siblings, children, friends - your com- THE WALL STREET JOURNAL. JULY 17, 1991 Borking Begins, but Mudballs Bounce Off Judge Thon Among the inadvertent benefits which He Is Black. When Sen. George Mitchell Judge Thomas wrote that a more endur- followed from the timing of the Bork nome- declared that Judge Thomas was nomi- ing opinion would have reflected the origi- ration was the coincidence of the regularly nated only because of his race, President nal intent of the post-Civil War amend- scheduled July annual meetings of mass Bush wondered if he "accused Lyndon ments, which fulfilled the promise of equal membership organizations, including Johnson of a quota" for nominating Thur- rights in the Declaration of Independence. Planned Parenthood, the NAACP, the Na- good Marshall. On what grounds is Judge Brown, he said, was a "missed opportu- tional Education Association, the National Thomas unqualified? He's written more nity to turn policy toward reason Organization for Women and the National law review articles than David Souter, has rather than sentiment, toward justice Abortion Rights Action League. These more law-enforcement experience than rather than sensitivity, toward freedom were followed by the August conventions of Justice Marshall and his years at Mon- rather than dependence-in other words, the Southern Christian Leadership Confer- santo would make him the only justice toward the spirit of the Founding.' A close ence and the national board meetings of with experience working as a corporation understanding of the Founders' back- lawyer. Admittedly, there is a single most- ground in natural-rights theory is impor- Rule of Law qualified nominee; maybe President Bush tant in interpreting the original intent of should send up Robert Bork's name if the document they left behind. Judge Thomas is defeated. He's an Anti-Semite. Critics dug out a By L. Gordon Crovitz He's an Affirmative Action Ingrate. 1983 speech where he praised Louis Far- Judge Thomas represents a generation of rahkan's message of self-help for blacks. minorities who have felt both sides of the Once Mr. Farrahkan's anti-semitism be- Common Cause, the AFL-CIO and the affirmative-action sword. At Yale Lav came widely known, Judge Thomas gave ACLU." School. he sat in the back of classrooms in speeches criticizing him-more than Rep. This reminiscence is from "The People the hope that professors would not notice Gus Savage and others in the Black Rising." a book celebrating how special in- his race and assume he was less qualified. Caucus can say. Mr. Thomas international- terest groups defeated Robert Bork's nomi- One of his happiest experiences at Yale ized the EEOC by demanding rights for So- nation. This past July 1. four years to the was when he went to pick up his blindly viet Jews. He was also the 1986 winner of day after the Bork nomination, many of graded final exam in tax law. The secre- the Humanitarian Award from the Union the same groups went into high gear when tary handed him a copy of the best exam of Orthodox Jewish Congregations of President Bush nominated another conser- while she looked for his. He was thrilled to America. recognized for his "commitment vative. Will Clarence Thomas also die the see that the model exam was his. to the right of all Americans to live free death of a thousand interest groups? He ran into a double standard when law from discrimination based on race. reli- "We're going to Bork him," Florence firms recruited him. Instead of discussing gion or national origin and your support Kennedy said of NOW's game plan. "We're his favorite legal subjects-tax and corpo- for the rights of Sabbath observers." going to kill him politically This little rate law-lawyers would only tell him He Has a Weird Personal Life. There creep. where did he come from? The about their minority hiring and public-in- was a leak about Judge Thomas using ma- ript calls for throwing up endless terest work. This is why Judge Thomas in- rijuana in college, which he disclosed when ears: if there's enough smoke, there's stead became assistant attorney general in he was appointed to the appeals court. excuse. Recall how Alabama Sen. How- Missouri under John Danforth, who agreed Then there were reports that Mr. Thomas eil Heflin explained that he voted against to treat him like anyone else. and his first wife had a bitter divorce. His Mr. Bork because "He had a strange life- Only Liberals Can Cite Natural Rights. former father-in-law said the two "were style." Senators representing the liberal The hypocrisy award goes to Harvard's congenial and have remained so," telling plantation must see a conservative black Laurence Tribe. After a career of urging the Boston Herald that "I'm very proud of as the very definition of a strange life- liberal judges to look beyond the Constitu- Clarence, my whole family is." It's been style. The attempted smears so far: tion. he criticized Judge Thomas for writ- reported that Judge Thomas hung a Con- He's Catholic. Judge Thomas's Catholic ing about natural federate flag in his Missouri office, but the upbringing is code for the assumption that rights. which he flag was the Georgia State flag. which he finds no constitutional right to abortion. hasn't invoked as a Judge Thomas displayed in mischievous The abortion issue has already returned to judge. He had a nar- patriotism for his home state. Perhaps try- the state legislatures following the Webster row purpose for ing to repeat the infarnous scoop of the vid- decision but. fresh from his grudge match thinking about natu- eotapes Mr. Bork had rented. reporters pe- with Chuck Robb. Virginia Gov. Douglas ral rights when he rused the books Judge Thomas stores in Wilder asked. "How much allegiance does ran the Equal Em- his garage. They found such lascivious ma- (Judge Thomas) have to the pope?" The ployment Opportu- terial as books by Ayn Rand. Alexander John Kennedy precedent aside, the Consti- nity Commission. Solzhenitsyn and Alexander Pope. tution says "no religious test shall ever be This is that he These mudballs have not stuck. but the required as a qualification to any office." thought Brown v. interest groups know they have until the This non-issue may be moot. Judge Board of Education September hearings. Judge Thomas and Thomas attends the Truro Episcopal did not go far the country deserve a debate on the Consti- Church in Virginia. enough because it tution, original-intent jurisprudence and ju- He's Not Black. Derrick Bell, a Har- relied on sociologi- Clarence Thomas dicial restraint. Instead, we will get end- vard law professor, declared that Judge cal evidence more than legal principle to less smears that liberals hope will post- Thomas "doesn't think like a black." Col- overrule the separate-but-equal doctrine. pone their greatest fear-a conservative umnist Carl Rowan said, "If you gave black justice who will help legitimize a Clarence Thomas a little flour on his face. competing social and legal view. you'd think you had David Duke talking." Ugly, but nothing new. "Here's a strange black." Judge Thomas says about how peo- ple see black conservatives. "Let's go see if he has two heads and a tail." WEDNESDAY. JULY 10. 