STUDY NOTE Fighting Like Cats and Dogs: The Rising Number of Custody Battles Over the Family Pet T. Christopher Wharton * INTRODUCTION Forget the phrase ―man‘s best friend.‖ Today, household pets enjoy increasing prevalence as ―non-human members‖ of the modern American family. 1 Currently, when families decide to separate, pets are classified as chattel—―no different from the silverware, the plasma TV, and the living-room sofa‖—a classification which seems rigid, antiquated, and ill-equipped to deal with pet custody issues.2 The legal status of pets as mere items of personal property must adapt to meet the evolving status of pets in modern American society. This note proceeds in five parts. Part I introduces the conflict between the importance of pets in society and their current legal status. Parts II and III will then review the issues presented in several historic and modern pet custody trials. Finally, Parts IV and V analyze recent changes in animal law and how these changes may help future pet custody disputes. II. ―LETTING THE CAT OUT OF THE BAG‖ THE CONFLICT BETWEEN P ETS‘ STATUS IN SOCIETY & IN THE LAW According to a survey conducted by the American Animal Hospital Association, eighty-three percent of pet owners referred to themselves as ―mom‖ or ―dad.‖3 The American Veterinary Medical Association (AVMA) found that of the millions of pet owners in this country, nearly half considered their pets to be full-fledged ―family members.‖4 The Animal Legal Defense Fund (ALDF) reported that forty-five percent of the ―dog guardians‖ they surveyed take their pets with them on vacations. 5 ALDF also states, ―[i]f stranded on a desert island, more than fifty percent of companion animal guardians would prefer the company of their cat or dog to that of another human‖ and almost the same amount of respondents stated they would be ―‗very likely‘ to risk their lives for their animal.‖6 * Junior Staff M ember, Journal of Law & Family Studies; J.D. candidate 2009. 1 Joyce Tischler & Bruce Wagman, Lawyers Must Plan for More Pet Custody Cases, A NIMAL LEGAL D EF. FUND , Aug. 18, 2006, www.aldf.org/news/details.php?id=192. 2 Jane Porter, It can be a Regular Dog Fight; Family Pets Involved in a Growing Number of Custody Cases, HARTFORD COURTANT, July 10, 2006, at D1. 3 Id. 4 A M. VETERINARY M ED . ASS‘N , U.S. PET OWNERSHIP & D EMOGRAP HICS SOURCEBOOK (2007), available at http://www.avma.org/reference/marketstats/sourcebook.asp. 5 Tischler & Wagman, supra note 1, at 1. 6 Id. 433 434 JOURNAL OF LAW & FAM ILY STUDIES [Vol. 10 For some, this may seem surprising or even a bit waggish, but the elevated status of pets is increasingly evident; think family portraits that feature Fido, the dog, and specially made Christmas stockings for Sox, the cat. Local ―dog parks‖ are gaining ground in the nation‘s metropolitan and suburban areas.7 ―Cat condos‖ and other cat furniture can be custom-made and designed ―not only for the cat but also for the discriminating homeowner.‖ 8 A press release from the American Pet Products Manufacturers Association (APPMA) revealed that the amount of ―pet spending has more than doubled from $17 billion in 1994 to an estimated $38.4 billion in 2006.‖9 The same source went on to state that according to Bob Vetere, president of APPMA, ―a continued trend in the humanization of pet products‖ is expected to increase industry spending in the future.10 In addition, there are companies offering pet health insurance, specialists offering advice on pet psychology, even pet chaplains and ministries that offer bereavement resources and pet funeral services.11 These and an expanding list of other examples illustrate just some of the efforts pet owners are willing to undertake. But as different segments of society begin to recognize and accommodate the deep, quasi-familial relationship shared by people and their pets, in the eyes of the law, pets are still just personal property. 12 III. ―SOM EWHERE BETWEEN A CHILD AND CHATTEL‖ A HISTORICAL CONTEXT OF THE LEGAL STATUS OF P ETS For thousands of years, domesticated animals have been considered personal property.13 In American jurisprudence, the Supreme Court articulated this view in 1897 in Sentell v. New Orleans & C.R. Co., stating that ―[b]y the common law, as well as by the law of most, if not all, the states, dogs are so far recognized as property.‖14 And, with few exceptions, this ancient doctrine remained unquestioned for another century. 