Attachment 30 Fullilove v Beame 48 NY2d 376 1979

Case MDL No. 3011 Document 25-30 Filed 06/24/21 Page 1 of 7
Fullilove v. Beame, 48 N.Y.2d 376 (1979)
398 N.E.2d 765, 423 N.Y.S.2d 144, 22 Empl. Prac. Dec. P 30,572
Original Image of 398 N.E.2d 765 (PDF)
48 N.Y.2d 376
Court of Appeals of New York.
In the Matter of H. Earl FULLILOVE et al., Respondents,
v.
Abraham BEAME, as Mayor of the City of New York, et al., Appellants.
Nov. 20, 1979.
Synopsis
Plaintiffs brought Article 78 proceeding challenging certain city affirmative action regulations promulgated pursuant to
executive orders of the mayor. The Supreme Court, Special Term, New York County, Abraham J. Gellinoff, J., declared
regulation unconstitutional, and appeal was taken. The Supreme Court, Appellate Division, First Department, 64 A.D.2d 961,
409 N.Y.S.2d 121, affirmed, and permission to appeal was granted. The Court of Appeals held that mayor was without authority
to initiate affirmative action regulation which provided that no contract could be awarded in a city or city-assisted construction
project until contractor selected submitted a written program of affirmative action to insure the opportunity for equitable
participation of minority group persons and women, in absence of legislative authorization for such regulation.
Affirmed.
Fuchsberg, J., dissented and filed opinion in which Meyer, J., joined.
West Headnotes (1)
[1] Municipal Corporations Validity and Sufficiency in General
Public Contracts
Determinative Factors in Making Award
Mayor was without authority to initiate affirmative action regulation which provided that no contract could be awarded
in a city or city-assisted construction project until contractor selected submitted a written program of affirmative action
to insure the opportunity for equitable participation of minority group persons and women, in absence of legislative
authorization for such regulation.
19 Cases that cite this headnote
Attorneys and Law Firms
*377 ***144 **765 Allen G. Schwartz, Corp. Counsel, New York City (L. Kevin Sheridan, Esmeralda Simmons, Brooklyn,
and Michael A. Vaccari, New York City, of counsel), for appellants.
Robert G. Benisch, New York City, for respondents.
*378 OPINION OF THE COURT
© 2021 Thomson Reuters. No claim to original U.S. Government Works. 1

Case MDL No. 3011 Document 25-30 Filed 06/24/21 Page 2 of 7
Fullilove v. Beame, 48 N.Y.2d 376 (1979)
398 N.E.2d 765, 423 N.Y.S.2d 144, 22 Empl. Prac. Dec. P 30,572
PER CURIAM.
In this case as well as in Matter of Fullilove v. Carey, 48 N.Y.2d —-, —-N.Y.S.2d ——, —- N.E.2d —— (decided herewith), the
fundamental question presented is not whether affirmative action is permissible or desirable. The question, simply and narrowly,
is whether, under our governmental system, the central feature of which is distribution of powers, the executive has the authority
to initiate affirmative action without legislative authorization.
Although the rule elsewhere may differ, the law of New York is clear.
The State Legislature, as well as the New York City Council, has unequivocally condemned discriminatory hiring practices.
The executive clearly has the power and obligation to implement programs designed to prohibit discriminatory hiring practices.
Indeed, the State Legislature has gone so far as to state that voluntary use of a State-approved affirmative action plan by private
employers “shall not be an unlawful discriminatory practice” (Human Rights Law (Executive Law), s 296, subd. 12).
But as this court stated in Matter of Broidrick v. Lindsay, 39 N.Y.2d 641, 644, 646-647, 385 N.Y.S.2d 265, 267-268, 350 N.E.2d
595, 598: “Nowhere in the law has the city council prescribed affirmative action to redress the effects of discrimination. There
is a dramatic distinction between the expressed legislative policy of prohibiting employment discrimination and the mayoral
***145 policy of mandating employment ‘percentages'.” Similarly there is a vast difference between permitting employers to
voluntarily adopt an affirmative action program and mandating that this be done involuntarily under threat of legal sanctions.
**766 The difference between obligations that require the taking of certain steps, and those that merely require one to refrain
from others, is, in this sensitive area of racial relations, not merely one of degree, but of kind. Where the Legislature has set
out nondiscrimination as the policy of the State, an order mandating that employers take certain actions cannot be viewed as
merely one step further along a continuum.