1991 A21 But we don't know black conserva- Maybe he really does believe that tives-we doubt that it is legitimate there's nothing the government can even to be a black conservative. What or should do about entrenched William Raspberry Thomas is speaks SO loudly to us that racism, but I doubt it. I hear him the we cannot hear what he says. same way I hear Wilder and Jackson Thomas None of this, I should note, speaks to and scores of other plain-spoken Themas's fitness for the Supreme blacks. I hear him saying with Wilder Court. He wouldn't have been my that blacks are foolish to wait for choice. But then no one likely to be whites to deliver us, that we must Lnd the appointed by a conservative Republican return to the old values that worked president would be my choice. I believe for us in harsher times than these. the court is too conservative al- that we must "redig the wells our ready-too devoted to the privileges of fathers dug." Black authority and too uncaring about the And I hear him saying with Jackson rights of ordinary people, too wrapped that whatever succor may exist in big- up in governmental theory and too ger budgets and greater concession from the larger society, there will re- Mainstream innocent of experience as outsiders in a society dominated by white men. main work that only we can do, that Given an unfettered choice, I'd opt "nobody can save us for us-but us." for a liberal whose bona fides include a The speaker. having recounted his history of concern for the underdog. own humble, race-restricted origins, But the choice isn't unfettered. urged his NAACP audience to take We're playing "Let's Make a Deal" with "pride in endeavor and accomplish- a host who offers us a choice between a ment, discipline of mind and body serviceable Chevrolet and a goat, and not succumbing to those who talk about we're holding out for a curtain that taking shortcuts." The young people in conceals (we hope) a Mercedes Benz the audience, he counseled. shouldn't with an interior designed by Thurgood be afraid to accept menial jobs or to say Marshall. Well, there's no Benz behind "yes, sir" and "yes, ma'am," if that is any of the curtains. If we're not pre- what it takes to get where they want to pared to deal with the goat, we'd better go. "If you know you have to be doubly take the Chevy. prepared, be doubly prepared. and then Granted it's a strange Chevy. We get on with doing the job." don't know many black Americans in He cautioned against race-specific high places who will dismiss affirmative approaches to solving the problems action out of hand, or who will argue that confront black people. "Only when against government catch-up programs America understands that they are not for blacks or who will align themselves problems but American problems with conservative politicians. We've e be able to solve them." Three seen conservatism and racism wearing trungs about that speech. delivered five the same garb SO often that we've years ago and greeted with near-unani- come to believe you can't have one mous enthusiasm: without the other. First. the speaker was a lawyer Well, I'm not convinced. At least working for the government, not a some of Thomas's conservatism finds nominee for the Supreme Court. Sec- echoes in black America, including ond. it wasn't Clarence Thomas: it was the black establishment. Note the re- Doug Wilder. then lieutenant governor marks of Jackson and Wilder. And the of Virginia. And third. the remarks rest of it, no matter how much I were well within the mainstream of might reject it, is inevitably tempered black thought. A full decade earlier, by his experience as a black man jesse Jackson was warning against the whose own opportunities have been rhetoric that leads black youngsters to blunted by racism. see themselves as society's victims As a friend of mine puts it, "Given a rather than as human beings capable of choice between two conservatives, I'll controlling their own destinies. "No- take the one who's been called 'nig- body can save us from us-but us," he ger.' used to say. I believe with this friend that Why is it that when a Wilder or a Thomas is sufficiently acquainted Jackson says these things they are with racism to recognize it when it taken as necessary, if uncomfortable, comes before him on the Supreme truth, but when a Thomas says them Court, that he is independent enough they are taken as evidence of personal not to see the critical issues in the smugness, of his lack of interest in the light of his own experience and that plight of his own people? he is smart enough to find in the The reaction, it seems to me, is less Constitution protection against the to what is said than to who says it. We presumptions of white privilege. know who Jackson and Wilder are- for their battles waged on behalf :ks and for their allegiance to Democratic politics, which has become the black political orthodoxy. ST.LOUIS POST-DISPATCH SUNDAY, JULY 28, 1991 3B The Clarence Thomas I Know His Life Is The Embodiment Of The Values Our Nation Prizes Clarence was a great conversationalist. Because he had By Alex V. Netchvolodoff literally grown up with discrimination. I was particularly inter- c larence Thomas is a black man from rural Pinpeint. Ga. ested in his views on civil rights. He had absorbed the thinking He was born to an impoverished family with an absentee of America's black leaders through the prism of his grandfa- father. an overworked mother. a home without plumb- ther's values. Clarence applauded Booker T. Washington's ing and a very bleak future. Yet Clarence Thomas has just been emphasis on black education. From W.E.B. DuBois, he bor- nominated by President Bush to serve as associate justice of rowed an aggressive and unbending contempt for discrimina- the U.S. Supreme Court. tion and social injustice. From Martin Luther King, he advocat- At an early age, Clarence was sent to live with his maternal ed nonviolence and social reconciliation. From Malcolm X, he grandparents. For him, it was a turning point. He became the embraced the imperatives of black independence, pride and object of his grandfather's unrelenting attention and expecta- self-help. And from Thomas Sowell, he accepted free markets and hard work as the best path tions. "work hard and then to economic justice. While argu- work even harder; be self-reli- ing that the full force of the law ant: get a decent education; be and the moral authority of soci- faithful to your vision of person- ety should be marshaled al achievement and, by example, against racial discrimination, to your own people's struggle." he rejected as counterproduc- Clarence has been living up to tive numerical goals and quotas his grandfather's expectations in schools and the work place. ever since. As chairman of the Equal Thomas' growing up was stark. Employment Opportunity Com- He had more than a full-time job mission, Clarence had a chance on his grandfather's truck, but