[8] In language that attempts to prevent future constitutional challenges, the sponsors of the 1954 Act expressly disclaimed a religious purpose. at 593. Copyright 2023 KGO-TV. at 314-16. Contact us. Circuit courts are not free to ignore Supreme Court precedent in this manner. Meteorologist Gerry Daz examines why Februarys storm door was left wide open and when more Students in Patricia Juri's 4th-grade class recite the Pledge of Allegiance during a bi-weekly assembly at Argonne Elementary School in San Francisco, Calif. on Friday, March 15, 2013. at 633. . at 315 ("[T]his policy was implemented with the purpose of endorsing school prayer. If the Justices are just pulling our leg, let them say so. Dist. ``They didn't strike down the Pledge of Allegiance,'' he said. President Obama has issued an executive order banning the Pledge of Allegiance in U.S. schools. When you get, give,'" expressed Cook before starting the meeting. Our reading of Wallace is supported by Santa Fe Independent School District v. Doe, 530 U.S. 290 (2000), where the Court upheld a facial challenge to a school district's policy of permitting, but not requiring, prayer initiated and led by a student at high school football games. The mere enactment of the 1954 Act in its particular context constitutes a religious recitation policy that interferes with Newdow's right to direct the religious education of his daughter. The phrase 'under God' recognizes only the guidance of God in our national affairs." However, it's worth repeating that students have the right to refuse to participate without fear of punishment or retaliation. Accordingly, the Court did not rule on the question of whether the Pledge violates the Establishment Clause. Moreover, the legislative history of the 1954 Act shows that the "under God" language was not meant to sit passively in the federal code unbeknownst to the public; rather, the sponsors of the amendment knew about and capitalized on the state laws and school district rules that mandate recitation of the Pledge. On June 22, 1942, Congress first codified the Pledge as "I pledge allegiance to the flag of the United States of America and to the Republic for which it stands, one Nation indivisible, with liberty and justice for all." My reading of the stelliscript suggests that upon Newdow's theory of our Constitution, accepted by my colleagues today, we will soon find ourselves prohibited from using our album of patriotic songs in many public settings. The suit alleged that this grant of real property, without any financial payment by the college, was a violation of the Establishment Clause. Allegheny, 492 U.S. at 628 (O'Connor, J., concurring). https://www.cnn.com/2019/02/19/us/pledge-of-allegiance-explainer-trnd Pitzen, an English teacher, initially posted the video on her own TikTok account, @mrsgillingsworth. Lynch, 465 U.S. at 688 (O'Connor, J., concurring). A decision by a three-judge panel of the Ninth Circuit Court of Appeals in 2002 stirred the debate over whether the Pledge violates the Constitution. 4 - In Marsh, the Court "held that the Nebraska Legislature's practice of opening each day's session with a prayer by a chaplain paid by the State did not violate the Establishment Clause of the First Amendment. The storms have delayed travel, shuttered schools and overwhelmed crews trying to dig out of the snow and repair downed power lines. Heres the impact of the latest 2022 tax returns: IRS further extends filing deadline for most Californians, Another winter storm? Francis Bellamy, an ordained minister, created a pledge that would be taken on Columbus Day by millions of school children. 1954 - Congress and President Eisenhower add "under God" to the pledge. The White House spokesman, Ari Fleischer, said President Bush called the decision ``ridiculous,'' and many legal experts said they expected it to be reversed on appeal. One Twitter user said, "Nothing against the pride flag, but we lost 13 service men and women a few days ago for that flag (in Afghanistan)… respect it! We should do no such thing. Ultimately, forcing schools to do it is kind of defeating the purpose, said Robert Leming, director of the We the People program at the California-based Center for Civic Education. One of the enduring traditions in public education is the recitation of the U.S. Tahoe snow: Massive blizzard wreaks havoc on the Sierra, burying Workers in S.F. Exp., Inc., 490 U.S. 477, 484 (1989) ("If a precedent of this Court has direct application in a case, yet appears to rest on reasons rejected in some other line of decisions, the Court of Appeals should follow the case which directly controls, leaving to this Court the prerogative of overruling its own decisions."). maintaining the secondary school. Examples abound of schools that don't include the pledge as part of the day or at some point in instruction. Id. 2d 29 (1985); Lynch v. Donnelly, 465 U.S. 668, 676, 693, 716, 104 S. Ct. 1355, 1361, 1369, 1382, 79 L. Ed. MCL 380.1304 HOUSE COMMITTEE ACTION: The House Education Committee reported out the Senate-passed version of the bill (Substitute S-2) without any amendments. Id. Because I don't think Republicans or Democrats will agree with it.''