JUSTICE STUDENT HUMAN RIGHTS NETWORK
CONTENTS
WELCOME
Welcome to the first JUSTICE Student Human Rights Network e-bulletin of 2008. This is an exciting time for the network as we have now announced the details of our first major conference on human rights for students, pupils and trainees, to be held on Saturday 8 March. For a booking form and further information click here. The conference will be hosted by Freshfields Bruckhaus Deringer and is supported by the College of Law and the Guardian. Places are half price for student, pupil and trainee members of JUSTICE - you can receive the discounted rate if you sign up as a new member when you make your booking. If you have any questions about the conference please contact jshrn@justice.org.uk or telephone 020 7762 6422.
This New Year edition of the bulletin has a focus on issues concerning asylum and human rights - this is the subject of both the briefing note and the case note.
The people section contains interviews with two barristers - Susie Alegre and Jessica Simor - both of whom have developed interesting careers in human rights and European Union law.
The bulletin concludes with ways you can get involved with the JUSTICE Student Human Rights Network and with human rights more generally - one of which being writing short articles which we will publish on the network website. We have recently received articles on the definition of public authority under the Human Rights Act 1998 and on the role of the judiciary since the introduction of the Human Rights Act. We will publish original and interesting pieces relevant to the issues covered by the e-bulletin with a maximum word limit of 1500 words. All work remains the property of the author and does not necessarily reflect JUSTICE's opinion. Please email jshrn@justice.org.uk if you are interested.
We hope you
enjoy this edition of the JUSTICE Student Human Rights Network e-bulletin
and as ever welcome your feedback - please email jshrn@justice.org.uk
with any comments or questions. We also hope to see you at our conference
in March!
INTRODUCTION
From
Suzanne Lambert
Barrister and Member of JUSTICE Council and Executive Board
Chair of JUSTICE Student Human Rights Network project
Happy New Year and welcome to the first e-bulletin of 2008.
Reflecting on the last year or so of the network brings a feeling of accomplishment as I look back at what began in the autumn of 2006 as an experiment with a tentative series of e-bulletins and a seminar at the Guardian Newsroom in Farringdon planned. Thanks to speakers such as Rabinder Singh QC, Nicholas Blake QC, Shaheed Fatima, Shaheen Rahman, Jessica Simor and Tom Hickman, and to the continued generosity of the Guardian in allowing us to use their premises, we held six seminars over the eighteen months. Even more importantly, all of those seminars have been extremely well-attended, many attracting in the region of ninety students and trainees, who have willingly given up their Saturdays to come discuss human rights, and some of whom who have travelled to London from as far as Wales and Scotland in order to attend the seminar. Not only does this provide immense encouragement as to the enthusiasm amongst the lawyers of tomorrow for human rights issues, but it also confirms that the network is fulfilling a genuine need, as the numbers of members continue to grow.
So, where to from here? This year, JUSTICE will build on the work of its
50th anniversary celebrations. As part of those celebrations a date has
been set for the long-promised network human rights conference. On Saturday
8 March 2008, the dream of the one-day conference will be realised, thanks
to Freshfields Bruckhaus Deringer,
who will be hosting the conference and thanks to the support provided
by the College of Law and
the Guardian. Through this conference
the network aims to give its members a unique insight into the current
state of human rights law in the United Kingdom, the key areas of argument
and debate, and likely future developments in policy and practice. Break
out sessions will provide opportunities for smaller group discussion and
more interactive involvement and will cover topics ranging from freedom
of expression to freedom of religion, torture and the Iraq War. There
will also be a special session on careers in human rights law. There will
be a small administrative fee of £10, reduced to £5 for those
who are student, pupil or trainee members of JUSTICE or who join when
booking a place on the conference. To see the conference flyer and booking
form click
here. As places are limited, I would encourage you to book early.
Apart from
the conference, we aim to continue with our regular programme of seminars
and e-bulletins and I cannot stress enough how much we want to hear from
you. Please do get in touch with contributions for the e-bulletin or the
network website, ideas about the future of the network, or even if you
would like to request speakers from JUSTICE for any human rights events
that you may be planning, for example. We want to ensure that the network
continues to fulfil your needs so we need to hear from you. Email us at
jshrn@justice.org.uk.
BRIEFINGS
Briefing: Asylum and human rights
Why is asylum a human rights issue?