nevertheless. he excelled at his to put these values into action. He had inherited a demoral- all-black parochial school. There ized, directionless agency. Sev- was little time and money for eral years later, Clarence diversion. Even so, Clarence dis- proudly showed me around. De- dained Savannah's segregated spite congressional budget cuts, movie theaters and restaurants. he had reorganized EEOC's fi- Instead, he satisfied his appetite nances, personnel and docket. for books at an all-black library. The staff was upbeat and proud Clarence left Savannah for of its accomplishments. New Holy Cross College with his wits enforcement records had been and a few dollars in the sole of his shoe. He founded the Black set. Upon Thomas' departure to the U.S. Court of Appeals. the Students' Union and began to new EEOC headquarters was consider how blacks could suc- named after him. ceed in a white society. He grad- Clarence Thomas is an au- uated with honors and went on to thentic American hero. His life Yale Law School, where he is the embodiment of the values served as a student volunteer at that our nation prizes. He has the New Haven Office of Legal developed, with singleness of Assistance. purpose, an inquiring and pene- I first met Clarence Thomas in trating mind. He has pursued. 1974 when I flew him to Jeffer- with equal tenacity, his vision of son City as part of an effort to recruit him as an assistant attorney general. He had to know self-improvement. He has served loyally as a role model for his how every gauge and every control worked on that plane. His own people. He has refused to bend to bigotry and discrimina- exuberant curiosity and penetrating mind were striking. By the tion. He has turned the other cheek. He has advocated a vision time we arrived, he was practically flying the plane, and he for social and economic justice that is focused on education and self-reliance, rather than on condescension and reprisal. was great company in the process. At his job interview, Clarence interviewed us! He wanted to He is open-minded, but he calls things as he sees then. He is be assigned the toughest litigation and a heavy workload. He forever linked by history and by personal memory to those in got his wish - and he delivered. As Thomas was leaving state our society who are weak, fragile or different. Who better to government for the climes of a corporate law practice at represent us in the Supreme Court of the United States of Monsanto, Robert Dowd, presiding judge of the Missouri Court America than Clarence Thomas? of Appeals. noted that Clarence was one of the best prepared I, for one, am proud to tell his story, and I look forward to his and most effective lawyers to appear in his court. service on the court for the challenge to us and the surprises Thomas was also a person of great self confidence and for us that I know it will bring. integrity. He once told the attorney general (who had suggested that Clarence show a bit more political sensitivity) that if the attorney general wanted a political opinion instead of a legal opinion. then he should go find a politician rather than a lawyer to write it. The opinion was issued as Thomas had drafted it. INTERVIEW And in the interim they encourage us to believe that redress is our power. I don't take any simpleminded black-and-white Nothing Is Ever Simply view and say racial preferences have nev- er done a bit of good for anybody. All I've tried to do is point out the down side Black and White and that we've probably come to the point where they are doing more harm than good. Outspoken author SHELBY STEELE defends Clarence Thomas and argues that too many African Americans see Q. Are you letting white people off the hook? themselves as victims A. I don't mean in any way to let white peo- ple off the hook. I think as American citi- A. Clarence Thomas is considered a conser- zens, they have a profound responsibility By SYLVESTER MONROE MONTEREY vative today because of the context, and the to black Americans. I favor every form of Q. Why are so many African Americans con- context is that for the past 25 years civil affirmative action except preferences. I fa- cerned about Clarence Thomas' nomination rights organizations have focused one-di- vor the government improving the educa- to the Supreme Court? mensionally on our oppression and de- tion system in the inner cities. I favor pro- A. On the deepest level, he touches the manded redress based on that. Well, here grams that go down to the teenage mother very soul of the debate in black Ameri- comes a man in 1991 who stands for self- and try. to break that cycle of poverty by ca, which is a debate between using the help, and so he is anathema. The principle teaching her parenting skills. The most important thing that people who have been victimized can under- ANDY FREEBERG FOR TIME "I don't say racial stand, whether it is fair or unfair, and it certainly is not fair, is that change will preferences have have to come from themselves. Thomas never done a bit of and I are not hardhearted people who are simply saying, "Get up off your butt, good for anybody. pull yourself up by your bootstraps." We All I've tried to do need government intervention to help us. is point out the But we've also got to help ourselves. Op- portunity follows struggle. It follows ef- down side and that fort. It follows hard work. It doesn't we've probably come before. come to the point Q. You once said that liberals are no friends where they are of blacks. What did you mean? doing more harm A. Watch out that your closest friend may be your greatest enemy, is my feeling about than good." liberals, because they encourage us to identify with our victimization. It is one thing to be victimized; it is another to make an identity out of it. I am not willing to be a boy because I am inferior, and I am not go- ing to be a boy because I am a victim. I re- ject both avenues to being a boy. The one thing a white liberal can never do with a black is be honest and tell him what he tells principle of self-sufficiency as a means of self-reliance seems to devalue victimiza- his own children. to power as opposed to using our history tion as a source of power. I don't think it of victimization. We have taken our necessarily does, but it seems to. And so Q. Which is what? power from our history of victimization, Thomas seems to be against the interests of A. Which is that you have to work hard and which gave us an enormous moral au- black people merely by standing for self-re- your life in many ways will reflect the thority and brought social reforms, to liance. He's not remotely anti-black. He's amount of effort you put into it. They teach the neglect of self-reliance and individ- just asking that we develop another source that every day to their own children, but ual initiative. And now, any time you of power. then they come out in public and talk about talk about self-reliance in relation to blacks as just victims who need redress. black problems, you are automatically Q. You have said that you are against