7 See AM. KENNEL CLUB, ES TABLISHING A DOG PARK IN YOUR COM MUNITY , 1–3 (July 2004), available at http://www.akc.org/pdfs/GLEG01.pdf. 8 See Sitting Pretty Kitty Cat Furniture and Cat Trees, http://www.sittingprettykitty.com (last visited Jan. 25, 2008). 9 Press Release, American Pet Products M anufacturers Association, Pet Spending at All Time High (M ar. 23, 2006), available at http://www.appma.org/press_releasedetail.asp?id=84. 10 Id. 11 See, e.g., Liz Pulliam Weston, Should You Buy Pet Insurance?, M SN MONEY (Apr. 2008), available at http://articles.moneycentral.msn.com/Insurance/AssessYourNeeds/ShouldYouBuyPetIns urance.aspx (stating that ―[w]ith vet bills soaring and fancy new treatments available, it‘s an option more owners are considering‖); see also Camille Chatterjee, Talk to the Animals, PSYCHOL . T ODAY (M ar. 1999), available at http://psychologytoday.com/articles/pto-19990301-000016.html (discussing the rising popularity of pet therapy books and experts); Laura Leslie, Chaplains Ease the Loss of Four-Legged Family, NPR broadcast (M ar. 20, 2006), available at http://www.npr.org/templates/stor y/story.php?storyId=5290121 (reporting on ―a new breed of minister who specializes in helping bereaved pet owners‖). 12 Drake Bennett, Lawyer for the Dog, BOSTON G LOBE , Sept. 9, 2007, at 1D. 13 Id. 14 Sentell v. New Orleans & C.R. Co., 166 U.S. 698, 701 (1897). In Sentell, the Supreme Court stated: 2008] CUSTODY BATTLES OVER THE P ET 435 Ten years ago, a claim asserting a quasi-parental right to shared custody of the family dog would have been laughed out of court. 15 But this is not to say that pet custody cases were completely non-existent.16 In the 1944 case of Akers v. Sellers, a recently divorced couple battled over the custody of their Boston Bull Terrier, arguing the case up to the Appellate Court of Indiana. 17 In a surprisingly progressive and considerate opinion, the Chief Judge vowed to approach the case with ―full realization that no man can be censured for the prosecution of his rights to the full limit of the law when such rights involve the comfort derived from the companionship of man‘s best friend.‖18 More recent cases, however, suggest the changing status of pets as more than just man‘s best friend. 19 Another landmark decision came in the 1981 case Arrington v. Arrington, where a Texas appeals court reviewed a custody decision involving ―Bonnie Lou,‖ a ―very fortunate little dog with two humans to shower upon her attentions and genuine love frequently not received by human children from their divorced parents.‖20 The case is particularly noteworthy for upholding Mrs. Arrington‘s designation as the ―managing conservator‖ with ―reasonable visitation‖ rights granted to her husband—an arrangement traditionally reserved for children.21 Nevertheless, within the context of more modern pet custody cases, the distinction between pets and children is increasingly blurry. They are not considered as being upon the same plane with horses, cattle, sheep, and other domesticated animals, but rather in the category of cats, monkeys, parrots, singing birds, and similar animals, kept for pleasure, curiosity, or caprice. They have no intrinsic value, by which we understand a value common to all dogs as such, and independent of the particular breed or individual. [. . .] While the higher breeds rank among the noblest representatives of the animal kingdom, and are justly esteemed for their intelligence, sagacity, fidelity, watchfulness, affection, and, above all, for their natural companionship with man, others are afflicted with such serious infirmities of temper as to be little better than a public nuisance. Id. 15 Bennett, supra note 12, at 1D; Porter, supra note 2, at D1. 16 Tischler & Wagman, supra note 1, at 1. 17 Akers v. Sellers, 54 N.E.2d 779 (Ind. App. 1944). 18 Id. at 779. 19 In Nahrstedt v. Lakeside Village Condominium Ass‘n., 8 Cal. 4th 361, 390 (1994) the court stated: [T]he value of pets in daily life is a matter of common knowledge and understanding as well as extensive documentation. [. . .] Those who suffer from serious disease or injury and are confined to their home or bed experience a therapeutic, even spiritual, benefit from their presence. Animals provide comfort at the death of a family member or dear friend, and for the lonely can offer a reason for living when life seems to have lost its meaning [. . .]. Single adults may find certain pets can afford a feeling of security. Families benefit from the experience of sharing that having a pet encourages. 