Gerrymandering and Economic Liberty

Welcome you to happens next. My name is Larry Bernstein. What happens next is a podcast which covers economics, education, and culture. Today's topic is gerrymandering and economic liberty. Our first speaker will be retired federal judge, Gary Finerman, who recently joined the law from Latham and Watkins as a partner in litigation. Gary will discuss the recent case in North Carolina related to gerrymandering and whether the state courts can overrule the state legislatures redistricting maps. Our second speaker is Renee Flarey, who is the attorney whose accessory already the case of Jackson versus Rafford's burger in the Georgia Supreme Court. This case is about the limits of state authority to regulate occupations. Jackson teaches new mothers how to breastfeed, but the state changed the licensing for that job demanding that she meet minimum education requirements that would prevent her from doing her chosen profession, which is counseling lactation care. Renee isn't attorney with the Institute for Justice, a NAFTA profit that challenges government overreach on licensing and regulation, as well as infringement on individual property rights. Let's begin today with retired judge Gary Finerman's opening six minute remarks. Thank you, Larry. Thanks for inviting me back. The Supreme Court just ended its term. It was another monumental term. Last week, I believe you discussed that affirmative action case students for fair admissions versus Harvard and University of North Carolina. There's also the case that I'm going to talk about more versus Harper, which has been described by former court circuit judge Michael Lutig as the most significant case in recent memory. So in terms of the factual backdrop, after the 2020 census, the North Carolina legislature rejrew the state's congressional districts. And the legislature engaged in a highly effective or political gerrymander, although North Carolina is close to a 50-50 state Democrats versus Republicans. The map had 10 Republican majority districts and three Democratic majority districts, which was an extraordinarily efficient political gerrymander even by the standards, Larry, that you and I are used to here in Illinois. Four years ago, the US Supreme Court in a case called Root Jo versus Common Cause held that the federal constitution is not prohibit partisan gerrymandering. So you can no longer go to federal court and argue that what the North Carolina legislature did in this case violated the federal constitution. But states have their own constitutions. And many state constitutions either explicitly prohibit partisan gerrymandering or have more general provisions that state courts have interpreted to prohibit partisan gerrymandering. North Carolina citizens, North Sudan, North Carolina state court, and last year, the North Carolina Supreme Court held that the North Carolina Constitution prohibits political gerrymandering. And that prohibition invalidated the legislature's map as an unlawful political gerrymander, the state Supreme Court directed the state trial court to draw a new map that resulted in a less skewed congressional delegation. The supporters of the map petitioned this US Supreme Court for surgery and the court heard arguing that this last term had issued its decision last week. The legal backdrop here has become known as the independent state legislature theory. And that theory arises from the elections clause, which is an article one section four of the US Constitution. And it states the times, places, and manner of holding elections for senators and representatives shall be prescribed in each state by the legislature they're out. But the Congress made at any time by law make or alter such regulations. What the proponents of the independent state legislature theory said and argued is that the elections clause reposes in state legislatures the authority to set election rules and draw maps for congressional elections, for federal elections. And that the only body that can counterman the state legislature in the Serena is Congress. So according to the proponents of the independent state legislature theory, a state court may not invalidate a state legislative enactment with respect to maps or other regulation of federal elections by pointing to the state constitution or some other provision of state law. So the maps, challengers, had a couple arguments in response, they pointed to the text of the elections clause acknowledged that instead of state legislature, but argued that that phrase pairs with an implicit understanding that the state legislature must act in accord with substantive and procedural rules set by state law, including judicial review by the state courts for compliance with the state constitution. They also pointed to historical practice at the founding that state courts did have the power to ensure that the state legislatures comply with state constitutions, including in the context of federal elections. Why is this important? If the proponents of the independent state legislature theory prevailed, it would have upset long-settled understandings regarding the relationship between state legislatures and state courts, it would allow state legislatures to operate in a state constitution free zone when it comes to federal elections. And there is also a political component, the state legislative maps are themselves