text:
Off the record: why the EEOC should change its guidelines regarding employers' consideration of employees' criminal records during the hiring process.
I. INTRODUCTION II. Background A. The Use of Criminal Records During the Hiring Process Has a Disparate Impact on Minority Applicants B. The EEOC's Origins and Authority Regarding Title VII C. The EEOC's Current Guidelines Regarding Employers' Use of Criminal Records During the Hiring Process. III. ANALYSIS A. The EEOC's Guidelines Lack Clarity and Deference 1. Lack of Clarity in the EEOC's Guidelines 2. Lack of Adherence to the EEOC's Guidelines Stems from a Lack of Deference B. The EEOC Recognizes that Changes Must be Made to Its Guidelines C. Problems Employers Cause When They Rely on Criminal Records Inappropriately 1. Employers Make Blanket Policies Rejecting All Applicants with a Criminal Record 2. Employers Waste EEOC Time and Resources When They Violate EEOC Guidelines D. Employers' Right to Use Criminal Records During the Hiring Process IV. RECOMMENDATION A. Make Guidelines More Explicit 1. Type of Offense 2. Time Since Last Offense 3. Timing of Inquiry B. Make Guidelines More Readily Available to Employers and Employees C. Incentives for Employers V. Conclusion
The United States releases approximately 700,000 inmates from prison each year. (1) Of those released, most are young men without a college education, and about two-thirds remain unemployed one year after their release. (2) Those who can find steady work after their release are both less likely to return to prison and more capable of taking on the social roles of spouse and parent. (3) Despite the obvious advantages to society, employers are less likely to hire people with criminal records than people without criminal records. (4)
Statistically, African American men are roughly six times more likely to go to prison than Caucasian men, and they are also overrepresented among released prisoners. (5) Thus, employers' refusal to hire individuals with criminal records creates a disparate impact on African Americans. (6) To help assuage and prevent this racially disparate impact, the Equal Employment Opportunity Commission (EEOC)--the commission Congress assigned to enforce its laws against race, sex, and religious discrimination in the workplace--should revise its guidelines to prevent employers from relying on criminal records inappropriately to exclude applicants with a criminal record.
This Note will discuss how and why the EEOC should revise its guidelines regarding the use of criminal records during the hiring process. Part II will discuss the history of the EEOC and the EEOC's current guidelines regarding employer use of criminal records during the hiring process. Part III will discuss how and why the EEOC should change its guidelines and the different perspectives regarding what these changes should entail. Finally, Part IV lays out specific recommendations regarding how the EEOC can change its guidelines to help minimize the disparate impact against minorities (7) during the hiring process.
To understand the need for a change in the EEOC's guidelines, it is important to be familiar with how the EEOC operates and how employers currently hire their employees. A discussion of how the use of criminal records during the hiring process has a disparate impact on minority applicants will highlight the need for a change in the EEOC's guidelines.
A. The Use of Criminal Records During the Hiring Process Has a Disparate Impact on Minority Applicants
The Civil Rights Act of 1964 (Civil Rights Act) was originally enacted to eliminate the last vestiges of Jim Crow laws (8) and segregation and deal with discrimination in voting, public accommodations, education, and employment. (9) Congress enacted Title VII of the Civil Rights Act (10) in 1964 to continue the practice of preventing employment discrimination started by "the Unemployment Relief Act of 1933, which provided '[t]hat in employing citizens for the purpose of this Act no discrimination shall be made on account of race, color, or creed.'" (11) Title VII prohibits employers from using facially neutral selection processes--such as the use of criminal records--that have the effect of disproportionately excluding people of a certain race, color, religion, sex, or national origin, from employment opportunities. (12)
When employers use facially neutral selection processes that have the effect of disproportionately excluding people of a certain race, color, religion, sex, or national origin from employment opportunities, affected job applicants may file a disparate impact claim. (13) In order to state a disparate impact claim under Title VII, plaintiffs must first present a prima facie case by "[identifying] the employment practice allegedly responsible for the disparities ... then [producing] statistical evidence showing that the challenged practice causes a disparate impact on the basis of race, color, religion, sex, or national origin." (14) Once the plaintiff makes a prima facie case, the burden of proof shifts to the employer who can either "directly attack [the] plaintiff's statistical proof by pointing out deficiencies in data or fallacies in the analysis" or "rebut a plaintiff's prima facie showing by demonstrating that the challenged practice is job related for the position in question and consistent with business necessity." (15) Despite Title VII's provisions regarding practices that cause a disparate impact on minority groups, several studies show that employers are extremely unlikely to hire an employee with a criminal record. (16)
Minorities are more likely to have criminal records than non-minorities, not because they tend to commit crimes more often than non-minorities, but because of racial profiling and other factors such as prosecutorial discretion, receiving jail time rather than bail, higher bails for similar charges, less advantageous proposals during plea bargaining, longer sentences, and higher receipt of the death penalty. (17) Provided that members of both minority and non-minority races are committing crimes at the same rate, when law enforcement officers stop and search minorities at a higher rate it follows that a larger number of minorities will be prosecuted. (18) Because minorities are criminally prosecuted statistically more often than non-minorities, employers who give too much deference to criminal records during the hiring process cause a disparate impact on minorities. (19) The EEOC has held that this disparate impact violates Title VII because it discriminates against minorities. (20) Because the disparate impact results in a Title VII violation, courts have held blanket policies where employers refuse to hire anyone with a criminal record illegal. (21)
B. The EEOC's Origins and Authority Regarding Title VII
Title VII created the EEOC, and "Congress intended the EEOC to be 'the lead enforcement agency in the area of workplace discrimination.'" (22) Originally, Title VII "limited the EEOC's functions to the investigation of employment discrimination charges and informal methods of conciliation (23) and persuasion." (24) Thus, when the EEOC's conciliation efforts failed in the course of an investigation, its involvement in the claim ended. (25) Derrig notes that "[w]hen it originally enacted Title VII, Congress hoped to encourage employers to comply voluntarily with the Act." (26) However, when many employers did not voluntarily comply with the Act, Congress strengthened the EEOC's powers of investigation and enforcement. (27)
Currently, "[t]he EEOC is empowered to prevent any person from engaging in any unlawful employment practice." (28) Title VII states that an employee must file a charge of discrimination with the EEOC before the employee may file a private lawsuit. (29) The employee must file the charge within 180 days after the allegedly discriminatory act occurred, and the EEOC must serve notice of the charge to the employer within ten days of filing. (30) After the employee files the charge with the EEOC and the employer has been notified, Title VII states that the EEOC is responsible for investigating the charge in "order to determine whether there is reasonable cause to believe that the statute was violated." (31) Before issuing some form of resolution, the EEOC may handle the processing of a charge in a number of ways. (32)
In order to assess whether there is reasonable cause to believe the charge is true, the EEOC examines "whether the 'evidence establishes under the appropriate legal theory, a prima facie case, whether the employer has provided a viable defense, and whether there is evidence of pretext.'" (33) The EEOC must determine whether there is reasonable cause as soon as possible, no later than 120 days from the filing of the charge. (34) If the EEOC finds that there is reasonable cause, then it can either file a suit on behalf of an individual or decide to close its case and, upon request, issue a "Right to Sue" letter. (35) Next, the EEOC must try to eliminate any allegedly unlawful employment practice through informal methods such as conference, conciliation, and persuasion. (36) During its conciliation efforts, the EEOC must "attempt to achieve a just resolution of all violations found and to obtain agreement that the respondent will eliminate the unlawful employment practice and provide appropriate affirmative relief." (37)
The EEOC can bring a civil action only once it has determined that it has been unsuccessful in obtaining a satisfactory conciliation agreement. (38) "If the EEOC does not bring an action within one hundred and eighty days after the claim is filed, it must then notify the aggrieved party of the failure of conciliation." (39) Next, "[t]he private civil action must be commenced within ninety days of receipt from the EEOC of a notice of right to sue." (40)
The charging party still has the right to file a lawsuit in federal court if the EEOC does not find reasonable cause. (41) The courts have rejected the argument that the EEOC finding of no reasonable cause should create a bar to filing a lawsuit. (42) Thus, parties who likely have no case may file a lawsuit.