. at 447- 48. But they do so at the price of removing a vestige of the awe we all must feel at the immenseness of the universe and our own small place within it, as well as the wonder we must feel at the good fortune of our country. The school district said that it was just following a New Jersey state law that requires schools to have a daily recitation of the Pledge, and that individual students werent forced to take part. 9 - The objection to the Pledge in Barnette, like in the case at bar, was based upon a religious ground. The magistrate judge reported findings and a recommendation; District Judge Edward J. Schwartz approved the recommendation and entered a judgment of dismissal. A profession that we are a nation "under God" is identical, for Establishment Clause purposes, to a profession that we are a nation "under Jesus," a nation "under Vishnu," a nation "under Zeus," or a nation "under no god," because none of these professions can be neutral with respect to religion. Rec. . To require a showing of coercion, even indirect coercion, as an essential element of an Establishment Clause violation would make the free Exercise Clause a redundancy." "It does challenge me to think, how do I feel about certain things. In 1984, several liberal members of the Supreme Court, including Thurgood Marshall, Harry Blackmun, John Paul Stevens and William Brennan, said references like ``In God We Trust,'' which appears on United States currency and coins, were protected from the Establishment Clause because their religious significance had been lost through rote repetition. The only other United States Court of Appeals to consider the issue is the Seventh Circuit, which held in Sherman v. Community Consolidated School District 21, 980 F.2d 437 (7th Cir. . by: Joe Carroll. "We refuse to turn a blind eye to the context in which this policy arose, and that context quells any doubt that this policy was implemented with the purpose of endorsing school prayer." (A pledge is a kind of promise; it is a tradition in our country, and a way we honor the United States.) 8 - The "subtle and indirect" social pressure which permeates the classroom also renders more acute the message sent to non-believing schoolchildren that they are outsiders. The court followed the previous decision of the Ninth Circuit and determined that the Pledge indeed violated the Constitution, but the case was later reversed on appeal to the Ninth Circuit (Newdow v. Rio Linda Union Sch. All rights reserved. . 21, 980 F.2d 437, 445-48 (7th Cir. The Pledge of Allegiance to the flag will fulfill this requirement." "[T]he government must pursue a course of complete neutrality toward religion." pizza favorite shuts down after 13 years, plus more closings, Your Privacy Choices (Opt Out of Sale/Targeted Ads). Except for the fact that my room does not have a flag. at 56 (citations omitted) (applying the Lemon test). Alaska. As the Court observed with respect to the graduation prayer in that case: "What to most believers may seem nothing more than a reasonable request that the nonbeliever respect their religious practices, in a school context may appear to the nonbeliever or dissenter to be an attempt to employ the machinery of the State to enforce a religious orthodoxy." v. Schempp, 374 U.S. 203, 306-08, 83 S. Ct. 1560, 1615-16, 10 L. Ed. California does require every public school to include a "patriotic exercise" every day - which the pledge would fulfill - but it's a vague requirement that's not enforced. Such a purpose runs counter to the Establishment Clause, which prohibits the government's endorsement or advancement not only of one particular religion at the expense of other religions, but also of religion at the expense of atheism. And does the repetition of a memorized statement encourage more love of country? Instead of applying any of the tests announced by the Supreme Court, the Seventh Circuit simply frames the question as follows: "Must ceremonial references in civic life to a deity be understood as prayer, or support for all monotheistic religions, to the exclusion of atheists and those who worship multiple gods?" Code 52720 (1989) (hereinafter "California statute").1 To implement the California statute, the school district that Newdow's daughter attends has promulgated a policy that states, in pertinent part: "Each elementary school class [shall] recite the pledge of allegiance to the flag once each day. 1999). The panel's decision prompted an immediate reaction in Washington, where senators unanimously passed a resolution condemning the ruling and where dozens of House members gathered on the steps of the Capitol to recite the pledge and sing ``God Bless America.'' Levine said. In accordance with state law and a school district rule, EGUSD teachers begin each school day by leading their students in a recitation of the Pledge