Although the practice of states granting asylum is very old, the idea of political asylum as a basic right was first expressed in Article 14(1) of the 1948 Universal Declaration on Human Rights, prompted by the experience of those fleeing Nazi persecution in the run-up to and during World War 2.
The 1951 Convention Relating to the Status of Refugees (the Refugee Convention) broadened the criteria under which states would grant asylum to include not just those fearing persecution on traditional political grounds but also those with a 'well-founded fear of being persecuted for reasons of race, religion, nationality, membership of a particular social group'.[1] In particular, the Refugee Convention granted a broad range of specific entitlements to those recognised as falling within its criteria.
Although the international legal framework for the protection of refugees was established in the immediate aftermath of WW2, asylum did not become a significant issue in most Western countries until after the end of the Cold War when the numbers of asylum seekers rose significantly.
This in turn has focused attention on the gap between the rights of foreign nationals under UK law vis-à-vis the rights of UK citizens. Although the Refugee Convention grants a broad range of rights for those recognised by the state as refugees under the Convention, it is largely silent[2] on the position of those applying for refugee status, ie asylum seekers. In the absence of such protection, the provisions of the European Convention on Human Rights (ECHR) by way of the Human Rights Act 1998 has been used to safeguard the rights of asylum seekers.
What are the main human rights issues facing asylum seekers?
Since the early 1990s, asylum seekers in the UK have been made subject to an increasing array of restrictions on basic rights. These include restrictions on the right of asylum seekers to appeal against negative asylum decisions by the Home Office, the introduction of 'fast track' procedures with minimal safeguards against removal, the use of 'non-suspensive' appeals whereby asylum seekers are forced to return to their home country to continue their appeals, the detention of asylum seekers for purely administrative purposes, limitations on access to medical treatment, and - in extreme cases - the removal of income support for food and shelter.
Food and shelter?
Section 55 of the Nationality Immigration and Asylum Act 2002 empowered the Home Secretary to deprive asylum seekers of subsistence support where satisfied that they had failed to apply for asylum 'as soon as reasonably practicable after the person's arrival in the United Kingdom'. When the provision came into force in early 2003, large numbers of asylum seekers were made destitute without money for food or shelter because Home Office officials determined they had failed to apply for asylum within 24 hours of their arrival, regardless of the reason for the delay in each case.
In the 2005 case of R v Secretary of State for the Home Department ex parte Limbuela,[3] the House of Lords upheld the decision of the courts below that the government's policy of waiting until an asylum seeker's destitution had reached the standard of inhuman or degrading treatment before reinstating support was itself in breach of Article 3 ECHR.
How are restrictions on asylum seeker's appeal rights justified?
One of the major problems for asylum seekers is that the European Court of Human Rights has repeatedly held that the guarantees of Article 6 of the European Convention on Human Rights does not apply to asylum decisions, on the basis that the right to asylum is not a 'civil right' within the meaning of Article 6(1) (see eg the judgment of the Grand Chamber in Maaouia v France 5 October 2000).
This has led the government to introduce fast-track procedures, non-suspensive appeals, and restrict appeal rights (see eg the Immigration and Asylum Act 1999, the Nationality Immigration and Asylum Act 2002). Most notoriously, as part of the Asylum and Immigration (Treatment of Claimants, etc) Act 2004, the government tried to include a clause 'ousting' the jurisdiction of the higher courts to judicially review the decisions of the Asylum and Immigration Tribunal. However, this clause was defeated in Parliament following strong opposition from JUSTICE and others, including the Bar Council and the Law Society.
Nonetheless, the replacement of judicial review with a more limited form of statutory review has so far survived legal challenge,[4] although the matter may yet be heard by the House of Lords.
What about the detention of asylum seekers?
Under Schedule 2 of the 1971 Immigration Act, the Home Secretary has the power to detain for a limited period foreign nationals seeking to enter the UK. This power was historically used sparingly but in 1999, the government announced a policy of detaining large numbers of asylum seekers in immigration detention centres for administrative purposes in order to 'fast track' their applications.
In the case of Secretary of State for the Home Department ex parte Saadi (also known as the 'Oakington' case),[5] JUSTICE intervened to argue that the detention of asylum seekers purely for the sake of administrative convenience of the Home Office amounted to a breach of the right to liberty under Article 5 ECHR. Unfortunately the Law Lords held the government's policy of detention was justified under the terms of Article 5(1)(f). The European Court of Human Rights has recently heard an appeal against this decision and judgment is expected shortly.