prefer- This is racial exploitation by white liberals, considered a conservative. ential treatment, not affirmative action per se. who transform this into their own source of But the widespread perception is that you power. We're being had by them, and we Q. You don't consider yourself a conservative? are anti-affirmative action, and so is Clar- really need to know that. A. No. I think of myself more as a classical ence Thomas. Liberals are screaming for racial pref- liberal. I focus on freedom, on the sacred- A. What I've tried to say, and I think erences. But as soon as they give you the ness of the individual, the power to be found Clarence Thomas stands for pretty much preference, they hold it against you. "Hey, in the individual. the same thing, is that by opposing racial you were helped by affirmative action," preferences we stand for black strength they say about Clarence Thomas. "You Q. But other black thinkers from Booker T. rather than weakness. The thing that dis- wouldn't be where you are if it was not for Washington to Malcolm X to Jesse Jackson turbs me about affirmative action, about affirmative action." That's one reason I have preached self-reliance, and nobody preferences, is that they can and will be have a problem with preferences. How can called them conservatives. taken away. They will diminish over time. he win? He can't. 6 TIME, AUGUST 12, 1991 Seldane INTERVIEW (terfenaone 60 mg Tablets BRIEF SUMMARY Q. How much impact does racism have on himself. Now you are going to take that CAUTION Federal law prohibits dispensing without prescription. the lives of black Americans? DESCRIPTION away from him and say he made it because Seidane (terfenadine) IS available as tablets for oral administration Each tablet A. I think being lower class has a much of affirmative action. He didn't have affir- contains 60 mg terfenadine Tablets also contain. as inactive ingredients. corn starch gesatin. lactose. magnesium stearate. and sodium bicarbonate. INDICATIONS AND USAGE greater impact. You and I both know, as a mative action back there in Pin Point, Ga. Seldane IS indicated for the relief of symptoms associated with seasonal allergic rhinitis such as sneezing. rhinorrhea. pruntus. and lacrimation middle-class black you can send your kid to His grandfather made him go to school and CONTRAINDICATIONS any school you want. But if you and I were study hard, and then he gets into the posi- Seidane 5 contraindicated in patients with a known hypersensitivity to terfena- dine or any of its ingredients. on the South Side of Chicago and not do- tion where, yes, maybe he could benefit. PRECAUTIONS General Terfenadine undergoes extensive metabolism in the Irver. Patients with ing very well economically, then clearly you But if all that early work had not been impaired hepatic function (alcoholic cirrhosis. hepatitis). or on ketoconazole or troleandomycin therapy. or having conditions leading to QT prolongation (e.g. would not be able to send your kid to what- done, we wouldn't know Clarence Thomas hypokalemia congenital QT syndrome) may experience QT prolongation and/or ventricular tachycardia at the recommended dose The effect of terfenadine in ever school you wanted. At this point, today. patients who are receiving agents which alter the QT interval IS not known These events have also occurred in patients on macrolide antibiotics. including class, poverty and isolation are far more erythromycin. but causality IS unclear. The events may be related to altered metaboism of the drug. to electrolyte imbalance. or both. difficult variables for blacks than racism. Q. What are you telling young blacks? Information for patients Patients taking Seldane should receive the following information and instructions. Antihistamines are prescribed to reduce allergic That does not mean racism is gone; I think A. The most important thing for young symptoms Patients should be questioned about pregnancy or lactation before starting Seidane therapy. since the drug should be used in pregnancy or lacta- you'll meet it wherever you go. But it does black people to do is what you and I did- tion only if the potential benefit justifies the potential risk to fetus or baby. Patients should be instructed to take Seidane only as needed and not to exceed not have the power to contain your life that become educated. If you are educated, the prescribed dose. Patients should also be instructed to store this medication in a lightly closed container in a cool, dry place. away from heat or direct sun- it used to have. then at least you have some kind of chance. light. and away from children. Drug Interactions: Preliminary evidence exists that concurrent ketoconazole or Learn to think, to read, to be in touch with macrolide administration significantly alters the metabolism of terfenadine. Concurrent use of Seldane with ketoconazole or troleandomycin IS not recom- Q. According to you, there is a great deal of the larger world. One of the saddest things mended Concurrent use of other macrolides should be approached with caution. Carcinogenesis mutagenesis. impairment of fertility Oral doses of terfenadine. opportunity that blacks are simply not taking I see is black students who say to me, "I corresponding to 63 times the recommended human daily dose. in mice for 18 months or in rats for 24 months. revealed no evidence of tumorigenicity Micro- advantage of. Many blacks disagree with only read' black writers." And what they bial and micronucleus test assays with terfenadine have revealed no evidence of you. really mean is they are reading people like mutagenesis. Reproduction and fertility studies in rats showed no effects on male or female A. It depends on how you define opportu- Don L. Lee and Louis Farrakhan. I say, fertility at oral doses of up to 21 times the human daily dose At 63 times the human daily dose there was a small but significant reduction in implants and at nity. I don't see opportunity in a one- Have you ever read any Jean-Paul Sartre? 125 times the human daily dose reduced implants and increased postimplanta- tion losses were observed. which were judged to be secondary to maternal dimensional sense as something that is Have you ever read any Ralph Ellison or toxicity Pregnancy Category C: There was no evidence of animal teratogenicity Repro- simply there either waiting or not waiting Albert Murray or James Baldwin? Nope. duction studies have been performed in rats at doses 63 times and 125 times the human daily dose and have revealed decreased pup weight gain and survival for somebody to come and grab it. I think But they read Don L. Lee's tract on what a when terfenadine was administered throughout pregnancy and lactation There are no adecuate and ell-controlled studies in pregnant women Seldane should of opportunity as something that one cre- black man should be, as though this is dif- be used during pregnancy only if the potential benefit justifies the potential nsk to the letus ates, that you generate opportunities for ferent from what any man should be. And Nonteratogenic effects