In Matter of Broidrick (supra), because only specific administrative *379 regulations were in issue, only those regulations, and
not the mayoral order in which they were grounded, were struck by this court as being in excess of the legislative authorization.
This led some (although not the courts below) to conclude, mistakenly, that the defect could be cured by different regulations
which did not prescribe specific percentage quotas.
The difficulty in Broidrick, as here, is not the means employed by the executive to impose affirmative action in hiring practices,
but rather that the executive attempted it at all. At the same time we note the distinction, carefully preserved in Broidrick,
between affirmative action in hiring practices, and executive affirmative action which “only would enlarge the pool of persons
eligible for employment based on discrimination-free merit selection” (Matter of Broidrick v. Lindsay, 39 N.Y.2d 641, 649, 385
N.Y.S.2d 265, 269, 350 N.E.2d 595, 599, Supra).
In sum, we would emphasize that the desirability of adopting a policy of affirmative action in hiring practices, and mandating
the same, is not a prerogative of the executive, but rather of the legislative branch and it is to those bodies that persons seeking
to impose affirmative action should direct their attention.
FUCHSBERG, Judge (dissenting).
Because I believe that neither the Governor's Executive Order No. 45Executive Order No. 45 nor the 1977 Rules and Regulations
promulgated on behalf of the Mayor of the City of New York in implementation of the latter's Executive Order No. 71Executive
Order No. 71 constitutes an excessive exercise of executive power, because in my opinion the majority's reading of Matter of
Broidrick v. Lindsay, 39 N.Y.2d 641, 385 N.Y.S.2d 265, 350 N.E.2d 595, to strike down each of these measures impermissibly
narrows the meaning of that decision, and because the net effect of the court's determination today is to prevent the heads of
© 2021 Thomson Reuters. No claim to original U.S. Government Works. 2

Case MDL No. 3011 Document 25-30 Filed 06/24/21 Page 3 of 7
Fullilove v. Beame, 48 N.Y.2d 376 (1979)
398 N.E.2d 765, 423 N.Y.S.2d 144, 22 Empl. Prac. Dec. P 30,572
State and local governments from taking lawful steps toward the realistic enforcement of our strong legal and societal policies
against race and sex discrimination, I must vote to reverse in both cases.
By the way of preface, since the majority's nullification of the two executive actions stems from their inclusion of a requirement
for “affirmative action”, in articulating my views I think it best to take the scare factor out of that phrase. Though subsuming
a broad range of policies and programs that have been introduced at State and Federal levels, “affirmative action” is basically
a concept representative of the conviction *380 that full equality of employment opportunity cannot be achieved simply by
decrying discrimination or even by decreeing that discrimination cease; rather, it proceeds on the assumption that, unless these
are accompanied by positive or “affirmative” steps to speed the elimination of the stubborn vestiges of discrimination, this
noxious condition will continue to feed on itself, and the goal of equal opportunity will remain beyond reach.
“Affirmative action”, therefore, contemplates measures such as the reinstatement ***146 or upgrading of those who have been
discriminated against, the recruitment of members of disadvantaged groups and the opening up of opportunities for attaining
vocational skills that will enable them to compete in the labor market. While, at times, impatience with the pace of acceptable
methods has led some to resort to quotas and programs of reverse discrimination, concepts quite different from equal opportunity
(cf. Alevy v. Downstate Med. Center, 39 N.Y.2d 326, 336-337, 384 N.Y.S.2d 82, 90-91, 348 N.E.2d 537, 545-546), it is not to be
assumed that a program of affirmative action necessarily encompasses preferential **767 treatment (see Matter of Broidrick
v. Lindsay, 39 N.Y.2d 641, 646-648, 385 N.Y.S.2d 265, 267-268, 350 N.E.2d 595, 597-598, Supra ). The rules and regulations
in Broidrick were properly struck down because they did. The executive actions here do not and, thus are not vulnerable to
such attack.