of Allegiance ("the Pledge"). . It has the underlying implication that this is not being done, when it already is, Sen. Christine Marsh, D-Phoenix, said of the bill, saying that she has never seen a classroom without a flag, constitution and bill of rights. If you believe your child has been forced or pressured to express ideas, religious or otherwise, against their will, you may want to speak with an attorney to discuss their constitutionally protected rights. This alleged distinction is irrelevant for constitutional purposes. Writing for the majority, Judge Goodwin said that the school district is ``conveying a message of state endorsement of a religious belief when it requires public school teachers to recite, and lead the recitation of the current form of the Pledge. Given the age and impressionability of schoolchildren, as discussed above, particularly within the confined environment of the classroom, the policy is highly likely to convey an impermissible message of endorsement to some and disapproval to others of their beliefs regarding the existence of a monotheistic God. exercises. The ruling came in a lawsuit filed in Federal District Court in Sacramento by an atheist, Michael A. Newdow, whose daughter attended elementary school in the Elk Grove Unified School District near the state capital. Rather, it relied on the principle that "at a minimum, the Constitution guarantees that government may not coerce anyone to support or participate in religion or its exercise, or otherwise to act in a way which establishes a state religion or religious faith, or tends to do so." Friends of the Earth, Inc. v. Laidlaw Envtl. Id. It not only refuses to apply the Lemon test because of the Supreme Court's criticism of that test in Lee, but it also fails to apply the coercion test from Lee or the endorsement test from Lynch. That phrase, 'Under God' was not written by him. The Pledge of Allegiance, what many would consider a Norman Rockwell requirement of public education, is no longer a given in an untold number of California Accordingly, we hold that Newdow has standing to challenge the 1954 Act. Dist. | https://codes.findlaw.com/ca/education-code/edc-sect-52720.html. c 223 28A.02.030. 5 - Although this formulation is referred to as the "coercion" test, it should be noted that coercion is not a necessary element in finding an Establishment Clause violation. Cal. Lemon, 403 U.S. at 612-14. FindLaw.com Free, trusted legal information for consumers and legal professionals, SuperLawyers.com Directory of U.S. attorneys with the exclusive Super Lawyers rating, Abogado.com The #1 Spanish-language legal website for consumers, LawInfo.com Nationwide attorney directory and legal consumer resources. In the 1990s, the American Civil Liberties Union (ACLU) repeatedly defended students in school districts who suffered reprisals for failing to participate in the Pledge of Allegiance. Jill Tucker is a San Francisco Chronicle staff writer. WebThe Pledge of Allegiance has important significance. Instead, he says he will honor those he believes are American patriots instead. Learn more about FindLaws newsletters, including our terms of use and privacy policy. "My (student) today goes, 'Hey, it's kind of weird that we just stand and we say it to nothing. One kid stood up in class and said the pledge anyway, according to a proudly irate mother. Judges Ban Pledge of Allegiance From Schools, Citing 'Under God', https://www.nytimes.com/2002/06/26/national/judges-ban-pledge-of-allegiance-from-schools-citing-under-god.html. (Interestingly, few adults pledge allegiance daily.). And California state standards do include the pledge as a first-grade social studies topic, while civics in general is usually reserved for senior year in high school. Lawmakers had intended them to be part of instruction on civics, history, and the Constitution, and they defined noncompliance as insubordination that was punishable by expulsion from school. CaliforniateacherKristin Pitzen was removed from teaching in her classroom as an investigation begins into aviral TikTok video where she joked about telling a student to pledging allegiance to a LGBTQPride flagrather than to the American flag. Praise for the panel's decision was muted. at 479-80, nor as a party personally injured as a consequence of the alleged unconstitutional action, see id. FindLaw Codes may not reflect the most recent version of the law in your jurisdiction. Were we to do so, the one that appeals most to me, the one I think to be correct, is the concept that what the religion clauses of the First Amendment require is neutrality; that those clauses are, in effect, an early kind of equal protection provision and assure that government will neither discriminate for nor discriminate against a religion or religions. Accordingly, a reversal of the order would result in the reinstatement of the complaint against the state. Across the Bay Area, many schools still say the pledge every day, conducted with announcements over the loudspeaker or in individual classrooms. If government-endorsed religion is to be treated differently from government-endorsed patriotism, the treatment must be less favorable, not more. -We, by the way, indicated as much in American Family Assn, Inc. v. City and County of San Francisco, 277 F.3d 1114, 1125-26 (9th Cir. Arthur Hayes, a law professor at Quinnipiac University, called the decision a ``well-reasoned opinion that is certain to enrage the Christian right.''