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Ronald Reagan Presidential Library Digital Library Collections This is a PDF of a folder from our textual collections. Collection: Blackwell, Morton: Files Folder Title: Legal Services Corporation (1 of 2) Box: 12 To see more digitized collections visit: https://reaganlibrary.gov/archives/digital-library To see all Ronald Reagan Presidential Library inventories visit: https://reaganlibrary.gov/document-collection Contact a reference archivist at: [email protected] Citation Guidelines: https://reaganlibrary.gov/citing National Archives Catalogue: https://catalog.archives.gov/ F1 (eservices In Ronald Reagan's Washington: BILL OLSON AND THE / POOR By Louis M. Peck '73 Photographs by Ann Stevens I was New Year's Eve, 1981, and much of official Washington was headed for the party circuit. One of the few people on the job that day was William J. Olson '71. As it turned out, Olson was headed straight for contro- versy. The day before, he had been ap- pointed by President Reagan as acting chairman of the board of the Legal Ser- vices Corporation, created in the early 1970s to provide legal aid for the poor. Fearful that the spending power of the agency had been overextended by hold- over appointees from the Carter Admin- istration, Olson called an emergency board meeting for December 31 - fewer than twenty-four hours before new contracts between the Legal Services Corporation and approximately 335 grantees were due to go into effect. Judged against the ceremonious standards by which deliberative bodies in Washington tend to operate, it was a highly unusual session. There was no formal public notice. Of the ten board members participating in the meeting, only four were physically present. The balance joined in by means of a confer- ence call. Bolstered by Reagan's ap- pointment of seven new board members - including Olson - the day before, the directors of the Legal Services Cor- poration acted to reduce spending for the month of January while curtailing the power of the corporation's staff to award new contracts. The aftereffects of the December 31 meeting are still being felt months later, and have served to place Olson's name in the headlines and at the hub of a con- On Bill Olson's office wall is a citation (center, top) from "The tinuing controversy over the Reagan Office of the President-Elect" for his work on the transition team. Administration's attitude toward legal 37 services for the poor. the personification of the Reagan phi- government that was in line with what Critics of the White House have losophy, spent much of 1968 organizing became known as the Silent Majority of questioned whether the session violated anti-Vietnam War activities at Michigan the 1960s - and which provided the the spirit, if not the letter, of the federal State University. underpinnings in the 1970s of the open meetings law. Several of the Car- That was the year that Olson Reagan revolution in government. And ter appointees to the board of the Legal headed Brown Students for Nixon- I think it was beneficial for students on Service Corporation have filed suit, Agnew. college campuses to be exposed to challenging the legality of Reagan's Less than a year and a half later, as conflicting views." making "recess appointments" to the the majority of the Brown student body Despite being part of what he board while Congress was out of ses- mobilized behind a move to shut down termed a "distinct minority" on the sion. And the hard-line conservatism of the University in protest over the Nixon Brown campus, on several occasions the Reagan appointees has prompted Administration's decision to invade Olson was able to use the element of some legal aid advocates to charge that Cambodia, Olson organized the Rhode surprise to score some political points - Reagan is pursuing a familiar pattern: Island Anti-Strike Coordinating Com- while catching both the Brown admin- destabilizing from within programs he mittee. Among its activities was a rally istration and the liberal student majority knows that Congress will not agree to in downtown Providence in support of off-guard. do away with. Nixon's policy in Indochina. In early 1970, the Brown Young Re- And the irony of the situation is "We had some RISD students mak- publican Club prepared a report analyz- that the December 31 meeting turned ing posters for us," Olson recalled re- ing approximately thirty speakers who out to be duplicative; it was subsequent- cently over a lunch of meat loaf and had appeared at University convoca- ly determined that the Carter-appointed potatoes at the National Lawyers Club. tions during the previous two-and-a- board members had acted in early De- "One of them was a 'Tell It to Hanoi' half years. "Something like twenty-four cember to insure that spending levels poster." He smiled at the memory. of them would have been considered did not exceed those authorized by In style as well as substance, Olson clearly liberal," Olson said. "There were Congress. "The corporation had already stood apart from many of his fellow perhaps two or three conservatives - - sent out reduced grants, so the action was not only unnecessary - in retro- spect, it looked pretty silly," says How- ard Eisenberg, executive director of 'The question now the National Legal Aid and Defender Association. is whether the Reagan Throughout all of this, Bill Olson has held to his position with the same philosophy can be tenacity he showed when he headed the hopelessly outnumbered Brown Uni- implemented and versity Young Republicans in 1969 and shown to work' 1970. He is offering no apologies. "We had a concern that the reduction in funding [for the Legal Services Cor- poration] had not been fully imple- Brown students of the late 1960s and and one of them was a student at URI. I mented by the corporation," Olson early 1970s. His blond hair was as felt that was totally contrary to the spirit said recently of his decision to call the close-cropped then as it is now. While of academic freedom." emergency board meeting. "In my opin- the uniform of the day was T-shirts and The Young Republicans' report first ion, it was the fairest thing we could do surplus Army jackets, Olson favored surfaced on a Monday in March 1970 - with the information we then had. What button-down shirts and an occasional in a page-one story in the Providence we did in that board meeting was blazer. Journal. It was, in the view of some, a exactly what we should have done." The leftish student majority would well-planned political sneak attack by Whatever the final outcome of the often react to his conservative parries by the YRs. Neither University officials nor legal services controversy, Bill Olson's ignoring him - or worse. "The liberal student leaders were contacted by the involvement is, in and of itself, sig- activists on campus would generally re- Journal for their response prior to pub- nificant. For it represents a coming of spond to our position with a very effec- lication of the story - a fact that age for several campus conservatives of tive political weapon - ridicule," he prompted a letter of protest by eleven the late 1960s, who - having weathered remembers with grudging admiration. Journal reporters to the paper's man- the liberal tide then running through And, unlike some activists on both sides agement. Eastern universities - have now of the spectrum, Olson was always Olson now says that "to the best of achieved positions of influence in affable and approachable - while never my recollection" there was no agree- Ronald Reagan's Washington. taking himself too seriously. ment between the Young Republicans At least for the moment, the Mi- "You couldn't put great weight on and the Journal that barred the Univer- nority has become the Majority. how people viewed your philosophy or sity from being contacted prior to publi- you wouldn't last too long. You had to cation. But Jack Rose '70, then an officer N ext to Bill Olson, David Stock- keep a sense of humor, a sense of in the YRs, told the Brown Daily Herald at man is a Sunshine Soldier. perspective. We felt we had a responsi- the time that such an "agreement" had Stockman, now regarded as bility to advance a basic philosophy of been struck to prevent "obfuscation" of 38 the Young Republicans' position. Reagan's victory in the 1980 election, "You cannot say that anybody who The Providence Journal was not the Olson received a call one day from an wants to effectuate change in govern- only newspaper that took notice; the re- old friend. ment policy should have access to a port on convocation speakers at Brown It was Loren Smith, who had been governmental attorney," Olson con- became the subject of editorials in such general counsel to the Reagan cam- tended. "It is not the role of the gov- conservative newspapers as the Chicago paign. And he wanted Olson to head ernment to fund one philosophy of Tribune and the Indianapolis News. The the task force on legal services during government over another. You can't editor of the News at the time was M. the Reagan transition. fund lawyers who want to file certain Stanton Evans, now a widely syndi- kinds of lawsuits - and then go out cated conservative columnist. I t is the height of understatement to looking for clients for these kind of law- "Stan and I are now good friends," say that Ronald Reagan has never suits." Olson said. "I worked for him when he been a fan of the Legal Services The liberals' response to this is that was head of the American Conservative Corporation. As governor of California, the federal government already funds Union, and now I work for him as his Reagan attempted in 1970 to block Legal these types of actions on the part of lawyer sometimes." (In 1979, Olson Services Corporation funding from com- large corporations and conservative filed suit on behalf of Evans' National ing into his state - apparently because legal foundations - - through the use of Journalism Center, seeking the release he felt that it was being used to further a tax breaks. It therefore should make this of Commerce Department in- host of liberal causes. type of opportunity available to the formation relating to high technology In the first year of his Presidency, poor, even if it involves direct federal exports to the Soviet Union). Reagan asked that the program be subsidies. Meanwhile, Olson was also making abolished. It was only after Congress Such arguments bring out Olson's important contacts through the Young balked that Reagan named Olson and conservative instincts. "Those conten- Republican network. From his post as the six others on December 30 as recess tions are predicated on the belief that all president of the Brown Young Republi- appointments. (Subsequently, Reagan money belongs to the government," he cans, he went on to become director of has formally submitted ten names to declared. "I don't accept that philoso- the New England College Republicans. Capitol Hill to serve on the corporation phy of government." Among the others then active in the Col- board. The designated permanent Neither, however, is Olson saying lege Republicans at the time: Morton chairman is Prof. William F. Harvey of that the poor should be without the Blackwell, now a top staffer in the White the Indiana University Law School, ability to sue the government. "You House's public liaison office; Roger with Olson nominated to one of the have a state monopoly on the justice Stone, an influential political consultant nine remaining slots on the board.) system, and you have an obligation to who headed the Reagan campaign in Despite the appointments, Reagan insure that all citizens have equal access the Northeast in 1980; and John (Terry) has not given up trying to do away with to that system. There are few cases Dolan, who now heads the controver- the legal services program. His pro- where a lawyer is needed more than sial National Conservative Political Ac- posed 1983 budget submitted in January when an individual poor person is con- tion Committee (NCPAC). once again asks that the corporation be fronting the state or federal govern- (There was also a personal divi- abolished. ment." dend: Olson met his wife, Janet, through According to several journalists The question then becomes one of the College Republicans. She is now who closely follow the area of legal how to protect the rights of the poor to executive director of the House Republi- services, the transition-team report sue government - - while preventing can Conference, headed by Rep. Jack drafted by Olson in late 1980 endorses such cases from becoming assaults on Kemp of New York). the Reagan aim of doing away with social and economic policy. After graduating from Brown in Legal Services. Olson has steadfastly re- "It's very difficult to draw those June 1971, Olson did stints at both the fused to comment on this, saying he is lines," Bill Olson admitted. "I know I Nixon White House and the federal De- pledged not to discuss the contents of don't have all the answers." partment of Transportation before re- the report. It is at such moments that Olson is turning to Rhode Island in 1972 to work But, as an appointee to the Legal reminded that responsibility can be a in the unsuccessful gubernatorial cam- Services board, he says he is committed sobering experience. As such, he shows paign of Republican Herbert F. De- to continuing the program. "I believe no glee or smugness over the fact that Simone '51. He then returned to Wash- that the people President Reagan has he is now Mr. Inside - and that his ington to work in the Office of Economic appointed should have the opportunity one-time liberal adversaries from Brown Opportunity (OEO was then headed by to try to effectively manage this corpo- days are on the outside. The early days Howard Phillips, a prominent figure in ration to maximize the benefit to the of the Reagan Administration have the New Right who has been a strong poor for the dollars spent," he said. taught Olson that it is often easier to ac- critic of federal legal services programs). At the crux of the conservatives' quire power than to use it or retain it. In the fall of 1973, Olson went on to the complaint is that the legal services pro- "The question now is whether the University of Richmond Law School. gram has gone far beyond the scope of Reagan philosophy can be implemented He graduated in 1976, moved back simply protecting the rights of the poor and shown to work," he reflected. to suburban Washington, where he in civil cases. Instead, the conservatives "That's really the challenge." soon became chairman of the Fairfax charge, it has been used by socially County (Virginia) Republican Commit- minded attorneys to force an expansion Lou Peck is a reporter in the Washington tee, and joined a law practice down- in government programs by recourse to bureau of the Gannett News Service. town. And then, following Ronald the courts. 