 It matters so many constitutional issues, you know? I think every business organization, every media organization has to have a constitutional lawyer, you know? On the staff, always available. Great idea, Jay. Avi Soyfer, the former dean of the Woody Mesh Richardson School of Law and active faculty member on constitutional law right now today. And it is the most important area of law in a country where democracy is in question. Thank you for coming to the show, Avi. My pleasure, as always, and good to see you, Jay. Good to talk about these important issues. Well, let's talk about Ukraine because we always start out with a little bit of Ukraine. And I just posted the Ukraine national anthem on our website. If anybody wants to listen to it, it's stirring. It says so is Zelensky stirring. And so is, you know, Zelensky as Jewish person is stirring. And so is this whole recollection of, you know, the Jews in Ukraine here on the Purim, which starts tomorrow, which is tomorrow, where we read the Megillah. The whole Megillah. The whole Megillah, which takes quite some time. But it's very interesting because it goes back to the days of old Iran, our friends in Iran, Persia and Mordecai and Haman and Akashveros. Esther was my favorite, a great story, a great narrative. It ends okay, although it was an attempt at genocide. So you want to comment at all about Purim and how Purim connects us with, you know, with what's going on in Ukraine? Well, I just thought of this as you were talking. And that is, you may have to take Ukraine with a grain of salt when you hear Jay talking about it. It's a little joke there, Jay. A grain, the grain part? Yeah. Yeah. So Purim is a boisterous holiday and there are not many in the Jewish tradition, but it is the holiday on which you're supposed to drink so much. You don't know the difference between Haman and Mordecai between the bad guy and the good guy. And those who are Orthodox Jews actually often try to follow that. But it's a celebration, somewhat like the ones that go on with Mardi Gras and so on, a lot of costumes and celebratory meals and lots of camaraderie. What it notes, what it celebrates is they really did try to kill all the Jews and the Jews didn't die and instead as the old jokos we eat. So that's what we do. Now it ends with a kind of reverse bloodiness which is that Haman, the bad guy and his sons are killed and up on pikes and their heads and so on and so forth. But it's all because of Esther who intermarried. She married the king because she won the beauty contest and she finally at the peril to her life goes to tell him the king that her people, the Jews are supposed to be killed. Haman has been plotting against them and the king, if he moves his specter one way, she dies but he welcomes her and Haman then is done in rather than the Jews. Great story. It is quite a story. And the kids are supposed to drown out the name of Haman whenever it's said during the reading of Megillah and they get little noise makers and so kids like it. Others get a headache, but that's the story. And so it's a one day, it starts tomorrow evening. It's a day said and it's a one day holiday and it's big stuff in Israel. They really do celebrate. Well, I'm sure it was big stuff in Ukraine when my family lived there, you know? They lived in Ukraine. They lived near Kiev in a village called Kamenetspadolsk and they celebrated holidays like Purim in Zishtetl. And I'm sure that Fiddler on the Roof, not to say there's a relationship between Fiddler and Fidel, but Fiddler on the Roof took place in that very same area. So, you know, the Jews and Ukraine have a long history together. Some of it was not pleasant. In 1905, they came here like family because there were programs in Ukraine. And we can't forget that. I think it's a different generation now, but then it was pretty hard. And there was a lot of collaboration between a lot of Ukrainians and the Nazis. So that's the thing that is also a much remembered, but you're right. It was a very important place in Jewish culture and in Jewish learning, actually. The founder of Qasidism, the Baal Shem Tov was from Ukraine. So you trace it back to some very important Jewish traditions and Ukraine and the borderistic Belarus very important in Jewish history. Different generation now. Five years ago, there was a college president from the University of Kiev here. In those days, they call it Kiev here at UH. And I met him and I told him about my family. I told him about my religious persuasion and so forth. And he was absolutely, he was not Jewish. He was so interested to meet me, so sweet, so nice. And I began to get the feeling that there is another generation in Ukraine, a generation that could elect a Jewish president and so forth. And he has been amazing. He just has a wonderful sense of who he's talking to and he adjusts what he's saying, but what he's saying is actually the same thing, which is very courageous. And I don't foresee a happy ending really, but it's been great that he has been the leader and he didn't take off, he didn't need that ride. So he's still there and he's still influencing things for brave people to really be giving up their lives for their country. He understands this is an inflection in human history and world history right now. And he's an important member of the inflection. And yes, but you're right, it may not end very well. And I find it very interesting that today, Vladimir Putin issued sanctions against Joe Biden, son, a number of people in government, not only in government today, but people who have been in government in the past. He just let it fly in all directions. This is interesting kind of a Trump-esque kind of move. You double down, you respond, may I use the term gaslight? You