In the meantime, the use of immigration has greatly expanded since the policy was introduced in 1999 and reports by the Chief Inspector of Prisons frequently attest to poor conditions in immigration detention centres.
How does the Human Rights Act 1998 help protect asylum seekers?
It provides an additional ground of protection, chiefly in relation to removals. Even if an asylum seeker does not qualify for refugee status (due to the relatively narrow grounds of persecution for a Convention reason), the Human Rights Act enables the courts to prohibit removal where an asylum seeker's return to their home country would otherwise result in a 'real risk' of ill-treatment contrary to Article 3 (see the decision of the Strasbourg Court in Soering v United Kingdom) or a 'flagrant breach' of any other Convention right (see the 2004 House of Lords decision in Ullah v Special Adjudicator,[6] in which JUSTICE intervened). In addition, an asylum seeker's family life in the UK may prevent removal but only in the more exceptional cases (see the 2007 judgment in Huang v Secretary of State for the Home Department).[7]
Footnotes
1
See Article 1A(2) as amended by the 1967 Protocol.
back up
2
The Refugee Convention does provide some limited protection, including Article 31 which prohibits states from imposing penalties on refugees who entered the country illegally.
back up
3
[2005] UKHL 66.
back up
4
See eg F(Mongolia) v Secretary of the State for the Home Department [2007] EWCA Civ 769.
back up
5
[2002] UKHL 41.
back up
6
[2004] UKHL 26.
back up
7
[2007] UKHL 11.
back up
Briefings form an important part of JUSTICE's work. To see all our current
work visit the In
The News section of our website.
CASE NOTE
R (on the application of EU (Peru)) v Secretary of State for the Home
Department [2007] EWHC 2530 (Admin)
Facts
The claimant (EU) was a Peruvian national, who applied for judicial review of the Secretary of State's (SS) decisions to refuse further representations from EU and to refuse to treat those representations as a 'fresh claim' under paragraph 346 of the Immigration Rules in force at the time. The issue was whether the SS erred in law when refusing to treat as a fresh claim EU's representations that there was deterioration in his mental health and a consequent risk of suicide if he were removed from the United Kingdom and returned to Peru.
EU had initially applied for asylum in 2001 when he arrived in the UK. He claimed to have witnessed atrocities committed by the Peruvian army and that his daughter had been abducted, beaten and raped, and he himself had been tortured and his house made the subject of an arson attack. His asylum claim was refused and on appeal the Adjudicator dismissed EU's account of his psychological symptoms as not credible and found that some of the documents did not appear genuine. Subsequently, additional medical evidence was provided as to EU's psychological symptoms and representations were made that there was a significant risk of EU committing suicide if he was removed.
The SS refused EU's further representations on the basis that EU had previously fabricated documents and that there was no realistic prospect that an immigration judge would conclude that EU's removal would amount to a violation of his rights under Article 3 of the European Convention on Human Rights (ECHR). EU contended that it was arguable that the threshold had been crossed whereby his removal, on the basis that he was a suicide risk, would amount to a violation of his rights under Article 3 and Article 8 ECHR and that it could not be said that an application before an immigration judge was bound to fail.
Held
In refusing EU's application, Mr Justice Simon explained that, in accordance with the Court of Appeal's judgment in WM (DRC) v SSHD [2006] EWCA Civ 1495, the correct approach for the SS when considering whether fresh representations amounted to a fresh claim was to consider the material and decide whether the new material was 'significantly different' from that already submitted and considered. If the material was significantly different the SS had to consider whether such material, taken together with old material already considered, created a realistic prospect of success in a further asylum claim.
Furthermore, Mr Justice Simon explained that in a case where a suicide risk is identified, the assessment of the prospects of success had to be carried out in accordance with the decision of the Court of Appeal in J v SSHD [2005] EWCA (Civ) 629. In J, a clear distinction was drawn between 'foreign cases' and 'domestic cases'. Foreign cases involved claims that the conduct of the state in removing a person from its territory to another would lead to a violation of that person's ECHR rights in that other territory, rather than claims that the state has violated the applicant's ECHR rights within its own territory. The relevant test was whether there are strong grounds for believing that the person, if returned, faces a real risk of torture, inhuman or degrading treatment or punishment. In relation to foreign cases, the Article 3 threshold was higher than in the context of domestic cases, particularly where the alleged inhuman treatment is not the direct or indirect responsibility of the public authorities of the receiving state, but results from some naturally occurring illness, whether physical or mental.