39 file LEGAL SERVICES CORPORATION 733 Fifteenth Street, N.W., Washington, D.C. 20005 Writer's Direct Telephone (202) 272-4040 May 28, 1982 Mr. Robert Kabel Office of Legislative Liaison The White House Washington, D.C. 20500 Dear Bob: Enclosed you will find a resume for Diane Jenkins, an attorney from Baton Rouge, Louisiana. Dennis Daugherty of my staff has known Diane since his high school years. He feels that she has the sensitivity and judgement to be a good addition to our Board of Directors. He says that she would deal with controversial subjects in the face of criticism graciously, but with determination. Over 30% of the caseload handled by Legal Services Cor- poration grantees last year arose in the area of juvenile and family law. Mrs. Jenkins' extensive experience in this area, particularly in regard to child support enforcement, would be very helpful to this Board. She would in addition provide the Board with the perspectives not only of an attorney and a woman, but that of a journalist and a businesswoman (newspaper owner). Dennis says that Mrs. Jenkins is a Democrat, but that she and her husband, State Rep. Louis E. (Woody) Jenkins, have supported many Republican candidates including President Reagan, Governor David Treen, and Congressman W. Henson Moore. Mr. Jenkins resigned as the state's Democratic National Com- mitteeman in order to support President Reagan's election. You should be aware that Mrs. Jenkins' husband has run for the United States Senate against both Senators Long and Johnston. Some of our grantees would be somewhat skeptical of her as well because Mr. Jenkins has chaired the state Conservative Caucus. He is a former chairman of the American Legislative Exchange Council (ALEC), a national organization of state legislators, and is active in a number of national conservative groups. LEGAL SERVICES CORPORATION Mr. Robert Kabel May 28, 1982 Page Two I would appreciate your bringing Diane Jenkins' interest in serving on our Board of Directors to the attention of the proper members of the White House staff. Sincerely, Jeny Acting President Gerald M. Caplan CC: William Harvey Biographical Summary DIANE A. JENKINS May 1982 Personal Background - Age 35; married; mother of three children I Resident of Baton Rouge, Louisiana, for past 21 years - Current address: 3684 Winnebago Street, Baton Rouge, La. 70805 - Phone: 504-383-6226 (office); 504-357-9874 (residence) Education - Honor graduate and secretary-treasurer of 1,800-member student body, Istrouma Senior High School, Baton Rouge, La. (1965) - Juris Doctor degree in law, LSU Law School (1972) - Graduate, Conference on Juvenile Justice, sponsored by the National District Attorneys Association, San Francisco, Calif. - Graduate, National Child Support Training School, sponsored by the National District Attorneys Association, Phoenix, Ariz. Government Service - Assistant District Attorney and Chief, Family and Juvenile Division, District Attorney's Office, East Baton Rouge Parish, supervising staff of 24 attorneys, investigators and secretaries with 8,000 active cases, and having responsibility over all crimes by or against juveniles, criminal non- support cases and administration of the 4-D Program under the United States Department of Health, Education and Welfare (1976-1980) - Responsible for self-generated $1.5 million budget - First woman to present a capital case to the East Baton Rouge Parish Grand Jury (a true bill was returned) - Prosecuted several thousand criminal cases of all types, with an overall won-loss ratio of over 90 per cent; made oral arguments before the Louisiana Supreme Court - Member, Louisiana Child Support Advisory Board (1976-1979) - Assistant Attorney General, State of Louisiana (1975-1976) - Youngest Assistant Attorney General in state history at time of appointment DIANE A. JENKINS/Biographical Summary/Page 2 - Member, Crimes Against Organized Government Section, with responsibility for prosecuting public officials accused of wrongdoing -across the state - Assistant District Attorney, East Baton Rouge Parish (1973-1975) - Member, National District Attorneys Association - Member, National Welfare Fraud Association Private Legal Practice - Attorney at Law (1973-1982) - Private practice (1980-1982) - Area of specialization: Immigration Law - Member, Louisiana and American Bar Associations Special Achievements in Law - First Place Award, Annual Moot Court Competition, LSU Law School; chosen over 140 other senior law students in written and oral arguments before the Louisiana Supreme Court (1972) - "Best Trial Presentation" Award, LSU Moot Court Competition - Editor, The Constitution of Vietnam, a two-volume study of the South Vietnamese legal system (1972) - Editor, The Civilian, LSU Law School student newspaper (1970-1971) Business Activities - Co-owner, Baton Rouge Advertising, a public relations firm (1972-1982) - Managing editor, North Baton Rouge Journal, a community weekly newspaper (1966-1969) - Member, Consumer Advisory Board, American Bank & Trust Company (1973-1974) - Member, Board of Advisors, Baton Rouge Enterprise (1976-1978) - "Outstanding Young Business Woman of Louisiana" for 1973, second place award, Louisiana Association of Business and Professional Women's Clubs - "Outstanding Business Student Award" for East Baton Rouge Parish, Administrative Management Society (1965) DIANE A. JENKINS/Biographical Summary/Page 3 - "Outstanding Salesman Award," Baton Rouge Junior Achievement (1963) Special Recognition - Governor, Pelican Girls State, State of Louisiana (1964) - "Americanism Youth Award" for State of Louisiana, Veterans of Foreign Wars (1965) Foreign Language - Spanish LA THE WHITE HOUSE Office of the Press Secretary For Immediate Release January 22, 1982 The President has granted recess appointments to the following individuals as Members of the Board of Directors of the Legal Services Corporation: HAROLD R. DEMOSS, JR., of Houston, Texas, is a partner with the law firm of Bracewell & Patterson. He was born December 30, 1930. He succeeds Steven L. Engelberg. CLARENCE V. MCKEE, of Washington, D.C., is counsel with the law firm of Smith & Pepper. He was born November 16, 1942. He succeeds Hillary D. Rodham. ANNIE LAURIE SLAUGHTER, of St. Louis, Missouri, was Director of Volunteers, Acting Administrative Assistant, and Director of Operations, Annie Malone Children's Home, from 1979 until May 1981. She succeeds Cecelia D. Esquer. ### File March 5, 1981 I strongly recommend that the nominees submitted by the following people for the Legal Service Corporation Board be scrutinized with an eye toward elimination from consideration based on the disturbing information obtained by Congressman Sensenbrenner: Howard Eisenberg Bob Evans Dan Bradley Judy Bernie Veney Marty Mario William McAlpin JAMES CENSENBRENNER, JR. WASHINGTON OFFICE: NINTH DISTRICT, WISCONSIN ROOM 315 CANNON HOUSE OFFICE BUILDING COMMITTEE ON THE JUDICIARY 202-225-5101 COMMITTEE ON STANDARDS OF OFFICIAL CONDUCT DISTRICT OFFICE 333 BISHOPS WAY BROOKFIELD, WISCONSIN 53005 414-784-1111 Congress of the United States House of Representatives Washington, B.C. 20515 February 4, 1981 The Honorable William French Smith Attorney General of the United States Department of Justice Constitution Avenue and 10th St., N.W. Washington, D.C. 20530 Dear Mr. Smith: I am hereby requesting the Department of Justice to investigate the possible misuse of appropriated funds by the Legal Services Corporation (LSC). It appears that appropriated monies have been used for political and lobbying purposes. As evidence, written on LSC letterhead, I submit the two enclosed memoranda dated December 10, 1980, and December 29, 1980. They were written by Alan W. Houseman, Director of the LSC's Research Institute. These documents clearly detail a plan for lobbying and political activity by the Legal Services Corporation, its employees and grantees to influence legislation reauthorizing that agency which the 97th Congress will be considering. I look forward this matter. Sincerely F JAMES SENSENBRENNER, JR., Member of Congress FJS:pkvt Enclosure LEGAL SERVICES CORPORATION MEMORANDUM DATE: December 8, 1980 TO: Coalition FROM: Alan illan SUBJECT: Tasks for Survival - An Update Below I have outlined what I understand to be the tasks assignments for survival. I have included both coalition and LSC staff. Also, I have set out future tasks and who I believe should be involved. We should discuss the latter to be sure there is agreement and make appro- priate changes. Immediate Tasks - To Be Done During Next Several Weeks 1. Transition Team and White House Contacts - Dan, Mary, Mario, Judy, Bill McAlpin and Howard. 2. Board Nominees - Howard Eisenberg, Bob Evans, Dan, Judy and Bernie. 3. Solidification and Strengthening of Local Political Base - Regional Meetings - Bucky, Bea, Alan, John McDonald, Mary, Denny Ray, Salvadore Tio, Marttie Thompson, Theron O'Connor and Steve Kostka. Joan Lieberman and John Arango are assisting as staff. 4. Dealing with Money Issues - Bruce, Bernie and: One-time Money - Gerry and ABC Committee. Drawdown Issues - Mario, Dan and Mary. Additional Resources for Emergencies - Alan and Gerry. 5. Private Bar Approach - ABC, Judy, Steve, Mario, Dan, Bruce, Bernie, De (John Dooley has assisted as staff). 6. LSC Board Position on Reauthorizing Legislation - Dan and Mary. 7. Support Center Grants - Andy and Mario. - 2 - Short-Term Activities - Started now but completed in January 1. Establishment of effective communications network. State Coordinators - Mary, De Other Communications Tim, Andy 2. Analysis of New Congress - Office Government Relations (OGR); De, Dick 3. Committee Composition of New Congress - OGR; Dick 4. Blue Ribbon Panel McAlpin, Dan, Core Group 5. Development of Affirmative Strategy on Legislation, White House and Congress - Mary, Judy, De, Bruce, Jim, Dick and Core Group. 6. Protective Actions re: Support and Policy Issues - Alan, Judy, Dave Madway, De, and Core Group. 7. Legal Support and Analyses including outside council - Mario, Denny, and Howard: 8. Basic Bureaucratic Vulnerabilities (Such as GAO, CBO, Fund Balances, Monitoring, Complaint Procedure, Weak Programs, Information Collection and Information on Puerto Rico Expenses) 1. Clint, Mario, Gerry and De. 9. Publications and Media - Public Affairs, NLADA. 10. Support for Supporters on National Level (Including Unions, Civil Rights Organizations, Bar Associations, etc.) - Judy, Jim Braude, and Bernie Veney. 11. Supporting Client Community - Bernie, Clint, and Bea. 12. Law Schools Bea 13. LSC Staff Morale and Staying Power - Gerry, Clint, and Mario. 14. Information System - Andy, Dick Long-Term Tasks - Begin now but take several months 1. Develop long-term outside organization to represent legal services in the long-term struggle . Howard, De, Bernie and Core Group. 2. Securing resources for. long-term effort - Howard, Bruce, De, Gerry, Alan and Core Group. - 3 8. 3. Press Relations and Publications - Tim, Howard and Press Committee. 4. Relationships to local, state and national bar associations - Steve, Tim, Dan, Howard, Bill McAlpin, Bob Evans and Core Group. 5. Identifying staff and "getting on board" staff to work in long-term effort - - Alan, Howard, De and Core Group. 6. Develop long-term strategies for national support - Dave Madway and Alan. 7. Develop long-term strategies for Clearinghouse - Andy, Alan. 8. Develop long-term strategies for training . - Bea, De and Alan. 9. Develop long-term strategies for research - Alan. 10. Develop long-term strategies for regional offices - Clint, Bucky. 11. Develop long-term strategies for Reggie program - - Willy, Clint. 12. Develop long-term strategies for state support - Alan, De, Clint. 13. Long-term funding theories - Gerry, Bruce, Alan and Core Group. 14. Long-term legislative advocacy strategies - Alan, De, Dick Skutt, Mary, Judy. 15. ABA Mid-Winter Meeting - Dan, Judy, Steve, Bernie, Bob. and De. LEGAL SERVICES CORPORATION MEMORANDUM DATE: December 29, 1980 's TO: State Coordinators and Other Interested Parties JAN 5 1980 FROM: Alan W. Houseman alan SUBJECT: Summary of our Overall Activities, Strategy and Perspective To assure that there is full knowledge among all critical actors in the effort we are undertaking to preserve aggressive legal services, I have prepared this summary of our activities, strategy and perspectives. Much of this cares from the oral remarks that have been given at the Regional Meetings and will not be new to most of you. Most of this infor- mation has been and will be supplemented in more detailed ways. Overall Perspective Today we face a severe threat to the continuation and growth of aggressive legal services. At stake is the survival of the legal services movement. By that I mean: - Survival of committed, aggressive and political staff whether they are lawyers, paralegals, support staff or other advocates; - Survival of aggressive advocacy, (i.e., advocacy which utilizes the full scope of representation including legislative and administrative representation, litigation and community education; advocacy which seek all possible remedies; and advocacy which is not restricted in what defendants can be sued, e.g., government entities); - 2 - - Survival of client involvement and control. All three of these are essential to the legal services movement. All three of these are under attack and must be pressured and strengthened. Far more is at stake than the survival of Legal Services. Many social benefit. and entitlement programs that have developed during the 60's and 70's to provide concrete benefits to poor people are threatened. As we proceed in our fight, WE rust take all the steps necessary at national, local or state levels to assure the continuation of other social benefit and entitlement pro- grams. It is essential that we join with others in preventing cutbacks in these programs, and preventing changes in other federal policies, such as affir- mative action, which are essential to the continued development of poor people and minorities in this country. At no time must we let our own concerns override the more basic concerns of poor people. Basic Principles It is useful to repeat the basic principles which guide the actions that will be collectively taken to preserve legal services. 1. Using all methods of counseling and representation, legal services exists to provide highest quality legal services to all those unable to afford legal assistance in a manner which best enables poor people to assert their rights and interests and effect change in ways that they themselves choose. 2. LSC and the legal services community will continue to emphasize utilization of program resources in a manner that has the greatest - 3 - impact on the largest number of poor people. 3. Legal Services must be accountable to the low-incame community in program governance, allocation of limited resources, and addressing the most pressing legal pro- blems of a particular local comunity. 4. The staff attorney system of delivery is essential to effective legal services and will remain the core of our delivery system. 5. LSC and the legal services community will resist any and all efforts to dismantle effective, existing programs We will never compramise the basic values and structures of this pro- gram and we will continue to resist efforts that would impose restrictions or undermine aggressive advocacy for poor people. Scope of Potential Threat We will certainly face serious efforts by opponents of aggressive legal services to: (1) Appoint members to the LSC Board who are not supportive or even hostile to aggressive legal services and the staff attorney system. Currently five terms are up; in June, the additional six positions will be up for nomination. (2) Add additional restrictions on the types of representation (legislative and administrative advocacy), on types of cases (aliens, education, abortion, suits against government entities), or on attorney fees. support and training. - 4 - (3) Reduce our appropriations and/or earmark existing or new funds. (4) Increase control of legal services staff and advocacy through a hostile bureaucracy, through political pressure from Congress, or through local and state government. (5) Substantially alter our current delivery system and reallocate current resources to judicare and other private attorney models of delivery. (6) Increase the role of local and state governments in funding and overseeing legal services delivery. There will also be attempts by the "far right" to dismantle or eliminate the legal services program. These proposals have surfaced during the transition and will also arise during consideration of our reauthorization in 1981. We can not now predict what efforts will be made, by who and their timing to restrict or dismantle legal services. There are many possible scenarios that may develop both in the short and long run. Whar we are doing is to plan for every possible development. Political Situation We have a new administration headed by a President who has historically shown hostility to Legal Services. While Governor of California, President elect Reagan attempted to veto and dismantle California Rural Legal Assistance. He also sought to impose additional controls on aggressive advocacy by Legal Services attorneys. - 6 - The American Bar Association, though remaining steadfast in support of aggressive legal services, has moved to introduce legislation seeking to mandate the involvement of private attorneys in the delivery of legal services. We must not let this development affect their support for effective, aggressive advocacy. Many of our allies are themselves politically weakened. Moreover, the organizations from which we traditionally received support have not yet made the survival of legal services a high priority. We may not have reached out sufficiently to other potential allies whether on a national or local level. We have lost the support of large numbers of clients and pocis people. Client involvement and control has not become a reality in most programs. Client organizations both on a local and national level have few resources to affectively advocate continuation of legal services. We are not prepared for battle. We are not effectively united. The Legal Services Corporation has not had to face a major political crisis since its inception. The Legal Services Community has not had to face a political crisis of this severity since 1973. There are many new people in Legal Services. Same may not share the values of the community's leadership. Same may not be willing to take political risks to preserve aggressive advocacy. On the other hand, we do not start from a position of weakness. We are stronger and more geographically diverse than ever before. We have able and committed staff working in programs throughout the country. - 5 - In the only public statement (in the American Bar Association Journal), the President-elect gave great deference to the pro bono efforts of private attorneys and called for an evaluation of the Legal Services Corporation to ensure "that it is serving the purpose for which it was intended. He went on to say: "Such a program should not be used to fund, at taxpayers expense, suits which are in reality attempts to force a judicial resolution of political and public policy issues properly left. to the elective branch through its representatives in Congress, I would also like to explore possible alter- natives to the monolithic federal approach to the legal problems of the poor. I believe there is room for increase activity on the part of local government and local bar associations." Some of President-elect Reagan's senior advisers and key cabinet members are people who may not be particularly supportive of legal services and who lack understanding of our program. We face a much more conservative Senate which is now controlled by Re- publicans and southern Democratics. Many of the newly elected Senators