. The judgment of dismissal is vacated with respect to these two claims, and the cause is remanded for further proceedings consistent with our holding. Scott Bomboy is the editor in chief of the National Constitution Center. The final question of standing relates to the 1954 Act. Such patriotic exercises for secondary schools shall be conducted in accordance Heres why California has seen so much active weather. ", First, minors can't legally pledge anything, he said. Created byFindLaw's team of legal writers and editors Family Ass'n, Inc. v. City and County of San Francisco, 277 F.3d 1114, 1120-21 (9th Cir. From an outsider's perspective, it might all seem a bit odd, Levine said. San Francisco is at its most unaffordable point in at least a decade, S.F. I think it is worth stating a little more about two of the cases which I have just cited. Welcome to FindLaw's Cases & Codes, a free source of state and federal court opinions, state laws, and the United States Code. No. because none of these professions can be neutral with respect to religion.'' Claim: President Obama has issued an executive order banning the Pledge of Allegiance in U.S. schools. L. No. Therefore, the policy and the Act fail the coercion test.-10 Finally we turn to the Lemon test, the first prong of which asks if the challenged policy has a secular purpose. . 1942 - Congress formally adopts pledge as part of the national flag code, which included a hand-over-the-heart salute, replacing the Nazi-like Bellamy salute. 12 - We recognize that the Supreme Court has occasionally commented in dicta that the presence of "one nation under God" in the Pledge of Allegiance is constitutional. Declining to reconsider the validity of the Lemon test, the Court in Lee found it unnecessary to apply the Lemon test to find the challenged practices unconstitutional. China lashed out at the U.S. for banning TikTok, describing the ban as an abuse of state power and suppressing firms from other countries. In 2014, the Massachusetts case Jane Doe v. Acton-Boxborough Regional School District involved a group of parents, teachers and the American Humanist Association in an action against a school district. CV-00-00495-MLS/PAN OPINION Appeal from the United States District Court for the Eastern District of California Edward J. Schwartz, Senior Judge, Presiding Argued and Submitted March 14, 2002-San Francisco, California Filed June 26, 2002 Before: Alfred T. Goodwin, Stephen Reinhardt and Ferdinand F. Fernandez, Circuit Judges Opinion by Judge Goodwin, Partial Concurrence and Partial Dissent by Judge Fernandez COUNSEL Michael Newdow, Pro Se, Sacramento, California, the plaintiff-appellant. at 314 (quoting Lynch v. Donnelly, 465 U.S. 668, 694 (1984) (O'Connor, J., concurring)), the Court held that the "mere passage by the District of a policy that has the purpose and perception of government establishment of religion," id., violated the Establishment Clause. Our application of all of the tests compels the conclusion that the policy and the Act challenged here violate the Establishment Clause of the Constitution. "Tonight we start this meeting in honor of the acclaimed author and activist Maya Angelou, who once said 'When you learn, teach. The most vehement reactions came from conservative religious groups. Even if a general lack of standing to directly attack 4 U.S.C. Nor were students, under the amended form of the statute, compelled to use the allotted time for prayer. But cf. It is a profession of a religious belief, namely, a belief in monotheism. Search, Browse Law But whatever it is called (I care not), it comes to this: such phrases as "In God We Trust," or "under God" have no tendency to establish a religion in this country or to suppress anyone's exercise, or non-exercise, of religion, except in the fevered eye of persons who most fervently would like to drive all tincture of religion out of the public life of our polity. Cook now wants feedback from the public, not on his decision, but to suggest names of other great Americans who, he says, deserve to be recognized. In short, I cannot accept the eliding of the simple phrase "under God" from our Pledge of Allegiance, when it is obvious that its tendency to establish religion in this country or to interfere with the free exercise (or non-exercise) of religion is de minimis.