“The War Against American Citizens”: Metastasizing Money Drowns Out The Voices Of Actual Americans
In 1971, before becoming a Supreme Court justice, Lewis F. Powell Jr. penned a memo to his friend Eugene Sydnor of the U.S. Chamber of Commerce advocating a comprehensive strategy in favor of corporate interests. Powell wrote, “Under our constitutional system, especially with an activist-minded Supreme Court, the judiciary may be the most important instrument for social, economic and political change.”
In last week’s ruling in McCutcheon v. Federal Election Commission , the Supreme Court was not a mere instrument so much as a blowtorch, searing a hole in the fabric of our fragile democracy.
This predictable decision from the 1 Percent Court to repeal federal limits on overall individual campaign contributions overturns nearly 40 years of campaign finance law.
It also completes a trifecta of rulings that started in 1976 with Buckley v. Valeo, and the Midas touch of judicial malpractice, turning money into speech. As Justice Stephen Breyer wrote in an impassioned dissent to McCutcheon, taken together with the 2010 ruling in Citizens United, “today’s decision eviscerates our Nation’s campaign finance laws, leaving a remnant incapable of dealing with the grave problems of democratic legitimacy that those laws were intended to resolve.”
This, foreshadowed in Powell’s decades-old memo, has always been the right’s plan — to shift the system in favor of the wealthy and powerful. Put it this way: If the limit hadn’t existed in 2012, the 1,219 biggest donors could have given more money than over 4 million small donors to the Obama and Romney campaigns — combined.
But McCutcheon was not the only body blow to our democracy, in what was possibly the worst week in the history of campaign finance reform.
New York Gov. Andrew Cuomo (D) let his proposal for publicly financed statewide elections die after years of promises to restore the public trust. In a state that’s often a laboratory of democracy, the governor has agreed to what is little more than a clinical trial — a single comptroller’s race this year — that some experts claim is “designed to fail.”
The American experiment seems to be run by a smaller and smaller control group as billionaires — like the Koch brothers and Sheldon Adelson — get expanding seats at the shrinking political table.
NASCAR drivers wear the corporate logos of their sponsors on their suits. The justices who sided with plutocracy ought to wear sponsorship logos on their robes, too.
Conversations about court rulings and policy proposals can obscure what’s really at stake: the well-being of the American people. The Court and Cuomo gave the 1 percent even more opportunities to, effectively, buy the kind of access to elected officials that most voters and small donors could never dream of. The weakening of campaign finance laws tracks with the widening income gap, as the wealthiest have secured policies, from lower taxes to deregulation — that enrich themselves at the expense of everybody else.
This, to paraphrase Massachusetts Sen. Elizabeth Warren (D), is why the system is rigged. Metastasizing money drowns out the voices of actual Americans, and suffocates policies such as raising the minimum wage and equal pay that would benefit workers. It also skews the playing field, not just between the haves and have-nots, but also between male and female candidates.
We live in a world where elected officials care less about checks and balances and more about their checkbooks and balance sheets. Where fundraising is more important than legislating. Where public policy is auctioned off to the highest bidder.
That’s why getting money out of politics is not a partisan issue. According to Gallup, nearly eight out of 10 Americans think campaigns should be limited in what they can raise and spend, while a 2012 CBS poll shows that about two-thirds of Americans believe in limiting individual campaign contributions.
Hopefully, popular outrage will boost the pressure for reform; there has already been a sharp increase in grassroots action. In the hours and days after the ruling, coalitions such as Public Citizen have mobilized thousands of people in 140 demonstrations across 38 states to protest the McCutcheon ruling. Nearly 500 local governments and 16 states and the District have called for a constitutional amendment to wrest our elections back from the elite. Move to Amend, which supports a constitutional amendment to reverse Citizens United and McCutcheon, and end the fiction that corporations are people and money equals speech, already has over 300,000 members.
A resolution from Sen. Tom Udall (D-N.M.) — with a House companion introduced by Rep. Jim McGovern (D-Mass.) — calling for a constitutional amendment to allow Congress to fully regulate campaign contributions, and to encourage states to regulate and limit campaign spending, already had 29 co-sponsors and picked up 3 more on the day the Roberts Court announced its decision. Citizens in New York, who are furious at Cuomo for failing to enact reform, are renewing the drive to hold him accountable for his actions. And even while pushing for a constitutional amendment — an uphill battle —supporters of clean elections in Congress and outside are fighting for increased disclosure and public financing of elections.