jerrymandered, and unless they engage in self-control, if there's no state constitutional constraint enforceable in state court against political jerrymandering, they will jerrymandered US House districts to the maximum extent possible, with no recourse in federal court due to Rucho, which I discussed a moment ago, or in state court, if in fact, the independent state legislature doctrine prevailed. So the US Supreme Court rejected that strong version of the independent state legislature doctrine by a six to three vote, and it upheld the decision of the North Carolina Supreme Court. Chief Justice Roberts wrote the opinion, joined by Justice Kavanaugh and Barrett, and the three liberal justices, Sotomayor, Kagan, and Jackson. And there were three dissenters, Justice Tomas Alito and Gorsuch, all three of them believed that the case was moot and shouldn't have been resolved in the merits, and Justice Tomas and Gorsuch went on to cast down the majority's understanding of the elections clause. So what the majority held is that the elections clause does not insulate state legislatures from state judicial review, when laws setting the rules for federal elections are challenged under state law. And the majority reason that the framers understood that when legislatures make laws, they are bound by the provisions of the very documents that gave them life, and hear the documents of the state constitutions. But the court was careful not to give state courts a blank check. The US Supreme Court held that when entertaining challenges to laws enacted by state legislatures regarding federal elections, state courts may not transgress the ordinary bounds of judicial review, such that they irrigate to themselves, the power vested in state legislatures, to regulate federal elections. So what happens next? There are two areas where we could expect further litigation arising out of more versus however. The first is to answer the question, what does it mean for a state court to transgress the ordinary bounds of judicial review? In other words, how much difference will the US Supreme Court give to state courts when state courts interpret and apply state constitutions to the work of state legislatures when it comes to federal elections? The second issue that could arise is what's gonna happen to the electors clause. The electors clause is a different clause of the constitution than the elections clause, and it deals with the selection of electors for the electoral college, which those aren't to select the president. And the electors clause states that each state shall appoint in such manner as the legislature thereof may direct, and here we have the reference to the legislature again. So the question will become, whether the US Supreme Court will apply the same construct from more versus Harper about the relationship between state courts and state legislatures in the context of selecting electors for the electoral college under the elections clause. I don't know the answer to that question, but we could very well find out the answer in either late 2024 or early 2025. The independent state legislature theory was rekindled during the case of Bush versus Gore. As listeners may recall, the Florida recount was certified by the secretary of state and then Gore litigated in the Florida courts. Gore sued successfully in Florida state courts to recount ballots only in the counties where Gore won and not where he lost. In Chief Justice Rhenquist's concurrence opinion, he stated that the Florida courts had gone rogue. They were hijacking the job of the state legislature in determining the rules on how to select Florida's electors. Chief Justice Rhenquist did write an opinion in Bush versus Gore, but it was a good occurrence. It was not the majority. It was just for himself and Justice's Scalia and Thomas. So his view of the electors clause did not command the majority of the court. What the court held in Bush versus Gore is that the Florida Supreme Court violated the Equal Protection Clause. It didn't turn on anything having to do with the elections clause or the electors clause. Chief Justice Rhenquist did find that the Florida Supreme Court for lack of a better phrase kind of went on a frolic and detour and wasn't really acting as a court in terms of interpreting state law, but still the Chief Justice's standard that he articulated in his concurrence, the standard that Justice Souter articulated in his dissent are fairly deferential to state courts in terms of their interpretation of state constitutions of decisions made by state legislatures in the federal election context. When you were describing the facts of this case, you mentioned that the North Carolina Supreme Court ordered the lower court to create its own gerrymandered map. It's one thing to evaluate whether the congressional map is constitutional and it's quite another thing for the court to create its own map and act like a legislature. It's a very tough and interesting question that you raise. What oftentimes happens in these state cases is that the state Supreme Court will invalidate something that the legislature has done and then send it back to the legislature to draw a new map. And let's say that the state legislature digs in its heels and doesn't fully effectuate what the state Supreme Court had required. So it goes back to court, the state Supreme Court says, nice try but not good