C. The EEOC's Current Guidelines Regarding Employers' Use of Criminal Records
During the Hiring Process
Employers may use criminal records during the hiring process so long as they demonstrate that the use of criminal records is "related for the position in question and consistent with business necessity." (43) In order for employers to decide whether the conduct from the criminal record is related to the position sought, the EEOC's current guidelines state that employers should look to the nature and gravity of the offense, how long it has been since the arrest or conviction, and the nature of the job the employee wants or has. (44) For example, in West v. The Salvation Army, the court held that "[t]he Salvation Army's practice to evaluate the employee and his criminal history demonstrates that the hiring policy attempts to ascertain the [applicant's] ability to perform the job as well as the risk to the Salvation Army." (45) In that situation, the job required that the plaintiff get household goods from private residences. (46) Thus, because the plaintiff had prior convictions for burglary of private residences, the employer's refusal to hire the plaintiff due to his criminal record was within the EEOC's guidelines because "[c]onvictions of serious crimes--such as burglary--may present a substantial risk for employers like the Salvation Army." (47)
This Part will outline the need for a change in the EEOC's guidelines. The EEOC's guidelines lack clarity and deference. Due to this lack of clarity and deference, courts do not enforce the EEOC's guidelines, (48) and because of this lack of enforcement, employers do not feel the need to adhere to the guidelines. (49)
A. The EEOC's Guidelines Lack Clarity and Deference
The EEOC's guidelines are not sufficiently clear because neither employers nor courts have a precise definition of what constitutes "business necessity." (50) Additionally, several employers appear not to follow these guidelines because they are not aware of them. (51) Due to this lack of clarity and the fact that employers are not aware of the guidelines, the EEOC is currently considering changing its guidelines for employers' use of employees' criminal records. (52)
1. Lack of Clarity in the EEOC's Guidelines
Courts and employers struggle to determine what constitutes a "business necessity." (53) The Third Circuit highlighted this confusion regarding whether a practice is a "business necessity" in El v. Southeastern Pennsylvania Transportation Authority. (54) The court held that the Southeastern Pennsylvania Transportation Authority's (SEPTA) policy, which "disallowed hiring anyone with ... a violent criminal conviction," did not violate Title VII. (55) In El, although the employee's second-degree murder conviction was 40 years old and he was 15 years old at the time of the incident, the court held that the employee's termination under SEPTA's policy was justified as a "business necessity" to prevent the employee from working as a paratransit bus driver. (56) El highlights the need for a clearer definition of what constitutes a "business necessity." What one did as a minor 40 years prior should not prevent that person from holding a job as a paratransit bus driver. Additionally, the court in El stated that "[i]f a bright-line policy can distinguish between individual applicants that do and do not pose an unacceptable level of risk, then such a policy is consistent with business necessity." (57) However, the court left it up to other courts to decide on the basis of the specific facts of the case whether a particular policy constitutes a "business necessity." (58) This ruling seems to conflict with other courts that have held blanket policies that refuse to hire any employee with a criminal record are illegal. (59)
2. Lack of Adherence to the EEOC's Guidelines Stems from a Lack of Deference
The court in El did not give much deference to the EEOC's guidelines. (60) The lack of deference was, in part, due to the Supreme Court's holding that when Congress enacted Title VII, it did not intend to give the EEOC authority to promulgate rules or regulations. (61) Rather, Congress intended for the amount of deference afforded the EEOC to depend on the thoroughness of its consideration, the soundness of its reasoning, and its consistency with prior and future pronouncements. (62) Presumably, if the EEOC changes its guidelines to appear more persuasive and to show the "thoroughness of its research," the courts will give the EEOC's guidelines more deference. (63) The lack of clarity in its guidelines and the lack of deference from the courts may have recently led the EEOC to hesitate to respond to a request from the National Employment Law Project (NELP) to investigate some allegations of employment discrimination. (64)
The NELP letter asked the EEOC to enforce its guidelines regarding the use of criminal records with three major employers: Bank of America, Manpower, and One-Stop Career Center. (65) The NELP letter alleges that those employers' "use of an absolute bar to employment for individuals with criminal records violates Title VII of the Civil Rights Act of 1964 and EEOC guidance, because such policies have an unjustified adverse impact on minority applicants for employment." (66) If this allegation is true, the EEOC will most likely follow Field, which held that blanket policies used by employers that exclude all employees with criminal records are illegal. (67) Additionally, the EEOC will most likely find that the NELP has a legitimate claim and will bring an action against the employers. (68) Perhaps in light of El, the EEOC appears reluctant to respond until it changes its guidelines and its decisions might evoke more deference from the courts. (69) Ideally, once the EEOC's guidelines are changed, courts will grant greater deference by more strictly enforcing the EEOC's decisions, thus resulting in employers following the guidelines more diligently. (70) The EEOC will likely find that the NELP has a legitimate claim against the mentioned employers once it revises its guidelines so that those guidelines are given more deference, and so that the NELP will be more likely to win its case. (71)
B. The EEOC Recognizes that Changes Must be Made to Its Guidelines
Due to the general confusion and lack of adherence to the current guidelines, the EEOC held a meeting on November 20, 2008 to discuss employment discrimination faced by individuals with arrest and conviction records. (72) Although nothing final resulted from the meeting, various people shared several different viewpoints that illustrate current opinions on the issue. (73) For example, Laura Moskowitz (74) suggested that the EEOC keep parts of its current guidelines, such as the presumption that the use of criminal records has a disparate impact on certain minority groups. (75) Retaining the presumption is critical because, otherwise, the misuse of criminal records during the hiring process would not be a Title VII violation, and the EEOC would not be able to adjudicate the situation. (76) Moskowitz also suggested that the EEOC's guidelines retain the prohibition of blanket policies excluding people with criminal records unless the employer can show a justified business necessity. (77) By excluding most blanket policies, the EEOC ensures that employers give at least some consideration to future employees with criminal records. (78) She also suggested that the EEOC's guidelines maintain consideration of rehabilitation and work history and the requirement that employers link each applicant's criminal record to the nature of the job. (79) Thus, an employer would have to demonstrate a connection between the employee's crime and what the employee's potential job would entail. (80) Once again, these guidelines focus on encouraging employers to evaluate employees more closely rather than arbitrarily rejecting them because of their criminal record. If the goal of the hiring process is for employers to hire those individuals who will perform the best at their jobs, employers must look past criminal convictions which are unrelated to the job. Commissioner Ishimaru mentioned that "[b]usiness and industry suffers as a result [of using criminal convictions inappropriately] because it is not able to benefit fully from the skills of every potential worker. For our economy to be successful, we cannot afford to waste any available talent." (81) Thus, when employers blindly refuse to hire employees with criminal records, they both create a disparate impact against minority employees and hurt the economy by "wasting talent." (82)
Moskowitz suggested some changes as well. For example, the EEOC's guidelines should prohibit the use of arrest records that have not led to convictions. (83) Moskowitz argued that, unlike convictions, arrests are mere allegations that can result in no conviction or a conviction of a lesser charge, and employers currently misuse them by failing to investigate whether the arrest led to a conviction. (84) Additionally, research has shown that after six to eight years without re-offending, people with criminal records are no more likely to re-offend than people without criminal records. (85) Moskowitz suggested that employers should not be allowed to consider criminal records seven years after the employee has been released from incarceration. (86) If people with at least seven-year-old criminal records are statistically as unlikely as people without criminal records to commit an offense, employers who wish to reject potential employees based on the existence of a criminal record lack the business necessity argument the EEOC already requires. (87)
Moskowitz also mentioned that employers are not aware of federal programs that are available to make it easier for employers to hire and insure themselves against employees with criminal records. (88) If the EEOC wants to prevent the misuse of criminal records from creating a disparate impact on minorities, and federal programs already exist to give employers incentive to hire employees with criminal records, then employers' lack of awareness essentially renders these federal programs useless. (89) Clearer guidelines could help make employers aware of these programs and potentially decrease the disparate impact on minorities the misuse of criminal records creates. It is futile for programs to exist if those who could benefit from them are not aware of them. Although it is difficult to determine precisely why employers do not take advantage of these programs, these beneficial guidelines will make employers more likely to take advantage of the programs. If employers are aware of the programs, they will be more likely to take advantage of them.
Commissioner Rae Vann highlighted the need for the EEOC's guidelines to be clearer, especially regarding when employers can legally rely on the use of criminal records during the hiring process. (90) Vann mentioned that because "heavily regulated industries such as insurance, healthcare and financial services, now are required to perform detailed criminal background investigations and to automatically disqualify certain applicants based on certain criminal offenses," the new guidelines should ensure that employers will not violate Title VII by relying on industry regulations. (91) This suggestion lends itself to the above discussion highlighting the need for clearer guidelines. In order for the guidelines to be sufficiently clear for employers to use and understand, they must specify when employers may not exclude employees because of their criminal records, and they must specify when employers must exclude employees because of their criminal records. (92)
C. Problems Employers Cause When They Rely on Criminal Records Inappropriately
When employers rely on criminal records inappropriately, they cause a variety of problems for employees, the EEOC, and themselves. (93) One of these problems includes making blanket policies that reject all applicants with a criminal record. (94) Another problem includes wasting the EEOC's time and resources. (95)
1. Employers Make Blanket Policies Rejecting All Applicants with a Criminal Record
Some employers refuse to hire anyone with any sort of criminal record. (96) Such an approach ignores statistical studies that have found that the type of offense, the time since the last offense, and the total number of offenses committed affect the probability that a potential employee will commit a crime that will affect his job. (97) Several cases have held that refusing to hire all people with criminal records violates Title VII, but employers continue with the policy partly because they are unaware that the EEOC prohibits such practices. (98)
2. Employers Waste EEOC Time and Resources When They Violate EEOC Guidelines
When employers use applicants' criminal records inappropriately--in violation of EEOC guidelines--the result is a waste of resources for both the EEOC and the judicial system. People who misinterpret or are unaware of the law end up violating the law, and oftentimes, they are prosecuted. Because prosecution requires court resources, time and money would be saved by clarifying the EEOC's guidelines. Thus, if the EEOC's guidelines help employers to better understand the law, more employers will follow the law, requiring fewer prosecutions and lessening the consumption of court resources. If the EEOC guidelines were clearer and more widely known among employers, the amount of litigation involved in suits against employers who misuse criminal records during hiring practices could be reduced. Such a reduction in litigation would leave the EEOC free to use its resources to investigate other cases of discrimination.