respond and everybody wonders where you got that from. You meet fire with fire, except there is no fire. So the question I put to you is, should I be concerned? I mean, there's an application form circulating now where you can apply to be sanctioned by Vladimir Putin. Some people consider it a badge of honor. But if I do that and I become, if I'm lucky enough to be sanctioned by Vladimir Putin, will he be able to enforce any sanctions against me? By the way, just to add, I do not have any assets or land in Russia, nor do I intend to have them. He knows about you, Jay, even if you don't sign. So, to the extent you have to worry, you have to worry already. But it's pretty ironic, isn't it? That the way to get at Russia is a way of getting at capitalism. It's getting their assets. It's getting their investments. So here we have socialism vulnerable because it's so intertwined with capitalism that that's the level of response that we are primarily making. I think in the end, this was a ridiculous move and everybody in every country in the world will see it that way as a ridiculous move. I mean, really sanctioned again. But it may be the last, I mean, as people are saying, he may not think he has to stop with Ukraine. So this is a real concern. He has his reasons. There was an article in the, where was it, a foreign affairs a couple of days ago for the proposition that this is actually capable of these times with the right moves of restoring Pax Americana. And reminding us that as Henry Kissinger said years ago that you have these two competing systems, the East and the West are Russia and the US and China tagging along with Russia. And you know what? That hasn't stopped. There's stills going on and we see it now. So that's why it's an inflection in history, I think. So let's talk about law for a minute, Abbey. So let's talk about this bizarre Missouri and Sippian statute they're about to pass that reaches beyond Missouri and would make, I guess make it criminal on a vigilante basis of any Missouri resident who went to another state and had an abortion. It just, it tests federalism, doesn't it? It tests the basic structure of states' rights. Isn't that a conservative concept of states' rights? What's happening here? It seems to rise and fall depending on what the issue is. And I've spent a fair amount of time teaching and some writing about federalism and it is not nearly as simple as people like to say. So I guess one of the things I wanna say is if any law students are watching, you gotta kinda hold your wallet when people say our federalism as if it gives the answer. Yes, we have federalism and it's an incredibly mixed matter these days because the federal government, of course, is giving a lot of money to the states. Individuals are supposed to have rights because of federalism, but in fact, in recent days or recent years, the Supreme Court has said, oh, you can't coerce the states but you can coerce individuals. A gun to the head in the Shelby County Voting Case, which is Chief Justice Roberts decision, unfortunately. So that you can't do. But you can compel individuals to do things even in the world of Medicare and Obamacare. So it's a weird and very complex area. And if you do history, you find that states' rights was big in the anti-slavery movement. And ironically, the Confederate would soon to be Confederate states were the ones who were saying, oh, the federal government has to help us return slaves to their status in the South. And it was Northern, you could say, digital aunties, but I wouldn't consider them that abolitionist heroes who were freeing slaves, sometimes from courthouses, as a matter of fact. And the feds were very mad about that. And so were the Southern states. Then they turn around. And of course, the Civil War is about states' rights and about state sovereignty. And they lost, but that's kind of forgotten. They lost on the field of battle, but they seem not to have lost legally because states' rights keeps coming back. And it comes back in ways that are really astonishing, even with a majority of the states in the case saying, we support the Federal Violence Against Women Act. Court says, we don't care what you say, we're doing this on your behalf. So there's a paternalism for states' rights that the court has been insisting upon in a whole range of cases, pretty weird. Twisted, twisted. I wanna get to twisted, but first I wanna ask you about what happens in the second phase of this Missouri statute because there was a, I guess it was an op-ed piece by a fellow named Conan Law Professor and two other law professors who said, we're in a battleground, a battlefield on abortion. And they spoke of incipient legislation in the state of California, which would make it very hard for the state of Missouri to chase its residents around and prosecute them for getting abortions in the state of California, like non-cooperation statutes in the state of California. And I mean, I would support that. I think a lot of people would support non-cooperation statutes like extradition, limit extradition and release of documents and public records that relate to the abortion that Missouri residents might have in California. But here's, and Hawaii might do the same thing, Avi, the same thing right here, just like California. And I would support that. But here we have a state trying to reach across the border and other states saying, no, you can't. And gee, the founding fathers must be spinning in their graves. They even see this sort of thing happening. This is such fragmentation of the nation that we have one state trying to reach across the border and the other saying, no, you can't. And having competing statutes and having to get to this, having a Supreme Court where you can't, you