Seldane IS not recommended for nursing women. The drug has caused decreased pup weight gain and survival in rats given doses 63 yourself. so there's this sort of intellectual segrega- times and 125 times the human daily dose throughout pregnancy and lactation Effects on pups exposed to Seldane only during lactation are not known. and A Jewish woman told my brother tion that I think is absolutely a death knell there are no adequate and well-controlled studies in women during lactation. Pediatric use Safety and effectiveness of Seidane in children below the age of 12 something I think is absolutely vital for for our future. years have not been established. ADVERSE REACTIONS black people to understand. It was a simple Experience from clinical studies. including both controlled and uncontrolled studies involving more than 2.400 patients who received Seldane. provides phrase: "Don't wait for people to love Q. Many blacks accuse you of allowing your- information on adverse experience incidence for penods of a few days up to SIX months The usual dose in these studies was 60 mg twice daily. but in a small you." We are too preoccupied with wheth- self to be used by white neoconservatives, number of patients. the dose was as low as 20 mg twice a day. or as high as 600 mg daily er white people love us or not, whether who are no longer willing to deal with the In controlled clinical studies using the recommended dose of 60 mg b.i.d. the incidence of reported adverse effects in patients receiving Seldane was similar they are racist or not, what they think problems of race and poverty. to that reported in patients receiving placebo. (See Table below.) about the color of our skin or the texture of A. Some of them do use me, and I think ADVERSE EVENTS REPORTED IN CLINICAL TRIALS our hair. Who cares? We have to go for- some of them do not have the best interests Percent of Patients Reporting ward and make our own opportunities. of black Americans at heart. But if every- Controlled Studies' All Clinical Studies** Adverse Seldase Placebe Control Seldane Placebe Event N=626*** body is hip enough to ask me this question, N=781 N=665 N=2462 N=1478 Q. You've told me that you admired your fa- then my use to the neoconservatives is Central Nervous System Drowsiness 90 81 18.1 85 82 ther and that he saved your life, taking you to neutralized. Heacache 63 74 38 15.8 112 Fatique 29 09 58 45 3.0 Dizziness 14 1.1 10 15 1.2 the YMCA when other black parents said it In many ways, the fear that I'm being Nervousness 0.9 02 06 17 1.0 Weakness 09 0.6 0.2 06 0.5 was too far to go or too expensive. Clarence used by neoconservatives reflects a para- Appetite increase 06 00 0.0 0.5 0.0 Gastrointestinal System Thomas talks much the same way about his noia that has always been part of black life, Gastrointestinal Distress (Abdominal distress. Nausea vomiting. grandfather. How do you duplicate that expe- and it is part of the life of any oppressed Change in Bowel habits) 46 3.0 27 7.6 5.4 Eye Ear Nose and Throat rience for less fortunate blacks? group, a paranoia about what you say in Dry Mouth Nose/ Throat 23 18 3.5 48 3.1 Cough 09 02 0.5 2.5 1.7 A. This is one of the heartbreaking things front of the Man because he'll use it Sore Throat 0.5 03 0.5 32 1.6 Epistaxes 00 0.8 02 07 0.4 about the politics of victimization. We against you. One of the things I stand for Siun Enuption (including rash have always had the tradition of self-reli- and urticaria) or itching 10 17 14 16 2.0 more deeply than anything else is that I do ance in the black community, but this tradi- not see the white man as all that powerful, "Duration of treatment in CONTROLLED STUDIES was usually 7-14 DAYS. "Duration of treatment in ALL CLINICAL STUDIES was up to 6 months. tion gets squashed because it conflicts with all that smart. Blacks really need to begin CONTROL DRUGS: Chiorpheniramine (291 patients). d-Chiorpheniramine (189 patients). Clemastine (146 patients). victimization. We think we are here be- to understand that these people do not Rare reports of severe cardiovascular adverse effects have been received which include armythmias (ventricular tachyarmythmia. torsades de pointes. ventricu- cause of affirmative action, but we are not. control our fate as much we think they do. lar fibriliation) hypotension. paipitations. and syncope in controlled clinical trials in otherwise normal patients with rhinitis. at doses of 60 mg b.i.d. small We are here because of those people who increases in QTc interval were observed Changes of this magnitude in a normal population are of doubtful clinical significance However, in another study (N=20 let us get into a position to be able to take Q. What has this debate and being labeled a patients) at 300 mg b.i.d. a mean increase in QTc of 10% (range -4% to +30%) (mean increase of 46 msec) was observed without clinical signs or symptoms. advantage of what society was trying to do black conservative done to Shelby Steele? in addition to the more frequent side effects reported in clinical trials (See Table). adverse effects have been reported at a lower incidence in clinical trials and/or for us. But this victimology causes us to de- A. It has put a lot of stress on me. It's not fun spontaneously during marketing of Seldane that warrant listing as possibly associated with drug administration These include alopecia (hair loss or thin- nounce as a race our greatest source of to be labeled when you know that it's very ning). anaphylaxis. angioedema. bronchospasm. confusion. depression. galac- torrhea insomnia. menstrual disorders (including dysmenorrhea). strength, which is people like that, who shortsighted. On the other hand. overall I musculoskeletal symptoms. nightmares. paresthesia. photosensitivity. seiz- ures. sinus tachycardia. sweating. tremor. urinary frequency. and visual ought to be held up as role models. am very, very happy because I think the disturbance Clarence Thomas ought to be held up terms of the debate have been really opened In clinical trials. several instances of mild. or in one case. moderate transamin- ase elevations were seen in patients receiving Seldane Mild elevations were as a role model. But no, we say, he made it up. I don't think things will ever be the same also seen in placebo treated patients Marketing experiences include isolated reports of jaundice. cholestatic hepatitis. and hepatitis. In most cases available by himself too much. He's not a victim. We again. And I think Clarence Thomas' nomi- information IS incomplete OVERDOSAGE don't want him. nation drives that nail home. There will now Information concerning possible overdosage and its treatment appears in Full Prescribing information forever more be diversity of opinion in the DOSAGE AND ADMINISTRATION One tablet (60 mg) twice daily for adults and children 12 years and older Q. But one major criticism of Thomas is that black community. People will think about Product information as of July 1990 MARION MERRELL DOW INC. he thinks he did make it all by himself. these things a great deal more than they did