On analysis, in their own way, the executive actions before us today were but modest attempts to deal with existing inequalities
of opportunity. Each recognized that discrimination in employment on the part of public contractors adversely affects the costs
of public works by, among other things, decreasing the pool of available labor. Both were directed against what had been found
to be a “specific” pattern of discrimination infesting the building and construction industry (Matter of State Comm. for Human
Rights v. Farrell, 43 Misc.2d 958, 960, 252 N.Y.S.2d 649, 652; see Fullilove v. Kreps, 584 F.2d 600, 606, cert. granted —-
U.S. ——, 99 S.Ct. 2403, 60 L.Ed.2d 1064; Equal Employment Opportunity Comm. v. Local 638, 532 F.2d 821, 2nd Cir.,
affd. as mod. 565 F.2d 31, 2nd Cir.; Rios v. Enterprise Assn. Steamfitters, Local No. 638, 501 F.2d 622, 2nd Cir.). Both had
as their aim simply to make the industry more responsive to its obligations as regards the employment rights of minority and
female workers.
For his part, the Governor acted pursuant to his constitutional authority ( N.Y.Const., art. IV, s 3) to see to the faithful execution
of our laws and to specify terms and conditions of contracts entered into by the State. In this tenor, Executive *381 Order No.
45 *381 Executive Order No. 45 required that all State contracts include a provision incorporating a program that would insure
that employees or applicants “are afforded equal employment opportunities.” To allow the contractors flexibility, the order did
not spell out precise requirements, except to indicate the program was to be one “to achieve goals and timetables designed to
reflect adequate utilization of minority group persons and women”. Instead, it set up an Office of State Contract Compliance
(OSCC) within the State Division of Human Rights, the agency already charged by the Legislature with the implementation of
antidiscrimination laws. The OSCC was commissioned to develop and enforce appropriate contract terms designed to effectuate
the order (9 NYCRR 3.45).
No terms had been issued by the OSCC by the time the petitioners, as representatives of employers and unions in the construction
industry, commenced this article 78 proceeding. There was, therefore, no reason to assume that, when issued, the “goals”
and “timetables” would not be ones directed at the undisputably permissible goal of attracting qualified minority applicants,
rather than granting some form of blunderbuss preferential treatment to minorities and women in the potential labor market.
In particular, especially in the light of the Broidrick guidelines, nothing compelled the conclusion that a fixed percentage or
quota formula would be imposed.
© 2021 Thomson Reuters. No claim to original U.S. Government Works. 3

Case MDL No. 3011 Document 25-30 Filed 06/24/21 Page 4 of 7
Fullilove v. Beame, 48 N.Y.2d 376 (1979)
398 N.E.2d 765, 423 N.Y.S.2d 144, 22 Empl. Prac. Dec. P 30,572
As for the city, the rules and regulations here challenged were promulgated for the Mayor by his city administrator. Their
issuance was authorized by Mayoral Executive Order No. 71Executive Order No. 71, which, undisturbed by Broidrick and with
seeming uncontestability, declared it the policy of the city to insure that employment of qualified persons on municipal contracts
be free from discrimination on account of race, creed, color ***147 or national origin (and, by later amendment, of sex and
age). The rules at issue replaced an earlier set that had been struck down by Broidrick as an unconstitutional application of
Order No. 71 because they had required contractors to commit themselves to employ specified percentages of minority workers
by specified dates on all their construction projects, whether public or private and whether funded by the city or not.
The new regulations carefully avoided these pitfalls. While they called upon each construction contractor to submit a proposed
program containing specific steps and actions which, *382 if diligently applied, could be expected to result in employment
opportunities substantially equivalent to minority **768 representation in the available work force, they were made applicable
only to city and city-assisted construction contracts. Moreover, failure to achieve an anticipated goal was to bring no automatic
imposition of sanctions, but instead would occasion review, opportunity for explanation and, where necessary, modification.
On such review, lack of progress was to be but a factor in determining whether the efforts to apply the employer's program
had been carried out in good faith.
Furthermore, neither the contractor nor the city were left to flounder in structuring a proposed plan, for the rules indicated that
the employer's program could include provision for notifying relevant labor, minority and community referral agencies and
city and State employment agencies of job openings on its city projects; maintaining files containing information on female
and minority persons referred to the contractor for employment together with the action that had been taken with respect to
their applications; disseminating its Equal Employment Opportunity (EEO) policy within its own organization as well as to
subcontractors and suppliers; enlisting the help of minority and other recruitment and training organizations, news media,
trade schools and secondary schools within the City of New York; evaluating women and minority personnel for promotion
opportunities and encouraging them to seek such opportunities.