enough and then sends it back. And you could see kind of a vicious cycle emerging where nothing ever gets done. So at some point, just as a practical matter, the courts, whether it's a state trial quarter, state Supreme Court, will have to step it and draw the map. Now as a practical matter, I think that's what ultimately has to happen in at least certain circumstances where there's just a standoff. But I do recognize your argument that it's no longer a state legislature at that point in the state court. And I imagine this is one of the things that the US Supreme Court will have to contend with in the aftermath of Moore versus Harper in determining what are the outer bounds of a state court's authority to interpret the state constitution consistent with the elections clause. In Bush versus Gore, the recount was under severe time constraints because under the law, the results had to be tabulated by a certain date. There was some chatter at the time that the state legislature could simply vote and determine that Bush was notorious in the election and then appoint the electors. How will real world constraints impact the future relationship between the courts and the state legislature? I mean, you may be drafting up on a story board cases that we're going to see in late 24 and early 25 where there may be challenges and a state legislature may step in and just declare the winner of that state's electors for presidential election. And then that will present the question that the Supreme Court did not have to reach in this case because it was about congressional districts and not presidential electors as to what is the power of the state legislature in that kind of a situation and can it be checked by a state court? There's another issue that could come up. The state legislature came in afterwards and decided the winner. I'll just quote it again. It says, each state shall appoint in such manner as the legislature thereof may direct. I think that there's a view that that electors clause allows the extent of the state legislature's power under the leave of the electors clause to set the rules ahead of time before the election and then not to come in afterwards and say, okay, this is who we think what? There are folks who disagree with that temporal reading of the state legislature's powers under the electors clause and can these state courts step in and say, no, state legislature, what you just did in the instance of your hypothetical to just award electors after the election has occurred whether that violates the state constitution. Some states through referendums, limit-gary, mid-ring, how does this square with the state legislature requirement in the election's clause? Well, the Supreme Court actually resolved that issue a few years ago. I think it may have been 2015 or 2016 in the Arizona state legislature case where the citizens of Arizona adopted a constitutional provision that were posed in an independent commission, the ability to draw congressional districts and the legislature sued and said, no, no, the elections clause says that it's us and with the Supreme Court held, I believe it was a five to four decision authored by Justice Ginsburg that a state commission in that context exercises legislative authority and therefore falls within a definition of legislature in the elections clause. Interestingly enough, Chief Justice Roberts dissented from that decision, but in his opinion and more versus Harper and just proving what an institutionalist, Chief Justice Roberts is, he took the Arizona state legislature case as settled law and applied it and deployed it very effectively to advance the majority's decision in the case regarding the nature of the elections clause. More versus Harper was decided six to three and the six Republican judges were split in half. Was this a partisan issue? It's not a partisan decision. I mean, just on its face, it was a mixed bag, at least with respect to the Republican appointees. What the judges are working to is the meaning of the Constitution and in deciding the meaning of the Constitution, they of course have their interpretive methodologies at a 30,000 foot level due as a general matter, although not always, map on to kind of a conservative approach to interpretation versus a liberal approach to interpretation and the cars are going to fall where they might in terms of politics. There have been elections that were virtual ties and there's been other elections with malfeasions. In 1876, Congress and the Supreme Court had an electoral commission to determine the presidential results. In 1960, there was evidence of cheating by the Democrats in JFK's winning election over Nixon in the states of Texas and Illinois. Who should determine these electoral outcomes that are complicated and inherently political? And why do you favor courts to resolve disputes generally arising over an election? Should it be the state legislatures, commissions or other organizations that can evaluate real-time, complicated, mixed up election disputes? Remember that Palm Beach ballots, the hanging chads and the other craziness in Florida in 2000 and more recently, Trump's dispute election in 2020. There is no ideal forum in which to resolve these disputes. So the question then becomes, what's the best form in adjudicating whether there's election fraud? The courts are the best place to do it rather than a legislative