can't really know what it's gonna do. Well, I think sadly we kind of do know what they're gonna do about abortion. Although I think there's much too much attention paid by media and I guess a lot of individuals too, to will they overrule Roe versus Wade? Because in practical terms, they have already. The test is no longer anything like what Roe versus Wade talked about. The court said it's an undue burden. So what is an undue burden? Well, the court will tell you case by case what an undue burden is. And lots of restrictions on the right have been considered not undue burdens. So that's my prediction would be they're not gonna explicitly overrule Roe versus Wade. They're gonna extend their attack on Roe versus Wade and say, well, this is not an undue burden either, whatever it is, 15 months. We'll see what they say about the heartbeat, the Texas law. But some of what you just pointed to is a reaction to what Texas is trying to say, which is any individual can sue anyone who cooperates in any way with an abortion. And that's just astonishing that it's still with us because one would have thought that the challenges to it were at least enough for the justices to intervene and say, well, this is an emergency situation. There is a right, it's still on the books. We haven't overruled it. And even if some judges in the Fifth Circuit think we have, we haven't. And therefore the right should be protected. That's what emergency orders are for and they wouldn't go there. And they had several chances. So the Texas law is still in effect in sharp contrast to the court saying, oh, there is an emergency. If there's an intrusion on religious free exercise because of the laws that have to do with the pandemic. In New York state, the law wasn't even in effect. And on the eve of Thanksgiving a couple of years ago, the court said, oh, this is an emergency. We're not gonna let the Second Circuit decide this. We have to intervene right away without briefs, without argument. That was an emergency. Texas situation, women denied an abortion, not an emergency at all. It's really stunning. So I think you have to be pessimistic about this court. And they are taking case after case that raised the really big social cultural issues of our time. Not much notice, but they took affirmative action the Harvard admissions and now North Carolina. So it's both private and public schools. And they probably didn't take it to a firm. And the North Carolina case is very underdeveloped. So there's a strategy there. But they've also taken a case involving the Indian Child Welfare Act, which favors Native Americans. Why'd they take that? Well, they probably took it to say that's too much favoritism for indigenous people. So they're also gonna deal with gun rights. They're dealing with religion again and some more. And of course they're doing things to the vote, which we used to think was fundamental. And what they did with that, which ties into what I was saying, July 1st in 2021, so end of the term, they finally get an opinion out. And they said, when Arizona changes laws and restricted the vote in several important ways, didn't violate the Voting Rights Act, such as is left of it after Shelby County, no violation there. And after all said Alito, voting is itself a burden. So this is not an undue burden. It's just a little bit more burden because voting itself takes time, concentration and I suppose a little energy. So the vote is now subject to sort of the same kind of subjective review, which says, we don't think it's much of a burden. So go ahead, Arizona. I'm, that's a good thing I didn't eat before the show. But okay, so let's talk about these two terms that came up when we were trying to identify issues to discuss. One of them is textualism, which I don't think people really understand. And the other is gaslighting, which I don't think they understand in the judicial sense, although there have been a number of articles and books for that matter that have charged the United States Supreme Court with gaslighting, which is not pretty. Can you talk about those two terms? I can do that. And there happens to be an article. I haven't really, it's not published yet, but I think it's actually pretty good. And what I accuse the court of doing is gaslighting in what looks like a narrow case. It's a statutory interpretation. And the textualists, who one would think, start with the text of the statute, ignore the text of the statute altogether. They pay no attention to the text and they go off and they talk about torchlighting. This is the 1866 Civil Rights Act, parts of which are still with us, which was meant to do something right after the Civil War to protect blacks, former slaves, and they had bad things happening to them. The rise of the Klan is just one example of talk about vigilante justice and violence. That's what was happening. And there were black codes that were passed in states saying they don't have the same rights. And Congress was saying, oh, yes they do. That's the first statute that was passed over a presidential veto on any major issue, Andrew Johnson being the president. And they really talked about how important this was. Based on the 13th Amendment followed very soon same Congress by the 14th Amendment. So the text matters in this situation and the court itself has said the text matters. And yet Justice Gorsuch's opinion ignores the torch. He's off talking about torts, which does not appear in the statute. And he's actually wrong in his history of tort law as well. And so I think it is gaslighting, which is now in my title. I was emboldened somewhat by the wonderful journalist who covered the Supreme Court, Linda Greenhouse who used the phrase in one of her terrific columns recently, but it is