The all-out assault against campaign finance reform, on the heels of the Court’s gutting of the Voting Rights Act in Shelby County v. Holder , is just one more example of our democratic system in crisis. “Under the leadership of Chief Justice John Roberts,” my Nation colleague Ari Berman recently wrote, “the Supreme Court has made it far easier to buy an election and far harder to vote in one.” But the fear of democracy’s premature death doesn’t look like it’s silencing people; instead, it is inspiring a renewed commitment to fight for its survival.
By: Katrina vanden Heuvel, Opinion Writer, The Washington Post, April 8, 2014
“Beyond Corruption”: A Campaign Finance System Warped Beyond What It Would Be Under Any Reasonable Conception Of Democracy
There was a time in our history, thankfully long past now, when bribery was common and money’s slithery movement through the passages of American government was all but invisible, save for the occasional scandal that would burst forth into public consciousness. Today, we know much more about who’s getting what from whom. Members of Congress have to declare their assets, lobbyists have to register and disclose their activities, and contributions are reported and tracked. Whatever you think about the current campaign finance system, it’s much more transparent than it once was.
But if outright bribery is rare, should we say that the system is good enough? It’s a question we have to answer as we move into a new phase of the debate over money in politics. In the wake of last week’s Supreme Court decision in McCutcheon v. F.E.C., many liberals are nervous that the Court’s conservative majority is poised to remove all limits on how much can be donated to candidates and parties. For their part, conservatives seem to be preparing to open a new front in this seemingly endless battle, this time on the disclosure requirements that allow us to track who’s spending money to get their favored candidates elected. But those of us who worry about money’s distorting effects on the process would do well to acknowledge that the combination of more transparency and more money—much, much more money—has created a new reality with dangers that aren’t well described by the traditional conception of “corruption.”
Over the last few decades of campaign finance history, the immediate arguments have changed many times. Sometimes we argued over “soft money” contributions to political parties, sometimes we argued over phony “issue ads,” or 527 organizations and 501(c)(4) organizations, or corporate contributions and aggregate contributions. The specific locus of controversy keeps changing because political money always seems to find its way around whatever obstacles are placed in its path. And the fundamental divide that runs through all these arguments is, just as it has always been, that liberals want to reduce money’s influence over politics while conservatives want to increase it.
Conservatives might protest that that’s not really true; they just care deeply about freedom. But no one buys that for a minute. Their position on the issue is both practical and ideological. They know that if the super-wealthy are allowed to put as much of their money as they want into elections, Republicans will benefit more than Democrats. It’s no wonder that Republican party chair Reince Priebus called the McCutcheon decision a “very big victory for the RNC.” And they genuinely believe that’s as it should be; both the poor person and the rich person have the same right to donate large amounts of money to candidates, and if in practice it’s a right only the rich person can exercise, well that’s the way of the world.
And exercise it they do, with candidates, parties, and independent groups the grateful recipients of that civic-minded largesse growing larger with each passing election. But if your idea of “corruption” is only that which is illegal under bribery laws, that isn’t a problem that demands a solution. In the McCutcheon decision, Justice Roberts was quite clear in his belief that “Any regulation must…target what we have called “quid pro quo” corruption or its appearance…a direct exchange of an official act for money.” Large donations meant to gain the donor access or mere influence over lawmakers, he argued, aren’t enough. In his dissent, Justice Breyer took issue with this rather pinched view, saying “we can and should understand campaign finance laws as resting upon a broader and more significant constitutional rationale than the plurality’s limited definition of ‘corruption’ suggest.”
So maybe what we have here is in part a problem of nomenclature. If you don’t want to call it “corruption,” call it “distortion”—the creation of a system that is warped far beyond what it would be under any reasonable conception of democracy, even if nobody’s breaking any laws.
There is a meaningful difference. Most of the benefits big money looks for these days are spread beyond an individual, sometimes to an entire industry (like banks or oil companies) and sometimes to an even larger group of people and entities who have a common interest, like wealthy people who want to keep taxes on investment income lower than taxes on wage income. If someone like the Koch brothers succeeds in getting their favored candidates elected and their favored policies enacted, many billionaires and corporations will smile in appreciation. They won’t be doing it just for themselves.