are idealogically opposed to legal services. While we have same strong support in the Senate Committee on Labor and Human Resources, we face severe problems with the entire Senate/ While the White House is still in Democratic control, it is much more con- servative. Many believe there is now a majority of conservatives in the House which can block most liberal legislation. Although, our committee will remain supportive, we will continue to face, as we have in the past, severe problems on the floor. - 7 - The Legal Services Corporation is an independent entity. Many people on the Hill, in the administration and the press perceive LSC to be an efficient and well run institution. We have more resources to devote to this effort than we have had in the past. We are more sophisticated politically at both national and local levels. What we are doing to wage this battle First, we are attempting to unite and join together in this struggle. We have formed a coalition with PAG, the National Clients Counsel (NCC) , NLADA, the National Organization of Legal Services Workers (NOLSW) and the Minority Caucus. It will be expanding to include others from within the legal services comunity, such as National Association of Indian Legal Services (NAILS), migrant farm workers group, women's caucus, Organization Legal Services Backup Centers (OLSBUC), state support and others. It will also expand to include orgranizations who are allies and supporters of legal services. The coalition members will be forming an outside entity to labby and coordinate survival activities on behalf of the legal services comunity. This entity will be established soon and will begin to function early in 1981. Second, we are expanding and strengthening our state coordination network. This is essential in order to assure effective communications within the comunity and for our congressional efforts. Third, we are seeking to diversify and strengthen the base of local and state programs. It is essential to broaden the base. In the short run, a strong local political base will be critical if we are to successfully obtain support from Congress for the continuation of an aggressive legal services program. Effective - 8 - löbbying in Washington will require local programs to establish credibility and a base in their communities and to develop allies who can and will assist them in persuading their Congressman and Senators to support legal services. In the long run, a strong local base will be necessary to survive possible efforts at local and state control through block grants or private bar control. These plans involves a series of regional meetings that will attempt to help programs identify how to shore an up and strengthen their base of support including support from the private bar, increased support from organizations that can be effective allies, effective use of the media and improved relations with Congressional offices. In addition to the meetings, there will be tech- nical assistance, training and other assistance available to local programs. Fourth, we are strengthening our base of support nationally by developing closer ties and better relationships with Civil Rights, labor, elderly, consumer and many other organizations and individuals who have been allied with us in the past. We are also reaching out to new organizations as well to develop alliances and obtain support. Because legal services is only one of many issues with which these organizations are concerned, the National Support Centers and others will be joining with these organizations in common efforts to prevent benefit pro- gram reductions. Fifth, we are addressing short-term issues that require immediate action. Through the National Legal Aid and Defender Association the coalition has identified potential nominess for the LSC Board of Directors who are supportive of legal services but also acceptable to the Reagan Administration. In addition, - 9 - we are working to acquaint key people in the Reagan Administration and in Congress (including the new Senate leadership) with our program, its in- dependence, and its achievements. We are shoring up and strengthening the support we have among some members of the Reagan team. We are identi- fying those who can influence members of the transition teams and the appointees of the new administration. Sixth, we are taking steps to protect programs and our overall delivery system. We will address basic bureaucratic and programmatic vulnerabilities that have been identified by GAO reports and by others. We are also reviewing our en- tire support structure to make sure it is sufficiently insulated from political pressure and can function effectively in the future. Seventh, we will be increasing the Washington lobbying efforts of the Corporation and our organizations. NLADA, for example, has hired a full-time experienced lobbyist to work on legal services and other matters. The new entity being formed will substantially expand our lobbying capacity. Eighth, we are developing an affirmative legislative strategy to deal with the difficult situations we face in the next session of Congress with regard to both appropriations and reauthorization. This year it will be necessary for us to get out reauthorization through Congress. The Senate will not approve our appropriations without a reauthori- zation. We will also need to work again with the Budget Comittees in the House and Senate. Last year, the budget process played a major role in setting priori- ties on substantive legislation as well as appropriation levels. Finally, con- firmation in the Senate of LSC Board nominees may require same efforts by the legal services community. Although an affirmative political strategy has not yet been fully developed, it will include at least the following components: 1. Selling the merits of legal services to Congress, media and others at the local, state and national level. Much of this will be done by local people and local programs. 2. Developing a broad range of support from a wide sector of group and organizations and making it in the interest of these groups for legal services to continue without restrictions. This will require effective work at a local, state and national level by legal services programs around the substantive issues affecting the members of the groups and organizations from which we seek support. 3. Improving our relationships with the private bar. We are developing a concrete partnership with the American Bar Association and other bar associations to preserve and expand legal services. This will require full implementation of the Delivery System Study Policy Report and increased involvement of private lawyers in the delivery of legal services. As part of our strategy we are seeking increase funds for expansion in the Fiscal Year 1982 Budget request. By seeking funds from Congress, we believe we can obtain support for the maintenance and expansion of existing programs and prevent mandates in the Legal Services Corporation Act that would reallocate current resources. 4. Developing an affirmative response to Congressional efforts to impose restrictions on legislative representation and other limitations on the scope of representation to be provided to our clients. To develop this affirmative strategy we are preparing at least two back- ground papers for circulation and discussion. John Dooley is preparing a paper discussing the private bar issues and options to address them. We are also preparing a paper analyzing possible options to prevent legislative representation restrictions. We will be meeting with a number of people to discuss each of these issues and will be holding strategy discussions with the coalition members in early January. In considering our affirmative strategy we are meeting with many advocates who are experienced in political and legislative strategy in Washington. We are seeking their views on how to take the initiative, how to best use the private bar issue and how to prevent restrictions on case types or the scope of re- presentation. Regardless of our efforts in Washington, an affirmative legislative strategy is dependent upon effective relations on a local level with congressional offices with state and local bar associations, and with organizations and individuals who are potential supporters and allies. What Must be Done Each legal services program must undertake the following: 1. Develop a specific action plan at state and sub-state levels. This plan should detail how each state will seek to maintain and improve or develop Congressional relations, relations with local and state bar associations, relations with allies and supporters, and relations with local and state governmental entities. The plan must also discuss efforts to develop and improve media relations and develop new media contacts. Finally, the plan should specifically include concret steps to maintain, improve and/or develop meaningful relations with poor people's organizations. Many states have already developed such plans. Others are beginning to do so and will be completing the plans at the regional meetings. These plans will require every program to shift program resources to undertake the efforts outlined in the plan and to change the priorities and work of project directors and staff. 2. Appoint a program coordinator or coordinators who will have overall responsibility for coordinating the implementation of the state and sub-state plans and assuring that all survival activities are carried out. 3. Develop timely and effective communications with the state coordinator. The state must assure that the coordinators have adequate staff and a means of communicating effectively and in a timely manner with all programs. 4. Develop effective internal communications networks that assure all staff with adequate and timely information about developments nationally and within state and local areas. 5. Continue to identify people who have contacts with officials of the Reagan Administration. State Coordinators and relevant Washington actors should be informed of these contacts. Please make sure I am informed of these contacts. - 13 - 6. Continue to identify potential Board nominees who are supportive of legal services and yet potentially acceptable to a Reagan Administration. Names of potential nominees should be sent to Howard Eisenberg at NLADA. 7. Analyze new members of Congress from your area and review all old members of Congress. What is needed is carefully complied information about all members of Congress. This includes: attitudes, public statements and prior voting records toward legal services and other social benefit programs; their sup- porters and major contributors from within the bar and general comunity; possible contacts with their supporters; and their political base in the district or state. This information should be sent to the state coordinator and Office of Government Relations. OGR will develop an analysis of each Congressional person and office. The completed analysis will be sent to each state and program coordinator. The analysis will also include such information as prior Congressional voting records on legal services, positions on other poor people's issues, committee assignments, names and background of key staff, and which members influence this member. The difficulties we will face now and during the next few years will require sacrifice and discipline by LSC and program staff. Among other things: 1. We must start taking this effort very seriously if we are to succeed. - 14 - 2. When program coordinators are asked to do something by the state coordinator, by LSC or members of the coalition, they must act responsibly and without delay to see that the tasks are done or that we are immediately informed that they can be done so that we can take the necessary actions to see that they are done. 3. This is the time to act and act quickly to organize within each state and local program to shore up and strengthen the base of ! political support. 4. Coordinated activity is important. This is not a time to act totally independent of the effort that is being initiated. Project directors and staff will have many good ideas, practical suggestions, intelligence and experience to share with national actors and with other programatic people. It is important to work together and keep in touch. Coaliton Building A critical means of strengthening the local political base is to develop coalitions and working relationships with local organizations and individualse who would see it in their interest to assure the continuation of an aggressive legal services program. Effective coalitions and working relationships will involve programs assisting these groups and organizations in concrete ways. Merely acting in concert or seeking assistance will not be sufficient. The local program must actually assist groups, individuals and coalition members SO that they have a real stake in the survival of the legal services program. The legal services program must become a integral part of their activities. - 15 - Usually coalitions and working relationships will eyolve out of common work on substantive issues, Legal services should seek out others in the community who may be involved on similar issues of concern to the program and client community. They should also seek to participate in activities by others that affect issues and problems of the client community, There are a variety of with whom local programs can deyelop re- lationships. Some are involved in advocacy for the poor (such as Comunity Action Programs); some are involved in services for the poor, Many are in- volved in common issues which affect both the poor and the members of the groups. (e.g., unions and food stamps; Associations of Retarded Persons and special education; elderly organizations, etc.) Many are involved directly in advocacy for populations which include the poor. (civil rights, etc.L. In developing working relationships and coalitions on substantive issues, legal services programs and staff should not forget their principal role as advocates for the poor. The point of developing working relationships and coalitions is to strengthen the power of pooe people not to shift the program toward a different population. Legal services should not be viewed as com- promising the interests of poor people for its own survival or for the broader good of the coalition. Moreover, legal services should seek to involve poor people directly in the coalitions and bridge relationships between poor people and individuals and organizations with common interests or issues. The Broader Picture - The Needs of our Clients The struggle for survival of aggressive legal services should never be perceived by us to be a higher priority than the struggles that poor people will face during the next several years as this new administration and Congress - 16 - attempt to curtail social benefit and entitlement programs and civil rights activities. We must not under any circumstances stop using most of our resources and most of our energies to continue providing aggressive impact advocacy to improve the lives and power of poor people. Moreover, we must take immediate steps to develop effective efforts with- in each state and on a national level to preserve the gains won by poor people and their advocates during the last 15 years. And we must continue to strive to increase social benefits, improve housing and health care, prevent arbi- trary private and public actions, improve job and educational opportunities, and eliminate discrimination. This will require targeting increased resources on substantive issues which will arise on a national and state level: development of more effective national and state networks of staff, clients and other advocates and allies; improved communications to each state about national developments and within each state about national, state and local developments; strengthening our capacity for legislative and administrative advocacy; and developing more effective strategies that use all of the tools available including more effective use of litigation as well as community education, legislative and administrative representation, networking and coalition building. Working with national and state support projects, we are strengthening current efforts and developing new approaches that will assist local and state programs in undertaking these critically important activities for sur- vival of poor people's basic needs. Although there are different- networks that will be used to work directly on these "substantive" activities, (i.e., the substantive networks that have developed through national and state support projects), we will keep all state coordinators informed of national cubstantive Thus, as we enter this struggle for our own survival, we must never forget that the purpose of our effort and the shift of some resources to our survival is not to save ourselves (or our jobs), not to save our current ways of doing things or even our current structures for that matter. Instead, the purpose of our efforts to preserve for poor people a force that they can call upon to use to improve their economic and social well-being. as Eagle Forum Diana Lozano of Rhode Island Box 121 A, Old Plainfield Pike Foster, Rhode Island 02825 WASHINGTON OFFICE: 316 PENNSYLVANIA AVE., S.E., SUITE 203. WASHINGTON, D.C. 20003 (202) 544-0353 HEADQUARTERS OFFICE: BOX 618, ALTON, ILLINOIS 62002 (618) 462-5415 November 9, 1981 The President The White House Washington, D. C. 20500 Dear Mr. President: In view of the recent votes in favor of funding for the Legal Services Corporation, we take comfort in your past pledge to veto any such legislation. Our group has been studying the Republican Study Committee Fact Sheet prepared by Loren Bruce and dated April 24, 1981. It documents many of the abuses of the Legal Services Corporation, and provides a number of ex- amples of how the Legal Services Corporation has spent much of its money: pursuing litigation which promotes a philosophy of government that has been repudiated at the polls as well as in legislative forum. We intend to give our support to your promise to veto all continued funding for the Legal Services Cor- portaion. Sincerely, (Mrs.) Judith F. Ryder, President Judith 7. Ryder Eagle Forum of Rhode Island "They that wait upon the Lord shall renew their strength; they shall mount up with wings as eagles; they shall run, and not be weary; and they shall walk, and not faint." Isaiah 40:31. file Legal Services corp. MISSIONARIES FOR LIBERALISM: UNCLE SAM'S ESTABLISHED CHURCH by Michael E. Hammond published by: THE CONSERVATIVE CAUCUS Research, Analysis & Education FOUNDATION, INC. 450 Maple Avenue East Vienna, Virginia 22180 18 to compel a man to furnish contributions of money for the propagation of opinions which he disbelieves and abhors, is sinful and tyrannical. "1 -Thomas Jefferson, 1777 "Today we face a severe threat to the continuation and growth of agressive legal services. At stake is the survival of committed, aggressive and political staff [and of] agressive advocacy " 2 -Alan W. Houseman, Legal Services Corporation, 1980 "Congress shall make no law respecting an establishment of religion " -First Amendment U. S. Constitution INTRODUCTION Since the beginning of the Congress has established var- Republic, Presidents and officers ious "intervenor funding" programs within each administration have for the purpose of financing stud- engaged in activities which could ies and appearances by "consumer legitimately be classed as "advo- advocates" before agencies. 