Prescription Products Division SELAE 302/A1895 Kansas City MO 64114 6130B1 A. This is the shortsightedness of victim- when we were a sort of one-party system. I ology. You're goddam right he made it by feel very good about that. TIME, AUGUST 12, 1991 The Washington Post Judge Thomas (Cont'd.) S INCE JUDGE Clarence Thomas's nomina- to the profile of the man that has emerged in the tion to serve on the Supreme Court, a host debate so far. "There is a tendency among young, of interest groups and prominent individuals have weighed in with their opinions. While most upwardly mobile, intelligent minorities to forget," he said. "We forget the sweat of our forefathers. of the offerings from both sides have been thoughtful and judicious, a few uninformed, silly We forget the blood of the marchers, the prayers comments have crept into the discussion. To and hope of our race." In that speech, Judge speculate about Judge Thomas's fate were he Thomas decried the erosion of those positive white (he's not) or to argue that he is a "quota" values that have enabled generations of African candidate is a good political shot to take at Americans to endure and overcome the worst anti-quota George Bush, but off the mark so far this nation has had to offer. His warning was as the nominee is concerned. What matters are directed particularly toward the younger genera- his qualifications and fitness to serve on the tion in our inner-cities who must bear the burden court. On that score, more voices will be heard of broken homes, joblessness, crime and depen- from in the weeks leading up to his September dency. confirmation hearings. As the smoke clears from But his was not a message of hopelessness. "Do this initial volley, however, Judge Thomas's nom- not become obsessed with all that is wrong with ination seems to us to have taken no disqualifying our race," he said. "Rather, become obsessed blow. with looking for solutions to our problems. Be It's not as if he were a total stranger. His tolerant of all positive ideas; their number is record of government service, particularly the much smaller than the countless number of civil rights enforcement record at the Equal problems to be solved. We need all the hope we Employment Opportunity Commission, is there can get." for examination. Having covered much of that From this and other speeches and writings, our territory only a year and a half ago during the sense is that Judge Thomas understands the confirmation process for his position on the America in which he lives and well knows that appellate court, the Senate, which approved him much of what this nation offers is conditioned on then, will be revisiting familiar ground. His quali- skin color and that discrimination is found across fications, judicial philosophy and views on that body of constitutional law and statutory rights the length of the land. It is not so much his that protect individual freedoms will be scruti- conservative political ideology as his personal and nized once more, as they should be. Again, based public life experiences that have made him less on the totality of what is known about Judge sanguine about the ability of law and social policy Thomas, it is quite a reach if not unfair to brand to solve by themselves those problems that him a "reactionary" and one whose "confirmation weigh most heavily on black America. That, it would be inimical to the best interests of African seems, is the genesis of his frequent pitches for .Americans" as the NAACP did this week. reliance on hard work and discipline, pride, self- Some excerpts from a speech he gave in 1985 respect and acceptance of responsibility by black to the graduates of Savannah State College, a Americans for their own destiny. His record will historically black institution, which were printed and should get a closer look next month. But it is in the New York Times, add a useful dimension important now not to caricature his views. AUGUST 5, 1991 QUOTES ABOUT JUDGE THOMAS WHAT OTHERS ARE SAYING ABOUT JUDGE THOMAS Alvares, Fred. (former Commissioner, EEOC) "He totally turned around the management and reputation EEOC had." Los Angeles Times: July 7, 1991 "The commission [EEOC] became a much stronger government agency in the years he was there. Miami Herald: July 11, 1991 Ashcroft, Governor John. (Governor, Missouri) "Thomas possesses the highest standards of honesty, integrity, and ethical conduct. His judicial intellect is superb. His life serves as an 1991 inspiration for all Americans." St. Louis Post-Dispatch: July 2, Bell, Griffin. (former United States Attorney General) "The people who think that we're entitled to have a black on the Supreme Court but only a liberal black, they will vote against him. But I can't imagine that there are too many senators like that. Whoever heard of such an argument that only a liberal black can be on the Supreme Court. What kind of country do we have where people would take that position?" Associated Press: July 9, 1991 Boicourt, Michael. (Chief Counsel, Office of the Missouri Attorney General) "Personally, there is a great dignity and self- confidence about him. He wore a sense of purpose about him that was almost overwhelming. He charmed and conquered everyone of all kinds of persuasions." Chicago Tribune: July 2, 1991 Civiletti, Benjamin. (former United States Attorney General) "I think the President made a good choice. I think he put quality and qualifications ahead of minority quotas." Baltimore Evening Sun: July 2, 1991 Danforth, senator John. (United States Senator, Missouri) "[Thomas] would have great empathy for the ordinary person. In many ways, Clarence Thomas is the people's nominee for the Supreme Court." St. Louis Post-Dispatch: July 9, 1991. "The clear message from those I visited was that Clarence Thomas had transformed the EEOC from the dregs of the federal bureaucracy to an efficiently operating agency, which was effectively performing the duties Congress had assigned to it. St. Louis Post-Dispatch: July 17, 1991 "If anyone thinks that Clarence Thomas is a pre-determined vote on any particular issue, that individual does not know Clarence Thomas. He is fiercely independent." St. Louis Post-Dispatch: July 9, 1991 DeConcini, Senator Dennis. (United States Senator, New Mexico) "I'm impressed with him. He has a lot of experience. He's a good writer. He's a conservative. That's positive as far as I'm concerned." Associated Press: July 7, 1991. Goldstein, Barry. (former attorney, NAACP Legal Defense Fund) "The EEOC policy seeking full relief for victims of intentional July 2, 1991 discrimination was a positive step. St. Louis Post-Dispatch: Hatch, Senator Orrin. (United States Senator, Utah) "This man is highly 1991 qualified and very, very capable." Boston Herald: July 2, Heflin, Senator Howell. (United States Senator, Alabama) "He has a 1991 good academic background." United Press International: July 11, Hooks, Benjamin. (Executive Director, NAACP) "When it comes to individual discrimination, his record is pretty clear. If a black or woman has been individually