body or an executive body. Both sides generally understood that it was the courts job. And I believe that the Trump campaign brought some, either they or their affiliates or allies brought some 60 lawsuits and lost all but one of them. What I will say is that the federal courts did their jobs. I'll mention three, there was a case out of Pennsylvania where the third circuit ruled against President Trump in a decision written by Judge Bevis, who is a Trump appointee. There was a case out of Wisconsin that ended up going to the seventh circuit. And the seventh circuit ruled against President Trump in a decision authored by Mike Schutter, a Trump appointee. There was a decision in the 11th circuit resolved again against President Trump. And it was a decision that was authored by Judge Kevin Newsom, a Trump appointee. So that very, very fraught situation that who is a country we're facing in late 2020 and early 2021 went to the courts and the courts resolved it under the law in a completely nonpartisan manner because of courts deciding things in a partisan manner. Those three decisions I mentioned and probably many others among the six of that were filed would have come out a different way. The founders thought that many elections would be settled by Congress. Why isn't the ultimate political body, the Congress, the best place to resolve these kinds of disputes, especially when it's repeating game with elections held every two years? Congress could come in under the elections clause and set the rules of the road for state-ledged soldiers. They haven't done it with respect to political gerrymandering but they have done with respect to race discrimination under the voting rights act. So could you get Congress a political body to pass a law saying that other legislatures can't engage in political gerrymandering? Not so sure that that's gonna happen but I think it would certainly be within Congress's power. The fact that Congress has not taken action on a gerrymandering issue to me is indicative that Congress doesn't find gerrymandering that problematic. Otherwise, they would do something about it. Yes, that could be many members of Congress on both sides come out of politically gerrymandered districts. So in a fact to ask Congress to pass a law, that doesn't allow for political gerrymandering would be asking a number of members to vote against their own interests. And I'm not saying that it's not conceivable that individual legislators, whether they're in Congress or in state legislatures, would vote against their own electoral interests. That certainly can't happen. And the better angels of their nature could prevail and they could come together and achieve a consensus on a result that would be good for the body politic as a whole as opposed to thinking solely about their own next election. Some other legislatures may do that, but oftentimes it has to be left to the voters in a state referendum like what happened in Arizona or state courts enforcing the state constitution, state constitutional provisions either directed towards equality or fairness in general. That was the North Carolina 2022 decision. There were any other state court decisions as well that take a dim view of political gerrymandering. Do you think that more versus Harper means the depth of the independent state legislature theory as an ongoing constitutional matter? It is the depth of the strong version of the independent state legislature theory and by strong version I mean the theory that state legislatures can operate without interference from state courts reviewing state legislative actions or compliance with state constitution or other state law. It's not the end of this area of the law for the reasons that I mentioned in my opening, which is we don't know what constraints the US Supreme Court will impose on the state courts review with respect to federal elections. In other words, we don't know what the Supreme Court will consider the ordinary exercise of state judicial review, what will be deemed in bounds, what will be deemed out of bounds. And if you wanna characterize that as under the rubric of the independent state legislature theory then I suppose it's not dead, but certainly the strong version that we've all been talking about is no longer a viable theory. Earlier you mentioned that Roberts was an institutionalist. So even though Roberts voted in the dissent in the Arizona State Commission gerrymandering case, he later applied the majority's opinion a few years later as settled law in this more case. Meanwhile, Justice Thomas did not behave that way. Thomas joined Rehnquist in the concurrence in Bush v. Score and continues to advocate and is to set in more with the same philosophical arguments of what the constitution means and is not influenced by this so-called settled law. What is the appropriate action for a Supreme Court justice? Should you follow your own view on the constitutional framework or follow the majority's opinion from previous settled cases? Well, it depends on your view of stare decisis. Chief Justice Roberts has a stronger view of stare decisis than Justice Thomas has and Justice Thomas has been buried. What's right about this? He's written about this in separate opinions where he is saying that it would violate judicial function to place too much importance on stare decisis that the court has to decide things in accord with