-9. Bryan Ruby becomes only active pro baseball player to be out as gay, Your California Privacy Rights/Privacy Policy. The State of California as a defendant. Taken within its context, the 1954 addendum was designed to result in the recitation of the words "under God" in school classrooms throughout the land on a daily basis, and therefore constituted as much of an injury-in-fact as the policies considered in Wallace and Santa Fe. Now they don't. The school district said that it was just following a New Jersey state law that requires schools to have a daily recitation of the Pledge, and that individual students " Wallace, 472 U.S. at 63 n.4 (Powell, J., concurring) (quoting Marsh, 463 U.S. at 792). at 592, the Court held that the school district's supervision and control of the graduation ceremony put impermissible pressure on students to participate in, or at least show respect during, the prayer, id. California Scraps Pledge of Allegiance Because Its Racist 1992), that a policy similar to the one before us regarding the recitation of the Pledge of Allegiance containing the words "one nation under God" was constitutional. Rep. No. At San Francisco's Claire Lilienthal School, K-5 students say the Pledge of Allegiance every day, while at the city's Harvey Milk Civil Rights Academy students say a Pledge to the World: "I pledge allegiance to the world, to cherish every living thing, to care for earth and sea and air, with peace and freedom everywhere.". In accordance with state law and a school district rule, EGUSD teachers begin each school day by leading their students in a recitation of the Pledge of Allegiance ("the amend. The Supreme Court found two constitutional violations. Pitzen imitated her studentpointing to the rainbow Pride flag. 100 Cong. 530 U.S. 310-16. Marsh v. Chambers, 463 U.S. 783, 795, 103 S. Ct. 3330, 3338, 77 L. Ed. The second and more direct infringement is government endorsement or disapproval of religion. This law also applies to federal contractors and other institutions that receive federal funding such as public schools. The text of the official Pledge, codified in federal law, impermissibly takes a position with respect to the purely religious question of the existence and identity of God. However, Newdow has no standing to challenge the SCUSD's policy and practice because his daughter is not currently a student there. [1] The Establishment Clause of the First Amendment states that "Congress shall make no law respecting an establishment of religion," U.S. Const. . SAN FRANCISCO (KGO) -- The President of the San Francisco School Board refused to recite the Pledge of Allegiance during last Tuesday's meeting. Id. at 508-09. While Valley Forge remains good law, the Supreme Court in more recent opinions has indirectly broadened the notion of Establishment Clause standing in public education cases by holding that the mere enactment of a statute may constitute an Establishment Clause violation. Visit our attorney directory to find a lawyer near you who can help. In sum, both the policy and the Act fail the Lemon test as well as the endorsement and coercion tests.-12 [10] In conclusion, we hold that (1) the 1954 Act adding the words "under God" to the Pledge, and (2) EGUSD's policy and practice of teacher-led recitation of the Pledge, with the added words included, violate the Establishment Clause. The recitation that ours is a nation "under God" is not a mere acknowledgment that many Americans believe in a deity. Name Relying in part on Supreme Court dicta regarding the Pledge, the court answers this question in the negative, determining that "under God" is a statement which, taken within its context in the Pledge, is devoid of any significant religious content, and therefore constitutional. Lee, 505 U.S. at 618 (Souter, J., concurring). Rep. No. Totally fine. Ultimately, does it matter whether kids say the Pledge of Allegiance? For more information about the legal concepts addressed by these cases and statutes, visit FindLaw's Learn About the Law. "[T]his court has never relied on coercion alone as the touchstone of Establishment Clause analysis. granted and judgment vacated by ___ U.S. ___, 122 S. Ct. 340, 151 L. Ed. Posted: Mar 1, 2023 / 02:03 AM EST. FERNANDEZ, Circuit Judge, concurring and dissenting: I concur in parts A, B and C-1 of the majority opinion, but dissent as to part D. We are asked to hold that inclusion of the phrase "under God" in this nation's Pledge of Allegiance violates the religion clauses of the Constitution of the United States. Id. . . Rather, the phrase "one nation under God" in the context of the Pledge is normative. Justice Frankfurter wrote in his dissent that, The very purpose of a Bill of Rights was to withdraw certain subjects from the vicissitudes of political controversy, to place them beyond the reach of majorities and officials and to establish them as legal principles to be applied by the courts., Later in the decade, some people added the words under God to the Pledge and in 1954, President Dwight Eisenhower signed a bill passed by Congress that put the words under God within the phrase one nation indivisible.. at 634 n.14. at 315. keys to navigate, use enter to select, Stay up-to-date with how the law affects your life. v. Americans United for Separation of Church and State, Inc., 454 U.S. 464, 488-90 (1982). Justice Kennedy, in his dissent in Allegheny, agreed: [B]y statute, the Pledge of Allegiance to the Flag describes the United States as 'one nation under God.' A Tulare County school district has apologized for one of its teachers omitting words from the Pledge of Allegiance. 