D. Employers' Right to Use Criminal Records During the Hiring Process
Employers can benefit from referring to candidates' criminal records during background checks because under certain circumstances "criminal convictions are relevant to fitness for employment." (99) Employers can also protect their assets, employees, and third parties from possible criminal activity, insulating their businesses from liabilities that may arise. (100) Employers have a right to run their businesses as successfully as possible so long as they do not infringe potential employees' Title VII rights. (101) In order to achieve that goal, Professor Foreman, who expressed his concerns for employers at the EEOC' s meeting on November 20, 2008, suggested that the EEOC make its guidelines more clear so that employers can more easily and confidently rely upon them in order to protect themselves from liability. (102) In addition to clarifying the guidelines, Professor Foreman also highlighted the importance of delaying any sort of inquiry into a potential employee's criminal record until the final hiring stages for a variety of public policy purposes. (103)
The public policy purposes involve expanding the applicant pool in order to improve the odds of selecting the most qualified individual. (104) The goal of the hiring process is to hire the most qualified person for the job. Thus, the EEOC's guidelines should work to expand the applicant pool in order to hire the most qualified person. (105) Another public policy purpose involves saving "employers the expenses associated with doing criminal background [checks] on applicants and reduc[ing] the likelihood of discrimination based on an unrelated record.... [I]t encourages individuals with prior convictions to apply for positions without the fear of immediate rejection and pledges a more holistic review will [take place]." (106) If individuals with prior convictions fail to apply for a job due to a fear of rejection, this may result in qualified applicants not applying for a job that they could have performed diligently and successfully.
Employers considering criminal records during the hiring process may benefit potential employees. (107) One study found that employers who looked at the criminal records of applicants were more likely to hire African Americans than employers who did not look at the criminal records of applicants. (108) These results prevailed among employers that were unwilling to hire people with a criminal record. (109) One possible explanation for this effect is that in the absence of criminal records, employers tend to use characteristics they perceive to correlate with criminal activity, such as race and breaks in employment history, to determine which candidates they will hire. (110) Thus, when employers reference and rely on actual criminal records rather than racial traits that they believe correlate positively with criminal activity, they tend to hire more minorities because records indicate these minorities do not have criminal records. (111)
Now that a need for a change in the EEOC's guidelines has been established, this Note will explain what these changes should entail and how they should be implemented. Making the guidelines more explicit is necessary in order for the employers to understand and follow them. Additionally, in order to increase awareness, the guidelines should be made more available to both employers and employees.
A. Make Guidelines More Explicit
As discussed in Part III.D, many employers still apply a blanket exclusion on potential employees with criminal records in violation of Title VII. (112) The Third Circuit highlighted the confusion surrounding the EEOC's current guidelines and the lack of deference courts give to the current guidelines. (113) In order to avoid blanket exclusions and confusion, the EEOC should clarify its guidelines and make them more accessible to employers. The new guidelines should be more detailed and leave less room for interpretation. (114) The substantive content that will make the EEOC's guidelines more explicit and easier for employers to follow and understand should include the type of offense, the time since the last offense, and the timing of inquiry.
1. Type of Offense
The EEOC should place a complete ban on employers looking at arrest records of employees. As discussed in Part II.A, arrest records are not an accurate representation of a potential employee's past criminal conduct because many arrests never lead to criminal convictions and, more generally, arrests are mere allegations that a crime occurred, not proof that a crime happened. (115) Because racial minorities are more likely to be arrested than non-minorities and an arrest is not reliable evidence that an employee committed a crime, the EEOC's new guidelines should ban the use of arrest records during the hiring and employment process. Several states have already adopted this view. (116) By not considering arrest records at all, employers will not risk misinterpreting or misusing them. A complete ban is the easiest type of guideline for employers to understand and follow, leaving no room for misinterpretation or misunderstanding.
Employers also need to understand what sorts of convictions constitute a "business necessity." In order to deal with the "business necessity" confusion discussed in Part III.A.1, the EEOC's new guidelines should outline what types of offenses constitute a "business necessity" in different types of careers. When deciding what constitutes a "business necessity," employers should consider: the "age of the person at the time of offense; [t]he length and consistency of the person's work history, including whether the person has recently been employed; [e]vidence of rehabilitation, whether for substance abuse or personal rehabilitation; and [e]ducational attainment." (117) The new guidelines could present this information in a chart format and provide information on how to find the contact information for the EEOC office closest to that employer in order to consult with the EEOC about the potential hire.
Additionally, employers need to comply with federal laws that require them to disqualify certain types of offenders from particular types of jobs. In order for employers to hire employees in a way that both complies with Title VII and federal laws, the EEOC's new guidelines should clearly outline these requirements. The new guidelines should devote a section to telling employers that they must obey federal laws that require them not to hire certain offenders in certain lines of work. In order to keep the guidelines concise, they should provide employers with instructions on how they can obtain information about who they may not legally hire.
2. Time Since Last Offense
Studies have shown that once someone has gone seven years since his last offense the odds of that person committing another offense are the same as someone who has never committed an offense. (118) These studies indicate that there is a fundamental unfairness in judging someone's character and ability to perform a job based on an offense that person committed seven years ago when they are statistically no more likely to commit a new offense than someone without a criminal record. (119) The EEOC should include this explicit seven-year timeline in its new guidelines for employers to use. This way, employers will not be tempted to use 40-year-old convictions to fire competent employees as the employer did in El. (120) Because rehabilitation has been said to be the "historical premise of the modern prison," (121) employers should trust that once potential and current employees have gone seven years without committing another crime the prison system has fulfilled its rehabilitative purpose. Thus, the applicants should be treated the same as potential applicants who lack a criminal record.
3. Timing of Inquiry
The EEOC should also instruct employers to save any inquiry into an employee's criminal record for the end of the interview process in order to avoid subconsciously or consciously tainting the employer's decision. (122) It would be far easier for employers to base their decisions on criminal records and allow these records to influence their decisions if employers inquire about them initially. It would be difficult for an employer to find out that a potential employee has a criminal record and then try not to allow that knowledge to taint that employer's judgment when making a hiring decision. Several different cities and counties already require this of their employers. (123) Implementing this requirement in the EEOC's guidelines would help to make nationwide hiring practices both more uniform and fairer and less likely to lead to a discriminatory impact against hiring minorities with criminal records.
B. Make Guidelines More Readily Available to Employers and Employees
Employers tend not to adhere to the EEOC's guidelines because they are not aware of them. (124) One way to raise employers' awareness of the EEOC's guidelines regarding the use of criminal records during the hiring process is to require employers to post a copy of the guidelines somewhere in their office in a location that is visible to employees as well. (125) By posting a copy of the guidelines, employers will be familiar with--and hopefully abide by--the guidelines and employees will know their rights regarding employment issues. To enforce this requirement the EEOC could fine employers for failing to post the guidelines. (126) In order to ascertain which employers do not post the guidelines, the EEOC should do site checks of places of employment. This would provide employers with an additional incentive to post the guidelines.
C. Incentives for Employers
The EEOC should highlight the various government-sponsored incentives for employers to hire employees with criminal records, including programs that give six-month insurance coverage for any theft committed by an employee with a criminal record and different tax credits employers may receive for hiring employees with criminal records. (127) The new guidelines should dedicate a specific, easily accessible (128) section to the various incentives for employers in order to make them aware of and entice them to use the incentives. This way such opportunities will no longer be wasted and employers will be more likely to give employees with a criminal record a chance, helping to reduce the disparate impact against minorities that occurs when employers refuse to hire employees with criminal records.
V. Conclusion
These new guidelines would have important implications for both employers and employees. Employers will have to spend more time during the hiring process to make sure that they do not unfairly discriminate against employees due to their criminal records. Employers will also have to spend some time thoroughly reading and understanding the EEOC's new guidelines, which must be located in a place that is easily accessible to both employers and employees.
These guidelines will also help both employers and employees to understand the law. When more people understand the law, more people will follow the law, and fewer violations will take place. With fewer violations of Title VII, the EEOC will be able to use its time, money, and resources on other issues that warrant its attention.
(1.) Devah Pager, Professor of Sociology, Princeton Univ., Remarks at Meeting of the Equal Employment Opportunity Commission: Employment Discrimination Faced by Individuals with Arrest and Conviction Records (Nov. 20, 2008), http://www.eeoc.gov/eeoc/meetings/11-20-08/pager.cfm.
(2.) Id.
(3.) Id.
(4.) Id.
(5.) Pager, supra note 1.
(6.) Id.
(7.) For the purpose of this Note, "minority" refers to all non-Caucasian populations.
(8.) For a detailed discussion of the history of Jim Crow laws, see NEIL R. MCMILLEN, DARK JOURNEY: BLACK MISSISSIPPIANS IN THE AGE OF JIM CROW (Univ. of Ill. Press 1990) (1989).
(9.) Celebrating the 40th Anniversary of Title VII, EQUAL EMP'T OPPORTUNITY COMM'N, (June 22, 2004), http://www.eeoc.gov/eeoc/history/40th/panel/firstprinciples.html [hereinafter EEOC, 40th Anniversary].
(10.) 42 U.S.C. [section] 2000e (2006) [hereinafter Title VII].
(11.) EEOC, 40th Anniversary, supra note 9.
(12.) Gulino v. New York State Educ. Dep't, 460 F.3d 361, 382 (2d Cir. 2006).
(13.) Id.
(14.) Id.
(15.) Id.