what the court believes is the right decision and not be bound by prior decisions that the current court thinks are incorrect. So if you strongly adhere to stare decisis, there are situations where you are overturned precedent that only in very particular circumstances and you will apply precedence, even if you believe that they were wrongly decided. So long as the precedents don't fall within an exception to stare decisis, whereas Justice Thomas is more of the view that if it's wrong, it's wrong and we ought to make it right. Justice Harlan in his famous descent in Pussy versus Ferguson laid the groundwork towards reversal nearly six years later in Brown. Justice Ginsburg said she writes her descent so that future justice can find reason to overturn a particular decision. And Justice Alito laid out in dobs why he thought that row is wrongly decided and must be overturned. What do you think should be the appropriate standard for overturning precedent? It just can't be solely because the current court believes that the prior court made a mistake. There has to be an extenuating circumstance. One of the extenuating circumstances is if a precedent has proven itself to be unworkable. It's had a standard that courts in the ensuing years just aren't able to apply sensibly. There's another exception to stare decisis is if the prior decision isn't just wrong, but is egregiously wrong. Whether a prior decision is wrong or egregiously wrong is often in the eyes of the beholden. At least as to Alito and Ginsburg, they articulate the same construct, I believe. Now they will disagree in its application, like if Justice Ginsburg were alive, I don't think she would agree that row versus wave was egregiously wrong, which is what Justice Alito concluded. Ginsburg and Alito, I believe, apply the same construct. They just would reach different decisions in different cases as to whether something was wrong or something was egregiously wrong. I think Justice Thomas operates under a different construct where a prior decision doesn't have to be egregiously wrong, to be overturned consistent with what he views as the proper role of stare decisis. What are you optimistic about as there are a way to a court's decision in more versus Harper? Harper makes me optimistic that courts will view decisions and issues that have a political tinge to them in a manner that derives from their interpretive methodology and their view of the Constitution. The courts did that in 2020. I'm hopeful that the courts will continue to do that in 2024 and optimistic that they will do so and then in the ensuing years. Thanks, Gary. We now move on to our second speaker, Renee Flarety, who works with the not-for-profit law advocacy group, the Institute for Justice, that defends individual property rights and economic liberty. I'm a long-standing supporter of IJ and I've asked Renee to discuss her recent victorious case in Georgia. Thank you for having me. My name is Renee Flarety and I'm a senior attorney at the Institute for Justice where nonprofit public interest law firm founded in 1991 and we represent ordinary Americans for free and cases against the government when it violates their rights. We're very busy because the government violates people's rights every day at every level, local, state, and federal. But our clients are special because they're working not just to change their own lives but to change the world. That's the point of public interest litigation. We're working to set precedent that helps everyone in advances our mission. We work in many different areas, free speech, property rights, educational choice, and what I'm here to talk about today, economic liberty. Economic liberty is the right of every American to earn a living in the occupation of their choice without unreasonable interference from the government. The case I'm here to talk about today was in Georgia but it's that precedent that judges all over the country will be looking at and it all started with lactation consultants. Those are people, usually women, who help moms breastfeed their babies. So it's an occupation that people have been doing since the dawn of time and doing it quite well and safely without interference from the government. But in 2016, Georgia decided to license lactation consultants. Under that law, my client, Mary Jackson, who has over 30 years of experience as a lactation consultant didn't qualify for a license. This is a woman who teaches doctors and nurses how to help breastfeeding moms and she's one of the leading experts in the country. She was going to lose her job but instead, she teamed up with IJ to challenge the law in court. We sued in 2018 and after five years of litigation two trips up to the state Supreme Court, we won. The court ruled unanimously that Georgia's law violated my client's right to earn a living free from unreasonable interference from the government. Unfortunately, judges often defer to government lawyers when they say that a law is justified no matter what effect that law is going to have on real people or the real reasons behind the law. And what's special about the Georgia Supreme Court's decision in this case is that the judges held the government accountable for what it's doing. And that's a big deal because sadly, it's really difficult to win these type of cases. States regulate most professions. What makes an unreasonable government