There’s an important caveat, which is that money can have a great influence on the arcane details of legislation, where the public neither knows nor particularly cares what’s going on. Lobbyists still give plenty of money to members of Congress, and they do so to ensure the access that allows them to nibble at the nation’s laws for their clients’ benefit. In and of itself, money may not be able to buy a big, visible policy change—a reduction in the top tax rate or the killing of a minimum wage bill, for instance. But it can still buy an obscure provision in the nation’s banking laws, one that could be worth billions to some very interested parties but makes no front-page news.
Even disclosure of all campaign contributions to every type of independent group would probably have just a small impact in reducing the distortion money imposes on the system, in part because citizens can’t be expected to expend the effort to follow its every tendril. When a voter sees an ad casting aspersions on Senator Smiley’s opponent and hears “Americans for an American America is responsible for the content of this advertising,” what can she conclude? Not much, unless she happens to also read an article informing her that AfaAA is a creation of Oswald Greedyhands, whom some consider a heroic job-creator and others consider a nefarious exploiter of working people. Then she’s going to have to think about Oswald’s relationship with Senator Smiley, and learn about the Senator’s legislative record to see what favors he might have done for Greedyhands Industries. It’s a lot to expect of a citizen who has her own life to lead.
So even if the information is out there somewhere, and activists sound the alarms, so long as the money keeps pouring in, the system will bend inexorably toward the interests of those who fund it. A plutocratic system of government of, by, and for the wealthy isn’t necessarily “corrupt,” in the sense of being awash in specific, explicit bribes. But it isn’t particularly democratic, either.
By: Paul Waldman, Contributing Editor, The National Memo, April 7, 2014
“Reclaiming Democracy”: A Resounding Vote Against Koch Brothers Dollarocracy
Even as the US Supreme Court attempts to expand the scope and reach of the already dangerous dominance of our politics by billionaires and their willing servants, Americans are voting in overwhelming numbers against the new politics of dollarocracy.
The headline of the week with regard to the campaign-finance debate comes from Washington, where a 5-4 court majority has—with its McCutcheon v. Federal Election Commission decision—freed elite donors such as the politically-ambitious Koch Brothers to steer dramatically more money into the accounts of favored candidates, parties and political action committees. The decision makes it clear that the high court’s activist majority will stop at nothing in their drive to renew the old Tory principle that those with wealth ought to decide the direction of federal, state and local government.
But the five errand boys for the oligarchs who make up that majority are more thoroughly at odds with the sentiments of the American people than at any time in the modern history of this country’s judiciary.
We know this because the people are having their say with regard to the question of whether money is speech, whether corporations have the same rights as human beings and whether billionaires should be able to buy elections.
In every part of the country, in every sort of political jurisdiction, citizens are casting ballots for referendum proposals supporting a Constitutional amendment to overturn US Supreme Court rulings that have tipped the balance toward big money.
In so doing, these citizens are taking the essential first step in restoring democracy.
On Tuesday, thirteen Wisconsin communities, urban and rural, liberal and conservative, Democratic-leaning and Republican-leaning answered the call of constitutional reform. Even as groups associated with billionaire donors Charles and David Koch were meddling in local elections in the state, voters were demanding, by overwhelming margins, that the right to organize fair and open elections be restored.
It even happened in Wisconsin Governor Scott Walker’s hometown of Delavan, where voters faced the question:
Shall the City of Delavan adopt the following resolution:
RESOLVED, the City of Delavan, Wisconsin, calls for reclaiming democracy from the corrupting effects of undue corporate influence by amending the United States Constitution to establish that:
1. Only human beings, not corporations, unions, nonprofit organizations nor similar associations are entitled to constitutional rights, and
2. Money is not speech, and therefore regulating political contributions and spending is not equivalent to limiting political speech.
BE IT FURTHER RESOLVED, that we hereby instruct our state and federal representatives to enact resolutions and legislation to advance this effort.
76 percent of the Delavan residents who went to the polls voted “Yes!”
They were not alone. A dozen other Wisconsin communities faced referendums on the same day. Every town, village and city that was offered a choice voted to call on state and federal officials to move to amend the US Constitution so that citizens will again be able to organize elections in which votes matter more than dollars.