As the rules make clear, the idea was to roll back and not to countenance the perpetuation of discrimination. Though raceconscious
and sex-conscious, as well they might be if the attitudes and effects engendered by past discrimination were to
be addressed in any meaningful way, they did not impose hiring or training quotas or otherwise depart from the principle
of merit selection. Indeed, as in the case against the State, the article 78 proceeding mounted against the city pointed to no
application of the city's rules and regulations that would in any guise constitute “a cover for the functional equivalent of a
quota system” ( University of Cal. Regents v. Bakke, 438 U.S. 265, 318, 98 S.Ct. 2733, 2763, 57 L.Ed.2d 750; United
Steelworkers of Amer. v. Weber, 443 U.S. 193, 99 S.Ct. 2721, 61 L.Ed.2d 480) or otherwise violate sound principles against
illegal reverse discrimination.
Far from exceeding the bounds of gubernatorial and mayoral power, as an examination of legislative history emphasizes, *383
these executive actions did no more than give effect to the policies, expressed and implied, of the laws of this State. As early
as 1945, the then State Commission Against Discrimination was already empowered to direct the taking of “such Affirmative
action including (but not limited to) hiring, reinstatement or upgrading of employees” (Executive Law, s 132; emphasis mine). 1
By ***148 1962 and 1963, when the commission had been renamed the State Commission for Human Rights (L.1962, ch.
165), the Governor was able to announce that $400 million appropriated by the Legislature for State-sponsored contracts would
be awarded in conjunction with a program to increase jobs to help assure realization of equality of job opportunities in New York
State and towards which there were to be “Positive action to promote equality of opportunity” in the construction industry in
recruitment, training and employment (Public Papers of Governor Nelson A. Rockefeller (1963), pp. 865-866 (emphasis mine)).
The same year a new contract form for State contracting agencies, still in use today, require contractors to “take Affirmative
action * * * (against discrimination because of race, creed, color or national origin) by way of recruitment, employment, job
assignment, promotion, upgrading, demotion, transfer, layoff or termination, rates of pay or other forms of compensation, and
Selection for training or retraining, including apprenticeship **769 and on-the-job training ”. (Id., at pp. 935-936 (emphasis
mine).)
© 2021 Thomson Reuters. No claim to original U.S. Government Works. 4

Case MDL No. 3011 Document 25-30 Filed 06/24/21 Page 5 of 7
Fullilove v. Beame, 48 N.Y.2d 376 (1979)
398 N.E.2d 765, 423 N.Y.S.2d 144, 22 Empl. Prac. Dec. P 30,572
Five years later, in 1968, the legislative revision of the Human Rights Law, in declaring that the purpose of the law was, Inter
alia, to afford to all citizens “an equal opportunity to enjoy a full and productive life”, spoke in terms of “encourag(ing) programs
designed to insure that every individual shall have an equal opportunity to participate fully in the economic * * * life of the
state” free from discrimination in employment ( Executive Law, s 290, subd. 3; s 297, subd. 4, par. c). The following year
an amendment authorized the Human Rights Division to work to increase the employment of members of any minority group
exhibiting a disproportionately high unemployment rate (L.1969, ch. 458, now codified as *384 Executive Law, s 296,
subd. 12). 2 And, in 1972, echoing this legislative sentiment, the State Department of Labor issued new regulations pursuant to
article 23 of the Labor Law described as intended to prohibit “discrimination based on race, creed, color, national origin (and)
sex * * * in apprenticeship programs, by requiring Affirmative action ” (12 NYCRR 600.1 (emphasis mine)). 3
Executive Order No. 45Executive Order No. 45 followed, along what had thus become a well-blazed trail, on the heels of
these and other even more practical expressions of support for such policies, including regular legislative appropriations “for
State participation in affirmative action programs”. 4 (Cf. Labor Law, ss 220-e, 815, subd. 5; Civil Rights Law, ss 40-c, 43).
Obviously, it embodies an effort to deal with matters identified by the Legislature as the focus of public concern, and to do so
in a manner consistent with State law and public policy. And, certainly no less consonant with the thrust of relevant legislation
was the Mayor's Executive Order No. 71Executive Order No. 71, for it carries forward the unequivocal expression of policy in
section 343-8.0 of the Administrative Code of the City of New York, which provides that: “It shall be unlawful for any person
engaged in ***149 * * * construction * * * pursuant to a contract with the city * * * to refuse to employ or to refuse to
continue in any employment any person on account of the race, color or creed of such person.” (Local Laws, 1942, No. 44 of
City of New York, eff. Sept. 9, 1942.)