3 The cacy." This advocacy--which has Federal Trade Commission's pro- frequently dealt with issues in- gram, for example, has handed mil- volving great controversy--was lions of dollars to groups which considered not only the right, but are almost without exception, ide- even the responsibility of the ologically liberal, and which, in President. most cases, have substantial fin- Recently, however, recipients ancial resources available.4 This of Federal largesse have engaged appears to be in direct violation in a form of advocacy which is of the FTC's charter, which prohi- qualitatively different from the bits "intervenor funding" for any "bully pulpit" which Roosevelt group which could otherwise afford knew. The difference between Alan to participate in FTC proceed- Houseman and Thomas Jefferson goes ings. 5 beyond Houseman's relative inarti- In areas such as Federal culateness and the banality of his funding intended to benefit the ideas. handicapped, "protection and advo- Houseman's statements repre- cacy" mechanisms have been estab- sent a new form of advocacy--an lished by statutes like the Devel- advocacy which is unresponsive to opmental Disabilities Act and the and uncontrollable by elected ex- Rehabilitation Act of 1978.6 Un- ecutive authority, attacks the re- der these programs, outside groups ligious beliefs of a substantial are funded for the purpose of lit- portion of Americans, is violative igating and lobbying on behalf of of the laws governing the program what has turned out to be a con- Houseman supervises, and consis- sistently liberal set of ideologi- tently represents a specific ideo- cal premises. 7 Although most logical point of view. "protection and advocacy" programs This new form of "government explicitly or implicitly prohibit ideology," transcending electoral lobbying the Federal government, 8 results, is not unique to any sin- the recipients of "P&A" monies gle Federal agency. freely acknowledge that they have -1- ignored these statutory maturity in this country or restrictions.⁹ in Congress for doing that In addition to those programs right now, and, what Congress expressly authorized to fund has responded to is not giv- advocacy activities, there are ing low-income people dignity many others which have had that that comes with meaningful unintended result. cash assistance--what they've For example, a House Appro- responded to is these priations Committee report found individual needs. We'll hand 5 that Sam Brown's ACTION had them some food stamps--we'll supported union organizing, funded give them a section 8 cer- a training institute for community tificate, which all of us activists to the tune of $432,235, get frustrated about some- and assigned volunteers to work in times, because that's not the 1979 Arkansas primary really doing anything to election. 10 eliminate poverty or change the conditions of poverty. In any event, you have Congress responding to LEGAL SERVICES ADVOCACY individual needs. They're not responding to a Poor People's Platform--they're But the Legal Services responding to individual Corporation (LSC) is probably more needs. And, whether I like extensively and exclusively invol- it or not because of my own ved in ideologically premised ad- personal political and social vocacy than is any other agency. views I know that on the food In 1981, this government- issue I get the most mileage created, semi-autonomous entity out of doing a bleeding received $321,300,000 in taxpayer heart, kind of churchie, funding. Like other advocacy feed-the-poor, kind of programs, which operate through thing. 12 extra-governmental non-profit corporations, it is characterized Legal services attorneys have by an organic statute which, while lobbied or litigated to secure not saying so, has the effect of disability payments to individuals channelling funding to individuals because they were homosexuals, 13 and organizations on one end of the cessation of technological de- the ideological spectrum. velopment of farm machinery be- It is an instructive indica- cause it would put migrant workers tion of ideological coloration out of work, 14 the imposition of that a representative of the LSC- racial quotas in medical school allied Food Research and Action admissions, 15 the turnover of Center, "11 went unchallenged when large portions of the Eastern she stated at a November, 1980 United States to persons of Indian conference of the National Legal ancestry, 16 the payment of Aid and Defender Association: supplemental social security benefits to alcoholics, 17 the What all of us ultimately establishment of "black English" care about--ultimately, is as a separate language, 18 and the meaningful welfare reform, upgrading of Armed Forces and a meaningful redistri- discharges for persons thrown out bution of wealth and income of the service because of in this country. Well, get- homosexuality. 19 ting from here to there is Most of these activities are easier said than done. It so not within the scope of litigation happens that there's not a envisioned by Congress when it -2- passed the Legal Services Corpora- tion's 1974 charter. This intent THE ILLEGAL SERVICES CORPORATION was most clearly stated by Senator J. Glenn Beall (R.-Md.), when he said: "[The type of cases which Section 1007 (b) of the Legal the Legal Services Corporation Services Act states: will be handling] are not cases which reach headlines or front No funds made available by pages of newspapers. But to the the Corporation may be poor, every one of these cases is used-- important, whether it be the family being evicted or a mother (7) to initiate the form- having her child taken away. Thus ation, or act as an organ- the poor (will be) provided izer, of any association, representation in difficult day- federation, or similar to-day problems in such areas as entity, except that this family law, landlord-tenant prob- paragraph shall not be con- lems with employment and consumer strued to prohibit the pro- cases. "20 vision of legal assistance Whether various activities by to eligible clients Legal Services recipients are actually illegal under the specif- Since the creation of the ic prohibitions of the Act is Corporation, proponents of the difficult to judicially estab- politicized Legal Services Program lish. In 1977, Congress added a have attempted to limit the scope provision to the Legal Services of the words "initiate the forma- Act to prohibit a litigant against tion" and "act as an organizer," a Legal Services client from rais- contained in the section 1007 ing the validity of that represen- (b) (7) limitation. The House tation in connection with the pen- Education and Labor Committee's ding lawsuit. Instead, represen- report attempted to draw a tation questions were to be refer- distinction between "prepar(ing) red to the Corporation for resolu- papers of incorporation" and tion and, presumably, were to be performing comparable technical judicially reviewed, if at all, services, which it viewed as only under standards which assumed lawful, and acting as an impetus the validity of the Corporation's to organizing efforts, which even very broad determination of the the House committee had to admit scope of its jurisdiction. 21 is unlawful. 22 Suffice it to say that this One thing should be clear to costly and partial procedure for even the most ardent proponents challenging LSC jurisdiction has of expansive LSC powers: A virtually assured that represen- Washington-based effort to assist tation decisions, however unlaw- in forming a national coalition of ful, have gone largely unchalleng- special interest groups does not ed. pass muster under the 1007 (b) (7) In spite of the dearth of ju- standard. dicial decisions to provide guid- In the December, 1979, issue ance, however, there are a vast of Clearinghouse Review²³ Alan number of cases in which involve- Houseman's Research Institute on ment by Legal Services recipients Legal Assistance solicited members would seem to be clearly in direct for a "national coalition, Citi- violation of any of a dozen speci- zens for Tax Justice (CTJ) a fic statutory restrictions. federation consisting of "the na- tional public interest organiza- tions, NAACP, National Consumer -3- Federation of America, the Nation- organizations who are allies al Council of Senior Citizens, and supporters of legal Mass Fair Share, Texas-ACORN, the services. 26 Ohio Public Interest Campaign, the AFL-CIO, the International Associ- In another instance, The ation of Machinists (IAM), and the Beacon Hill Update bragged that American Federation of State, "(t)he four prominent prison re- County, and Municipal Employees form groups - Family and Friends (AFSCME). of Prisoners (F&F), the American Readers interested in member- Friends Service Committee Prison ship were given the address and Project (AFSC), the Mass. Correc- telephone number of the executive tional Legal Services (MCLS), and director of CTJ. 24 the Self-Development Group (SDG) - The article went on to recom- are working towards building a mend that "those [LSC-funded] pro- coalition to strengthen their hand grams active in tax reform activi- in opposition to [Massachusetts ties, but not interested in join- Governor Ed] King['s] administra- ing the coalition may want to con- tion policy [relating to prison sider contacting the coalition for construction]". 27 technical assistance and informa- If these efforts at organiz- tion about coalition members who ing coalitions for political pur- may be active in their local poses are not in violation of sec- area." It also solicited sugges- tion 1007 (b) (7), it is hard to un- tions and ideas about "other derstand what is. actions the legal services and The Office of Management and client community could take in Budget, in an opinion dated May, conjunction with the CTJ. "25 1981, found widespread violations In a strikingly similar case by the Corporation and its recipi- involving the same recipient, ents of Federal laws prohibiting Houseman, in his December, 1980, lobbying. Acting Comptroller lobbying strategy memorandum, ad- General Milton J. Soclar held vocated the same sort of coalition that: building. Stated Houseman: In summary, through the use of recipient organizations First, we are attempting to and their contacts at the unite and join together in State and local level, LSC this struggle. We have form- had developed an extensive ed a coalition with PAG [Pro- lobbying campaign to support ject Advisory Group], the reauthorization legislation National Clients Counsel for the corporation and (sic) (NCC), NLADA [National related appropriation Legal Aid and Defender Asso- measures being considered by ciation], the National Orga- the Congress. This activity nization of Legal Services violates the anti-lobbying Workers (NOLSW) and the Mi- statutory and appropriation nority Caucus. It will be restrictions described expanding to include others above. 28 from within the legal serv- ices community, such as The anti-lobbying provisions National Association of Indi- referred to are 18 U.S.C. $1913, an Legal Services (NAILS), sections 1006 and 1007 of the migrant farm workers (sic) Legal Services Act, and appropria- group, women's caucus, Orga- tions restrictions on lobbying and nization (sic) Legal Services propaganda. 29 Backup Centers (OLSBUC), Unlawful lobbying activities state support and others. It by the Corporation and its recipi- will also expand to include ents take a wide variety of -4- forms. Some ostensibly arise out festation of this strategy. In of client representation. How- it, Houseman lays down an eight- ever, in such cases, when the lob- point plan for "waging battle" on bying occurs without the client's behalf of not only reauthorizing knowledge or consent, 30 it sug- legislation satisfactory to the gests that the client was simply a Corporation, but also retention of device for the recipient to engage other Federal agencies which in a predetermined mode of policy President Reagan seeks to replace 3 advocacy. with block grants. 35 Because it In addition, however, there deals with problems other than the is a day-to-day mechanism where Corporation's own authorization issues targeted by backup centers and because it represents a on a national level are systemati- Washington-generated effort, this cally lobbied by legal services comprehensive lobbying plan is not recipient organizations. 31 protected by the two biggest loop- The method by which issues holes in LSC's lobbying are selected varies from case to prohibitions -- the client repre- case. In at least one case, a sentation loophole and the backup center has polled its mail- loophole dealing with lobbying on ing list for recommendations. 32 behalf of Legal Services funding. After a decision is made to Key passages include: lobby on behalf of a given issue, the backup center phones local In the short run, a legal services offices. The local strong local political base contact can be a state lobbying will be critical if we are to coordinator, as in the case of successfully obtain support Marshall Cohen of Pine Tree Legal from Congress for the contin- Services in Maine. 33 In other uation of an aggressive legal states, there may be no designated services program. contact, and the national backup center simply phones each Legal we are strengthening Services office within the our base of support state. 34 nationally by developing Contacts made through this closer ties and better system occur regularly. They relationships with Civil involve issues which are seemingly Rights, labor, elderly, unrelated to the Legal Services consumer and many other Corporation's authorizations or organizations and appropriations. They may be made individuals in response to a poll or other Washington-based decision-making we will be increasing the process, rather than the needs of Washington lobbying efforts a particular client. Nothing of the Corporation and our would appear to be more clearly in organizations. NLADA, for violation of all four major Legal example, has hired a full- Services lobbying restrictions. time experienced lobbyist to It is against this backdrop work on legal services and that the Corporation, in 1980, other matters. The new en- launched a massive illegal lobby- tity being formed will sub- ing effort to secure its reauthor- stantially expand our lobby- ization and, after the election of ing capacity. Ronald Reagan to the Presidency, to achieve the defeat of the There is ample evidence that Reagan economic package. the Houseman plan to defeat the The lobby strategy memorandum Reagan budget is being vigorously by Houseman represents perhaps the pursued by a wide variety of fund- most self-evidently illegal mani- ing recipients. -5- Beginning around the first dent's budget cut proposals. 