The Wisconsin votes provided the latest indication of a remarkable upsurge in support for bold action to renew the promise of American democracy. Since the Supreme Court began dismantling the last barriers to elite dominance of American politics, with its 2010 Citizens United decision, sixteen states and more than 500 communities have formally requested that federal officials begin the process of amending the constitution so that the court’s wrongheaded rulings can be reversed.
Last fall, John Bonifaz, the co-founder and executive director of the reform group Free Speech For People, calculated that “In just three years since the Supreme Court’s Citizens United ruling, we have come one third of the way to amending the US Constitution to reclaim our democracy and to ensure that people, not corporations, shall govern in America.”
Since the start of 2014, however, the movement has seen a dramatic acceleration in the grassroots pressure for action. During the first weeks of March, forty-seven town meetings called for a constitutional amendment—in a move that put renewed pressure on the New Hampshire legislature to act on the issue.
It is the experience of big-money politics that has inspired renewed activism for reform.
Wisconsin has had more experience than most states with the warping of democracy by out-of-state billionaires, “independent” expenditures and SuperPAC interventions. Governor Walker’s campaigns have reaped funds from top conservative donors, including the Koch Brothers. And a Koch Brothers-funded group, Americans for Prosperity waded into contests this spring for the local board of supervisors in northern Iron County, where mining and environmental issues are at stake; and in the city of Kenosha, where school board elections revolved around questions of whether to bargain fairly with unions representing teachers. In other parts of the state, business interests poured money into school board contests and local races Tuesday, providing a glimpse of the role corporate cash is likely to play in local, state and national elections in the months and years to come.
The Koch Brothers had mixed success Tuesday. Three Iron County Board candidates who were attacked by Americans for Prosperity mailings and on-the-ground “field” efforts in the county won their elections—beating incumbents who were promoted by the outside group. But in Kenosha, two school board contenders who were seen as anti-union zealots won.
There were, however, no mixed results when voters were given a clear choice between dollarocracy and democracy.
The signal from Wisconsin is that grassroots politics can and does still win.
In fact, it wins big.
Encouraged by groups such as United Wisconsin and Move to Amend, activists went door to door in the depths of winter to place amendment questions on local ballots in towns, villages and cities across the state. Many of the communities were in heavily Republican regions of Wisconsin. Yet, the pattern of support was strikingly consistent; in no community did an amendment proposal win less than 60 percent of the vote, and in several the support was over 85 percent.
“Citizens United opened the floodgates to unlimited corporate spending in our elections. Now, Wisconsin voters are standing up to the corrupting influence the flood of special interest money has had on our elections and in our state and national capitols where laws are made,” says Lisa Subeck, the director of United Wisconsin. “Tuesday’s victories send a clear message to our elected officials in Madison and in Washington that we demand action to overturn Citizens United and restore our democracy.”
Whether all those elected representatives will get the message remains to be seen. Several of the communities that voted Tuesday are in the district of Congressman Mark Pocan, D-Madison, who has already introduced an amendment proposal and has been an ardent backer of reform. But many other communities are represented by recipients of the big-money largesse of Wall Street traders, hedge-fund managers, casino moguls and billionaires looking to cover their bets.
Communities in the home district of House Budget Committee chairman Paul Ryan, R-Wisconsin, voted by margins as high as three to one to support an amendment strategy. The results were similar in conservative Waukesha County, which has historically been a Republican stronghold; in the city of Waukesha, for instance, 69 percent of the electorate called for action to amend the constitution. In Wauwatosa, the Milwaukee suburb where Governor Walker now maintains his voting residence, the vote for an amendment was 64 percent.
Wisconsin has several legislative proposals to put the state on record in support of a constitutional amendment. But they face uphill climbs in the current Republican-controlled legislature. And Walker shows no enthusiasm for reforming the system that has so richly rewarded his campaigns. Yet, grassroots activists like Ellen Holly, who helped organize the amendment vote in Walworth County—the heart of Paul Ryan’s district and Walker’s old home turf—is not blinking. She says it’s essential for the Move to Amend campaign to take the fight into even the most conservative areas and to deliver messages to politicians like Ryan.
The widespread support for overturning Citizens United, especially from rural and Republican-leaning areas offers a reminder that the reform impulse is bipartisan and widespread. The same goes from the broad coalitions that have developed. Among the loudest voices on behalf of the referendum campaign in rural Wisconsin was the Wisconsin Farmers Union, which hailed Tuesday’s voting as “a clear message that we the people are ready to take back our democracy.”