(16.) See, e.g., Devah Pager, The Mark of a Criminal Record, 108 AM. J. SOC. 937, 960 (2003) ("[M]ere contact with the criminal justice system, in the absence of any transformative or selective effects, severely limits subsequent employment opportunities ... ex-offenders are only one-half to one-third as likely as nonoffenders to be considered by employers."); Harry J. Holzer et al., Will Employers Hire Ex-Offenders? Employer Preferences, Background Checks, and Their Determinants 41 (Inst. for Research on Poverty, Working Paper No. 1243-02, 2002), available at http://www.irp.wisc.edu/publications/dps/pdfs/dp124302.pdf ("Employer willingness to hire ex-offenders is very limited, even relative to other groups of disadvantaged workers (such as welfare recipients)."); Transcript of the Equal Emp't Opportunity Comm'n Meeting of Nov. 20, 2008, http://www.eeoc.gov/eeoc/meetings/11-20-08/transcript.cfm (Nov. 20, 2008) [hereinafter EEOC Transcript] ("[C]lose to 60 percent of employers have told researchers that they would not or probably would not hire someone with a conviction history.").
(17.) See, e.g., Eric Lotke, Racial Disparity in the Justice System: More than the Sum of its Parts, FOCUS, May-June 2004, at 3--4 (discussing why racial minorities are more likely to have criminal records); End Racial Profiling Act of 2001, S. 989, 107th Cong. [section] 2(a)(2) & (5) (2001), available at http://www.aele.org/s989.html (discussing statistics that show "racial profiling is a real and measurable phenomenon" and a 2001 Department of Justice Report which found that "although African-Americans and Hispanics were more likely to be stopped and searched, they were less likely to be in possession of contraband"); J. Mitchell Pickerill et al., Search and Seizure, Racial Profiling, and Traffic Stops: A Disparate Impact Framework, 31 LAW & POL'Y 1, 11, 19 (2009) (finding that even when controlling other factors dealing with "individual, situational, and contextual characteristics of a stop," "race still has an impact on the likelihood of a search"); EEOC Transcript, supra note 16 (citing the war on drugs as a law enforcement practice that disproportionately targets minorities, leading to higher arrest and conviction rates in some minority communities).
(18.) See Lotke, supra note 17, at 3 ("If more African Americans are searched, then more contraband will be found on African Americans and more of them will be sent to prison. Thus, the raw numbers weigh against African Americans even though probability tells a different story.").
(19.) See Laura Moskowitz, Staff Attorney with the Nat'l Emp. Law Project, Remarks at Meeting of the Equal Emp't Opportunity Comm'n: Employment Discrimination Faced by Individuals with Arrest and Conviction Records (Nov. 20, 2008), http://www.eeoc.gov/eeoc/meetings/11-20-08/moskowitz.cfm (explaining that employer reliance on criminal records has a disparate impact on minorities because minorities are more likely than whites to be arrested and incarcerated).
(20.) See Why Do We Need E-RACE?, EEOC, http://www.eeoc.gov/initiatives/e-race/why_e-race.html ("Facially neutral employment criteria are significantly disadvantaging applicants and employees on the basis of race and color.").
(21.) See, e.g., Field v. Orkin Exterminating Co., No. Civ. A. 00-5913, 2002 WL 32345739, at *1 (E.D. Pa. Feb. 21, 2002) (holding that defendant employer who terminated plaintiff employee, an office manager and bookkeeper for a small pest control company, because she "had been convicted several years earlier of interfering with the custody of a child, concealing the child's whereabouts and conspiracy," violated Title VII, and holding generally, "a blanket policy of denying employment to any person having a criminal conviction is a violation of Title VII").
(22.) Catherine R. Caifano, When the Music Stops, Why Not Require Certain Title VII Plaintiffs to Find a Chair on Which to Rest Their Complaint?, 42 J. MARSHALL L. REV. 505, 511 (2009).
(23.) During a conciliation effort, "[t]he EEOC attempts to 'achieve a just resolution of all violations found and to obtain agreement that the respondent will eliminate the unlawful employment practice and provide appropriate affirmative relief.'" Ellen N. Derrig, Title VII-The Doctrine of Laches as a Defense to Private Plaintiff Title VII Employment Discrimination Claims, 11 W. New Eng. L. Rev. 235, 242 n.31 (1989) (citing 29 C.F.R. [section] 1601.24 (1988)). If the employer accepts, "the remedy is embodied in a conciliation agreement that is signed by the charging party and the employer." Id.
(24.) Id. at 241 -42.
(25.) Id. at 242. "Enforcement could be achieved, if at all, only if the Title VII claimant initiated a private suit within thirty days after the receipt of EEOC notification that conciliation efforts had not been successful." Id.
(26.) Derrig, supra note 23, at 242.
(27.) Id. at 242-43.
(28.) Caifano, supra note 22, at 511. But see Brent T. Carney, Part-Time Employees Divide the Circuits: An Interpretation of "Employer" Under Title VII and the ADEA, 31 NEW ENG. L. REV. 167, 170 (1996) ("Congress exempted small businesses having fewer than fifteen employees from Title VII in order to protect them from the threat and expense of litigation.").
(29.) Caifano, supra note 22, at 511. Title VII also "prescribes that the EEOC is responsible for processing the charge." Id.
(30.) Derrig, supra note 23, at 243-44.
(31.) Caifano, supra note 22, at 511-12. "Title VII provides that the EEOC's investigation can be broad." Id.
(32.) The "EEOC may assign a charge for priority investigation if the initial facts appear to support a violation of the law." Id. at 512 n.50. The EEOC can also try to settle a charge. Id. However, "if, in the agency's best judgment, further investigation will not establish a violation of the law," the EEOC may dismiss a charge. Id. "When a charge is dismissed, a notice is issued in accordance with the law which gives the charging party ninety days in which to file suit." Caifano, supra note 22, at 512 n.50.
(33.) Id. at 512 (quoting EEOC Compliance Manual (CCH) [section] 40.2). "Between FY 2001 and FY 2006, the EEOC made a 'reasonable cause' determination seven percent of the time on average per year." Id.
(34.) Derrig, supra note 23, at 244.
(35.) Caifano, supra note 22, at 513.
(36.) Derrig, supra note 23, at 245.
(37.) Id. (quoting 29 C.F.R. [section] 1601.24(a) (1998)). "Successful conciliation avoids litigation through the execution of a formal conciliation agreement." Id.
(38.) Id. at 245.
(39.) Id.
(40.) Derrig, supra note 23, at 245.
(41.) Caifano, supra note 22, at 513.
(42.) Id. "The U.S. Supreme Court said 'whatever the practical merits of this (respondent's) argument, the Federal Rules do not contain a heightened pleading standard for employment discrimination suits.'" Id. at 514.
(43.) Gulino v. New York State Educ. Dept., 460 F.3d 361, 382 (2d Cir. 2006) (quoting 42 U.S.C. [section] 2000e2(k)(1)(A)(i) (2006)).
(44.) EEOC, Notice No. 915.061, Policy Guidance on the Consideration of Arrest Records under Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. [section] 2000e et. seq. (1982) (Sept. 7, 1990), available at http://www.eeoc.gov/policy/docs/arrest_records.html.
(45.) West v. The Salvation Army, No. 07-10269, 2007 WL 1839984, at *5 (E.D. Mich. June 27, 2007).
(46.) Id.
(47.) Id.
(48.) See infra note 50 (discussing why courts do not enforce the EEOC's guidelines).
(49.) See infra note 51 (discussing how employers fail to comply with the EEOC's guidelines).
(50.) See El v. Se. Pa. Transp. Auth. (SEPTA), 479 F.3d 232, 240-43 (3d Cir. 2007) (discussing the history of the courts' confusion regarding what constitutes business necessity).
(51.) See Letter from National Employment Law Project, to Stuart J. Ishimaru, Acting Chairman, U.S. EEOC (June 9, 2009), available at http://nelp.3cdn.net/aa8a86751197fa03ef_z2m6b5abc.pdf (alleging that "one of the nation's largest banks (Bank of America), one of the world's largest staffing agencies (Manpower), and a state office charged with helping individuals obtain employment (One-Stop Career Center) conspicuously failed to comply with the EEOC's guidance regulating criminal background checks for employment") [hereinafter NELP Letter].
(52.) See EEOC Transcript, supra note 16 (discussing why and how the EEOC's guidelines should change regarding employer use of employees' criminal records).
(53.) See, e.g., El, 479 F.3d. at 241 (discussing the history of the courts' confusion regarding what constitutes business necessity).
(54.) Id.
(55.) Id. at 235. In this case, the employee was working as a paratransit bus driver whose "position involve[d] providing door-to-door and curb-to-curb transportation service for people with mental and physical disabilities." Id.
(56.) Id. at 235-36, 248. Although the court notes that the EEOC's guidelines require "employers to consider the circumstances of that offense," the court also mentions that the EEOC's guidelines are silent regarding "whether an employer justifiably can decide that certain offenses are serious enough to warrant a lifetime ban." El, 479 F.3d at 243.
(57.) Id. at 245.
(58.) Id.
(59.) Field v. Orkin Extermination Co., No. Civ. A. 00-5913, 2002 WL 32345739, at *1 (E.D. Pa. Feb. 21, 2002).
(60.) El, 479 F.3d at 244.
(61.) Id.
(62.) EEOC v. Arabian Am. Oil Co., 499 U.S. 244, 257 (1991).
(63.) El, 479 F.3d at 244.
(64.) NELP Letter, supra note 51.
(65.) Id.
(66.) Id. at 1.
(67.) Field, 2002 WL 32345739, at *1.
(68.) See infra Part IV (proposing new guidelines for the EEOC).
(69.) El v. Se. Pa. Transp. Auth. (SEPTA), 479 F.3d 232, 240-43 (3d Cir. 2007).
(70.) See id. (describing why courts do not give much deference to the EEOC's current guidelines).
(71.) NELP Letter, supra note 51.
(72.) EEOC Transcript, supra note 16.
(73.) Id.