43 week in March, 1981, hundreds of In April, 1981, and on numer- local newspapers began featuring ous other occassions, Corporation curiously similar interviews with President Dan Bradley had stood the heads of their local Legal with other Legal Services repre- Services programs, in many cases sentatives in the reception room resulting from press releases of the Senate chamber, accosting emanating from those programs. senators to encourage them to bust With a similarity of themes the President's budget resolution. which makes coincidence unlikely, According to Budget Committee these articles bear titles such as Chairman Pete Domenici (R-N.M.), "Legal aid lawyer says cuts would the budget of the Legal Services hurt rural poor worst, "36 "Cuts Corporation was not at issue in Would End Legal Aid to Rural Poor, connection with this legisla- Director Warns, ⑉37 "President tion, 44 meaning that there was no Reagan's Legal Aid Cuts Will Hurt section 1006 or 1007 justification North Dakotan's (sic) According to which would render the lobbying State Office News Release, "38 activities lawful. "Local legal aid staff fears bud- To staff this elaborate net- get cuts will hurt clients, ⑉39 work of illegal lobbying activi- "Legal Services says cutbacks will ties, the Corporation and its re- hurt poor, "40 and "Free legal aid cipients hire on the basis of po- may be taken from area poor. "41 litical and legislative acumen, In each article, the director and actively fight for the reten- of the local Legal Services pro- tion of a politicized staff. gram laments the closing of his In May, 1977, the National office which, he claims, will in- Consumer Law Center bragged that exorably result from having to it "has traditionally devoted a seek funds from block grant money significant amount of its resourc- which the Reagan administration es to legislative activity at the would make available to the state and federal level, although states. Many directors go on to its resources and willingness to paint a picture of frustrated poor be of assistance may not be gener- people taking to the streets in a ally known. "45 It went on to ad- rebirth of the urban rioting of monish that = the willingness of the 1960's. Legal Services attorneys to con- Among the statements typical- tact (and have others contact) ly made in defense of Legal members of Congress can be Services is a remark by Oakland crucial. "46 attorney John Burris, who said: Similarly, the Luzerne County "[Reagan's Legal Services proposal Legal Services Association ad- is] totally insane, exhibiting a vertised in Clearinghouse Review callous insensitivity to the needs for a "law reform specialist, "47 and aspirations of the poor. and the Contra Costa Legal Serv- Former National Bar Association ices Foundation boasted to would president Robert L. Harris went on be recruits of its "tradition of to add that "[b]lack America must strong community involvement and rise up and confront the Adminis- aggressive participation in local tration on this proposed political, social and economic madness. "42 battles on behalf of its client In implementing the Houseman communities. "48 plan on the Washington level, the Clearinghouse Review, which Food Research and Action Center received $840,000 from LSC in and the LSC-funded Native American Fiscal Year 1981, serves as a bul- Rights Fund both joined a coali- letin board for liberal legisla- tion of feminist groups signing a tive causes, alerting readers to petition in protest of the Presi- Congressional status of liberal -6- agenda items such as "intervenor hibits provision of legal assis- funding" legislation4 and the tance with respect to any "pro- Domestic Violence Prevention and ceeding or litigation which seeks Services Act, 50 as well as har- to compel any individual or pooning conservative legislation institution to assist in the such as the Family Protection performance of an abortion, or Act. 51 provide facilities for the perfor- mance of an abortion, contrary to 5 the religious beliefs or moral convictions of such individual or PRO-ABORTION ACTIVISM institution." Obviously, a state or local government which, reflecting the religious or moral convictions of It has become apparent with its citizens, either by law or time that the Legal Services Act's policy, restricts the use of its prohibition on abortion litigation facilities and funds in connection was intended to be more of a loop- with the performance of abortions, hole than a proscription. Never- falls within the category envi- theless, there are some abortion- sioned by the statute. Hence, related activities which the when in 1979 the Neighborhood Corporation and its recipients Legal Services office in clearly may not engage in. Pittsburgh forced a Pittsburgh The language of section 1007 jail to transport an inmate to a (b) (8) prohibits two different hospital for an abortion, 53 it was types of abortion-related activi- requiring that jail to make avail- ties. First, it states that: able its assistance in connection with the performance of an abor- No funds made available by tion, contrary to the religious the Corporation may be and moral convictions of the com- used to provide legal munity, as reflected in the rules, assistance with respect to policies, and statutes governing any proceeding which seeks to the operation of the jail. procure a nontherapeutic In another case, Preterm, abortion. Inc. V. Dukakis, Greater Boston Legal Services helped challenge a In spite of this language, Massachusetts law limiting expen- recipients have engaged in pro- diture of state funds to abortions ceedings to procure abortions necessary to prevent the death of which cannot reasonably be classi- the mother. 54 The provision of fied as "therapeutic." For those state funds were "assist- example, in 1979, Michigan Legal (ance) in the performance of an Services filed an amicus brief on abortion," contrary to the reli- behalf of a governor's item veto gious beliefs or moral convictions of a provision barring state funds of the individuals who enacted the for nontherapeutic abortions. 52 statute and the citizens of If Congress intended to go on Massachusetts who elected them to record in opposition to the pro- engage in that law making deter- curement of individual nonthera- mination. peutic abortions, it is highly un- Similarly, in Zbaraz V. likely that the Corporation or its Quern, the Legal Assistance recipients could successfully Foundation of Chicago successfully argue that actions to compel the sought an injunction against en- financing of large numbers of non- forcement of an Illinois statute therapeutic abortions could pass preventing state medical payments muster. for abortions except when neces- Section 1007 (b) (8) also pro- sary to save the life of the -7- mother. 55 requirements, either through leg- For those who would argue islative advocacy or through liti- for a very narrow interpretation gation." He adds: "The National of this language based on a statu- Center for Youth Law would be hap- tory purpose to protect the py to assist with such efforts. "61 mother, rather than the fetus, it Again, this is a legislative is important to note that Legal advocacy project which was initia- Services has actively worked on ted not as a result of client need behalf of other nontherapeutic as required by sections 1006 and operations with ramifications for 1007 of the Legal Services Act, the mother's health as profound or but rather as a result of the leg- more profound than the performance islative agenda of a backup of a nontherapeutic abortion. center. For example, in June, 1977, Michael Shepard of Utah Legal Services sued on behalf of a minor woman challenging HEW's policy of DIRTY TRICKS refusing to pay for nontherapeu- tic sterilizations of women under 21 years of age. 56 The court dis- The practice of collecting missed the case, finding that dossiers on members of Congress there was no "suspect classifica- and their staffs is also encour- tion" capable of sustaining a con- aged centrally. Houseman suggest- stitutional objection to the poli- ed this when he stated: cy. 57 Finally, Clearinghouse Review Analyze new members of has contained articles advocating Congress from your area and abortion-related activities in vi- review all old members of olation of abortion, organizing, Congress. What is needed politicking and lobbying restric- is carefully complied (sic) tions in the Legal Services Act. information about all members These included an article by of Congress. This includes: feminist Sylvia Law on "Reproduc- attitudes, public statements tive Freedom Issues in Legal Ser- and prior voting records vices Practice. "58 According to toward legal services and Law, "The problems of insuring other social benefit pro- poor women the right to reproduc- grams; their supporters and tive choice are overwhelming major contributors from with- Work in this area can also provide in the bar and general com- legal services lawyers opportuni- munity; possible contacts ties to form alliance with others, with their supporters; and help develop community organiza- their political base in the tion, and strengthen the political district or state The base for dealing with issues that analysis (which will be pre- critically affect the lives of pared from this information) their clients. "59 will also include such infor- In another article by an at- mation as prior Congressional torney employed by the LSC-funded voting records on legal ser- National Center for Youth Law, vices, positions on other analyzing the "abortion-without- poor people's issues, commit- parents'-consent" decision in tee assignments, names and Bellotti V. Baird, 60 the author background of key staff, and states that "it is important that which members influence the legal services attorneys devote member. 62 considerable energy to opposing the imposition of burdensome This advice was echoed at parental consent and notification the Legal Services conference in -8- San Juan, where one speaker ad- workers' unions in California, vised: Florida, the Midwest, and New Jersey.68 The more information we have about the congressional dele- gations from your state hope- fully the less we would need CLASS AGAINST CLASS to pester you for informa- tion. Anything that you can get into our hands makes our The question of whether Legal job easier These are some Services is illegally shifting its of the ways that you can feel entire set of priorities away from like you are involved in what the statutorily mandated represen- happens in Washington, be- tation of individual poor people cause God knows I know you and toward representation of col- all don't want to just sit lective interests is of transcen- home and read the newspapers dent importance, though it is not passively about what Congress as legally clear-cut as the ques- is going to do to poor people tion of whether Legal Services is next year. 63 unlawfully lobbying. The first finding of section 1001 of the Legal Services Act of 1974 is a declaration that "there TRAINING AND ORGANIZING THE CADRES is a need to provide equal access to the system of justice in our Nation for individuals who seek Legal Services training goes redress of grievances." Section far beyond instructions on the 1007 (a) (2) (c) mandates that the simple gathering of political in- Corporation "insure that recipi- formation. The January, 1979, is- ents adopt procedures for deter- sue of Clearinghouse Review con- mining and implementing priori- tained an article entitled "An ties taking into account the re- Advocacy Guide to the Community lative needs of eligible clients Development Block Grant Program," for such assistance." intended to advise Legal Services In short, the statute envi- lawyers on how to obtain govern- sions the creation of priorities ment funds. 64 States the article: which focus on individual legal "A community group's main consi- needs and do not set macrocosmic deration, for example, might be to interests of a diverse group of back a sympathetic political fac- beneficiaries over the specific tion or public agency over an un- needs of eligible clients. sympathetic one "65 The Indian claims cases are As for "labor or anti-labor one example of how recipients activities, boycotts, picketing, have used their mandate to repre- strikes, and demonstrations," sent the poor in a way which may there is extensive evidence of be antithetical to the interests Legal Services involvement in of the larger portion of their these as well. In Belle Glade, clients. Florida, for instance, attorney In some of those cases, Donald Mason of Florida Rural Legal Services attorneys have sued Legal Services was active in or- to return major portions of ganizing a rent strike against the Eastern states to the indigenous local Belle Glade housing authori- Indian population, without regard ty. 67 And Charles Fields of the to the status of current owners of American Farm Bureau Federation the land or the number of people has charged that Legal Services who would be put out of work as a lawyers have helped organize farm result of Indian acquisition of -9- the land. for non-payment of utility bills76 In Maine, Pine Tree Legal --a suit which, however meritori- Assistance, Inc. litigated to ous or non-meritorious, does not return two thirds of the state to strictly impact on the client com- the Passamaquoddy and Penobscot munity. Indians, potentially displacing Similarly, California Rural 350,000 persons. 69 Legal Services, litigated on be- On Cape Cod, it was the half of 19 farmworkers to chal- Native American Rights Fund which lenge the entire California system sued to return a large sector of of publicly sponsored agricultural the state of Massachusetts to the research to produce more efficient Indians. 70 farm machinery, claiming it was In Utica, New York, farmers displacing migrant farmworkers. 77 are being sued on behalf of the The rationale for all of this Oneida Indians for return of litigation is curiously self- roughly 5,000,000 acres of land. 71 contradictory. On one hand, reci- These cases pit poor landown- pients are willing to engage in ers against poor Indians. They litigation resulting in substan- pit "economic development" and tial economic losses for the poor jobs for eligible clients against on the basis of a single eligible persons who are much less likely client. On the other hand, Legal to use the land for purposes of Services recipient organizations development. Moreover, they rest freely turn away eligible indigent on the notion that any eligible clients on the grounds of priority client who walks through the door litigation on behalf of mixed can invoke Legal Services activity groups of eligible and noneligible detrimental to the interests of beneficiaries. most other eligible clients. Legal Services representation of the Ku Klux Klan is also illustra- tive of this final proposition. 72 INCITEMENT OF LITIGATION Ironically, this "impact lit- igation" against the interests of many poor people and on behalf of All of this raises the funda- as little as a single eligible mental question of whether the client has frequently resulted in types of litigation engaged in by an inability to adequately service LSC recipients are being deter- other eligible clients seeking le- mined by the needs of particular gal assistance. For example, clients or the ideological Northeast Ohio Legal Services predilections of taxpayer funded turned away indigent would-be lawyers. clients in order to pursue litiga- Section 1007 (a) (10) of the tion designed to prevent United Act requires that the Corporation States Steel from closing its "insure that all attorneys, while local plants or, alternatively, to engaged in legal assistance acti- require it to sell the plants to a vities supported in whole or in worker-community group that would part by the Corporation, refrain seek Federal funding. 74 from the persistent incitement of In North Carolina, Catawba litigation and any other activity Valley Legal Services, Inc., for- prohibited by the Canons of Ethics mally accepted only 587 of 1168 and Code of Professional Responsi- requests for legal services in bility of the American Bar 1980. 75 Yet, it spent substantial Association. amounts of resources in a suit to Yet, there is extensive docu- limit the ability of public utili- mentation that blatant and persis- ties to terminate services to tent incitement of litigation financially heterogeneous groups takes place. -10- For example, Bob Duren of the on "legal assistance with respect Legal Aid Foundation of Los Ange- to any proceeding or litigation les advertised in a Los Angeles relating to the desegregation of newspaper that six offices of his any elementary or secondary school organization were open "to receive or school system. "82 complaints from victims of police misconduct." The announcement went on to offer legal assistance and referral services for "any INTERPRETING THE PUBLIC INTEREST person complaining of police abuse or misconduct. 78 Likewise, the Veterans Educa- Section 1007 (b) (5) makes it tion Project advertised in Clear- unlawful for the Corporation to inghouse Review of the availabili- make grants or enter into con- ty of material to help homosexuals tracts with any private law firm thrown out of the Army upgrade which expends 50% or more of its their discharges. 