Therefore, there were two questions to be considered. First, whether the SS had considered that there was a realistic prospect of an immigration judge (applying the test of 'anxious scrutiny') thinking that the applicant might be exposed to Article 3 risks on his return to Peru. Secondly, whether, in considering that question, she had satisfied the requirement of 'anxious scrutiny'.
There was no doubt that the new material produced since the determination had not been previously considered by an immigration judge. Thus, the core issue was the view that the immigration judge might take of it.
First, the evidence of a risk and the degree of that risk of suicide was equivocal in EU's case. Secondly, since the instant case was a 'foreign' case and it was not suggested that the alleged inhuman treatment was the direct or indirect responsibility of the public authority of the receiving state, there was a particularly high threshold for the level of the severity of treatment that EU would suffer if removed. Thirdly, there was no allegation of a significant risk of suicide in the United Kingdom. It was appropriate to take into account the material relating to the risk in Peru, but that risk fell to be assessed in the light of all the material available to the SS about the availability of treatment there. That material provided support for the conclusion that there was treatment in Peru. Fourthly, the SS was entitled to question EU's credibility and to take the view that his psychological symptoms did not explain the fabrication of documents with the intention to deceive to which the Adjudicator referred.
In relation to issues arising under Article 8, the threshold for establishing a breach of Article 8 in mental health cases is very high (see Razgar v SSHD [2004] 2 AC 368). Therefore, where Article 8 rights are invoked in relation to an applicant's mental health and/or risk of suicide, they were very unlikely to succeed where a claim under Article 3 was not made out. The SS considered the claim based on Article 8 in detail and was, on the basis of the test in J, entitled to conclude that EU's representations did not amount to a 'fresh claim', as they did not have a realistic prospect of success before the asylum and immigration tribunal.
Comment
In relation
to foreign cases, the Article 3 threshold was higher than in the context
of domestic cases, particularly where the alleged inhumane treatment is
not the direct or indirect responsibility of the public authorities of
the receiving state, but results from some naturally occurring illness,
whether physical or mental. The threshold for establishing a breach of
Article 8 in mental health cases was very high and where Article 8 rights
were invoked in relation to suicide, they were unlikely to succeed where
a claim under Article 3 was not made out.
Top
PEOPLE
Susie Alegre
How did you get into law? Did you take it as a subject at university?
No. I did French and Philosophy. After my degree, I went to Spain for two years, first teaching English and then working as an interpreter and researcher at an international conflict resolution research centre based in San Sebastian, Gernika Gogoratez. As part of that work, I was a research assistant for a comparative project on the early release of politically motivated prisoners run by the Northern Ireland Association for the Care and Resettlement of Offenders. This was presented to Parliament as a contribution to the Northern Ireland peace process. As a result of this work, I decided that I wanted to study law with a view to being able to put human rights and conflict resolution theories into practice.
So you came back to London?
Yes. I got onto the last common professional examination course that was available. Then I did two years of straight study, following with the Bar Vocational Course.
Then what did you do?
I tried for pupillage but did not get it. Instead, I applied to do a 'stage' at the European Commission. I got this and it was accepted as my 'second six' months pupillage. So I did the 'second six', before the first. I followed the time at the Commission with a three month 'stage' at the Directorate of Legal Affairs of the Council of Europe before coming back to do my first six pupillage in London.
So, you would recommend the experience of stages to anyone wanting to develop a human rights career?
Yes, absolutely. And not necessarily just in human rights. Those tend to be oversubscribed but other areas of work can be very interesting and have considerable human rights implications. Both my stages were on international cooperation in criminal law and extradition.
And after pupillage…
Because I had got some experience with extradition law, I went to Raymond Buildings, a specialist international criminal law practice. I did a third 'six' there and then squatted. After 18 months, I took a break, doing some freelance translation; went to Mexico; travelled; set up a small NGO to help rural and indigenous people in Mexico and then, finally, came back to London.
To a job with us at JUSTICE.