“Citizens United has allowed big money to drown out the voices of ordinary people and created an environment where, too often, our elected officials are sold to the highest bidder,” says Subeck, a Madison city council member who this year is running for the legislature on a promise to focus on campaign-finance issues. “To fully restore public trust in our democracy, we must return control of our elections to the people through common sense campaign finance reform, starting with the reversal of Citizens United.”
By: John Nichols, The Nation, April 3, 2014
“Stunning Hypocrisy”: Hobby Lobby 401(k) Discovered To Be Investor In Numerous Abortion And Contraception Products While Claiming Religious Objection
In what just may be the most stunning example of hypocrisy in my lifetime, Mother Jones has uncovered numerous investments on the part of Hobby Lobby’s retirement fund in a wide variety of companies producing abortion and contraception related products.
Hobby Lobby is currently seeking relief from certain contraception benefit requirements of Obamacare in a United States Supreme Court case that promises to be a landmark decision on the rights of corporations and the extension of personal religious protections to corporate entities. In the case of the Hobby Lobby corporation, the company is closely held by the Green family who purport to have strong religious objections to certain types of contraceptive devices and are suing to protect those religious rights.
Remarkably, the contraceptive devices and products that so offend the religious beliefs of this family are manufactured by the very companies in which Hobby Lobby holds a substantial stake via their employee 401(k) plan.
As I suspect many readers will find this as hard to believe and digest as I, the data can be confirmed by reviewing the company’s 2012 Annual Report of Employee Benefit Plan as filed with the Department of Labor.
This according to Mother Jones’ Molly Redden:
“Documents filed with the Department of Labor and dated December 2012 (see above)—three months after the company’s owners filed their lawsuit—show that the Hobby Lobby 401(k) employee retirement plan held more than $73 million in mutual funds with investments in companies that produce emergency contraceptive pills, intrauterine devices, and drugs commonly used in abortions. Hobby Lobby makes large matching contributions to this company-sponsored 401(k).”
In a brief submitted to the Court in support of Hobby Lobby’s position in the case, the company specifically names contraceptive products such as Plan B, Ella, and IUDs as violating their religious beliefs because they work by preventing a fertilized egg from implanting in a woman’s uterus. According to the Green family, interfering with an already fertilized egg is tantamount to abortion—an act unacceptable to the family and one they refuse to participate in no matter what the Affordable Care Act may require .
However, it turns out that the owners of Hobby Lobby do not appear to have any problem with profiting from the companies that manufacture the very products that so grievously offend their religious principles.
The following is a summation of the companies manufacturing these products that are held by the Hobby Lobby employee retirement plan, as set forth by Ms. Redden’s remarkable reporting:
“These companies include Teva Pharmaceutical Industries, which makes Plan B and ParaGard, a copper IUD, and Actavis, which makes a generic version of Plan B and distributes Ella. Other holdings in the mutual funds selected by Hobby Lobby include Pfizer, the maker of Cytotec and Prostin E2, which are used to induce abortions; Bayer, which manufactures the hormonal IUDs Skyla and Mirena; AstraZeneca, which has an Indian subsidiary that manufactures Prostodin, Cerviprime, and Partocin, three drugs commonly used in abortions; and Forest Laboratories, which makes Cervidil, a drug used to induce abortions. Several funds in the Hobby Lobby retirement plan also invested in Aetna and Humana, two health insurance companies that cover surgical abortions, abortion drugs, and emergency contraception in many of the health care policies they sell.”
When added up, the nine funds holding the stated investments involve three-quarters of Hobby Lobby’s 401(k) assets.
You may be thinking that it must have been beyond Hobby Lobby’s reasonable abilities to know what companies were being invested in by the mutual funds purchased for the Hobby Lobby 401(k) plans—but I am afraid you would be wrong.
Not only does Hobby Lobby have an obligation to know what their sponsored 401(k) is investing in for the benefit of their employees, it turns out that there are ample opportunities for the retirement fund to invest in mutual funds that are specifically screened to avoid any religiously offensive products.
“To avoid supporting companies that manufacture abortion drugs—or products such as alcohol or pornography—religious investors can turn to a cottage industry of mutual funds that screen out stocks that religious people might consider morally objectionable. The Timothy Plan and the Ave Maria Fund, for example, screen for companies that manufacture abortion drugs, support Planned Parenthood, or engage in embryonic stem cell research.”