79 resources or time litigating is- sues in the broad interest of the majority of the public. NO one has yet defined with specificity DISREGARD OF FORCED BUSING what kinds of litigation fall into RESTRICTIONS this category, and no inventory exists of the amount of "broad public interest litigation" that The list of presumably is annually engaged in by various explicit proscriptions against recipients. Legal Services recipients covers California Rural Legal several pages in the United States Assistance brags that it spends Code. And, for virtually every 35% of its time litigating class specific prohibition contained in action suits alone. As the fol- the Legal Services Act, there are lowing examples illustrate, more- reported instances of abuse. over, class action suits represent While the major areas suggesting only a small percentage of litiga- pervasive patterns of illegal tion proscribed by section activities have already been 1007 (b) (5). Hence, many of these discussed, it would be unfair to lawsuits, while perhaps not fall- suggest that unlawful practices ing within specific ambit of any have been limited to these. other Legal Services Act prohibi- Other highly questionable tion, do represent controversial activities include: Preparation issues which may put the Corpora- of a friend of the court brief in tion and its recipients in viola- the Bakke case in favor of the tion of section 1007 (b) (5). University of California's uncon- At any rate, these cases di- stitutionally discriminatory vert funds from the sort of admissions system, 80 in violation landlord-tenant, business-consum- of the section 1006 (c) (1) prohibi- er, and husband-wife suits which tion against LSC "participat( (ion) the Legal Services Act was intend- in litigation unless the Corpora- ed primarily to address. tion or a recipient of the Corpor- Massachusetts Law Reform ation is a party and partici- Institute offers a revealing pation by the LSC-funded Center illustration of this problem when for Law and Education in a suit it lobbies for a graduated state which led a Federal district court income tax83 or challenges efforts to place South Boston High School to reduce welfare fraud. 84 Both in receivership in order to accom- of these activities take enormous plish integration, 81 in spite of amounts of organizational time and the section 1007 (b) (9) restriction represent a clear attempt by legal -11- services officials to legislate the Legal Aid Society of their particular view of what is Louisville successfully sued to good for the poor as a class. establish the principle that a In the District of Columbia, mother's lesbianism is not suf- the Migrant Legal Action Program85 ficient grounds 95 for changing cus- challenged the Secretary of tody of a child, Labor's failure to promulgate OSHA All of the activities out- regulations for farm labor. 86 lined above were brought by orga- Gabe Kaimowitz and Kenneth nizations directly Federally fund- Lewis of Michigan Legal Services ed by grants from the Legal Ser- sued to compel the Ann Arbor vices Corporation. But as has school district to give special already been suggested, Clearing- bilingual education in "black house Review also performs a very English. "87 controversial function. A typical The Federally funded Western recent article was "Police Bruta- Center on Law and Poverty of Los lity," by the Research Institute Angeles and San Fernando Valley on Legal Assistance. 96 According Neighborhood Legal Services of to this article: "Legal services Pacoima, California88 litigated to lawyers and others continue to compel payment of Federal SSI litigate these difficult cases and benefits to alcoholics. 89 contribute to an evolving body of The Legal Action Support law regarding them. As part of Project of the Bureau of Social this effort to combat [so-called] Science Research, Inc., studied police abuse, several publications food stamp recipients in order to have been developed to assist both lay the groundwork for a suit by lawyers and clients." It proceeds Alaska Legal Services to require to refer readers to a publication people to draw food stamps. 90 by the radical National Lawyer's In Florida, Legal Services Guild. 97 recipients are engaged in lawsuits to strike down vagrancy laws9 state criminal statutes-- presum- ably in violation of section 1007- REMEDIES (b) (2) of the Act, which prohibits legal assistance with respect to criminal proceedings. Politically, the response of In Dallas, Texas, Legal Serv- the Legal Services Corporation and ices has been active in school its proponents to complaints about desegregation litigation. 92 these abuses does not suggest that In Tampa, Bay Area Legal Ser- they could be corrected by mere vices filed suit challenging adjustments in the Corporation's Florida high school competency statute. testing. 93 In the first place, given In In re Evans, Montana Legal that the problem is pervasive Services Association successfully violation of the LSC statute, how sued to obtain disability payments is it possible to alter the for a "biological male and emo- statute and thereby correct the tional female who is presently deficiency? attempting to pass in society as a Second, the Corporation's woman." Ruling that ridicule of illegal activities are effectively his/her transsexuality by fellow insulated by statute from judicial workers caused him/her "severe review. In 1977, ostensibly as a emotional trauma,' an Administra- result of large numbers of motions tive Law Judge found eligibility challenging the legality of Legal for Federal SSI and disability Services representation decisions, benefits. 94 the Senate Human Resources Commit- In Stevenson V. Stevenson, tee reported a bill which would -12- have almost totally divested the an audit by the General Accounting courts of jurisdiction to deter- Office of alleged abuses and il- mine that a particular client legalities.101 could not be legally represented One of the representations with Legal Services money or that used to defeat the Hayakawa a particular issue could not be amendment was a promise that litigated with Federal funds. 98 liberals on the Labor and Human Although proponents agreed to re- Resources Committee would sign a move the proposal from the Senate letter requesting a GAO audit once bill as a result of conservative the bill was passed. Yet, Senator pressure, the conference committee Jacob Javits (R-N.Y.) -who had reported language which severely made such a commitment--subse- limited judicial scrutiny of quently refused to sign a letter unlawful Legal Services requesting the audit when it was activities.99 forwarded to his office. Third, concessions making Fifth, the very nature of the incremental changes in the Legal staff attorney system frees Legal Services statute have never been Services attorneys from the econo- regarded by the Corporation as mic constraints against high-pro- imposing any permanent restric- file litigation imposed on most tions on its conduct. Invariably, law offices. When the client pays as soon as the political climate the lawyer's fee, he has a finan- improved, LSC was actively working cial interest in keeping the liti- to obliterate the last authoriza- gation focused on his particular tion's compromises. For example, grievances. If too much energy in 1974, a pivotal portion of the and money is spent on issues with compromise which allowed the pas- only broad social ramifications, sage of the Legal Services Act was the client will find another the Green amendment, a provision lawyer. prohibiting the establishment of Because Legal Services "backup centers" for legal advoca- recipients do not rely for their cy and research not directly rela- income on the poor people who come ted to the representation of to them for help, they have been clients. 100 able to remain accountable to After having established a their own priorities and concerns, political base, the Legal Services as well as those of backup centers Corporation proceeded to success- and other ideological brethren. 102 fully work in 1977 for elimination It is hard to understand how of the Green amendment. As par- any client-responsive system could tially recounted herein, backup be structured under which recipi- centers have subsequently been at ents were not reliant on clients the forefront of the illegal and for funding. politically questionable activi- Sixth, so long as the Legal ties engaged in with Corporation Services Corporation and its re- funds. [see Appendix A] cipients are allowed to engage in Fourth, the LSC has thus far representation of groups as oppos- successfully resisted an in-depth ed to individuals, the practical impartial study of allegations of political effect is the enforce- improper conduct, and the Senate ment of an "iron triangle" in has not been willing to investi- which liberal congressional com- gate charges of illegalities. In mittees, liberal outside groups, 1980, the Corporation succeeded in and liberal officials of Legal defeating, with only 24 favorable Services Corporation recipient votes, an amendment by Senator groups join together to tie the S.I. Hayakawa (R.-Calif.) to con- hands of whatever titular over- dition out-year funding for the seers might be appointed by a Corporation on the performance of hypothetical conservative -13- administration. and local governments will be President Reagan's political allowed to channel funds to those appointees in areas such as the services which they feel are most Department of Justice already have urgently required. seen how difficult it is to exer- If, as ABA Secretary and cise any effective control over Legal Services Corporation board the monstrous liberal bureaucra- chairman F. William McAlpin cies which they are appointed to contends, "it's not realistic to supervise. ask a welfare mother to take ten Additionally, political percent of the food out of the alliances involving Legal Services mouths of her children in order to recipients have built a strong and pay for legal services," it may be dedicated constituency which is equally "unrealistic" to require a prepared to work politically in diversion of funding from food and order to thwart any efforts to housing programs for the poor to a reign in the bureaucracy. These program that essentially puts include homosexual rights groups, money in the pockets of lawyers. "tax reform" groups, "Indian Apparently intimidated by rights" groups, anti-business President Reagan's recommendation groups, and any other movement that service providers be required which has benefitted from Legal to compete for resources under the Services representation. 103 control of state officials, Legal As long as the Legal Services Services Corporation President Dan Corporation continues to exist as Bradley responded: a Federally-funded entity, it will represent a type of mechanism dif- I felt an atomic bomb had ferent from and in many ways more been dropped on the Legal insidious than any other Federal Services Program for the poor governmental entity: it is a poli- I wouldn't be surprised if tical apparatus, largely unrespon- [Legal Services opponent] sive to the American electorate, Howard Phillips were not over with a broad legal mandate (with at the Supreme Court building which it cannot seem to comply) today with a hammer and a allowing it to engage in active chisel, chiseling out the lobbying and politicking for the words 'equal justice under purpose of retaining and expanding law.' [If the Legal Services its status as an ideological free Corporation is not funded,] agent. The continued existence of there will not be justice for this form of mechanism has severe 30 million poor people in ramifications for our system of America. 104 democracy. The first problem with Bradley's exaggerated predictions of dire consequences is that Legal ALTERNATIVES TO THE Services' current level of funding LEGAL SERVICES CORPORATION is historically unprecedented. 105 In 1965, the Office of Legal Serv- ices was created within the Office of Economic Opportunity with a BLOCK GRANTS budget of $1.3 million. By 1975, that figure had grown to $90 mil- The attraction of the compre- lion, rising to $157.4 million in hensive Social Services Block 1978, $261 million in 1979, and Grant approach is that state gov- $321.3 million for 1981. The 1981 ernments are permitted to set pri- figure, therefore, was three and orities among competing service one half times the amount author- bureaucracies. If enacted, state ized only six years earlier. 106 -14- What McAlpin and his col- taxable year. leagues really fear is that states The proposal would not be would not place legal services, as triggered until the attorney had presently provided, high on the given at least twenty hours of list of priorities for servicing free services for which he the poor. New York Mayor Edward received no tax advantage. After Koch indicated in a statement, "It this initial $1000 worth of has always been my policy that services had been provided, the Federal financing of the Legal attorney would be allowed to Services Corporation should be ex- deduct fifty percent of the tended. But now priorities must reasonable value of the legal be set. My highest priorities are services he provided free of mass-transit aid, the continuation charge to poor persons. A cap of of the food stamp program and aid $50 per hour, and a $1000 under Title XX of the Social deduction ceiling would be Security Act for the elderly and imposed. very young. "107 The advantage of the Similarly, a spokesman for Hyde-Ashbrook tax incentive plan New York Governor Hugh Carey is that it would lead to a stated that the Governor had not client-based, rather than a included Legal Services among provider-based, system for items on a list of proposed assuring the poor equal access to Federal budget cutbacks to which our system of justice. Carey would have serious In other words, eligible objections. 108 indigent individuals would But, in other states, such as establish priorities for Calfornia, there is strong politi- representation. This would cal support for local funding of contrast sharply with the present legal services projects. system, in which the officers and employees of Legal Services TAX INCENTIVES FOR LAWYERS projects are able to set priorities, controlling, as they Congressmen Henry Hyde (R- do, a monopoly on the supply of a Ill.) and John Ashbrook (R.-Ohio) "free" service, the demand for have introduced H.R. 3929, a bill which is potentially unlimited. to provide tax incentives for the provision of free legal services ALTERNATIVE FUNDING to the poor. [See Appendix B] Attorneys would receive a tax Even without Block Grant credit for voluntarily contribut- funds or a system of tax ing legal services to the poor incentives for lawyers to contri- free-of-charge. The credit could bute their services to the poor, not be invoked for types of repre- there are numerous alternative sentation which could not current- private and public sources of ly be funded by the Legal Services financing, including the Corporation because of the re- Administration on Aging, Revenue strictions contained in section Sharing, Community Development 1007 (b) of the Legal Services Act. Block Grants, Titles IX and XX of In addition, an individual the Social Security Act, CETA, could not take a legal services VISTA, United Way, and many more. tax credit for representation of Los Angeles County Bar poor relatives, representation at Association President and LSC criminal proceedings, or represen- supporter Joseph Mandel concedes tation which would result in a that private contributions from credit exceeding 30% of the individuals and entities such as individual's tax liability for the the United Way can be expected to -15- increase somewhat if Legal utilization of volunteer Legal Services Corporation grants are Services by Legal Aid Societies, eliminated. 109 expansion of Legal Services pro- Prepaid legal insurance is vided by individuals on a pro bono another significant way of meeting basis, and the enhancement of law genuine legal needs. school clinical programs serving Private lawyers can also be the poor. expected to increase their already Finally, in 1979, Congress extensive provision of free legal enacted the Dispute Resolution services to the poor. Currently, Act, which was designed to fund for example, the Los Angeles Bar's experimental state programs to Mandel estimates that members of shift minor controversies out of his association are annually pro- courts and into more informal for- viding more than $2-million of ums. 115 The notion was that, free legal services to the through the increased use of medi- poor. 110 The Columbus (Ohio) ation, small claims courts, peer Citizen-Journal paraphrases a adjudication, and other methods of similar sentiment by Legal Aid informal dispute resolution, the Society of Columbus Executive costs of resolving these minor Director Douglas Rogers: "Before disputes--in which attorneys fees the government got into the legal often far outweigh the amount in aid business, private lawyers pro- litigation--could be considerably vided the poor with free help. "111 reduced. 116 This new program, For some unexplained reason, which has not yet received Federal Rogers felt that "times have funding, should be given priority changed," and that these private ahead of programs to fund more lawyers would be more reluctant to costly and formal methods of legal service the poor today. 112 If adjudication. some members of the American Bar Association have their way, attor- neys may not have a choice. A resolution currently under consi- CONCLUSION deration by the ABA would require that lawyers provide a stipulated amount of pro bono work as a con- In considering the role of dition of practice. 