gaslighting. And getting back to your question, textualism is appealing psychologically, right? You wish you could just look it up. It appeals to that urge. What's the answer? What does it say in the text? But the text is the starting place, but it doesn't answer itself. And I've got some evidence of Supreme Court so-called textualists actually misrepresenting what the second or third meaning in the dictionary is. So they quote it incorrectly, but they say, oh, the dictionary answers this question. Well, it doesn't because what's the context of that text? And Scalia led the way in saying, we don't care about the intent of the legislature, although even he, when he was pressed said, well, I'm not insane. I mean, I wouldn't take it to the extreme degree. But when you start ignoring the text altogether, which ought to be the starting point, then it's pretty alarming. And so that's not an example of the shadow docket. That's an example of a case that was briefed, argued, and the court went off in a very strange direction and narrowed it, including saying Congress reacted to some narrowing decisions in 1991. And they said, well, they didn't react to this decision. Well, of course they didn't, because we hadn't decided it yet. I mean, that's logically and rhetorically pretty appalling. And you say, well, they didn't foreclose what we're about to say because they didn't know you would actually say this strange, strange thing. That's really, well, that's an example of gaslighting too, I suppose. I went and looked it up. It's broad, but it always involves a deception of some kind. And I think what I get out of this is that gaslighting always, watch the verb, trumps textualism. In other words, if you can gaslight, you can do anything. So my question to you is, these are bad decisions coming down. The court is hard to argue but the court is still impartial, non-partisan. But it is partisan now. I mean, we have Kavanaugh, we have Barrett and they're doing what one might expect them to do appointed by Trump. And so the question I ask you, taken together with the other four, are they doing this purposely? Is it a mistake? Is it a faulty legal education? Is it organic? What is it? Have they do this and expect to get away with it and have nobody notice that it's backward and it's gaslighting? Well, to some extent, you can say constitutional law goes beyond the text all the time. On the other hand, you do start with the text and sometimes, and we should, I think be clear about this, sometimes textualism has good results. So you look at the text and you say, well, the text didn't change. I mean, this is what Gorsuch who claims he's a textualist and I've just complained about him. But in a case involving Indian country in Oklahoma, he said there was a treaty, happens to be the same year as the statute that I'm writing about, 1866, and they haven't changed it. Therefore, we're bound by the treaty. Therefore, criminal law on Indian land still covered by the treaty. So sometimes the text comes out in ways that I would applaud. I don't say it ends the thing or it should be ignored. I say it should be a starting place. But I think the very fact that they're taking the cases that they're taking and they have almost complete discretion, not completely, but almost complete discretion as to which cases they take is itself looking partisan. And Justice Sotomayor wrote a powerful dissent in which she talked about the stench of partisanship. Now that's strong language from someone who's actually easy to get along with and quite collegial. So she starts saying that alarm bells should go off. And she's talking about partisanship in that context. I think it was about votes, which the Warren court thought were the most fundamental of all, and they're not the first to say that. And it was not Brown versus Board of Education. Earl Warren said it was his most important decision. It was Reynolds versus Sims. It was one man, I guess he said one man, one vote. And that's what's at risk now. It's really shaky, even if it's still with us as fundamental as the court thought it was in 1964 when that decision came down. And as I said, Shelby County moves away from that. And the argument there by Roberts is, well, it was needed at the time it was passed the Great Voting Rights Act of 1965, but it's not needed anymore. Now that's a weird constitutional doctrine that, oh, it's not true, it's not true by any standard. As we have seen repeatedly already, it's not true. And it also is not a constitutional doctrine that things are unconstitutional when they start not being necessary. That's a lot of things would be unconstitutional. Well, you know where we are, you and I and millions of lawyers in this country were taught in law school whether they practice constitutional issues or not, that the Supreme Court walked on water. And they were in the balance of the balance of power, they were very important to guide the country over the long-term and find the morality, find the ethics, find the city on a hill. And we have lost that because I think most people will recognize that we have a partisan court now. This is pretty serious. And it goes to the underpinnings of, hey, the legal profession, but also the country and having confidence in the ability of the government. There are other parts of the government, you can lose confidence in too, but this one is really important and really special. Go ahead, sorry. Well, it brings us to the last area I wanna discuss with you. And that is Clarence Thomas. Well, so this goes back to some doubts about the court for a long, long time, I would imagine in terms of what Clarence Thomas has been up to. And I know you wanna talk about the recent revelations about his spouse and her activism, including her