20 Arrington v. Arrington, 613 S.W.2d 565, 569 (Tex. Civ. App. 1981). 21 Id. 436 JOURNAL OF LAW & FAM ILY STUDIES [Vol. 10 IV. ―EVERY DOG HAS HIS DAY. . . IN COURT ‖ THE RISE OF P ET CUSTODY TRIALS While pet custody disputes still represent a small niche within the legal profession, the Los Angeles Times reported a ―hundredfold increase‖ in these cases since 1990. 22 This noticeable trend has generated interest from legal practitioners, eager to debate the issues raised in pet custody cases, as well as media commentators, eager to deliver the scoop to the pet-loving public. A. Pet Peeves: The Legal Issues Presented In Pet Custody Litigation In the 1993 case Bennett v. Bennett, the divorcing couple agreed to the stipulations of a Florida district court‘s judgment of dissolution in all areas except one: possession of the dog, ―Roddy.‖ 23 Following a hearing in which the husband asserted his claim to the dog as a ―premarital asset,‖ the trial judge granted possession of Roddy to Mr. Bennett.24 However, sympathetic to the wife, the court also granted visitation rights to Ms. Bennett every other weekend and every other Christmas.25 Both parties filed a series of motions contesting the court‘s decision. 26 On appeal, the court reversed the decision-holding that Roddy was personal property subject to state‘s equitable distribution statute.27 Even though the appellate court recognized that ―a dog may be considered by many to be a member of the family,‖ it firmly held there was ―no author ity which provides for a trial court to grant custody or visitation pertaining to personal property.‖ 28 The appellate court went on to state: While several states have given family pets special status within dissolution proceedings, we think such a course is unwise. Determinations as to custody and visitation lead to continuing enforcement and supervision problems (as evidenced by the proceedings in the instant case). Our courts are overwhelmed with the supervision of custody, visitation, and support matters related to the protection of our children. We cannot undertake the same responsibility as to animals. 29 22 Sanjiv Bhattacharya, To Love, Honor and Belly Scratch: Marriages Come and Go But Judging by the Number of Rising Pet-Custody Disputes, Some Passions Endure, L.A. T IMES M AG ., Jan. 9, 2005, at 20. 23 Bennett v. Bennett, 655 So.2d 109, 110 (Fla. Dist. Ct. App. 1995). 24 Id. 25 Id. 26 M r. Bennett refused to comply with the ruling and requested an immediate rehearing. Id. M eanwhile, M s. Bennett requested a custody transfer or a change in the visitation order. Id. After the court rendered final judgment in favor of M s. Bennett‘s requested visitation changes, M r. Bennett appealed the decision. Id. 27 Id. 28 Id. 29 Id. at 110–11 (internal citation omitted). 2008] CUSTODY BATTLES OVER THE P ET 437 The court‘s decision in this case may seem callous in light of the parties‘ emotional connection to Roddy. However, in this case, the law could not abide the trial court‘s ruling. As the appellate court concluded, ―[w]hile the trial judge was endeavoring to reach a fair solution under difficult circumstances, we must reverse [and remand] pursuant to the dictates of the equitable distribution statute.‖ 30 Courts in other jurisdictions have adopted an attitude similar to the Florida Court of Appeals in Bennett—that unequipped laws and overstrained divorce court dockets simply cannot accommodate complex, drawn-out pet custody litigation. 31 B. Copy Cat: The Similarities Between Pet Custody and Child Custody Cases Another theme arising in many pet custody cases are pleas asking the court to consider ―what is in the animal‘s best interest‖—an inquiry usually reserved for child custody litigation. 32 In Zovko v. Gregory, two former roommates were at odds over the custody of their cat, ―Grady.‖ 33 The court found that the happiness of Grady ―took priority‖ over the property rights asserted by both parties. 34 In a rare departure from the strict personal property considerations typically taken by courts, the Virginia trial court ruled that it was in the ―best interest of Grady‖ to grant custody to the non-owner roommate.35 The Alaska Supreme Court case Juelfs v. Gough provides another example of courts placing the interests of the pet before the property interest of the owners. 