113 the Federal government in the pro- Other approaches are possi- vision of Legal Services, there ble. In Sacramento, Democratic are at least two important public State Senator Nicholas Petris of policy questions to be addressed. Oakland introduced a state bar- One of those questions sponsored bill which would allow relates to the inability of many interest on client trust fund ac- Americans, not just the poor, to counts to be used to pay for legal afford to sue because of economic services programs for the poor. constraint. The bill is similar to legislation Contrary to the claims of which has been approved in Legal Services Corporation advo- Florida. 114 cates, there must be some limits In a commencement address to on the degree to which the Ameri- Widener University's Delaware Law can taxpayer, himself unable to School, Presidential Counsellor afford legal services in many Edwin Meese III advocated "a vari- cases, must be required to hire ety of mechanisms such as the lawyers for others. Judicare program in which individ- Another equally, if not more ual lawyers render service and important, public policy question then present their bills to be is whether the fundamental recompensed as in the case of accountability and legitimacy of Medicare." He went on to discuss our political system is undermined -16- by subsidizing a group of advo- cates who, purporting to act in the interests of a class of the public, are accorded a specially subsidized place of influence in the arena of public policy debate. The problems with the Legal Services Corporation can not be cured merely by the designation of a new board of directors, or the selection of a new headquarters staff. The more than 323 organiza- tions which are recipients of Legal Services funds enjoy a pre- sumptive right to refunding which will not be affected by the appointment of Reaganites to vacancies on the Corporation Board. No recipient program can be closed down because of disa- greement with its policy priori- ties, only on the basis of estab- lished violations of an Act which is itself admittedly full of loop- holes. Even when violations occur, procedures are so arcane that it is virtually impossible to single out an abusive grantee for punishment or reform. Nor would the appointment of a new board cure the fundamental structural problem in Legal Ser- vices: the staff attorney system. No degree of regulation can adequately quard against the esta- blishment of secular faith which results when some 17,000 individu- als are given guaranteed annual salaries and authorized to engage in lobbying, litigation, grass roots organizing, media campaigns and the manipulation of Federal resources, to advance their parti- cular notions of what constitutes justice for the public as a whole, or for a particular class. -17- FOOTNOTES ¹Julian P. Boyd (ed.), Papers of Thomas Jefferson (Princeton, N.J.), pp. 545-547. This principle was adopted in 1786 by the Virginia General Assembly, and was incorporated in the First Amendment. 2Alan W. Houseman, Memorandum, December 29, 1980, p. 1. 3In addition, the Consumer Product Safety Commission is authorized to pay "offerors" who assist the Commission in the development of trade regulations. 4Funded groups have included, according to Don Lambro in Fat City, LSC's own National Consumer Law Center ($675,632 from the Legal Services Corporation in Fiscal Year 1980), the Sierra Club, with $6,473,418 in revenue in 1976; the Environmental Defense Fund, Inc., $1,788,309 in 1976; the Natural Resources Defense Council, $2,036,797 in 1976; Consumers Union, with assets of $10,000,000 in 1977 (Ryan K. Falconer, Jr., "Liberal Lobbyists on the Dole," Conservative Digest, October, 1979, p. 10.); and the National Council of Senior Citizens, which received $50,000,000 out of a $52,000,000 budget in Federal funds (Rochelle L. Stanfield, "Defunding the Left' May Remain Just Another Fond Dream of Conservatives," National Journal, p. 1376). 515 U.S.C. §57a(h). 642 U.S.C. $6012. 7MOSt often, Federally financed litigation under this program takes the form of efforts to push for more extensive forms of custodial care for the handicapped. Active lobbying has occurred on behalf of increased funding for handicapped programs and various efforts to increase the responsiblity of the Federal government in this area. 8see, e.g., 42 U.S.C. $6012. 9In Louisiana, for example, despite enactment of the McClure amendment prohibiting "protection and advocacy" monies for the handicapped from being used to lobby the Federal government, recipients of such Federal funding freely conceded to me that they had subsequently engaged in such activities. ¹⁰congressional Record, September 21, 1979, pp. S13138-S13145. Footnotes, continued 11The Food Research and Action Center received from the Community Services Administration $645,000 in the twelve month period which will end 12/1/81, according to Larry Goldberg, Assistant Director for External Affairs Designate, September 11, 1981. 12Bari Schwartz, at a conference of the LSC-funded National Legal Aid and Defender Association (NLADA) in San Juan, Puerto Rico, November 9-14, 1980. 13In re Evans (Soc. Sec. Admin., Bur. of Hearings & App., Sept. 17, 1979). See also Clearinghouse Review, January, 1980, p. 715. See also supra. 14 Two Complaints," The New Republic, February 3, 1979, p. 5. See also supra. 15The 36-page amicus brief was filed on June 7, 1977, by Alice Daniel and James E. Coleman, Jr., on behalf of the Legal Services Corporation. The Regents of the University of California V. Allan Bakke, No. 76-811 (U.S.S.Ct., Oct. term, 1976). See also Congressional Record, June 27, 1977, p. H6540. See also supra. 16In one case in Maine, 350,000 people would have been displaced had the LSC lawyers prevailed with respect to the initially requested remedy. A similar suit brought by the LSC-assisted Wampanoag Tribe asserts ownership of the entire town of Mashpee, Massachusetts, or approximately 17,000 acres. See "Indians on the Lawpath," The New Republic, April 30, 1977, pp. 16-21. See also supra. 17 Shirley Scheibla, "Bar Sinister: The Legal Services Corporation Stretches its Mandate," Barron's, January 24, 1977, pp.5, 12. See also supra. .8Reginald Stuart, "Court to Decide if Black English is a Learning Barrier," New York Times, June 12, 1979. See also supra. 19 Clearinghouse Review, March, 1980, p. 878. See also supra. 20congressional Record, January 31, 1974, p. S1626. 21 Legal Services Act, section 1006(b) (1) (B). 22H. Rep. 93-247, June 4, 1973, P. 12. Footnotes, continued 23 Clearinghouse Review is the Legal Services Corporation's Federally financed in-house organ. According to Linda Perle, Assistant General Counsel of LSC's Washington, D.C. office, Fiscal 1981 funding was $840,000. 24 Clearinghouse Review, December, 1979, p. 603. 25Ibid. 26Houseman, p. 7. 27 'Advocates Want to Stop Prison Boom," The Beacon Hill Update, December 29, 1980, p. 4. The Beacon Hill Update is published by North Shore Community Action Center, Inc. which receives part of its funding from the Community Services Administration. 28 Letter from Acting Comptroller General Milton J. Soclar to Congressman F. James Sensenbrenner, Jr., May 1, 1981, p. 12. 29The fundamental anti-lobbying statute at Federal law is 18 U.S.C. §1913, which seeks to prohibit direct or indirect payment for "any personal service, advertisement, telegram, telephone, letter, printed or written matter, or other device, intended or designed to influence in any manner" any Federal legislation, except by communications to Congress through official channels. This section can be overridden with respect to a particular program by express statutory language to the contrary. Section 1006 (c) of the Legal Services Act makes it unlawful for the Corporation to "undertake to influence the passage or defeat of any legislation," but creates exceptions for legislation directly affecting the Corporation or Corporation testimony at the request of a legislative body or member. Section 1007(a) (5) of the Act makes it unlawful for a Legal Services recipient to lobby, but exempts activity on behalf of the Corporation's affairs, legislatively requested testimony, and activity on behalf of a client. Finally, there is a provision in P.L. 95-431, October 10, 1978, which has explicitly been made applicable to the Corporation's appropriations each year since Fiscal 1979, which states: " Provided, No part of this appropriation shall be used for publicity or propaganda purposes designed to support or defeat legislation pending before Congress or any State legislature." Footnotes, continued Suffice it to say that the exceptions contained in the two Legal Services Act proscriptions are very broad. The ability of the Corporation and its recipients to lobby is, however, not limitless, even under the broadest possible interpretations of its organic statute. All four civil and criminal prohibitions in the act, for instance, would seem to apply to a Washington-initiated effort not directly related to the Corporation's affairs. 30schwartz, infra.: And, make sure that everything is covered, so that we don't have the situations where you don't have the file on a client who you say you're representing and somebody calls this client - that happened to us in Georgia once, where the client said, "I had no idea that somebody was gonna go to the legislature for me. You know, I just knew I'd talked with somebody in the program. Although the criminal penalties specified in the second paragraph of section 1913 deal specifically with "officer(s) or employee( of the United States or of any department or agency thereof," the first paragraph in no way limits the section 1913 prohibition to those personages. Rather, they apply to any person who appropriates his monies for any of the prohibited activities. 31schwartz, infra.: there's around 17 national support centers now, and one of the encouraging developments of the last couple of years - again, as you all know - is that most of the support centers have now opened Washington offices, something that the Corporation has definitely encouraged and supported. All of us, in some way or another, have taken a lot of pains over the last few years to try to nurture the development of major national organizations of low income people around our different substantive issues. So, we relate to national groups as well as to all of your individual clients and state and local client groups. Schwartz, infra.: Every support center has a different mechanism for deciding priorities - for deciding what kinds of issues we're going to work on. A number of us have, over the last couple of years, developed questionnaires. FRAC, for example, sent out a major questionnaire this summer to everyone on our mailing list. We have about 4500 people on our mailing list. And we ask people to write the different Footnotes, continued activities that we work on to - and, when I say activities I mean both substantive issues - we listed every possible substantive issue, generally falling under the rubric of food and hunger. 33pine Tree Legal Services recieved $1,258,577 from LSC in Fiscal Year 1980. 34Schwartz, infra.: The way we've organized ourselves in Maine is you are supposed to call my office - I think Marshall's in the state capital in Maine - you're supposed to call my office - you're supposed to ask for me and I will then get the job done. This is the way we want it done in Maine. That is perfectly fine for us - that helped us out a great deal to know that. And that's the sort of thing you - I encourage you to think through in your states. I also want to make a point about how you can help us out to make people realize in your state that they do make a difference when we put out mailings, which I know you must get several each month from all the support centers - asking local people - local legal services people and clients - to try and get letters coming into Congress on different issues. 35Houseman, pp. 7-9. 36The Atlanta Journal, March 24, 1981, p. 1. 37The Grand Rapids Press, March 11, 1981. 38park River, North Dakota, Press, March 18, 1981. 39Fredericksburg, Virginia, Free Lance-Star, March 7, 1981. 40 Harrisburg, Pennsylvania, News, March 10, 1981. 41 Knoxville, Tennessee, Journal, March 27, 1981. 42 Black Lawyers' Prexy Assails Budget Cuts," Sacramento, California, Observer, March 19, 1981. 43Bernard Weinraub, "Feminist Groups Attack Reagan Budget Cutbacks," New York Times, March 27, 1981. The Native American Rights fund received $238,337 from LSC in Fiscal Year 1980. Footnotes, continued 44 Congressional Record, April 1, 1981, p. S3180. 45Clearinghouse Review, May, 1977, p. 23. The National Consumer Law Center received $675,632 from LSC in Fiscal Year 1980. 46Ibid. 47 Clearinghouse Review, March, 1977, p. 1006. 48Clearinghouse Review, March, 1977, p. 1003. The Contra Costa Legal Services Foundation received $471,158 from LSC in Fiscal Year 1980. 49 Clearinghouse Review, May, 1977, p. 25. 50 Clearinghouse Review, January, 1981, p. 955. 51 Ibid. 52 Stopczynski V. Milliken, No. 45458 (Mich. Ct. App., filed July 17, 1979). Clearinghouse Review, October, 1979, p. 457. The Michigan Legal Services received $317,235 from LSC in Fiscal Year 1980. 53 Doe V. Jennings, No. 79-681D (W.D. Pa., May 23, 1979). Clearinghouse Review, October, 1979, p. 466. Neighborhood Legal Services of Pittsburgh received $1,504,638 from LSC in Fiscal Year 1980. 54Clearinghouse Review, April, 1979, p. 913. Greater Boston Legal Services received $2,285,187 from LSC in Fiscal Year 1980. 55Clearinghouse Review, March, 1979, p. 840. The Legal Assistance Foundation of Chicago received $3,986,657 from LSC in Fiscal Year 1980. 56peck V. Califano, No. C 76 229 (D. Utah, June 30, 1977). Clearinghouse Review, November, 1979, p. 494. Utah Legal Services received $1,002,878 from LSC in Fiscal 1980. 57 Ibid. 58 "Reproductive Freedom Issues in Legal Services Practice, # Clearinghouse Review, November, 1978, pp. 389-403. 59Ibid., p. 403. Footnotes, continued 6099 S.Ct. 3035 (1979). The National Center For Youth Law received $625,158 from LSC in Fiscal Year 1980. 61 Clearinghouse Review, February, 1980, p. 763. 62Houseman, p. 13. 3schwartz, infra. 4Clearinghouse Review, January Supplement, 1979, pp. 601-679. 65 Ibid., p. 641. ⁶⁶Florida Rural Legal Services received $1,969,236 from LSC in Fiscal Year 1980. 67See Frederick Burger, the Miami Herald, March 25, 1981, where Mason is quoted as saying: "What this town needs is a good B-52 strike." 68Hearings on the Legal Services Corporation, Subcommittee on Courts, Civil Liberties and the Administration of Justice, House Judiciary Committee, March 25, 1981. 69 Robert Levey, "Maine Indian land pact becomes law," the Boston Globe, October 11, 1980, p. 19. Scheibla, January 24, 1977, p. 12. "Trial Opening Today Could Decide If Indians Own Land on Cape Cod," New York Times, October 17, 1977. 71walter C. Mehlenbacher, Castile, New York, News Release, undated. 72Bill Winter, "Klan Defense Raises Legal Aid Furor," American Bar Association Journal. "Legal Services Defends Klan," (National Lawyer's) Guild Notes, January-February, 1980. 73Northeast Ohio Legal Services received $496,351 from LSC in Fiscal Year 1980. 74John C. Boland, "Unholy Alliance: Church Groups, Legal Services Corp. Launch Attack on U.S. Steel," Barron's, June 2, 1980, pp. 9, 20-25, 31. 75Marla Carpenter, "Legal Services Agency Faces Fight For Existence, Hickory, North Carolina, Record, March 13, 1981. Footnotes, continued 76 Ibid. 77 Two Complaints," New Republic, p. 5. California Rural Legal Assistance received $4,797,568 from LSC in Fiscal 1980. 78Los Angeles, California, Southside Journal Wave, February 12, 1981. The Legal Aid Foundation of Los Angeles received $3,035,565 from LSC in Fiscal Year 1980. 79 Clearinghouse Review, March, 1980, p. 878 80Filed June 7, 1977, by Alice Daniel and James E. Coleman, Jr., The Regents of the University of California V. Allan Bakke, No. 76-811 (U.S. S. Ct., October term, 1976). 81 Shirley Scheibla, "Bar Sinister-Part II: How the Legal Services Corporation Thwarts the Will of Congress," Barron's, January 31, 1977, p. 20. The Center for Law and Education received $601,472 from LSC in Fiscal Year 1980. 82 Congressional Record, April 1, 1981, p. S3177. 83 Scheibla, January 24, 1977, p. 5. 84william F. Doherty, "Garrity stops King's welfare roll probe," the Boston Globe, April 4, 1979. 85The Migrant Legal Action Program received $565,827 from LSC in Fiscal 1981. 86National Congress of Hispanic American Citizens V. Usery, 554 F.2d 1196 (D.C. Cir. June 1, 1977). Clearinghouse Review, December, 1977, p. 506. 37stuart, infra. 88The Western Center on Law and Poverty of Los Angeles received $1,076,198 from LSC in Fiscal Year 1980, and the San Fernando Valley Neighborhood Legal Services of Pacoima received $922,379 from LSC in Fiscal Year 1980. 89 Scheibla, January 24, 1977, p. 12. 90 Scheibla, January 31, 1977, p. 20. Alaska Legal Services received $1,448,196 from LSC in Fiscal 1980. 91A1 French, "Legal Services' 'struggle for survival, Florida Agriculture, April 1, 1981, p. 2. Footnotes, continued 92Terrence Stutz, "Judge Taylor quits Dallas desegregation suit," the Dallas Morning News, March 21, 1981, p. 1. Dallas Legal Services Foundation received $1,369,509 from LSC in Fiscal Year 1980. 93 Debra P. V. Turlington, 474 F. Supp. 244 (M.D. Florida, July 12, 1979). Congressional Record, November 17, 1980, p. E4956. Bay Area Legal Services received $732,704 from LSC in Fiscal Year 1980. 94In re Evans, infra. Montana Legal Services received $990, 119 from LSC in Fiscal 1980. 95 Stevenson V. Stevenson, No. 79-CA-1588-MR (Ky.Ct.App., Nov. 7, 1979). Clearinghouse Review, January, 1980, p. 686. The Legal Aid Society of Louisville received $1,061,527 from LSC in Fiscal Year 1980. 