discriminated against or mistreated he'll go to the ends of the earth to correct it." Associated Press: July 24, 1991 Jackson, Alphonso. (Executive Director, Dallas Housing Authority) "Clarence has the greatest appreciation for Thurgood Marshall, for Martin Luther King. He knows, he truly knows, that without them we would not be where we are. And that's why he believes people must be judged on merit and not on the color of their skin. We've all had experiences with racism, but he did not use those experiences as a crutch. He used them as a propeller." Dallas Morning News: July 2, 1991 Keith, Judge Damon. (Judge, United States Court of Appeals, 6th Circuit) "If I or a member of my family were in trouble, he is the kind of person I'd like to appear before. Our judicial philosophy may not be the same, but he is a bright and reflective man who believes passionately in fairness. I say this without about him." Wall Street Journal: July 2, 1991 reservation, and in full knowledge of all the people who complain Kemp, Evan J. (Chairman, EEOC) "He made the EEOC a first-rate law enforcement agency where people were proud to say they worked.' Associated Press: July 2, 1991. Lecraft Henderson, Judge Karen. (Judge, United States Court of Appeals, DC Circuit) "Clarence Thomas is the American dream personified." Associated Press: July 1, 1991 Leighton, Richard J. (attorney who argued case before Judge Thomas) "Judge Thomas' decision in the case [Alpo Petfoods V. Ralston Purina] has been cited often, and is being discussed in all the seminars on the Lanham Act (a federal law on false advertising). It's an extraordinarily clear opinion that's piece of fluff." Associated Press: July 2, 1991 written in a scholarly fashion. This was a weighty opinion, no Lits, Judge Arthur. (Judge, Circuit Court of St. Louis County) "I have known Judge Thomas for over 15 years. He first appeared before me as Assistant Attorney General of Missouri in an important case having statewide effect. I immediately was struck not only by his demeanor, superior knowledge and presentation of the law, but his fine personality and warmth. The country will greatly benefit from the acumen, knowledge, and attitude of such a fine gentleman, lawyer, and judge." Letter of Recommendation to President Bush: June 28, 1991 Mikva, Judge Abner. (Chief Judge, United States Court of Appeals, DC Circuit) "He has been a very good colleague." Wall Street Journal: July 2, 1991 Nunn, Senator Sam. (United States Senator, Georgia) "My intention right now is to support him, and I'll be having warm words of support at the hearings." Atlanta Constitution: July 17, 1991 "Clarence comes from a background of a segregated society, and I think over a period of time, if he is on the court, he will be very sensitive to discrimination." Washington Times: July 17, 1991 Quevedo, Frank. (former Chairman, Mexican-American Legal Defense and Education Fund) "[Thomas] made this agency (EEOC) responsible to the concerns of Hispanics, in word and in deed." Associated Press: July 25, 1991 Richey, Judge Charles R. (Judge, United States District Court for the District of Columbia) "I like Clarence Thomas. He's knowledgeable about the law. 1 think that he has all the sensitivities required to be a great justice." Associated Press: July 1, 1991. Robinson, Judge Aubrey. (Chief Judge, United States District Court for the District of Columbia) "[Thomas is] a very hardworking person He'll be very conscientious." Savannah Morning News: July 5, 1991 santaniello, Judge Angelo. (Justice, Connecticut Suprame Court) "How would I describe him? He's a very warm person. Humble, personable, intense, straightforward with no airs. Clarence Thomas is a real fair guy. He shouldn't be stereotyped, because he won't walk a stereotyped line. Clarence calls it as he sees it, not as someone wants him to see it." New York Newsday: July 17, 1991 silberman, R. Gaull. (Vice-Chairman, EEOC) "He walked in the door, rolled up his sleeves and went to work and turned the agency around. Under Clarence Thomas' leadership, the agency found its mission as a law enforcement agency and it attained a credibility that it had never had before." Los Angeles Times: July 7, 1991. Spradling, James. (former Chairman, Missouri Department of Revenue) "He's one of the best lawyers I ever ran into. St. Louis Post-Dispatch: July 2, 1991 THE WHITE HOUSE WASHINGTON July 25, 1991 MEMORANDUM FOR EDE HOLIDAY FROM: GARY BLUMENTHAL SUBJECT: Clarence Thomas Update We do not have much to report at this time. 1) Connie Newman's speech to the National Federation of Business and Professional Women's Clubs on July 22 reportedly went very well. Nonetheless, they passed a resolution opposing him (see attached). 2) Bobbie told me yesterday that Gwen King was connecting with the National Association of Blacks in Government and that it should work out for their July 29 - August 4 meeting. 3) Just to repeat, Secretary Sullivan is likely to appear at the Catholic Golden Age Conference on August 15. 4) We are still awaiting word whether Roger Wallace will do the Texas Hispanic Chamber of Commerce convention on July 27. Thus far, we have failed with Carla Hills, John Negroponte, Mike Farren, and Jules Katz. It is Roger's last day as Dep. Und. Sec. before he heads for his new position as commercial counselor in Mexico City. Therefore, it is a real inconvenience from a personal standpoint. I called Shiree yesterday to check what she thought of Lujan or Madigan, but I havn't heard back from her. 5) Both Alexander and Sullivan are working on the HBCU resolution. Remember that the goal is made just slightly more delicate by the ambition of the HBCU Board to be physically located at the White House. IDEAS FOR THE FUTURE Dan Casse of course claims the news in the next few weeks will be dominated by the William Kennedy Smith trial and the Milwaukee mass murder case. Nonetheless, a few wild thoughts for future activities: a. Alexander has found it very effective to challenge audiences to read the 1985 Clarence Thomas piece from the New York Times in which he explains the basis for his philosophy in life. Others may try a similar tack since reading Clarence Thomas is more persuasive then listening to pressure groups. -2- Page Two b. The President may attend the September 11 Stan Scott dinner. The presence of many Black leaders could make it an opportune time to mention Judge Thomas. C. We can remind the Cabinet of the President's discussion of the nomination at the July 23 Cabinet meeting and suggest they be prepared for him to possibly raise it again at the September 4 Cabinet meeting (e.g. follow what he wants). Please call if you have questions. RESOLUTION #10 SUPREME COURT NOMINATION WHEREAS, the National Federation of Business and Professional women's Clubs, Inc. (BPW/USA) has traditionally supported and sought to protect individual rights and freedoms foz all and has promoted and supported said individual rights for women in particular, and; WHEREAS, the retirement of Justice Thurgood Marshall has created a vacancy on the