(74.) Laura Moskowitz, a staff attorney at the National Employment Law Project, staffs the Second Chance Labor Project where she works in collaboration with "advocates, unions, and policymakers to promote the employment rights of people with criminal records and a more fair and effective system of employment screening for criminal records." Biography of Laura Moskowitz, U.S. EEOC, http://www.eeoc.gov/eeoc/ meetings/11-20-08/moskowitz_bio.cfm (last visited Nov. 14, 2009).
(75.) Moskowitz, supra note 19.
(76.) See EEOC Transcript, supra note 16 (explaining why the use of criminal records can lead to a disparate impact on minorities, which is a Title VII violation).
(77.) Id.
(78.) Moskowitz, supra note 19.
(79.) Id.
(80.) See id. (describing the connection an employer must make between the crime and the job the employee seeks).
(81.) EEOC Transcript, supra note 16.
(82.) Id.
(83.) Moskowitz, supra note 19.
(84.) Id. Twenty states already prohibit or advise against the use of arrest records during the employment process due to possible misuse, creating conflict with the EEOC's guidelines which currently allow the use of arrest records. Id.
(85.) EEOC Transcript, supra note 16.
(86.) Moskowitz, supra note 19.
(87.) See id. (discussing why after seven years, employers likely do not have a legitimate business necessity for refusing to hire someone because of their criminal record).
(88.) Id. Some of these programs include:
the Department of Labor's free bonding program which insures employers against losses due to [employees'] dishonesty or theft and also the Federal Work Opportunity Tax Credit, which allows a company to claim a tax credit for hiring an employee with a felony conviction within one year of the date of his or her conviction or release from incarceration.
EEOC Transcript, supra note 16.
(89.) Moskowitz, supra note 19.
(90.) EEOC Transcript, supra note 16.
(91.) Id. One specific example Vann mentioned was "Section 19 of the Federal Deposit Insurance Act [that] bars financial institutions from hiring anyone who has been convicted of any criminal offense involving dishonesty, breach of trust or money laundering unless and until they are able to obtain a written consent letter from the FDIC...." Id.
(92.) Id.
(93.) See generally supra note 16 (discussing why the EEOC should amend its guidelines to help employers and employees).
(94.) See infra Part III.C.1 (discussing why making blanket policies rejecting all applicants with a criminal record is a problem).
(95.) See infra Part III.C.2 (discussing how employers waste the EEOC's time and resources when they use applicants' criminal records inappropriately).
(96.) See supra note 16 and accompanying text (citing studies that have found that employers would rather not hire employees with criminal records).
(97.) See Moskowitz, supra note 19 (explaining why employers should consider these factors when referring to employees' criminal records).
(98.) Field v. Orkin Exterminating Co., No. Civ. A. 00-5913, 2001 WL 34368768, at *2 (E.D. Pa. Oct. 30, 2001).
(99.) Donald R. Livingston, Partner at Akin, Gump, Strauss, Hauer & Feld, Remarks at Meeting of the Equal Emp. Opportunity Comm'n: Employment Discrimination Faced by Individuals with Arrest and Conviction Records (Nov. 20, 2008), http://www.eeoc.gov/eeoc/meetings/11-20-08/livingston.cfm.
(100.) See Michael L. Foreman, Professor, The Penn. State Univ. Dickinson Sch. of Law, Remarks at Meeting of the Equal Emp. Opportunity Comm'n: Employment Discrimination Faced by Individuals with Arrest and Conviction Records, (Nov. 20, 2008), http://www.eeoc.gov/eeoc/meetings/11-20-08/foreman.cfm ("If an employer discovers, or should have discovered, that the job applicant has a criminal record, and that negligence results in harm to someone the employer may be liable for substantial damages."); see also Rae T. Vann, Gen. Counsel, Equal Emp. Advisory Council, Remarks at Meeting of the Equal Emp. Opportunity Comm'n: Employment Discrimination Faced by Individuals with Arrest and Conviction Records, (Nov. 20, 2008) http://www.eeoc.gov/eeoc/meetings/11-20-08/vann.cfm ("[R]eviewing criminal conviction history can be critical in determining an applicant's suitability to perform a specific job, minimizing workplace safety issues, and avoiding legal liability.").
(101.) See Foreman, supra note 100 (discussing employer's rights and concerns during the hiring and employment process).
(102.) Id.
(103.) Id.
(104.) Id.
(105.) Id.
(106.) Foreman, supra note 100.
(107.) Harry J. Holzer et al., Perceived Criminality, Criminal Background Checks, and the Racial Hiring Practices of Employers, 49 J.L. & Econ. 451, 474 (2006).
(108.) Id.
(109.) Id.
(110.) Id. at 452.
(111.) See id. at 473 ("[E]mployers with a particularly strong aversion to ex-offenders may be more likely to overestimate the relationship between criminality and race and hence hire too few African Americans as a result.").
(112.) See Field v. Orkin Exterminating Co., No. Civ. A. 00-5913, 2002 WL 32345739 (E.D. Pa. Feb. 21, 2002) (discussing employers' use of blanket exclusions).
(113.) See supra Part III.A.2 (discussing the lack of deference courts give to the current guidelines).
(114.) Too much room for interpretation would lead to employers interpreting the guidelines differently and thus adhering to the guidelines differently.
(115.) See Moskowitz, supra note 19 (discussing why arrest records should not be used at all during hiring and employment decisions).
(116.) Id. "[T]wenty 'states have specifically prohibited or advised against pre-employment [arrest] inquiries in their fair employment laws due to the possible misuse of this information.'" Id. (quoting Policy Guidance on the Consideration of Arrest Records in Employment Decisions under Title VII of the Civil Rights Act of 1964 (Sept. 7, 1990)).
(117.) Id. (quoting Legal Action Center, Advocacy Toolkits to Combat Legal Barriers Facing Individuals With Criminal Records, http://www.lac.org/toolkits/arrests/arrest_inquiries.htm) (last visited Sept. 17, 2010).
(118.) Id.
(119.) See supra Part III.B (discussing why it is unfair to deny someone the opportunity to perform a job because of a conviction from seven years ago).
(120.) El v. Se. Pa. Transp. Auth. (SEPTA), 479 F.3d 232, 235 (3d Cir. 2007).
(121.) See Edward L. Rubin, The Inevitability of Rehabilitation, 19 Law & Ineq. 343, 352 (2001) (arguing that rehabilitation is the primary purpose of the modern prison).
(122.) See Moskowitz, supra note 19 (explaining the "ban the box" method, where employers may not inquire into potential employees' criminal records until the final stage of the hiring process).
(123.) Some cities and counties that have instructed employers to save inquiry into employees' criminal records until the end of the hiring process are "[Chicago,] Boston, Minneapolis, St. Paul, San Francisco, Baltimore, Battle Creek (MI), Alameda (Oakland, CA area) County, Multnomah (Portland, OR area) County, and Travis (Austin, TX area) County. Initiatives have also been proposed in Los Angeles, Philadelphia, Newark, New Haven, Oakland, Seattle, and San Antonio." Id.
(124.) See NELP Letter, supra note 51 (detailing employers' lack of awareness regarding the EEOC's guidelines).
(125.) Some federal regulations already require employers to post certain regulations in the office, such as the Family and Medical Leave Act (FMLA), which specifies that "[e]ach employer shall post and keep posted, in conspicuous places on the premises of the employer where notices to employees and applicants for employment are customarily posted, a notice, to be prepared or approved by the Secretary, setting forth excerpts from, or summaries of, the pertinent provisions of [the FMLA]." 29 U.S.C. [section] 2619(a) (2006).
(126.) The FMLA specifies that "[a]ny employer that willfully violates this section may be assessed a civil money penalty not to exceed $100 for each separate offense." Id.
(127.) See Moskowitz, supra note 19 (discussing the various programs which exist to encourage employers to hire employees with criminal records).
(128.) By "easily accessible" this Note means that the incentives should be located in the table of contents or on one of the first few pages of the guidelines to ensure that employers will be aware of the incentives available to them.
Emily J. Carson, J.D. Candidate, University of Iowa College of Law, 2011; B.A. Grinnell College, 2008. I would like to thank my parents for all of their support.
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Diversity and Aging in the Social Environment
By (author) Sherry M. Cummings Colleen Galambos
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Diversity and Aging in the Social Environment by Sherry M. Cummings
Book DescriptionToday, nearly one of every eight Americans is 65 or older, and by 2030, over 20% of the population will be in this age group. Are you prepared to work with this vastly diverse--and rapidly growing--population? This single source is designed to help social service professionals provide effective services to America's vastly diverse and rapidly growing elderly population. Diversity and Aging in the Social Environment explores the impact of race/ethnicity, gender, sexual orientation, and geographic location on elders' strengths, challenges, needs, and resources to provide you with a more complete understanding of the issues elders face. In order to be more responsive to older adults, social workers and other human service professionals need to enhance their knowledge of the aging population and the factors that impact the way seniors interact with society, organizations, community resources, neighborhoods, support networks, kinship groups, family, and friends. Diversity and Aging in the Social Environment examines differences in race, ethnicity, geographical location, sexual orientation, religion, and health status to help current and future human service professionals provide culturally competent services to the diverse range of elderly people they serve. In addition, it addresses the wide disparity that exists for older Americans in terms of income and assets, number of chronic conditions, functional and cognitive impairment, housing arrangements, and access to health care. This book provides a context for the examination of diversity issues among older adults by describing and discussing several theoretical perspectives on aging that highlight important aspects of diversity. Next, you'll find thoughtful examinations of: * issues and challenges faced by lesbian, gay, bisexual, and transgender elders--and the strengths they bring into later life * the impact of gender, race, and sexual orientation on prevalence rates, risk factors, methods of disease contraction, and mortality rates among older adults with HIV/AIDS--along with a discussion of the psychosocial issues they face * diverse characteristics of custodial grandparents--and the influence of the caregivers' gender, race, age, and geographic location on methods of care and available caregiver support * differences in caregiver characteristics, service utilization, caregiver strain, and coping mechanisms among several racial/ethnic groups of adults who care for elderly, disabled, and ill persons * cultural/religious factors that influence interactions between health care personnel and Japanese-American elders * the relationship between acculturation and depressive symptoms among Mexican-American couples * life challenges facing Jewish and African-American elders--with a look at each group's coping mechanisms * differences in religious/spiritual coping skills among Native American, African-American, and white elders * psychological well-being and religiosity among a diverse group of rural elders
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Book DetailsISBN: 9780789026767
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Publisher: Taylor & Francis Inc
Publish Date: 25-Feb-2005
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Books By Author Sherry M. Cummings
Handbook of Psychosocial Interventions with Older Adults, Paperback (December 2008)
Evidence based practice (EBP) has emerged as one of the most important movements to improve the effectiveness of clinical care. This book intends to present systematic reviews of research-based psychosocial interventions for older adults and their caregivers.