96Clearinghouse Review, January, 1980, pp. 670-1. 97 Ibid., p. 671. 98s. 1303, §6(a), 95th Congress. This is the current section 1006(b) (1) (B) of the Legal Services Act, which states: (B) No question of whether representation is authorized under this subchapter, or the rules, regulations or guidelines promulgated pursuant to this subchapter, shall be considered in, or affect the final disposition of, any proceeding in which a person is represented by a recipient or an employee of a recipient. A litigant in such a proceeding may refer any such question to the Corporation which shall review and dispose of the question promptly, and take appropriate action. This subparagraph shall not preclude judicial review available under applicable law. 100 The Green amendment, which was enacted in section 1006 (a) (3) of the Legal Services Act, which stated: the Corporation is authorized- (3) to undertake directly and not by grant or contract-- (A) research, (B) training and technical assistance, and (c) to serve as a clearinghouse for information. (Emphasis added) The 1977 amendments explicitly allowed all of these activities to be engaged in by grant or contract. Footnotes, continued 101 Congressional Record, June 13, 1980, pp. S6878-81. 2Schwartz, infra. 103For example, representatives of Welfare Rights Organi- zations from several states sit on the boards of directors of LSC National Support Centers, including the Center on Social Welfare Policy, the National Center on Women and Family Law, the National Health Law Program, and the Nation- al Senior Citizens Law Center. Maggie Kuhn of the Gray Pan- thers is also on the board of the National Senior Citizens Law Center as is a representative of the American Associa- tion of Retired People which receives $40 million per year in Federal funding (according to National Journal, op. cit., p. 1376). Representatives of the Youth Project funded by VISTA during the tenure of its former director Marge Taban- kin, the Mexican American Legal Defense Fund, the Worker Rights Institute, and the United Construction Workers Asso- ciation, all serve on the board of the National Employment Law Project. Alan Houseman, Director of the LSC-funded Research Institute on Legal Assistance, advises in his introduction to the "Information Directory on National Support Projects," that among the principle functions of LSC National Support Centers is "to coordinate and establish networks with other advocate organizations and organiza- tions representing the poor." Margaret E. Wagner, ed., "Information Directory on National Support Projects," (Re- search Institute on Legal Assistance, Legal Services Corp.: 1979). 104 WDVM-TV, Washington, D.C., March 7, 1981, 6:00 p.m. 105In addition to the $321.3 million the Legal Services Corporation distributes to grantees, information aquired by The Conservative Caucus Research, Analysis, and Education Foundation through use of the Freedom of Information Act has indicated that individual grantees have received funds from the Department of Energy, the Federal Trade Commission, the U.S. Department of Housing and Urban Development, ACTION/VISTA, the Community Services Aministration, the Equal Employment Opportunity Commission, and the U.S. Department of Health and Human Services' Office of Civil Rights. 106For an excellent summary of LSC's prodigious growth and recidivism, see Don Lambro, Fat City: How Washington Wastes Your Taxes, (South Bend: Regnery/Gateway, 1980), pp. 332-38. 107 Angel Castillo, "Legal Services Lawyers Descry Plans to Halt Funds," New York Times, March 14, 1981. 108Ibid. Footnotes, Continued 109Gene Blake, "Proposed Budget Cut May Drastically Curtail Legal Aid to Poor," Los Angeles Times, March 15, 1981. 110Ibid. lllMary Carran Webster, "Legal aid attorneys fear cuts will leave poor defenseless," Columbus Citizen-Journal, March 20, 1981, p. 2. The Legal Aid Society of Columbus received $791,291 from LSC in Fiscal Year 1980. 112Ibid. 113see, e.g., the American Bar Foundation news release, "Mandatory Pro Bono Work the Legal Profession's Last Chance to Preserve Its Spirit of Public Service, Speculates an Attorney-Scholar," March 16, 1981. 114Alan Ashby, "Bar Bill Offered To Use Interest For Legal Aid Plans,' the Los Angeles Daily Journal, March 20, 1981. 115pub. L. 96-190, 94 Stat. 17. 116H. Rep. 96-492, September 28, 1979. APPENDIX A NATIONAL SUPPORT CENTER FISCAL YEAR 1980 FUNDING Center for Law and Education Cambridge, Massachusetts $ 601,472 Center on Social Welfare Policy and Law New York, N.Y 691,258 Migrant Legal Action Washington, D.C 565,827 National Center for Immigrants' Rights Los Angeles, Calif. 130,000 National Center on Women and Family Law New York, N.Y 167,500 National Center for Youth Law San Francisco, Calif 625,158 National Clients Council Washington, D.C 550,000 National Consumer Law Center Boston, Mass 675,632 National Economic Development Law Project Berkeley, Calif. 423,669 National Employment Law Project New York, N.Y 520,760 National Health Law Program Santa Monica, Calif 630,061 National Housing Law Project Berkeley, Calif. 740,234 National Legal Aid and Defender Association Washington, D.C 53,000 National Senior Citizens Law Center Los Angeles, Calif. 609,079 National Social Science & Law Center Washington, D.C 317,090 Native American Rights Fund/Indian Law Support Center Boulder, Colo 238,337 APPENDIX B I 97TH CONGRESS 1ST SESSION H.R.3929 To amend the Internal Revenue Code of 1954 to provide a credit for the provision of certain charitable legal services. IN THE HOUSE OF REPRESENTATIVES JUNE 16, 1981 Mr. HYDE (for himself and Mr. ASHBROOK) introduced the following bill; which was referred to the Committee on Ways and Means A BILL To amend the Internal Revenue Code of 1954 to provide a credit for the provision of certain charitable legal services. 1 Be it enacted by the Senate and House of Representa- 2 tives of the United States of America in Congress assembled, 3 That Part IV of subchapter A of chapter 1 of the Internal 4 Revenue Code of 1954 (relating to credits against tax) is 5 amended by adding at the end thereof the following new 6 section: 7 "Sec. 44F. Credit for charitable legal services. 8 "(a) ALLOWANCE OF CREDIT.- 2 1 "(1) GENERAL.-In the case of a qualifying 2 person (as defined in subsection (d)(2)), there shall be 3 allowed as a credit against the tax imposed by this 4 chapter for the taxable year an amount equal to 25 5 percent of the value of charitable legal services (as de- 6 fined in subsection (d)(1)) provided by such person 7 during the taxable year in noncriminal proceedings or 8 matters to an eligible client, other than are described 9 in subsection (b)(3). 10 "(2) AMOUNT.-The value of charitable legal 11 services shall be an amount equal to the reasonable 12 fixed or contingent fee that would have been charged 13 to a similarly situated client paying for such services. 14 "(b) LIMITATIONS.- 15 "(1) GENERAL RULE.-The credit allowed by 16 subsection (a) shall not exceed 30 percent of the 17 liability for tax for the taxable year. 18 "(2) No CREDIT AGAINST CERTAIN TAXES.- 19 The credit allowed by subsection (a) shall not be al- 20 lowed against the tax imposed by section 56 (relating 21 to minimum tax for tax preferences), Section 22 72(m)(5)(B) (relating to 10 percent tax on premature 23 distributions to owner-employees), section 408(f) (relat- 24 ing to additional tax on income from certain retirement H.R. 3929-ih 3 1 accounts), and section 402(e) (relating to lump-sum 2 distributions). 3 "(3) No CREDIT FOR SERVICES PROVIDED TO 4 CERTAIN RELATIVES.-The credit allowed under this 5 section shall not be allowed with respect to charitable 6 legal services provided to an eligible client who bears 7 any of the relationships described in paragraphs (1) 8 through (8) of section 152(a) to the taxpayer, or, if the 9 taxpayer is a professional corporation, to any stock- 10 holder of such corporation, or if the taxpayer is a 11 member of a partnership, to any other member of such 12 partnership. 13 "(4) No CREDIT FOR CERTAIN SERVICES.-The 14 credit allowed under this section shall not be allowed 15 with respect to- 16 "(A) charitable legal services rendered, di- 17 rectly or indirectly, to influence the issuance, 18 amendment, or revocation of any Executive order 19 or similar promulgation by any Federal, State, or 20 local agency, or to undertake to influence the pas- 21 sage or defeat of any legislation by the Congress 22 of the United States, or by any State or local leg- 23 islative bodies, or State proposals by initiative pe- 24 tition, except where— H.R. 3929-ih 4 1 "(i) representation by a qualifying 2 person for any eligible client is necessary to 3 the provision of legal advice and representa- 4 tion with respect to such client's legal rights 5 and responsibilities (which shall not be con- 6 strued to permit a qualifying person to solicit 7 a client, in violation of professional responsi- 8 bilities, for the purpose of making such rep- 9 resentation possible); or 10 "(ii) a governmental agency, legislative 11 body, a committee, or a member thereof re- 12 quests the qualifying person to testify, draft, 13 or review measures or to make representa- 14 tions to such agency, body, committee, or 15 member, or is considering a measure directly 16 affecting the activities for which a credit is 17 allowable under this section; 18 "(B) any political activity, or any activity to 19 provide voters or prospective voters with trans- 20 portation to the polls or provide similar assistance 21 in connection with the election (other than legal 22 advice and representation), or any voter registra- 23 tion activity (other than legal advice and 24 representation); H.R. 3929-ih 5 1 "(C) legal assistance in civil actions to per- 2 sons who have been convicted of a criminal 3 charge where the civil action arises out of alleged 4 acts or failures to act and the action is brought 5 about against an officer of the court or against a 6 law enforcement official for the purpose of chal- 7 lenging the validity of the criminal conviction; 8 "(D) support for or conduct of training pro- 9 grams for the purpose of advocating particular 10 public policies or encouraging political activities, 11 labor or antilabor activities, boycotts, picketing, 12 strikes, and demonstrations, including the dissemi- 13 nation of information about such policies or activi- 14 ties, except that this paragraph shall not be con- 15 strued to prohibit the training of attorneys or 16 paralegal personnel necesary to prepare them to 17 provide adequate legal assistance to eligible 18 clients; 19 "(E) initiating the formation, or organizing, 20 of any association, federation, or similar entity, 21 except that this subparagraph shall not be con- 22 strued to prohibit the provision of legal assistance 23 to eligible clients; 24 "(F) legal assistance with respect to any pro- 25 ceeding or litigation relating to abortion unless H.R. 3929-ih 6 1 such abortion is necessary to save the life of the 2 mother, or support in whole or in part of any 3 legal assistance activity of any attorney in con- 4 nection with any proceeding or litigation relating 5 to abortion unless such abortion is necessary to 6 save the life of the mother; 7 "(G) legal assistance with respect to any 8 proceeding or litigation relating to the desegrega- 9 tion of any elementary or secondary school or 10 school system; 11 "(H) legal assistance with respect to any 12 proceeding or litigation arising out of a violation 13 of the Military Selective Service Act [50 App. 14 U.S.C. 451 et seq.] or of desertion from the 15 Armed Forces of the United States, except that 16 legal assistance may be provided to an eligible 17 client in a civil action in which such client alleges 18 that he was improperly classified prior to July 1, 19 1973, under the Military Selective Service Act or 20 prior corresponding law; 21 "(I) legal assistance for or on behalf of any 22 individual who is known to be an alien in the 23 United States in violation of the Immigration and 24 Nationality Act or any other law of the United 25 States, or convention or treaty to which the H.R. 3929-ih 7 1 United States is a party, relating to the immigra- 2 tion, exclusion, deportation, or expulsion of aliens; 3 or 4 "(J) legal assistance for any litigation which 5 seeks to adjudicate the legalization of homo- 6 sexuality. 7 "(c) CARRYOVER AND CARRYBACK OF UNUSED 8 CREDIT.- 9 "(1) ALLOWANCE OF CREDIT.-If the amount of 10 the credit allowed under subsection (a) for any taxable 11 year exceeds the limitation provided in subsection (b)(1) 12 for such taxable year, such unused credit shall be- 13 "(A) a charitable legal services credit 14 carryover to each of the three taxable years fol- 15 lowing the taxable year during which such unused 16 credit occurs, 17 "(B) a charitable legal services credit carry 18 back to each of the three taxable years preceding 19 the taxable year during which such unused credit 20 occurs 21 and shall be added to the amount allowable as a credit by 22 subsection (2) for such years. 23 "(2) LIMITATION.-The amount of the unused 24 credit which may be added under paragraph (1) for any 25 preceding or succeeding taxable year shall not exceed H 3020-ih 8 1 the amount by which the limitation provided by subsec- 2 tion (b)(1) in such taxable year exceeds the sum of- 3 "(A) the credit allowable under subsection (a) 4 for such taxable year, and 5 "(B) the amounts which, by reason of this 6 subsection, are added to the amount allowable for 7 such taxable year. 8 "(d) DEFINITIONS.- 9 "(1) CHARITABLE LEGAL SERVICES.-The term 10 'charitable legal services' shall mean legal services (in- 11 cluding all ordinary and necessary expenses paid or in- 12 curred with respect thereto for which no deduction 13 under section 162 has been taken by the taxpayer) per- 14 formed by a qualifying person for an eligible client, 15 from which no net earnings accrue to the benefit of 16 such qualifying person. 17 "(2) QUALIFYING PERSON.-The term 'qualifying 18 person' means— 19 "(A) an individual admitted or otherwise au- 20 thorized by law, rule or regulation, to practice 21 law under the laws of any state or the District of 22 Columbia, or 23 "(B) a professional corporation all of whose 24 stockholders are individuals described in subpara- 25 graph (A). H.R. 3929-ih 9 1 "(3) ELIGIBLE CLIENT.-The term 'eligible 2 client' means any person financially unable to afford 3 legal assistance as determined by the Secretary under 4 subsection (e). 5 "(e) ELIGIBILITY GUIDELINES.-The Secretary shall 6 establish, in consultation with the Director of the Office of 7 Management and Budget, guidelines setting maximum 8 income levels (taking into account family size, urban and 9 rural differences, and substantial cost-of-living variations) for 10 eligible clients under this section. Such guidelines shall insure 11 that the eligibility of clients will be determined on the basis of 12 factors which include— 13 "(1) the liquid assets and income level of the 14 client, 15 "(2) the fixed debts, medical expenses, and other 16 factors which affect the client's ability to pay, 17 "(3) the cost of living in the locality, and 18 "(4) such other factors as relate to financial in- 19 ability to afford legal assistance, which may include 20 evidence of a prior determination that such individual's 21 lack of income results from refusal or unwillingness, 22 without good cause, to seek or accept an unemploy- 23 ment situation." H.R. 3929-ih 10 1 SEC. 2. The table of sections for part IV of subchapter 2 A of chapter 1 of the Internal Revenue Code of 1954 is 3 amended by adding the following at the end thereof: "Sec. 44F. Credit for charitable legal services." 4 SEC. 3. The amendment made by the first section of this 5 Act shall apply to legal services rendered after September 6 30, 1981. H.R. 3929-ih MICHAEL E. HAMMOND Michael E. Hammond has served as General Counsel to the Senate Steering Committe since 1978. Previously, he was special Assistant to U.S. Senator Harry F. Byrd, Jr. (I-Va.) and was Legislative Assistant to Senator James L. Buckley (R-C-N.Y.). Formerly a Contributing Editor to Financial World, Mr. Hammond has had his articles published in the Washington Star, the Christian Science Monitor, the Conservative Digest, and Human Events. After graduating magna cum laude from Washington University of St. Louis in 1971, Mr. Hammond attended the New York University School of Law from which he received a Juris Doctor degree in 1975. He was admitted to practice by the bar of the State of New York, the District of Columbia, and by the Supreme Court of the United States. Mr. Hammond was a member of the Reagan Transition Team for both the Justice and Education Departments. The Conservative Caucus Research, Analysis, and Education Foundation (TCCRAEF) is a not for profit 501 (c) (3) research organization which documents the voting records of incumbent Senators and Congressmen, analyzes Federal grants and contracts to non-profit corporations, and reviews U.S. national security policy. Contributions to TCCRAEF are fully tax deductible and there are no limits on how much can be contributed. Nothing written here is to be construed as necessarily reflecting the views of The Conservative Caucus Research, Analysis and Education Foundation or as an attempt to aid or hinder any bill before Congress. 4 e G - e