licensing requirement? When the government wants to regulate an occupation, you have to ask why are they doing it? Is it to actually protect the public health and safety or is it for a different reason? And in this case, with lactation consultants, the reason for the law was actually pretty clear. It was because one group of privately certified lactation consultants lobbied the legislature to get the license passed. And so that, according to the court, is not a legitimate aim of the government to protect one group from competition from another. This is not the first time that the Institute for Justice has fought to limit the power of the state to acquire needless licenses. Tell us about your ongoing battle to allow individuals to braid hair. We've done many different cases about braiding. IJ's very first case in 1991 when it was founded was on behalf of braiders in Washington, DC. They were required to get a full cosmologist license just to braid hair. And whenever you get a cosmologist license, you usually don't learn how to braid. You're learning how to cut and use chemicals and do all sorts of things that braiders don't do. And so it was an absolutely useless credential for them. We had that case in DC where we sued and then they changed the law, which was great. In the Georgia lactation case, what were the constitutional issues related to economic liberty and pursuing your occupation without government interference? So the decision in Georgia was under the state's constitution. Georgia's constitution protects the right to earn a living without unreasonable interference from the government under its due process clause. And so that was the claim that we brought in state court in Georgia because state constitutions often provide more protection for economic liberty than the federal constitution. So it can be easier to win these cases at the state level because state judges are much more concerned about their own constitutions, special protections for economic liberty than unfortunately federal judges are most of the time. And why is that? I think that state judges are more interested in protecting individual rights under their state constitutions because it's important to them to pay attention to how their state is unique. And so you have a lot of case law in various states that push back against those fringes of government power that you were talking about earlier. And often it is where people are making a living in these ordinary occupations like lactation consulting. And in Georgia, there are a lot of cases about striking down plumbing licensing. And they actually tried to license photographers in Georgia, which is crazy. And that was struck down under Georgia's due process clause. IJ has had success in state courts in Pennsylvania in Texas as well. Both of their state constitutions have been found to provide greater protection for economic liberty than the federal constitution. In the Georgia plumbing cases, the law required licensing for plumbers working on new construction but not existing buildings. And the court view that as arbitrary and shut it down. Tell us about that. Often laws that aren't really connected to health and safety have these problematic exemptions. That's kind of a symptom of an underlying problem. And that's something that the justices in the lactation consultants case pointed out. If a law is not really connected to the public health and safety, it's going to be like Swiss cheese. There are going to be all of these holes and exemptions for people to get through because at root, there's no pressing health and safety concerns. And so you can exempt people without a problem. So for example, in the lactation consultants case, you didn't have to get a license as long as you did the work for free, as long as you weren't getting paid for it. If you worked for the government, you didn't have to get a license. If you were a doctor or a nurse, you didn't have to get a license. Even if you had no training in helping breastfeeding moms. And so the court pointed out, if there are that many exemptions, you've got to think, is there really the public health and safety concern that would merit such a restrictive license? The federal constitution incorporates the 14th amendment, which has been construed in the locker decision to give individuals economic liberty as always to employment. Lockner was then later overturned and now the government has much broader authority to regulate your occupation. Does the federal constitution protect economic liberty after the repeal of a lockner? So lockner is kind of the favorite boogie man of federal judges whenever they're saying, we need to defer to the government because we don't want to be like lockner. That's just one of the most reviled cases. And if you look at the facts in lockner, it was a case about bakers and how many hours they could work. Bakers who were immigrants were willing to work very long hours to support their family. They were trying to earn a living, but the existing bakers weren't happy with the competition. So you have a law that it really was protectionist, but the court was trying to say that there were health and safety concerns. And so now federal judges always point to lockner when they say, oh, the court can get out of control with protecting economic liberty. But state judges usually aren't so afraid of lockner because they don't feel