On the State level, the executive branch is also authorized by statute to make contracts for the construction, alteration and repair
of public buildings and for the procurement of materials, equipment and supplies ( State Finance Law, s 163; see Public
Buildings Law, s 8). These statutes indicate a *385 legislative policy favoring the setting of standards through which persons
dealing or seeking to deal with the State may be furnished with notice of the terms and conditions that attend such relationships
as well as some assurance against institutional caprice. It should be apparent, then, that the issuance of an executive order
mandating that particular standard provisions and clauses appear in State contracts comes well within the scope of executive
authority conferred and contemplated by the statutes.
Apart from this, however, Executive Order No. 45Executive Order No. 45 may be viewed, more fundamentally, as issued
pursuant to the constitutionally protected contract-making power that inheres in all “member(s) of this state” **770
(N.Y.Const., art. I, s 1). Against the constitutional and statutory backdrop for the exercise of the State's contracting powers, the
executive order would fall well within the range of authority reserved to the executive branch of our State government, and of
the Governor as its chief executive officer, to “expedite all such measures as may be resolved upon by the legislature” and, as
already indicated, to “take care that the laws are faithfully executed” ( N.Y.Const., art. IV, s 3).
In addition, I note that the Constitution of the State of New York does not establish a form of government in which the Legislature
is supreme (see Matter of La Guardia v. Smith, 288 N.Y. 1, 5-6, 10, 41 N.E.2d 153, 154-155, 157;
Matter of Village of
Saratoga Springs v. Saratoga Gas, Elec. Light & Power Co., 191 N.Y. 123, 132-138, 83 N.E. 693, 695-697), and indeed, on
the broader plane of American political experience, the actual delineation of power between the executive and the Legislature
has never been at all clear-cut, either in theory or in practice. Pertinently, the framers of the Federal Constitution rejected a
proposal that would have limited the function of the executive to enforcement of the laws enacted by Congress and instead
assigned that office a much more independent role (De Chambrun, The Executive Power in the United States: A Study of
Constitutional Law, 111 (1874)).
© 2021 Thomson Reuters. No claim to original U.S. Government Works. 5

Case MDL No. 3011 Document 25-30 Filed 06/24/21 Page 6 of 7
Fullilove v. Beame, 48 N.Y.2d 376 (1979)
398 N.E.2d 765, 423 N.Y.S.2d 144, 22 Empl. Prac. Dec. P 30,572
So, it is recognized that each branch, to protect its own independence, to some extent may exercise inherent powers that, strictly
speaking, may be thought to belong to another (see Youngstown Co. v. Sawyer, 343 U.S. 579, 637, 72 S.Ct. 863, 96 L.Ed.
1153 (Jackson, J., concurring); Hall, Constitutional Law, p. 21). Moreover, as long as it does not contravene a statute, the
executive branch may freely enter into contracts on whatever conditions and provisions it deems will best promote the interests
of the government *386 (cf. Kern-Limerick, Inc. v. Scurlock, 347 U.S. 110, 74 S.Ct. 403, 98 L.Ed. 546; Locke, Second
Treatise on Government, s 159), a power that certainly should not be construed in a more limited fashion when its purpose is
to eradicate the manifestations of racial discrimination.
The public interest is, in fact, even more directly involved in such a case when, aside from the incalculable importance of
social justice to the welfare of the State and Nation, the perpetuation of the problem raises spectres of labor unrest, and of
an economy burdened by an economically disenfranchised and unproductive class yet tolerating a restricted labor pool with
attendant increases in costs. (See Associated Gen. Contrs. of Mass. v. Altshuler, 490 F.2d 9, 1st Cir., cert. den. ***150 416
U.S. 957, 94 S.Ct. 1971, 40 L.Ed.2d 307; Farmer v. Philadelphia Elec. Co., 329 F.2d 3, 8, 3rd Cir.; Brunsfeld & Sons
v. Board of Educ., 54 Ill.App.3d 119, 11 Ill.Dec. 829, 369 N.E.2d 283; Weiner v. Cuyahoga Community Coll. Dist., 19
Ohio St.2d 35, 249 N.E.2d 907; Note, Gubernatorial Executive Orders as Devices for Administrative Direction and Control,