United States Supreme Court and Judge Clarence Thomas of the U.S. Court of Appeals has been nominated for this position by President George Bush, and; WHEREAS, Judge Clarence Thomas has limited experience in the Judiciary, opposed most affirmative action plans as the former head of the Equal Employment Opportunity Commission, and appears reluctant to clearly state his position on basic individual rights, including a woman's right to reproductive freedom, and failed to provide full and fair interpretation and enforcement of existing civil rights laws, and; WHEREAS, there are many qualified and experienced members of the Judiciary who aggressively support individuals' rights and freedoms provided under the Constitution of the United States, now, therefore, be it RESOLVED that BPW/USA strongly opposes the appointment of Judge Clarence Thomas to the Supreme Court, and endorses the appointment and confirmation of a qualified, experienced Justice to the Supreme Court of the United states, who aggressively supports and promotes the preservation of individual rights and freedoms for 211, and be it further RESOLVED that BPW/USA ask all state federations and all other women's organizations to request their U.S. Senators to vote against ratification of the appointment of Clarence Thomas. THE WHITE HOUSE WASHINGTON October 1, 1991 MEMORANDUM FOR SECRETARY ALEXANDER FROM: EDE HOLIDAY SAA ASSISTANT TO THE PRESIDENT AND SECRETARY OF THE CABINET SUBJECT: Calls placed on behalf of Judge Clarence Thomas As you know, the confirmation vote of Judge Clarence Thomas is nearing. We are asking for your help in ensuring his confirmation by contacting the below listed Members of the Senate on his behalf: * Senator Graham * Senator Pell Please place these calls no later than Wednesday, October 2 and contact Fred McClure, Assistant to the President for Legislative Affairs (456-2230), with your evaluations. Your help with this very important nomination is greatly appreciated. THE WHITE HOUSE washington October 1, 1991 MEMORANDUM FOR SECRETARY MOSBACHER FROM: EDE HOLIDA ASSISTANT TO THE PRESIDENT AND SECRETARY OF THE CABINET SUBJECT: Call placed on behalf of Judge Clarence Thomas As you know, the confirmation vote of Judge Clarence Thomas is nearing. We are asking for your help in ensuring his confirmation by contacting Senator Bill Cohen. Please place this call no later than Wednesday, October 2 and contact Fred McClure, Assistant to the President for Legislative Affairs (456-2230), with your evaluation. Your help with this very important nomination is greatly appreciated. THE WHITE HOUSE washington October 1, 1991 MEMORANDUM FOR SECRETARY BRADY FROM: EDE HOLIDAY that ASSISTANT TO THE PRESIDENT AND SECRETARY OF THE CABINET SUBJECT: Call placed on behalf of Judge Clarence Thomas As you know, the confirmation vote of Judge Clarence Thomas is nearing. We are asking for your help in ensuring his confirmation by contacting Senator Lloyd Bentsen. Please place this call no later than Wednesday, October 2 and contact Fred McClure, Assistant to the President for Legislative Affairs (456-2230), with your evaluation. Your help with this very important nomination is greatly appreciated. THE WHITE HOUSE washington October 1, 1991 MEMORANDUM FOR SECRETARY MADIGAN FROM: EDE HOLIDA MA ASSISTANT TO THE PRESIDENT AND SECRETARY OF THE CABINET SUBJECT: Call placed on behalf of Judge Clarence Thomas As you know, the confirmation vote of Judge Clarence Thomas is nearing. We are asking for your help in ensuring his confirmation by contacting Senator Richard Shelby. Please place this call no later than Wednesday, October 2 and contact Fred McClure, Assistant to the President for Legislative Affairs (456-2230), with your evaluation. Your help with this very important nomination is greatly appreciated. THE WHITE HOUSE WASHINGTON October 1, 1991 MEMORANDUM FOR SECRETARY SKINNER FROM: EDE HOLIDAY SAAA ASSISTANT TO THE PRESIDENT AND SECRETARY OF THE CABINET SUBJECT: Call placed on behalf of Judge Clarence Thomas As you know, the confirmation vote of Judge Clarence Thomas is nearing. We are asking for your help in ensuring his confirmation by contacting Senator Wendell Ford. Please place this call no later than Wednesday, October 2 and contact Fred McClure, Assistant to the President for Legislative Affairs (456-2230), with your evaluation. Your help with this very important nomination is greatly appreciated. THE WHITE HOUSE washington October 1, 1991 MEMORANDUM FOR SECRETARY LUJAN FROM: EDE HOLIDAY ASSISTANT TO THE PRESIDENT AND SECRETARY OF THE CABINET SUBJECT: Call placed on behalf of Judge Clarence Thomas As you know, the confirmation vote of Judge Clarence Thomas is nearing. We are asking for your help in ensuring his confirmation by contacting Senator Jeff Bingaman. Please place this call no later than Wednesday, October 2 and contact Fred McClure, Assistant to the President for Legislative Affairs (456-2230), with your evaluation. Your help with this very important nomination is greatly appreciated. THE WHITE HOUSE washington October 1, 1991 MEMORANDUM FOR SECRETARY DERWINSKI FROM: EDE HOLIDA SAA ASSISTANT TO THE PRESIDENT AND SECRETARY OF THE CABINET SUBJECT: Calls placed on behalf of Judge Clarence Thomas As you know, the confirmation vote of Judge Clarence Thomas is nearing. We are asking for your help in ensuring his confirmation by contacting the below listed Members of the Senate on his behalf: * Senator Dodd * Senator Pryor Please place these calls no later than Wednesday, October 2 and contact Fred McClure, Assistant to the President for Legislative Affairs (456-2230), with your evaluations. Your help with this very important nomination is greatly appreciated. THE WHITE HOUSE WASHINGTON October 1, 1991 MEMORANDUM FOR SECRETARY KEMP FROM: EDE HOLIDAY & ASSISTANT TO THE PRESIDENT AND SECRETARY OF THE CABINET SUBJECT: Calls placed on behalf of Judge Clarence Thomas As you know, the confirmation vote of Judge Clarence Thomas is nearing. We are asking for your help in ensuring his confirmation by contacting the below listed Members of the Senate on his behalf: * Senator Moynihan * Senator Lieberman * Senator Shelby Please place these calls no later than Wednesday, October 2 and contact Fred McClure, Assistant to the President for Legislative Affairs (456-2230), with your evaluations. Your help with this very important nomination is greatly appreciated. 7/11/91 MEMORANDUM TO ALL ASSOCIATE DIRECTORS FROM: GARY BLUMENTHAL Gary SUBJECT: JUDGE THOMAS First, please call your contacts and ask that they seek all opportunities for their Cabinet member to plug Judge Thomas. They should keep a tally of all the times their boss does a plug and report them to you. Second, you need to review all major addresses by your Cabinet members between now and mid-October. By COB tomorrow, I want to present to Ede this separate calendar with a recommendation as to those speeches where we think the Cabinet member could make it a major address on behalf of Judge Thomas. Thank you for your help on this. Please call with questions!