presence on January 6th, though she says she got cold and didn't go up to the Capitol. I believe it, I believe it. I absolutely believe it, I believe it, yeah. But Jay, before we leave people on a real down kind of mood, I think we should recognize, and it's important to say we've said this to one another privately as well as on camera, the court did stand up to Trump, right? And he lost 60 sometimes in his attempts to get judges on his side when he was challenging the election. Well, that's kind of significant too. And so the court is what we got. This is, I think, a terrible example as we've been talking about it. But if you didn't have the court, if you didn't have law, what would you have? And I was rearranging letters during a boring meeting. There were some boring meetings when I was dean, not ours, they were up for campus. And you take rule of law, you rearrange the letters and you have awful law. But law is not, I think, awful law. And the rule of law is important. And there's a story that Martha Minotel also clerked for Thurgood Marshall and a very empathetic situation. Someone misses filing deadline by a day and she goes in and she says, we should do this. And she and her other clerk say, they used to say, you gotta do this. And he would point up to his commission and say, I don't gotta do anything. Whose name is up there? But his answer to clerks who were saying, look, this is the kind of case you really care about. If we didn't have those rules, we would be in even more trouble. If we didn't have the rules, the procedures, and so on. So I want to say something for the rule of law as dubious as we can be sometimes about whether the court's getting it right or wrong. Well, the thing with Clarence Thomas, it was a shaky appointment in the first place. And regrettably, Joe Biden was one of the guys that helped confirm it in the Senate. The king guy, right? He wouldn't take anything like that. The king guy, yeah. And he did that for political reasons. It shows you a little more about him, I suppose. But Clarence Thomas has never been a shining example of a justice. I don't know if we want to talk about it, great. I think we can just assume that as a given. He is not the sharpest justice in the draw, so to speak. And he hasn't made much of a contribution nor has he even asked questions in most of the cases. Now he is, no, for years he was quiet. But he's actually now the senior judge. And if Roberts doesn't vote with him, then as the senior judge, the Chief Justice gets to assign if he's in the majority. Now it's Thomas who assigns the opinions. So he's in a role of responsibility within the court. So we shall see. But he, at times, insists that the text takes him back to some places where maybe we should go back. However, I agree with you that it is not a stellar judicial record. So all of that considered, this is the first time I can remember you've been following the court for years and decades and what have you, lifetimes. But I can never remember a judge who was criticized this way for having his wife go out and take a position on such a controversial threatening issue as this. And she's done it a couple of times already all within the last few months. And you really wonder what that relationship is like. You wonder what his acumen is like, that he would let her do this and that he would not recuse himself. It really seems to be unprecedented, no? I think it is. And I think it shows that we need some rules about when justices should recuse themselves because certainly one would have thought that he should. And this is perhaps just coming out for a lot of people. It's been covered in the New Yorker and in the Times Magazine and so on. And the detail is pretty shocking about not just January 6th, she's been involved in all sorts of ways, very outspoken and really a leadership role in things that are coming before the court. So. Wow, try that in the courts of Hawaii and it'll be on the front page. It's interesting that he can get away with that and who's to call them on it? Nobody, but the press can call them on it. Well, perhaps his colleagues, we shall see. We shall see. I hope so. And this goes to the question, my final question to you and something we've talked about before and I remember your answer, but I'm sure you do too. What about fixing the court? Joe Biden had a commission and it went, it was a nothing burger. We don't need to fix this. Maybe we'll get to it later. Do we need to fix the court? Do you feel differently than you did before? Well, I agree with some who think that court packing is a very risky thing to do. And I've made the point that even very good politicians like FDR discovered that there was very serious pushback when he tried to do that in the mid 30s, 1930s. So that is risky politically, but it also, you do it now, then the next time around someone else will do it. You got to worry about those kinds of things. I heard Breyer talking about mandatory retirement as most state courts have. And he was sort of in favor of that. Now personally, he said that would take pressure off me. People wouldn't always be asking, are you gonna retire? Of course, since then he has announced his retirement. I think 70 is too early. Of course I do, given my age. And you wouldn't so would I, but you're a lot closer to being a pointier than I am, I'll be. Don't bet on it. But you could see that. But of course, for the complaints we've been making about the current court, you would have to grandfather as it were. The current justices I think you couldn't say, oh, by the way, your lifetime term is now 10 years shorter or whatever you might say. So you'd be stuck with them. So one of the victories of the court change might be longevity for the judges that you're most