36 In Juelfs, the court upheld the former husband‘s sole custody of ―Coho,‖ the family‘s Labrador retriever, after arguments that the wife‘s other dogs threatened the Labrador‘s life. 37 The court determined that the dog was not safe at the wife‘s residence.38 In considering the best interests of the pet, some litigants offer expert testimony from animal behaviorists, pet care professionals, and even the local veterinarian. Dr. Amy Marder, a veterinarian practicing in Lexington, Virginia has been asked several times to assess which divorcee would be a better parent for the pet.39 But before providing testimony, specialists like Dr. Marder have to conduct a ―proper evaluation,‖ which includes an hour and a half consultation with the pet and its owners.40 For instance, Dr. Marder ―asks the owners a barrage of questions: which of the two spends more time with the animal, who plays with it more, who 30 Id. at 111. 31 Pat Shellenbarger, Do Dogs Belong in Divorce Court, GRAND RAP IDS PRESS, Jan. 11, 2008, at A1. 32 ―[A]pparently for the first time in the [United States], a judge in Tennessee appointed a guardian ad litem to look out for the interests of a dog that is the subject of a highly emotional battle between a divorced couple.‖ Terry Carter, Beast Practices, 93 A.B.A. J. 39, 39 (Nov. 2007) (discussing In re Estate of Ronald W. Callan Jr., No. D-2252, (Shelby County Probate Court 2007)). 33 Zovko v. Gregory, No. CH 97-544 Arlington County (Va. Cir. 1997). 34 Id. 35 Id. 36 Juelfs v. Gough, 41 P.3d 593 (Alaska 2002). 37 Id. at 595. 38 Id. 39 Bennett, supra note 12, at 1D. 40 Id. 438 JOURNAL OF LAW & FAM ILY STUDIES [Vol. 10 feeds it. She asks about the pet‘s upbringing, its temperament, how much it exercises.‖41 After Dr. Marder has completed her examination, she analyzes the situation using ―the same sort of considerations that would go into deciding a child-custody case.‖42 The final recommendation is based on which party is likely to be a better caretaker, as well as which party seems to have a stronger connection with the pet.43 The only alternative in deciding which party shares a stronger bond with the pet is a so-called ―calling contest.‖44 In these somewhat arbitrary and often cruel productions, the parties meet at a neutral location, stand at equal opposing distances, and call to the animal to see who it goes to first. Consider this description of one such contest: As the vet brings Lemons in, both wife and husband spring to life, both of them calling and patting their knees. ―Here girl! Come on Lemons!‖ The poor creature looks confused for a moment. Then he bounds over to the wife. It‘s settled—Lemons apparently has a greater emotional bond with her. Such is the force of these calling contests that ultimately, in an out-of-court settlement two months later, she will be awarded full custody of the dog. In return she will compensate her ex with $1,200. 45 Dr. Marder does not approve of calling contests,46 and considering the tactics that some parties are willing to employ, it is difficult to disagree. ―For a couple of days beforehand, [the dog] has to stay with a third party so that nobody has an unfair advantage, which you would if you fed the dog that morning.‖ 47 Competing callers have also been known to use more deceptive tactics such as rubbing their hands with sausage.48 ―That‘s why you need the vet there, to check their hands.‖49 Elaborate measures to ensure the fairest possible calling contest, coupled with the questionable results it can potentially produce, make it easier to understand why parties may seek the analysis from pet experts. And considering the recent strides regarding the parent-child type relationship many owners have with their pets, ―the concept of what‘s best for the child could transfer over to what‘s best for the pet.‖50 41 Id. 42 Id. 43 Id. 44 Id. 45 Bhattacharya, supra note 22, at 20. 46 Bennett, supra note 12, at 1D. 47 Id. 48 Bhattacharya, supra note 22, at 20. 49 Id. 50 Chris Duke, Custody Battles Can Involve Pets, BOULDER D AILY CAMERA , Dec. 7, 2007, available at http://www.dailycamera.com/news/2007/dec/07/custody -battles-can-involve-pets/. 2008] CUSTODY BATTLES OVER THE P ET 439 C. The Bark Is Worse Than The Bite: Media Attention In Pet Custody Cases Adding to the umbrage felt toward pet custody cases is the fact that while pet custody cases have recently gained substantial media attention, these cases are often profiled for entertainment value rather than legal merit. In Assal v. Kidwell, the parties were back in court two years after their divorce, fighting over the custody of a Keeshond dog named ―Sable.