Apparently, Hobby Lobby was either not aware that these options existed (kind of hard to believe for a company willing to take a case to the Supreme Court over their religious beliefs) or simply didn’t care.
By: Rick Ungar, Op-Ed Contributor, Forbes, April 1, 2014
“Advancing A Political Agenda”: When Freedom Of Religion Becomes A Sword, Not A Shield
Growing up, I went to a small school in Boston that was affiliated with the church across the street. The headmaster was Father Day. We went to services, the school had a great arts program and I loved my classmates. But what I remember most about it was that it was a warm and loving place to learn and grow.
Years later, I went to an historically Jewish university. Worship wasn’t part of the curriculum, but at some level, religion was knitted into every nook and cranny. I had the time of my life. It was a great place to be.
Those two experiences reflect my mixed religious lineage. I’m not sure what you’d call me today, but it’s the background I come from when thinking about the religious controversies that have been making headlines of late.
If you’re like me, freedom of religion feels something like this: It’s the right to believe, to express your belief without fear of reprisal, and to worship in accordance with your beliefs. It’s one of our country’s most fundamental rights, and it should be. No one should be able to tell you what you can and can’t believe, and no one should penalize you for your beliefs.
So the freedom of religion cases that feel the most intuitive are those in which someone’s ability to express their religious faith has been compromised. The Sikh who is told he can’t wear his turban at work. The orthodox Jew told to work on Saturday or lose his job. These kinds of cases feel immediately unjust: Unless your religious beliefs somehow irredeemably impair your ability to complete your duties, what business is it of your employer to tell you how you can or cannot live out your faith?
In other words, in these cases, the freedom of religion acts as a protection, a shield rather than a sword. That helps explain something else that feels right about cases like the ones just mentioned, at least in terms of how we understand them on a gut level: In each one, its the more powerful employer who is trying to impose its will on the less powerful employee who is only trying to exercise his or her faith. In other words, the person in need of protection is the one finding protection in the Constitution.
That feels very different from how some of the more recent controversies surrounding the freedom of religion have been playing out. Take the Arizona bill that would have allowed businesses to deny service to homosexuals. The argument for it was: If I own a business I ought to be able to operate it in a way that accords with my most fundamental beliefs (and if I think homosexuality is wrong, I shouldn’t have to serve homosexuals). But here the power dynamic was different. This wasn’t a case where a person being discriminated against cited the Constitution as evidence that the discrimination was impermissible. Instead, it was the opposite: a case where the person who wanted to do the discriminating sought justification in the Constitution.
In the Hobby Lobby case that was before the Supreme Court this week, the power dynamics are similarly flipped. Here, it isn’t a case of an employee charging that a much larger corporation is forcing him or her to choose between livelihood or beliefs. Instead, it’s the corporation that’s saying its religious beliefs have been compromised, and that the remedy is to withdraw a benefit offered to its (less powerful) employees.
In other words, here the freedom of religion is being used as a sword, not a shield. I’m not asking you to protect my right to believe what I want, I’m asking you to take something away from someone else on the basis of my belief. That’s a different kind of thing. And it doesn’t feel right.
There are other themes that factor into these kinds of controversies, of course. On the one hand, there are those who see the most powerful actor in these disputes as the government, and its efforts to compel people to behave in ways they would rather not. On the other, there are people like me, who see the claim of religious liberty being deployed by some as a way to advance a political agenda that really may not have all that much to do with religion.
But look, I’m one of those people who believes that when it comes to religion we ought to spend a lot more time listening to each other and a lot less time being knee jerk, because for many of us faith is so personal and important. Different people will feel differently about what their faith means, how it is expressed and how it may be impinged upon. And in my experience, when we assume we know someone else based entirely on their religious faith, or the lack thereof, more often than not we’re wrong.
But here’s something I’m pretty sure about, too: While everyone is entitled to their freedom of religion, we don’t honor that freedom when instead of using it to protect you from discrimination on the basis of what you believe, we use it to justify discrimination against others on the basis of who they are or what they believe. And that’s true no matter how uncomfortable you may find their beliefs, or the expression of it, to be.
By: Anson Kaye, U. S. News and World Report, March 27, 2014
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