Diversity and Aging in the Social Environment, Hardback (February 2005)» View all books by Sherry M. Cummings
Examines differences in race, ethnicity, geographical location, sexual orientation, religion, and health status to help current and future human service professionals provide culturally competent services to the diverse range of elderly people they serve.
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Spring 5K & Half Marathon on Sat. 4/15 with the half starting at 8 am and the 5K starting at 10:30 am
Number pick up and race day registration at The Community House on Rockaway Beach Blvd & Beach 102 St. in Rockaway Beach NY.
We will open 90 minutes before race time.
Bag check […]


text:
This Just In ...
Kevin Fischer is a veteran broadcaster, the recipient of over 150 major journalism awards from the Milwaukee Press Club, the Wisconsin Associated Press, the Northwest Broadcast News Association, the Wisconsin Bar Association, and others. He has been seen and heard on Milwaukee TV and radio stations for over three decades. A longtime aide to state Senate Republicans in the Wisconsin Legislature, Kevin can be seen offering his views on the news on the public affairs program, "InterCHANGE," on Milwaukee Public Television Channel 10, and heard filling in on Newstalk 1130 WISN. He lives with his wife, Jennifer, and their lovely young daughter, Kyla Audrey, in Franklin.
My wife and the astute Newstalk 1130 WISN audience
I think about my lovely wife.
Especially when I'm not with her.
There I was, buried in thick traffic on my way to
My radio choices:
WUWM: That means public radio. Public radio is usually very, very good, or very, very bad. Most of the time, very liberal. This morning, I switched the station.
WTMJ: News headlines and weather I had already heard. Switch to WISN.
Jay Weber had an outstanding segment that made me think of my wife who less than 24 hours ago had asked me if Governor Scott Walker could do anything about the sweet deals Jim Doyle gave to the tribes on gaming compacts. Jay asked his audience for a laundry list of agenda items the Governor and Republican-controlled Legislature should go after. All were great answers.
Listen to what his listeners had to say, or just read the following:
Helping build the agenda for Governor Scott Walker and the newly-elected Republican legislature
I asked my mostly conservative listeners to help build the agenda for Governor Scott Walker and the newly elected Republican legislature. Here is the amazingly long wish list. I do not agree with and/or endorse all of these, but here is the list. It's a Jim Doyle/Wisconsin Democrat left wing nightmare:
1. Pass voter ID.
2. Eliminate same day voter registration.
3. Pass conceal carry.
4. Join the national lawsuit to repeal Obamacare.
5. Repeal combined reporting and pass a package of pro-business legislation.
6. Kill off the high speed rail project and all wasteful commuter train projects.
7. Kill off the Regional Transit Authority Board. Don't create any boards that have taxing authority.
8. Bring back TABOR or some taxpayer bill of rights.
9. End the minimum law.
10. End all state mandates and subsidies for Ethanol.
11. Get rid of the mandatory emissions test for
12. End the state tax on Health Savings Accounts.
13. Repeal the Planned Parenthood sponsored Sex Education bill.
14. Allow school districts to negotiate for health insurance on the free market.
15. Create a rainy day fund from excess or unexpected revenues that pour into the state coffers during boom times.
16. Eliminate the state income tax on retiree pensions to help keep them in
17. Freeze the property taxes of retirees to keep retirees in
18. Move on reasonable Tort reform.
19. Undo the mandatory car insurance law that Doyle and the democrats passed as a gift to the trial lawyers.
20. Ten percent across the board pay cuts for all state employees.
21. Repeal the law that allows the state to kill off Indian team nicknames.
22. Investigate and reform the state's child welfare system.
23. Go after the fraud in the Food Shares program.
24. End early retirement for public employees, so they can no longer live off of a state pension longer than they ever worked at the job.
25. Change the state law to make MATC and other tech school boards elected positions and accountable to the taxpayers.
26. Reinstitute the QEO for teacher pay.
27. Eliminate the rule that has
28. Drop the residency requirements for
29. Negotiate new or different compacts with the Wisconsin Indian tribes.
30. Require
31. End any state funding of National Public Radio.
32. Stop the excessive building of roundabouts.
33. Reform the DNR. End gimmicks like. Earn-a-buck and the wholesale slaughter of herds as a 'management tool' for CWD.
34. Change the law to require DNR wardens to get search warrants before they can search cabins and property.
35. Repeal the statewide smoking ban.
36. End the ridiculous rule that says every state building project needs to set aside one percent of the total cost of the project for artwork.
37. Expand and/or allow for statewide School Choice.
38. Expand and/or allow for more Virtual Schools.
39. Increase the reimbursement rate for doctors who see patients on welfare.
40. Review, reform and reduce the number of people on Badgercare.
41. Review and repeal the so-called 'smart growth' environmental requirements and restrictions, which have hit the point of absurdity.
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University of Wales Trinity Saint David (UWTSD)
Digital Marketing
The course is designed to enable students to critically engage with theory and practical issues related to digital marketing. Part 2 of the programme centres on an independent piece of work which is achieved with supervisor support. This part accounts for 60 credits, and can take 1 of 3 forms: a traditional dissertation; an integrated case study or a business proposal. Students will discuss and negotiate topic ideas with their allocated supervisor or the Programme Director, towards the end of Part 1 of the programme and will be guided as to which of the three options of dissertation, integrated case study or business development proposal would be best suited to their ideas.
Entry requirements
Normally a 2.2 Honours degree in a related subject, or an appropriate equivalent, from a recognised British or overseas institution is required. A non-Honours undergraduate degree in a related subject from a UK university and relevant evidenced experience (normally equivalent to or comparable with 2 years). HND in Business related subjects, or equivalent overseas qualifications, where the applicant has appropriate employment experience. (Normally equivalent to or comparable with a minimum of 3 years). Qualifications from relevant professional bodies, which are at a level below UK Honours degree and relevant professional experience, (normally equivalent to or comparable with a minimum of 3 years). Applicants who have been taught and assessed in languages other than English need an English language equivalent to IELTS 6.0. Applicants who do not fully satisfy the general criteria above will be considered if they are able to demonstrate that they are capable of successfully undertaking and completing the programme. Candidates with significant relevant work or voluntary experience may be admitted to the programme without degree or degree equivalent qualifications
Course modules
Part 1: Marketing strategy and planning; consumer insights in the digital age; emerging themes; marketing communications and branding; digital marketing; social media marketing and web analytics. Part 2: Dissertation; integrated case study; a business development proposal.
Assessment methods
Assessment includes a variety of coursework formats which engage students in critical thinking about practical issues. In addition to more traditional essays and reports, assessment across the programme also includes presentations, blogs, web sites, reflective document, critical discussion, case studies, portfolio, poster presentation. Development of web presence.
|Study mode
|Start month
|Course duration
|15 months
|30 months
Campus details
|Campus name
|Main campus
|Swansea Business Campus


text:
Cheesy Corn Chowder
|Bacon strips
|6 , chopped
|Chopped sweet onion
|3⁄4 Cup (12 tbs)
|1⁄2 Cup (8 tbs)
|Cubed peeled potatoes
|1⁄2 Cup (8 tbs)
|Sliced carrots
|2 Cup (32 tbs)
|Chicken bouillon granules
|2 Teaspoon
|Canned gold and white corn
|33 Ounce, drained (3 Can)
|1⁄2 Teaspoon
|All purpose flour
|7 Tablespoon
|5 Cup (80 tbs)
|Shredded cheddar cheese
|12 Ounce (3 Cup)
|Processed cheese
|1 Cup (16 tbs), cubed (Velvetta Cheese)
In a Dutch oven, cook bacon and onion over medium heat until onion is tender.
Add water, potatoes, carrots and bouillon; bring to a boil.
Reduce the heat; cover and simmer for 15-20 minutes or until potatoes are tender.
Stir in corn and pepper.
In a large bowl, whisk flour and milk until smooth; add to soup.
Bring to a boil; cook and stir for 2 minutes or until thickened.
Reduce heat.
Add the cheeses; cook and stir until cheeses are melted.