‖ 51 After the former wife spent approximately $20,000 to maintain custody of Sable, the court granted visitation rights to the former husband. 52 The battle finally ended when a Maryland circuit court judge threatened to sell the dog and split the profit if the parties could not reach a workable visitation agreement. 53 In Raymond v. Lachmann, ―Lovey,‖ an ailing ten-year-old cat, became the subject of a fierce battle between two former roommates. 54 The New York appellate court couched their reasoning with ―cognizan[ce] of the cherished status accorded to pets in our society,‖ but the court was quick to shoo the case away based on its own ―limited ability to resolve [pet custody cases] satisfactorily.‖ 55 Although Assal and Raymond received a fair amount of notoriety, the 2000 ―Perkins Case‖ is perhaps the most infamous pet custody dispute. 56 In this case, an affluent San Diego couple launched an all-out war over the custody of ―Gigi,‖ a little dog who reportedly took up half of the Perkins‘ three-day divorce trial.57 Throughout the course of the litigation, Ms. Perkins allegedly invested some $146,000 in the case to finance, among other things, a ―canine bonding‖ study conducted by a professional animal behaviorist and a video about the dog titled ―A Day in the Life [of Gigi].‖58 V. ―THE TAIL WAGGING THE DOG‖ RETHINKING THE LEGAL STATUS OF P ETS In response to the rise in pet custody cases—and animal law in general—the legal community outside the courtroom is encouraging law students and lawyers to rethink the way animals are classified under the law.59 In 1986, the first animal law 51 Assal v. Kidwell, Civil No. 164421 (M d. Cir. Ct., M ontgomery Cty. Dec. 3, 1999) [closed records]. For a more in depth case history see Assal v. Kidwell court records available at M aryland Judiciary Case Search, http://casesearch.courts.state.md.us/inquiry/inquiry -index.jsp (select ―Circuit Court Judgment and Liens‖ hyperlink; enter Assal into partyname searchbox; select ―M ontgomery County‖ from the county dropdown menu; click twice on case number 9286FL) (accessed Jan. 25, 2008); Sally Kalson, In Pet Custody Battles, Courts Treat Animals as Property, PITTS BURGH POST- GAZETTE , June 25, 2006, at E7. 52 Kalson, supra note 51, at E7. 53 Id. 54 Raymond v. Lachmann, 264 A.D.2d 340, 340–41 (N.Y. App. Div. 1999). 55 Id. at 341. 56 See, e.g., Bennett, supra note 12, at 1D; Bhattacharya, supra note 22, at 20; Alex Roth, It’s a Dog-Eat-Dog Battle in Court for Pet Custody, SAN DIEGO U NION T RIB., M ay 29, 2000, at A1. 57 Kalson, supra note 51, at E7. 58 Id. 59 See, e.g., Porter, supra note 2, at D1. 440 JOURNAL OF LAW & FAM ILY STUDIES [Vol. 10 course was taught at Pace University Law School. 60 Now, as many as ninety-five law schools across North America offer courses or study groups on animal law, many of which include segments on pet custody. 61 Some law schools even provide resources for students to specialize in animal law with co-curricular resources like the Animal Legal and Historical Center at Michigan State University College of Law and the Animal Law Review at Lewis & Clark Law School. 62 The resources for animal law advocates are also becoming more widely available. The ALDF boasts over one hundred Student Animal Legal Defense Fund chapters scattered across the United States and Canada.63 Beginning in 2001, a foundation started by Bob Barker (television personality and long-time animal rights advocate) has provided several one million dollar grants for animal law courses, workshops, and scholarships to students at Harvard, Columbia, Duke, Georgetown, Northwestern, Stanford, and the University of California at Los Angeles (UCLA).64 Such targets ―suggest that Barker wants to create an influential animal law community of legal professionals.‖ 65 Indeed, the emergence of animal law professionals is becoming evident among practicing lawyers. More than twenty state and local bar associations have animal law sections and committees. 66 In 2000, the ALDF reported that seventy law firm lawyers volunteered to take on animal law cases pro bono; that number has now increased to more than six hundred. 67 Among the modest number of lawyers currently practicing animal law, there are even a few pet custody specialists.68 Despite the burgeoning issues and practitioners, substantial improvements in future pet custody cases will require serious changes in state laws and policies.69 Responding to arguments that courts are already overburdened with child custody cases, pet custody advocates say that if divorcees ―can share a piece of vacation 60 Carter, supra note 32, at 39. 