bound to what federal judges said in the 1930s about economic liberty. And they can look to their own state constitutions and their own case law that provide similar protections to lockner, but they don't feel bound to reject it. How do federal judges view economic liberty and constitutional protections in a post-lockner world? Unfortunately, they don't like it. We've had less success in federal court than we have had in state court. A very recent example, one of my cases, was Washington DC again, requires a college degree for daycare providers, a regulation that was enacted by an administrative agency in 2016. And they said, now to be a daycare provider in DC and care for babies, infant zero to three, you had to have an associate's degree. And my client, Alumi Sanchez, is an immigrant. And she moved to the US in the 90s and decided to pursue her dream of caring for children. And she's had a home daycare since 2006. And she has a college degree, but it's from her home country of the Dominican Republic. And it's not in early childhood studies. So she didn't qualify under these new regulations, even though she is an amazing daycare provider. So we teamed up with her and we sued. And after five years in court and two appeals, we lost that one in federal court. My niece is a high school student, and she babysits. Does she really get a college degree to babysit? Babiesitters were exempt from DC's regulation. So there again, you've got an exemption to a law. I think it's fine to license daycares. But you have to look at what the regulation requires, which was a college degree. And you have to say, is there a real connection between the provider having a college degree and those kids being safe and happy? Do you think that lawyers need to be licensed? So I have absolutely no interest in protecting my own cartel from competition. I think that there are a lot of things that lawyers do that can be done by ordinary people. A lot of it is just helping people fill out forms. And the majority of what I do is just speech. With lawyer licensing, there is a great deal of things that ordinary people can do without even going to law school. I'm not afraid to say that lawyer licensing is up for grabs. What do judges think about these economic liberty cases? Back when we were founded in 1991, we were often laughed out of court when we went in and tried to litigate economic liberty cases. But if you flash forward to now, there has been a lot of success. It's obviously taken 30 years, but people's attitude is different. And that includes judges, that includes legislators, and the general public. And IJ, we don't just litigate cases in the court of law, we litigate them in the court of public opinion. So we have a communications team. We have a strategic research team that does research to find facts, to back up the things that we say whenever we go into court. And we have a legislative team that crafts model legislation and hopes that legislatures will enact it. And we've had success on all fronts. And I think that our big wins, like in the lactation consultants case, like in the Patel case in Texas, all contribute to that. And it's like a giant snowball that we hope will just keep going and going and bring people more economic liberty. Tell us about the Patel case. This involved eyebrow threaters, people who use the cotton thread to remove unwanted hair from your eyebrows. So a very simple thing. It's an ancient Middle Eastern art. So a lot of immigrants do that. And Texas wanted them to get a full aesthetician's license. So that would involve learning how to wax, maybe even give massages. I can't remember, but it was just mostly vastly irrelevant to what they do. And so we challenged that on behalf of a threater. And that case probably took five years. And we won in the Texas Supreme Court. And they said that when you challenge an economic regulation in Texas, the review is meaningful. A judge is actually going to look at the real reasons behind the law and about whether it's protecting the health and safety. And in this case, they said that it's not. It's too burdensome to require a threater to get hundreds of hours of training and spend thousands of dollars to do something that they already know how to do. Let's change topics of civil forfeiture. Civil forfeiture is a huge problem all across the country. And the government can actually take your money without even charging you with a crime. You don't have to be charged. You don't have to have done anything wrong or even contemplated doing anything wrong. And they can take your cash just because you have it. And the reason why is because they have a profit incentive. They get to keep part or maybe even all of what they seize. And so naturally, that's going to lead to seizing more cash. And it's happened to ordinary Americans carrying cash for whatever reason. A lot of the times, some of our clients have been buying trucks. And that's often a business where you go somewhere and you hand them cash. And they've had their money seized. And this is sometimes people's life savings. There was another case where there was a woman who was going to build a medical clinic in Nigeria. And she had her money seized. She was a nurse. And that was both her savings and money that people had given her to start the clinic. There was a guy who was a member of a band. And he was an immigrant from Asia and raising