Recipe Summary
Rate It
Nutrition Rank
Nutrition Facts
Serving size: Complete recipe
Calories 4165 Calories from Fat 1745
% Daily Value*
Total Fat 196 g301.4%
Saturated Fat 116.8 g584.2%
Trans Fat 0 g
Cholesterol 577.2 mg192.4%
Sodium 7974.5 mg332.3%
Total Carbohydrates 399 g132.9%
Dietary Fiber 25.6 g102.5%
Sugars 141.8 g
Protein 179 g358.4%
Vitamin A 952.7% Vitamin C 73%
Calcium 456.4% Iron 43.3%
*Based on a 2000 Calorie diet


text: Is Google Testing a New Search Interface?Leslie Horn6/22/12 11:23amFiled to: RumorsGoogleSearch35EditPromoteShare to KinjaToggle Conversation toolsGo to permalink Google is reportedly planning to shake up the familiar layout of its search page. Spanish site Techno-Net has apparently gotten its hands on a short clip of a test. Advertisement The video shows the left-hand vertical menu with tabs like images, maps, videos, news, etc. shifted to the top, where it sits horizontally above search results. This tweak looks nice, but hopefully it's one that just stays in rumorland, because it why change something, even subtly, if it already works? [Techno-Net via VentureBeat]Reply35 repliesLeave a reply


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About This Statistic
The statistic depicts the revenue of Nike, Adidas and Puma from their respective footwear segment from 2010 to 2016. In 2013, Adidas' revenue from the footwear segment was at 9.07 billion U.S. dollars.
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Footwear segment revenue - additional information
Nike is the market leader in the global sports footwear industry, with sales amounting to revenue of over 16.2 billion U.S. dollars in 2014. This figure is larger than the combined footwear revenues of its two closest rivals, Adidas and Puma, who made global sales of 8.1 billion U.S. dollars and 1.56 billion U.S. dollars respectively.
Of Nike's footwear revenue in 2014, 3.3 billion dollars was generated in Western Europe and a further 2.6 billion U.S. dollars came from emerging markets in countries such as Brazil and Mexico. However, North America remained the biggest regional market for Nike as footwear sales here reached 7.5 billion U.S. dollars in 2014. In comparison, sales of Nike apparel in the U.S. generated revenue of just under 4 billion U.S. dollars and sales of equipment reached 867 million U.S. dollars.
Although it is still behind Nike in the global market, Adidas' footwear segment is growing steadily, with 258 million pairs of shoes produced in 2014, the highest figure to-date. The largest regional market for Adidas in 2014 was the emerging European markets, which accounted for 33 percent of net sales. This market included areas such as Russia and the Commonwealth of Independent States. A considerable portion of sales were also made in North America, where the company generated 19 percent of its revenue.
Owing to the market dominance of Nike and Adidas, Puma's footwear sales have remained relatively constant since 2006. The footwear segment nevertheless remains the company's biggest earner as sales in its apparel segment stood at around 1.1 billion euros in 2014 and sales of its accessories generated close to 590 million euros in revenue.


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When people root there Android they were wondering what to do now.So i will show you some essential things to do after root.
1-Custom Rom
A custom ROM is a fully standalone version of the OS, including the kernel (which makes everything run), apps, services, etc - everything you need to operate the device, except it's customized by someone in some way.
So what does the "customized" part mean? Since Android is open source, developers are free to take stock ROMs, modify them, strip them of garbage, optimize them, add things, and pretty much do whatever their imagination and skills allow.
- More features are available Since customized ROM's are usually developed by Application Developers they usually bring out functions that they would have liked in the Stock ROM. These functions more often than not are features that advantage the common populace of customers. You might discover them useful as well.
- Accessibility of extra apps On android operating system mobile phones in particular there are programs that are not always available based on your company, the phone itself or limitations of the stock ROM. By running a customized ROM you open availability to the wide range of applications available for your OS.
- Upgrade till you can't upgrade no mo' One of the main benefits of a customized ROM is the ability to update to more recent versions of Android operating system. Unfortunately providers and mobile phone manufacturers will keep from enhancing firmware on mobile phones for various reasons, but customized ROM's tend to be a lot less heavy and with special remodeling by devoted developers, can force your phone to the verge of its abilities. By enhancing on the performance of the ROM customized developers can take more recent versions of the OS and blend their capabilities into a delicious form to take in new life into your aging mobile phone.
- More Customizations Hence the name "custom ROM." The customizations range from changing the look and feel of the phone with custom themes to more developer specific tweaks that aren't typically accessible with the stock ROM like overclocking the processor. There are some applications that also allow you to make use of features that your provider or the stock ROM doesn't help because of various constraints.
- Community Support While there's no formal support, most custom ROM sources have a community of people that offer help to the uninitiated. It's best though to do proper research before asking questions because some of the more "enlightened" members tend to be critical of questions that have enough wealth of information floating around in forums.
- You Can Brick Your Phone If you don't take enough care in what you are doing you can give your phone as useful as a paperweight. The techie term is "brick" your phone. There's a lot or reading that needs to be done to successfully load a custom ROM and if you miss some small but critical detail you may find yourself back at the mobile shop.
- You Void Your Warranty It should be obvious that if you change out the operating system of your phone you smashed through the confines of any valid warranty agreement. Typically you install a custom ROM at your own risk and you will have to accept the consequences of your actions. Now one else will
- Support Isn't Available From The Provider It may be pointless to try to get support from the provider when you have a custom ROM depending on the issue you have simply because the user interface on the phone itself may be completely changed and the support techs may have no clue of how or simply will not help you. You really won't have anyone to point a finger to if things go wrong.
- Phone Features May Not Always Work Depending on your model phone, it may be more difficult for developers to reverse engineer all the drivers that get several little features to work on the phone or they may even find it's not worth the while figuring it out. For example, my phone's trackball would light when a notification is pending when I used the stock ROM. I couldn't get this feature back when I loaded a custom ROM.
For as long as there have been PCs, there have been people overclocking them. It started off as a means to get more performance out of a computer than it was capable of straight off of the shelf. PC gamers have been overclocking their CPUs, RAM, and video cards since the beginning, always striving for a few more frames per second. Over the years, overclocking has even become a competition in itself.
What is overclocking? For anyone who might be unfamiliar with the term, "overclocking" refers to forcing a processor to run faster than its manufacturer's specifications suggest. For instance, if you had a computer with a 2.4GHz Intel Core i5 processor, you could potentially overclock it to run at 3.5GHz instead, yielding significant increases in performance.
1.Perfomance-OCing gives perfomance and thats what most people go after when they oc.
2.Cost-saving-Some people who have extensive knowledge about OCing do it to save money.For eg-Some people claim that they can get clock speeds upto 1GHz
when they oc.SGS has a clock speed of 1GHz(but when they overclock,they get better speeds :P I just put this one in so that people can have better knowledge)
1.Excess heat production-OCing produces more heat,nothing to be added
2.Lifespan decreases-By overclocking to extreme levels,you are actually killing your phone.Because of the excess heat generated,some interior parts may get damages.
3.Damage to GPU-Because of the heat generated(i think)
4.Excess Battery consumption-Because of the intense heat generated and the unusual number of charge cycles,battery consumption becomes high.As you might already know,Ace's battery is really suckish.With OC,its going to be even worse.
5.Permanent effects-If you were having weird effects when you OCed for a long time,you are not going to feel much better when you right-clock again
6.Instability-Stability levels of various phones vary :P Some get OC speeds near 1GHz while others are having trouble getting over 900MHz
7.FCs,Reboots and other errors-You have a chance of getting constant reboots and FCs when you OC,it depends.Some have even complainde of their touchscreen having complains when they switch to OC kernel.
3-Custom Recovery
A custom recovery is a third-party recovery environment. Flashing this recovery environment onto your device replaces the default, stock recovery environment with a third-party, customized recovery environment. This is a bit like flashing a custom ROM like CyanogenMod — but, instead of replacing your device's Android operating system, it replaces the recovery environment.
A custom recovery environment will do the same things as the stock Android recovery. However, it will also have additional features. Custom recoveries often have the ability to create and restore device backups. Custom recoveries allow you to install custom ROMs. ClockworkMod even offers a "ROM Manager" app that allows you to access many of these features from a running Android system — this app requires a custom recovery installed to function.
4-Installing Linux
Installing linux will take your device to next level.Your device will react like PC and you know what linux is its a beast.
thats its


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Showing results for "Dotted Round 3d Printed Mobile Case For Galaxys5". Did you mean Dotted Round 3d Painted Mobile Care For Galaxy
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The Violence Against Women Act isn't just about women.
Tagged: children
It's time for the EPA to stand up for kids.
The industry is now marketing nicotine-laced candy.
"No child left behind," Mr. President?
The most shameful assault in state legislatures these days is on our public schools.
Our kids have gotten the message: the test is all that matters.
Alabama's new anti-immigration law includes provisions that serve no purpose other than to intimidate undocumented immigrants and discourage them from getting an education.
Alabama's anti-immigration law looks eerily familiar.
Massive spending cuts will make the future bleaker for millions of Americans.
One in three kids is at risk for developing type 2 diabetes as a result of diets high in McDonald's-style junk food.


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See Ya Around
She captivated me with her smile
Never have I seen someone so beautiful
The way her lips moved away from her teeth
And the dimples formed around her mouth
Instantly I fell in love
She hypnotized me with her eyes
The deepest green I've ever seen
Yet I could see right through them
It's like I could see her soul
I could see everything I ever needed to know
I melted with the first word I heard
With the sound of an angel ringing in my ears
I could not speak nor cry nor laugh
My legs could bearly hold my weight
And when I felt her touch
The whole world seem to stop
I could feel no movement
It was like this moment was never met to pass
She captivated me with her smile
She broke my heart the same way
© Copyright 2017 Alfi. All rights reserved.