Yes. I was working on the human rights implications of EU criminal justice developments, especially the European arrest warrant. I started just after 9/11 so it was an interesting time. There was a flurry of counter-terrorism initiatives in the EU. So, I did a lot of lobbying in the EU and the UK; research; interviews; public speaking; looking at implementation of EU policies here in the UK. I wrote a book together with Marisa Leaf who succeeded me in the post when I left. I was very lucky to work with great interns.
And after us…
I went to Amnesty International's EU office in a new programme to focus on human rights in the EU. It was based in Brussels. I continued to work on criminal justice issues and the broader matters like the establishment of the Fundamental Rights Agency, discrimination and developments around the EU reform treaty. I also wrote a report on EU activities in counter-terrorism.
And from there?
I went to Warsaw to work for the Organisation for Security and Co-operation in Europe (OSCE) in its Office for Democratic Institutions and Human Rights (ODIHR). This gave me the link in my work between human rights and counter-terrorism that I sought when I decided to be a lawyer.
So you enjoyed the OSCE?
Yes. I was working with really interesting and dedicated people. I really enjoyed working on the inside, talking directly to those involved in, and responsible for, counter-terrorism in places like Kyrgyzstan, Kazakhstan and Azerbaijan.
You did that for a couple of years?
Yes. I left at the end of my contract. I wanted to move on from Warsaw and to explore other regions and make better use my languages. I decided to become a freelance consultant which is what I had always wanted to do, so I decided to give it a go.
And what kind of work do you do?
A lot of training; justice capacity building in places like Rwanda and Turkey. Also policy and background publications. All for a range of organisations including the Foreign and Commonwealth Office, the UN and NGOs.
So, very varied.
Yes. Very. Which is what I really love.
How do you think that the legal world has changed?
When I was
studying and applying for pupillage, I was told that I should be doing
EU competition law because I had French and Spanish. There was no need
for languages in criminal law. In the last ten years, both criminal and
human rights law have become increasingly international. Every country's
human rights and criminal justice system depends on the countries with
which it co-operates. Law has become increasingly globalised and the range
of work correspondingly broader. There is a lot of very interesting work
to be explored.
Jessica Simor
Matrix Chambers
Did you do law at university?
No. Geography. I was interested in environmental matters. I thought about environmental sciences and then the law. I went to City University to do the CPE and then did the Bar Vocational Course. I chose a chambers doing EU work, Monckton, on the basis of an interest in both policy and the environment. I ended up doing quite a lot of environmental and EU competition law.
You stayed on at Monckton as a tenant?
Yes - I planned on the basis that I would not be taken on, so had organised a 'stage' in the environmental directorate of the European Commission in Brussels for six months immediately following my pupillage but then got taken on. Monckton were happy for me to go and then I stayed for a further period at their annex in Brussels, doing some competition work and some environmental work for the Commission. Then, I came back to London to practice.
What sort of work did you do?
The same stuff as before - EC law, competition law, public law. In 1995, I went to work in the Commission for Human Rights in Strasbourg. Colleagues thought that it was not a good idea because it came just at the time that I was building my practice. But I went all the same because I was getting really interested in human rights and frankly, life's too short to miss out on such opportunities. I did 14 months at the Commission (which of course has since been merged with the Court of Human Rights) and worked on the UK human rights cases. It was great. I loved it. Then, I was offered a job in Sarajevo in an organisation that had been set up under the Dayton Accords - the Human Rights Ombudsman. I went there for seven months.
What kind of work were you doing?
The European Human Rights Convention was implemented as a result of Dayton. Most of the work was about property rights but I also did a report on the Mostar shootings and did a couple of hearings before the Chamber of Human Rights. After that, the question was whether to stay on the international circuit and do something like working on Rwanda or to come home to England.
So you came back?
Yes. I decided to settle here, though I was attracted to wandering for a bit longer, I felt I had to return to build a 'home life'. I wrote a significant and critical article about the Ombudsman's office in Bosnia, which took a lot of thought and was at that time very important to me, as the whole experience had been quite eye-opening. It was published in the European Human Rights Law Review. Ben Emerson then asked me to write a book with him and we went on to write what became a looseleaf: human rights practice, for which I took another six months off practice. This was in 1998-9 after the Human Rights Act had been passed but before it came into effect in October 2000. There were not many people at that time who knew very much about and there was a fairly small group who got to know each other quite well. That led to us founding Matrix in 2000.