1943: Supreme Court Upholds Establishment Clause In West Virginia State The case of Elk Grove Unified School District v. Newdow is one such debate that has challenged the constitutionality of the pledge. In between, she spent two years as a Peace Corps volunteer teaching English in Cape Verde, West Africa. at 590. The Seventh Circuit makes an even more serious error, however. BARTs second Transbay Tube could get quashed as planners scale back S.F. As you can see, it's not always so clear. "God Bless America" and "America The Beautiful" will be gone for sure, and while use of the first and second stanzas of the Star Spangled Banner will still be permissible, we will be precluded from straying into the third.-8 And currency beware! See Eastland v. United States Servicemen's Fund, 421 U.S. 491, 503 (1975). During the press conference, the President explained his decision was based on a personal belief that the language used in the pledge is divisive and contrary to Americas deepest held values.. 1628 (1943), for example, the Supreme Court did not say that the Pledge could not be recited in the presence of Jehovah's Witness children; it merely said that they did not have to recite it.-7 That fully protected their constitutional rights by precluding the government from trenching upon "the sphere of intellect and spirit." Id. Initially, we note that the 1954 statute challenged by Newdow is similar to the Alabama statute struck down in Wallace. In fact, 43 states have laws stating it has to be recited, but students can opt out. Reciting the Pledge of Thus, although we do feel good when we contemplate the effects of its inspiring phrasing and majestic promises, it is not primarily a feel-good prescription.-6 In West Virginia Board of Education v. Barnette, 319 U.S. 624, 630, 642, 63 S. Ct. 1178, 1181, 1187, 87 L. Ed. - The citations to the four preceding Supreme Court opinions are to majority opinions, concurring opinions, and dissents. at 484 (citation and internal quotation marks omitted). 505 U.S. at 593. We begin our inquiry by noting the general rule that the standing requirements for an action brought under the Establishment Clause are the same as for any other action. 980 F.2d at 444. 1 - The relevant portion of California Education Code 52720 reads: In every public elementary school each day during the school year at the beginning of the first regularly scheduled class or activity period at which the majority of the pupils of the school normally begin the schoolday, there shall be conducted appropriate patriotic exercises. '', The Rev. at 630, 63 S. Ct. at 1181. Yosemite breaks snow record; park closed indefinitely, The epic California snowpack is inching toward record levels. As discussed earlier, Newdow has standing as a parent to challenge a practice that interferes with his right to direct the religious education of his daughter. at 693 (O'Connor, J., concurring); Abington Sch. Explore our new 15-unit high school curriculum. 3 - Compelling students to recite the Pledge was held to be a First Amendment violation in West Virginia State Board of Education v. Barnette, 319 U.S. 624, 642 (1943) ("[T]he action of the local authorities in compelling the flag salute and pledge transcends constitutional limitations on their power and invades the sphere of intellect and spirit which it is the purpose of the First Amendment to our Constitution to reserve from all official control."). Turns out, reciting the Pledge of Allegiance has become passe, considered by some to be an outdated and unnecessary ritual with a constitutionally questionable religious reference and false promises of liberty and justice for all. Id. If there is any fixed star in our constitutional constellation, it is that no official, high or petty, can prescribe what shall be orthodox in politics, nationalism, religion, or other matters of opinion or force citizens to confess by word or act their faith therein. The state law violated the Fourteenth Amendment's requirement of due process and the First Amendment's requirements of religious freedom and free speech upon the state. The federal defendants "do not dispute that the words 'under God' were intended" "to recognize a Supreme Being," at a time when the government was publicly inveighing against atheistic communism. A powerful House committee voted to advance legislation on Wednesday that would make it easier to ban TikTok from the United States and crack down on other China-related economic activity, amid vocal objections from some lawmakers and civil liberties advocates who argue the proposal is unconstitutionally broad and threatens
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