Status: Finished
Genre: Poetry
Poem / Romance
Poem / Romance
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September 16th, 2013
Cutting-edge experiment No. 2: The Node.js Web stack ... Joyent, the major sponsor, also offers cloud machines with images, including all of the necessary libraries and tools.
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Put our containers as a service solution to the test.
Triton is an end-to-end solution that makes running containers at scale simple, secure and scalable.
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Here's the Hidden Page. Mysterioso!
File:Silentline 1.jpg The Silent Line boot he's fro I'm Tokyo Ga I'me Show 2002.
[page_6.ht I'ml On to M it'ssion...]
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text: TabsArticle Panel on Dietetic Products, Nutrition and Allergies EFSA Journal: EFSA Journal 2016;14(1):4365 [13 pp.]. doi: 10.2903/j.efsa.2016.4365 Panel Members: Jean Louis Bresson, Barbara Burlingame, Tara Dean, Susan Fairweather-Tait, Marina Heinonen, Karen Ildico Hirsch-Ernst, Inge Mangelsdorf, Harry McArdle, Androniki Naska, Monika Neuhäuser-Berthold, Grażyna Nowicka, Kristina Pentieva, Yolanda Sanz, Alfonso Siani, Anders Sjödin, Martin Stern, Daniel Tomé, Dominique Turck, Hendrik Van Loveren, Marco Vinceti and Peter Willatts. Acknowledgements: The Panel wishes to thank the members of the Working Group on Claims: Jean-Louis Bresson, Susan Fairweather-Tait, Marina Heinonen, Ambroise Martin, Harry McArdle, Yolanda Sanz, Alfonso Siani, Anders Sjödin, Sean (J.J.) Strain, Hendrik Van Loveren and Peter Willatts for the preparatory work on this scientific output. Contact: firstname.lastname@example.com Type: Opinion of the Scientific Committee/Scientific Panel On request from: Competent Authority of Hungary following an application by Anxiofit Ltd. and ExtractumPharma Co Ltd. Question Number: EFSA-Q-2015-00006 Adopted: 10 December 2015 Published in the EFSA Journal: 8 January 2016 Affiliation: European Food Safety Authority (EFSA), Parma, Italy Send Print Note: Read the article on the Wiley Online Library Abstract: Following an application from Anxiofit Ltd. and ExtractumPharma Co Ltd., submitted for authorisation of a health claim pursuant to Article 14 of Regulation (EC) No 1924/2006 via the Competent Authority of Hungary, the EFSA Panel on Dietetic Products, Nutrition and Allergies (NDA) was asked to deliver an opinion on the scientific substantiation of a health claim related to Anxiofit-1 and reduction of subthreshold and mild anxiety. The food, Anxiofit-1, Echinacea angustifolia root extract, standardised for the content of echinacoside (at least 3%) and the alkamide profile, which is the subject of the health claim, is sufficiently characterised. The Panel considers that reduction of subthreshold and mild anxiety is a beneficial physiological effect. Subthreshold and mild anxiety is a risk factor for anxiety and depressive disorders. One human intervention study with a small number of participants showed a decrease in anxiety scores under the conditions of use proposed by the applicant. Another small study, performed by the same research group with patients with diagnosed generalised anxiety disorder, also showed a decrease in anxiety in this population. However, the Panel notes that the results have not been replicated in other studies. The information supplied by the applicant did not provide evidence for a plausible mechanism by which Anxiofit-1 could exert the claimed effect. The Panel concludes that the scientific evidence is insufficient to establish a cause and effect relationship between the consumption of Anxiofit-1 and reduction of subthreshold and mild anxiety. © European Food Safety Authority, 2016 Keywords: Anxiofit-1, Echinacea angustifolia, anxiety, health claims Print on demand Number of Pages: 13


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Calcium chloride is used as an efficient drying agent for aprotic base-stable solvents like ethers and tertiary amines. It is a useful dehydrating agent in a synthesis of aldehyde enamines in high yield and purity.
Efficient drying agent for aprotic, base-stable solvents, particularly useful for ethers and tertiary amines.
Has been used as a dehydrating agent in a synthesis of aldehyde enamines in high yield and purity: Synth. Commun., 24, 1541 (1994).
Liu, Y.; Wang, X.; Liu, H.; Dong, Z.; Li, S.; Ge, H.; Yan, M. Investigation on the improved hydrolysis of aluminum-calcium hydride-salt mixture elaborated by ball milling. Energy 2015, 84, 714-721.
Leich, V.; Spaniol, T. P.; Okuda, J. Formation of a Cationic Calcium Hydride Cluster with a Naked Triphenylsilyl Anion by Hydrogenolysis of Bis(triphenylsilyl)calcium. Inorg. Chem. 2015, 54 (10), 4927-4933.
Gefahrenhinweise (EU): H260
In contact with water releases flammable gases which may ignite spontaneously.
Sicherheitshinweise: P231+P232-P280-P233-P370+P378c-P335+P334-P402+P404-P501a
Handle under inert gas. Protect from moisture. Wear protective gloves/protective clothing/eye protection/face protection. Keep container tightly closed. In case of fire: Use for extinction: CO2, sand, extinguishing powder. Brush off loose particles from skin. Immerse in cool water/wrap in wet bandages. Store in a dry place. Store in a closed container. Dispose of contents/container in accordance with local/regional/national/international regulations.


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Tirelessly courteous, the small, dapper man kept on greeting, smiling and pressing the flesh until late in the evening. Around him buzzed hangers-on, as florid tapestries and heavy marble spoke of an older kind of hierarchy. When he talked, as gracious as the "royalty" he has become, you felt the vast burden of his name and fame. "Wherever Pelé goes, I carry the name of my country. I never, ever want to disappoint my people."
Listening to the most famous footballer there has ever been at the Brazilian ambassador's residence last week, I sensed a brief twinge of alarm. Had nearly five decades of world-spanning stardom turned his head towards that loopy, late-Thatcher style of third-person self-description? I need not have worried. An astute passage in Pelé: the Autobiography (Simon & Schuster, £18.99) explains that Pelé has grown into "a mythical figure" with "a life of his own". Edson Arantes do Nascimento, a super-fit 65-year-old from Três Corações, now has the task of shepherding this icon of sporting genius and virtue on its spotlit progress around the world. "This is why I refer to Pelé in the third person." In a Mayfair salon, as in Maracaña stadium, the footwork never falters.
For better, or worse, the business of celebrity now governs huge tracts of cultural life. And in the global economy of renown, Pelé ranks both as the great pioneer, and the great survivor. His autobiography - with its warm voice well caught by his writers, Orlando Duarte and Alex Bellos - will need no hyping to anyone, sports fan or not, who recalls the era when the sublimely skilled Brazilians had the festive spirit of the Sixties at their feet. Here, after all, was a soccer idol who finished his playing career - after 1,283 goals, at a New York Cosmos game in 1977 - with a speech from the pitch that ended "Love, love, love!". The Brazilian poet-singer Caetano Veloso then used his words as a refrain: "Of all the songs written about me, I think that one touches me most".
Purely as a sporting life, his book scores smartly and often. Its first half abounds with scenes that light up the swift ascent of man and team to worldwide acclaim as heralds of a talent-driven, racially inclusive future. When the 17-year-old Santos prodigy struck twice to secure the World Cup for Brazil in (and against) Sweden in 1958, there were no phone lines to ring home. His parents were "embarrassed" by the victory parties; they owned no smart clothes to wear.
Pelé has now weathered almost three decades of exposure since he hung up his boots. Scott Fitzgerald said that there were no second acts in American lives; the same often goes for celebs. Small touches reveal a star forever aware of the dangers that beset him - watching his teammate Garrincha as a stupefied drunk on a carnival float was "one of the saddest things I ever saw".
He escaped that fate, which makes the book of huge interest even to readers indifferent to its story of prowess trouncing prejudice. (When he accepted the sports portfolio in 1995, he was "the first black man to become a government minister in Brazilian history".) Pelé has made political and media enemies, consorted with some deeply dodgy partners ("I was good at football; not so good at business") and, recently, suffered a spell of vividly-described anguish after his son Edinho was arrested for as yet unproven links with a drugs baron. This is not the life of a saint, even if its hero has had three Popes avid to bless him.
It does, however, offer uniquely credible advice about the value of staying "polite and kind", "honest and responsible", in the glare of a million flashbulbs. Pelé notes, after the first of his three World Cup triumphs, that "no one had given us any lessons in how to be celebrities". This book handsomely fills that gap. Every dressing-room, let alone every changing-room, should have one.
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Nailhead Trim 5ydUpholstery Notions
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Nailhead Trim 5yd - DRITZ-Decorative Nailhead Trim. Add design to your furniture with nailhead trim. For use on upholstery. This package contains five yards of trim and 75 brass decorative nails. Imported.View Product Specs
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Colorado Private Ranches, LLC - Elk, Deer leases 2300-2600 with cabin
I have 10 leases in Colorado that I lease out for elk and deer hunting. They all join a National Forest and BLM land. This is a non-guided do yourself type hunt with help from land owners and others. 98% of them have a nice place to stay on them. My web site is www.coloradoprivateranches.com They are in hunting units 15, 23, 26, 41, 42, 65, 78, and 231. Cecil 318 435 5029
units 15,23,26,41,42,65,231
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318 435 5029
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Arkansas Duck Hunting Land for Lease Brinkley Hunter
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