How easy was it for you to start up in new chambers?
I was alright. I had some interesting work already and I had done some big cases. Most of us had quite established practices. However, I had children in 2002 and 2004 and that did affect my practise, albeit temporarily, as I took 8 months off for my first child and a year for my second.
What sort of human rights cases have you done since you came to Matrix?
All kinds. I feel the most significant case in the domestic courts, for me, has been a case about a prisoner who died in custody as a result of an asthma attack because of poor medical treatment (R Wright and Bennett v SSHD [2001] EWHC Admin 520). This was the first case in which the government has ever been ordered to carry out a public inquiry. I was also in the latest case on the meaning of 'public authority' (YL v Birmingham City Council 2007 UKHL 27) where, as you know, I acted for JUSTICE, Liberty and the British Institute of Human Rights in their joint third party intervention, having acted for the claimant in the Johnson case in the Court of Appeal. I am currently doing a lot of work in relation to human rights issues that arise in relation to Iraq, in the context of both British soldiers and their treatment by the military and Iraqi citizens.
What would you say are the outstanding legal issues to be decided in relation to human rights?
There remain major jurisdictional issues. I don't think that the cases of Al-Skeini ([2007] UKHL 26) and Al-Jedda ([2007] UKHL 58) have, by any means, sorted out all the points that arise in relation to British troops in Iraq. I am particularly interested in the rights of British soldiers - for example, to medical care, equipment and so on. I think these raise really interesting issues about jurisdiction.
There is another, related matter - which is not really directly about human rights but also concerns access to justice. To challenge EU legislation, you need to show 'a direct and individual concern'. This is very narrowly construed and it is practically impossible to get standing to challenge secondary legislation. In effect, judicial review of EU legislation is severely limited. In that important context, I think there is a real lack of access to justice. Access to justice is also of course, in practice, very affected by the availability of legal aid and the proposed reforms.
And the outstanding political issues?
I think there will always remain the issue of the sovereignty of Parliament and whether we really want it to be able to decide that it can limit our rights. Until we have a written constitution with a Constitutional Court that can strike down legislation, it will always be an issue. But in a way that's not an issue that politicians are likely to be very interested in. The important live political issues are for me more about inequalities in means and opportunity than about legal rights. Those inequalities seem to be increasing not decreasing and rights legislation appears to have no impact on that. I think, with all its faults, our administrative court does keep the executive in check and ensure that all are subject to the rule of law. The recent Munby decision in the SK case, is a fine example.
WHAT YOU CAN DO
1. Come to our conference!
Saturday
8 March 2008
Human Rights Law: Today's issues for tomorrow's lawyers
Saturday 8 March 2008
Hosted by Freshfields Bruckhaus Deringer and supported by the College
of Law and the Guardian
£10 fee (£5 to JUSTICE student, pupil and trainee members)
Click here for conference
flyer and booking form
2. Write something for the student human rights network.
We have recently received articles on the definition of public authority under the Human Rights Act 1998 and on the role of the judiciary since the introduction of the Human Rights Act.
If you would like to have your work on the website please email jshrn@justice.org.uk.
We will publish original and interesting pieces relevant to the issues covered by the electronic bulletin. Maximum word limit of articles 1500 words. All work remains the property of the author and does not necessarily reflect JUSTICE's opinion.
3. Join JUSTICE as a student/pupil/trainee member.
See http://www.justice.org.uk/supportus/becomemember/index.html for further information.
4. Take an internship.
The Human Rights Lawyers Association runs a bursary scheme to assist students who wish to undertake a human rights internship in the summer of 2008. For more information click here.
For details of JUSTICE's summer internship programme click here. Please note that interns undertake in-depth legal research in a particular area of JUSTICE's work. For this reason we are now seeking applications from law graduates only. This includes people who expect to have completed a law degree or conversion course by the time they start their internship.
5. Get involved in JUSTICE's student human rights network.
We intend to develop the network as a way of bringing together and encouraging students, trainees and pupils interested in human rights. We will send out three bulletins a year by email.
To join or contact us about anything to do with the network:
email jshrn@justice.org.uk
We want to
make the network as participatory as possible. If you would like to participate
in a virtual advisory committee then also tell us.
You are welcome to use the information in this website but must attribute
the source to JUSTICE in any written work
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do not bear responsibility for the content of external websites