50 Iowa L.Rev. 78.)
These irresistible bases for Executive Order No. 45Executive Order No. 45 and the rules and regulations before us, we now
turn to examine Matter of Broidrick. Carefully read, it supports the State and city in the cases before us on all counts. As though
possessed of the prescience that the present litigation would arise in due course, it took care to make clear that discriminatory
practices are appropriate areas for “a broad declaration of policy, leaving to the executive discretion to determine the particular
otherwise valid means necessary to enforce antidiscriminatory prohibitions”. And, even while it was holding the old city
regulations objectionable because they mandated quotas, were unrelated to cost considerations and attempted to impose these
dictates beyond city contracts, it recognized that “a policy limited to increasing the pool of eligibles for employment, by
including previously excluded minority workers” might well call for an opposite result (39 N.Y.2d, pp. 646-647, 385 N.Y.S.2d,
pp. 267-268, 350 N.E.2d, pp. 597-598).
Order No. 45 and the 1977 regulations do call for such a result. They do not impose “quotas”. They seek to increase the pool of
**771 previously excluded eligible minority applicants. They apply only to State and State-assisted projects in the one case
and city and city-assisted ones in the other. They do not even mandate a rate for accepting minority apprentices. And, though a
contractor must make diligent good faith efforts to implement a program, there is no requirement that it hire a specific number
of minorities or that parity be reached between *387 its work force and the minority work force at large. Finally, an expressed
governmental concern in each case is cost minimization and other economic factors related directly to governmental contracts
and not to an unrelated extrinsic policy.
For all these reasons, deference to a most compelling State policy and the permissible practices undertaken by those charged
with its enforcement require that, in each case, the order of the Appellate Division be reversed and the petition dismissed, or,
in the alternative, on conversion of the proceedings to actions for declaratory judgment, that there be declarations that Order
No. 45 and the 1977 rules and regulations are constitutional.
COOKE, C. J., and JASEN, GABRIELLI, JONES and WACHTLER, JJ., concur in Per Curiam opinion.
FUCHSBERG, J., dissents and votes to reverse in a separate opinion in which MEYER, J., concurs.
Order affirmed, without costs.
© 2021 Thomson Reuters. No claim to original U.S. Government Works. 6

Case MDL No. 3011 Document 25-30 Filed 06/24/21 Page 7 of 7
Fullilove v. Beame, 48 N.Y.2d 376 (1979)
398 N.E.2d 765, 423 N.Y.S.2d 144, 22 Empl. Prac. Dec. P 30,572
All Citations
48 N.Y.2d 376, 398 N.E.2d 765, 423 N.Y.S.2d 144, 22 Empl. Prac. Dec. P 30,572
Footnotes
1 The term “affirmative action” was already part of the remedial provisions in Federal and State labor relations laws.
(49 U.S.Stat. 449; U.S.Code, tit. 29, s 151; Labor Law, s 700.) Interpretations of those statutes were relied upon in
the drafting of the Law Against Discrimination. (See Report of the New York State Temporary Commission Against
Discrimination, N.Y.Legis.Doc., 1945, No. 6, pp. 19, 33.)
2 Some conception of the serious extent of the disproportionality, both then and now, may be garnered from State Profile
of Employment and Unemployment, 1977 (Washington, D.C., U.S. Bureau of Labor Statistics, 1978); Foner, Organized
Labor and the Black Worker, 1619-1973.
3 The regulations go on to state: “Affirmative action is not mere passive nondiscrimination. It includes procedures,
methods and programs for the identification, positive recruitment, training and motivation of present and potential
minority and female (minority and nonminority) apprentices. It is action which will equalize opportunity in
apprenticeship so as to allow full utilization of the work potential of minorities and women. The overall result to be
sought is equal opportunity in apprenticeship for all individuals participating in or seeking entrance to the State's labor
force” (12 NYCRR 600.5(b)).
4 (L.1973, ch. 50; L.1974, ch. 50; L.1975, ch. 50; L.1976, ch. 50; L.1977, ch. 50; L.1978, ch. 50.)
End of Document
© 2021 Thomson Reuters. No claim to original U.S. Government Works.
© 2021 Thomson Reuters. No claim to original U.S. Government Works. 7