money and collecting charity to build an orphanage. So you've got these ridiculous situations where the government has just taken someone's property when they've done nothing wrong. Winning lawsuits is only part of the solution. I suspect you need to embarrass senior government officials to change behavior. You sued the feds because they seized a motel, owned by an innocent Indian immigrant after a random drug deal went down in one of the motel rooms. And after you won the lawsuit, you as a charity general, Eric Holder, changed the policy on seizing innocent party's property because of the public outcry. Unfortunately, the reforms that you're talking about were quite modest. That was about the federal equitable sharing program. And that's a program where even when state law enforcement seizes assets with civil forfeiture, they can share it with federal agents. Because in a lot of states, they'll have stricter civil forfeiture laws. So it's harder to seize property from people without convicting them of a crime. But they can get around those stricter laws by using the federal equitable sharing program. And that was what Holder made very modest reforms to. And it left intact the majority of the program. But fortunately, there is a bill pending in Congress right now that could actually make some real reforms to civil forfeiture at the federal level. And IJ has been involved with that for a long time. It only gets so far every year, but I think this year, it's gotten further than it's ever gotten before. And it has bipartisan support. So hopefully, after IJ has pushed for years and years through communications, through litigation, through legislation, we might actually see some real reform. You work for a public interest law firm. What does that mean? So public interest law is bringing strategic cases to further that mission. So you're being choosy about the issues and the clients you work with. And in the case of the Institute for Justice, our mission is to increase freedom in the areas that we work in. We're a nonprofit, and we represent our clients for free. And we look for those special types of clients. Other public interest firms, the ACLU, the NAACP, they both have missions that they're furthering through their litigation in the court of public opinion through legislation. Do you sometimes find that you win by losing? Absolutely. That's the Kilo versus New London case. In many ways, a heartbreaking loss for IJ, because we had this entire neighborhood that was going to be taken by a minute domain for building condos and shopping and everything for the people who are going to work at Pfizer. So taking property and handing it over to a private entity for private use, whereas a minute domain is meant to take property and use it for a public use, like a road or a park or a hospital or something like that. But in this case, the US Supreme Court said actually it's OK for the government to take property and hand it over to a private entity for a private use. In 2005, we lost that case. But we immediately turned around and said, how can we use this? And we said, this has happened, but at the state level, you don't have to tolerate this, states. You can change your laws and prevent this from happening in your own states. And so the reaction was huge. And everybody was up in arms about it. And so the vast majority of states reformed their eminent domain laws as a result of Kilo. And so at this point, it's pretty rare that you get a case like Kilo. We sort of won so much that those cases are vanishingly rare. And that's a great thing. Hi, Andy Chepisode. I'm a note of optimism, Renee. What are you at Mystic about as are awaits to economic liberty? I'm optimistic about bringing economic liberty claims under state constitutions. I think that there are a lot of judges who are out there looking at their state constitution and eager for these cases to come before them. And so I'm optimistic that we'll be able to find those opportunities and bring those cases and win. Thanks to Gary and Renee for joining us today. If you missed last week's show, check it out. The topic was, Asians get to attend Harvard. Our speaker was Rick Banks, who is the Jackson Eli Reynolds Professor of Law at Stanford Law School and the co-founder and faculty director of the Stanford Center for Gratial Justice. You may recall that Rick was previously the co-host for this podcast, what happens next, along with me during the most of 2020. Rick discussed the Supreme Court decision in the students for fair and mischievous cases against Harvard and the University of North Carolina. I now want to make a plug for next week's podcast with Thomas Bologna, who is Professor of Management at MIT Sloan School and is the director of the MIT Center for Collective Intelligence. Tom is the author of the book, Superminds, the surprising power of people and computers thinking together. AI is obviously a big topic right now. And I want to learn from Tom about how we will interact with AI-based algorithms to become a supermind using the best of humans can do with the awesome computing power of the most advanced computers working together. You can find our podcast and previous episodes and transcripts on our website, what happens next in six minutes.com. Please subscribe to our weekly emails and follow us on Apple Podcasts or Spotify. Thank you very much for joining me. Goodbye.