critical of. Okay, well, that would be one measure, but it wouldn't take place. You wouldn't have any effect for a long time. I do think that the nominee for the next justice is very impressive. And we underestimate the effect of the personal relationships within a collegial body. And she I think will be a force. And I picture her and Sotomayor reinforcing each other in very different ways. And that will also, I think, change the court more than just one more vote. So stay tuned. I assume she will get confirmed, but you never know. I had a show with Camille Nelson, the current dean, your successor, who knows her, who served with her on a committee or commission at one point. And what came to my mind was that, yes, it's a matter of relationships. They must have, the none of them must have relationships. And they must have some influence, hopefully some influence on the others. They do meet, even if it's just for of all the soup. They do have some, you know, some effect. And I envision, and I like Katanji because I, what shall I call her, Judge Katanji. I like her because I think she's very relatable. All you have to do is look at her. Look at the way she deals with people. Look at the way she articulates her views. Look at the kindness and the focus and the, you know, the human caring. You can see it all. And so I'm thinking that maybe in the privacy of their bowl of soup or whatever they do, she would actually be able to say now, come on boys and girls, how about, you know, thinking this through? How about not, you know, not guest lighting the United States? How about some honest and moral, you know, determinations here? Is it possible that this could happen? Oh, I think so. I just heard a talk earlier today by Goodwin Liu who was on the California Supreme Court because he was nominated for the Ninth Circuit and he was stalled over and over again to the point that he finally withdrew because the Republicans, and that was back in the days when there was still a filibuster possibility. So he's a very distinguished guy who clerked for Breyer, sorry, who clerked for Ginsburg. And he was talking about her effect quietly, her emphasis on the collegial part of it. He clerked Bush versus Gore here. So they were pretty much mad at each other about various things procedurally as well as the result. But she insisted on, you know, not saying intemperate things, not saying critical things about her fellow justices. And the story that he told among some others he's very good was about her influence when they had a case involving a strip search of a 13 year old girl. And Justice Ginsburg said, none of you knows what that means for a 13 year old girl. A very effective argument. She was always effective, wasn't she? Well, maybe at times she will be effective too, in that way. I think she will. And if you're paired with Sotomayor, I think that's more than two votes. Yeah, so get those old guys to come around. Well, I just, I wanna kind of summarize on this. We live in a time that's very threatening, a time of war, a time of outrageous invasion and violations of human rights. That's another conversation. Harold Koh, the Dean of the Yale Law School for a long time is doing prosecutions of war criminals charges, war crime charges in the Hague, I guess. And with these are very, this is a big inflection historically. And we can never forget while Rome is burning, Rome is burning here at home too. And you see that all the time. So my final question to you today is... I've heard that three times now. Yes, Dave. Is, you know, what's your advice on how we should feel while all these things are happening? Well, I think Ukraine is so horrible. It's such a just awful tragedy. It is, you know, moving in the, it's a celebration of human life and you encourage, but it's also awful that it's very hard to watch the news or listen to NPR just to hear about what's going on. Nonetheless, I think we have to keep our eye on who's doing what. I think it's very important to be informed. And it's very scary that newspapers are not being read much and even the silo TV station, I heard some statistics, apparently MSNBC gets 2% of the viewership and Fox gets 3% roughly. So that's not where people are getting their news. They're getting it through social media. They're getting it by word of mouth. That's troublesome because the people who are spreading those things don't have a check on what they're spreading. And I think we are in big trouble because of that. So one of the things to be done, and I think to be lobbied for is to make the purveyors, the carriers of those things through false and whatever liable when there's a defamation that goes forth. And I think even First Amendment advocates sometimes agree with that. So at this point, we have to worry about how we take the news and who takes the news. And finally, we have to continue to try to turn out for votes, right? The turnout is appalling, votes matter. And so phone banks and sign waving, those things are really important. They're also important for building communities. So they're important not just for the result of the election, but for involvement. So that's what I think we have to continue to do. And a lot of people should continue to go to law school. Yes, they should. Thank you, Avi Sawyer, for Avi, former dean of the William A. Richardson Law School and a constitutional lawyer for many, many years. And we really enjoyed talking to him. Thank you so much, Avi. Thank you, Jay. A pleasure. Thank you so much for watching Think Tech Hawaii. If you like what we do, please like us and click the subscribe button on YouTube and the follow button on Vimeo. You can also follow us on Facebook, Instagram, Twitter and LinkedIn and donate to us at thinktechhawaii.com. Mahalo.