61 Animal Legal Defense Fund, ALDF: Animal Law Courses, http://www.aldf.org/content/inde x.php?pid=83 (last visited Apr. 17, 2008). There are also textbooks on animal law for those courses. See DAVID S. F AVRE , ANIMAL LAW : WELFARE INTERESTS AND RIGHTS (2008); SONIA S. WAISMAN ET AL ., A NIMAL LAW : CASES AND M ATERIALS (2006). 62 Animal Legal and Historical Center, http://www.animallaw.info (last visited Jan. 25, 2008); Animal Law Review, http://www.lclark.edu/org/animalaw (last visited Jan. 25, 2008). 63 Animal Legal Defense Fund, SALDF Chapters, http://www.aldf.org/content/index.php?pid= 51 (last visited M ar. 31, 2008). 64 Carter, supra note 32, at 42. 65 Id. 66 Animal Legal Defense Fund, ALDF Resources, http://www.aldf.org/resources/details.php?id =101 (last visited Jan. 25, 2008). 67 Carter, supra note 32, at 39. According to Jonathan Lovvorn, vice president for animal- protection litigation for the Humane Society of the United States (HSUS), the organization ―opened its own legal shop in 2005 with three lawyers. That practice has grown to 12 lawyers and 40 active cases, with about 200 lawyers helping out pro bono, including members of six of the 10 biggest law firms in the country.‖ Id. 68 Animal Legal Defense Fund website, ALDF: Resources, http://www.aldf.org/resources/detail s.php?id=78 (last visited M ar. 30, 2008). 69 See Kalson, supra note 51, at E7 (―Even when judges recognize that pets have a special place in a family‘s life, the law may not support that recognition.‖). 2008] CUSTODY BATTLES OVER THE P ET 441 real estate at the shore, they can share a pet.‖70 The challenge arises in compelling courts to enforce shared custody agreements absent a statute.71 Fortunately for pet custody advocates, attorneys and state legislators recognizing the need for change are already making headway in several jurisdictions. In 2007, Wisconsin became the first state to propose legislation allowing couples to establish pet custody and visitation rights. 72 If the feuding couple can not reach an agreement on their own, the statute also allows judges to assign custody or turn the pet over to a local animal shelter and ―[w]hoever gets there first owns the dog, cat or even goldfish.‖ 73 In 2008, a similar bill was introduced in the Michigan Legislature that would ―require any spouse filing for divorce to include a list of all pets, their species and when they were purchased.‖74 The divorcing couple must also file any custody agreements made out of court, ―[o]therwise, a judge should decide who gets custody of the pets.‖75 Critics of pet custody legislation claim that special attention from lawmakers is unnecessary and silly. 76 But if the previously detailed cases are any indication of future pet custody battles, the added clarity that statutory guidelines could potentially offer seems well worth the effort. VI. CONCLUSION Only time will tell whether pet custody legislation will be successful—both in its ability to pass through state legislatures, and in its ability to effectively improve pet custody cases in state courts. Ultimately, finding workable solutions to the issues raised in pet custody cases will depend on current and future pet custody advocates. According to one such advocate, Jonathan Rankin, a Boston attorney who recently left the firm Glickman Turley to open his own animal law practice, ―courts are always behind society.‖ 77 However, Rankin remains optimistic that eventually, by statute or by precedent, positive changes will eventually improve future pet custody disputes. ―If corporations can be persons in the eyes of law, if ships can be persons in the eyes of the law, then the law should be able to figure out something for animals.‖ 78 70 Id. 71 According to one Pennsylvania pet custody advocate: Every state will deal with the distribution of the pet as part of marital assets, but not many will deal with shared custody. [. . .] In Pennsylvania, the same courts that will enforce an agreement to share a boat or season tickets to the ball park will not enforce a similar agreement regarding an animal. Id. 72 A. B. 436, 2007 Reg. Sess. (Wis. 2007), available at http://www.legis.state.wi.us/2007/data/ AB-436.pdf. 73 P.J. Huffstutter, Who Gets Custody of Fido, L. A. T IMES, July 15, 2007, at 13. 74 Shellenbarger, supra note 31, at A1. 75 Id. 76 Id. 77 Bennett, supra note 12, at 1D. 78 Id.
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