The information on this site does not constitute legal advice and is for educational purposes only. If you have a dispute or legal problem, please consult an attorney licensed to practice law in your state. Additionally, the information and views presented on this blog are solely the responsibility of Justin Bathon personally, or the other contributors, personally, and do not represent the views of the University of Kentucky or the institutional employer of any of the contributing editors.
I am growing more and more frustrated in how the courts are handling school resource officers. The courts seem to have no trouble concluding that school resource officers are more like school officials for purposes of getting under the reasonable suspicion standard of the 4th Amendment (searches and seizures). On the other hand, courts, such as this one in Florida, seem to have no problem still giving school resource officers all the protections traditionally afforded the police force. The Florida case even conceded the point that the resource officer was under the direction of school administrators, but still found a student guilty of the crime of battery of a law enforcement officer when he fought with the resource officer that stopped him in the hallway. How are students supposed to know how to treat these people? They discipline like principals, have the authority of school administrators, get the protections of school administrators, yet if you interact incorrectly with them, all the built-in protections we afford police in this country can come down on top of (and ruin) the student's life.
We absolutely need clarity from the courts on whether school resource officers are more like school employees or more like police. This having it both ways stuff (to the detriment of the students in all cases) has got to stop.
There's another AP sexting story all over the country's newspapers today. It was not responding to any particular event that just happened yesterday, they just ran one to run one and local papers picked it up.
This is a big part of why schools are struggling with technology. The newspapers just keep pushing the angle until they make every last penny off scaring people away from this stuff.
I don't mean to discount the sexting issue, it is a legitimate issue, but one that is blown way out of proportion in my eyes. They got everyone in such a hype over this that we have child pornography laws being changed to charge kids with sexual assault. Luckily, we still have some judges with common sense, but that is not going to stop it.
I hope this controversy dies down over the summer and in the fall we actually take a realistic look at how we can do a better job on technology usage education for our children.
Check this one out and decide for yourself. A principal in South Carolina has taken to "whippen" kids to restore order in the school -- and it has worked to the benefit of his school achievement scores.
You can decide for yourself on this one, but it really depends on the definition of success, doesn't it. A scared school doesn't necessarily strike me as a successful school, no matter what the test scores say. We have made a lot of progress over the past few decades in phasing out corporeal punishment and I would really hate to see young principals start picking it back up because they feel like they have no other options to get test scores up.
This is a pretty bad one - I have not seen this before (I have a son who is potty training now, so I hope our daycare doesn't send something similar home to us).
But, the lesson here is that you can't just do nothing altogether. The school sent an e-mail a couple days later and then did nothing else. When parents, or anyone for that matter, don't get any responses to inquires, at some point they all start to think of the media as the next place to turn. I know that lawyers have a tenancy to tell clients to do nothing and say nothing (in the hopes problems will go away), but this is sometimes the effect of that strategy. An incident that may have been handled on a personal level with reprimanding the teacher now is a national news story.
H/T Scott M. - who I am just going to start calling my researcher.
We'll do a little mail today as I have a couple a need to get to (I try to be pretty responsive to reader requests or questions as much as I can without practicing law, so feel free to contact me):
A reader from Michigan writes in with a question/musing:
"How is it a school district thinks it has a right to scan students' Facebook pages and assign consequences to those that express dislike for certain teachers or use profanity in any way."
This is an excellent, excellent question and I want to address this in two parts, the legal part and then the ethical part.
First, legally, what the courts have done is establish a mechanism by which schools can reach outside of the four corners of the school and regulate off-campus behavior. Here is the mechanism: (1) the court looks for a "nexus" (connection) with the school district. This can literally be anything and the courts have been pretty liberal in establishing this nexus. When the Internet was still new, courts were more reluctant, but now we are seeing them permit quite a bit of regulation of the net. (2) Once the nexus is established, then we run through the traditional student speech analysis. (a) Is it speech? - Is it meant to convey an idea? If yes, continue, if no - regulate. (b) Is it lewd, vulgar, plainly offensive? Here is where your profanity comes in and school authorities feel comfortable regulating. (c) Does it promote illegal activities, such as drug use. Yes = regulate. No = continue. (d) Does it cause a disruption? This is the biggie. There is a lot of legal history here establishing what is and is not a disruption, but the administrator's perception will usually get quite a bit of deference. Typically, if you have a nexus, you probably have a disruption - as the disruption is the nexus.
Anyway, that's the legal standard that courts consider. As you can probably tell, it is pretty broad and gives schools quite a bit of leeway in regulating off-campus student speech.
Second, though, I want to talk about the ethical issues here. I addressed the legal "how," but there is a second "how did it get to this point?" type question embedded in the musing, so I also want to address that. How it got here is a complex deal, but let me throw some motivating factors out there. (1) Columbine. The effect that incident, and the other school shootings in that period, had on schools is so profound that I think we are just now starting to come to grips with it. One major effect though was to make schools much more proactive in regulating everything related to students. Before Columbine we did not think our students would kill us or others, after Columbine, we were not so sure anymore. (2) Bullying and Cyberbullying. The Columbine events also woke us up to bullying issues and especially those bullying issues that occured online. A Secret Service report concluded that bullying was a substantial motivating factor in these incidents and that woke up the national conscious to this issue. States responded with anti-bullying statutes and some, like Kentucky, even created online harassment misdemeanors to punish kids who bully. (3) Sexual predators & Porn. In the late 90's and early 2000's adults really had no idea what was going on online. In fact, one can make a pretty cogent argument that most adults still don't 'get it.' When people don't understand something, they fear it - and we feared the Internet for a long time and possibly still do. All a lot of average American's hear about the Internet is the bad things, like predators and porn. (4) Lots of other factors from teacher facebook incidents to the rise in smaller, private school administrator preparation programs which spend all their time telling "war stories" and scare the heck out of future school administrators.
All those factors combined to create an environment where school regulation of off-campus speech was not just allowed by courts ... but it was encouraged by society and school boards. At some point administrators thought it was their job to regulate off-campus speech - which, in my opinion, it isn't their job nor has it ever been. But, at some point we crossed a threshold where the bounds of the school were extended beyond the four corners of school property. We sort of put schools in charge of student discipline all the time, not just between 8 and 3. How long this will continue I don't know. Certainly questions like yours show indications of a push-back, where school personnel start to say, "what a second ... why am I regulating what kids do at home?"
Following up on my post yesterday, I am going to make a follow-up plea today that we start eliminating these rooms. Last night I had access to some school data on usage of time-out rooms and I was absolutely in shock. Unfortunately, I cannot share this raw data and you will just have to take my word for it, but it was stark. Students were being forced into the "time-out" room sometimes more frequently than they were in the classroom. In one school year, one of the students at this school spent 80 hours in the time-out room. Some teachers referred students to the time out room on a daily basis. Sometimes for nothing more than not having their homework finished. Some administrators, in taking in a troubled student from another district, planned for the student to spend the majority of his days in time-out. Before they even met the kid.
This has got to stop.
The question is how do you make this stop.
Legislation would be a good idea. A bill in Missouri attempted to do just that, and hopefully those bills will become more popular across the country until a few get passed and hopefully that will start the ball rolling. Some departments of education are passing guidance, but I see this as being above the DOE level.
Secondly, Colleges of Education have to do better on preparing administrators and teachers for this. The disparity between teachers in how they used this room in the data I saw (some teachers never, some teachers daily) speaks to the lack of preparation for this issue.
Third, though, I think there is a huge potential for lawsuits here to bring these rooms down. First, this is false imprisonment. Certainly my post yesterday had the makings of a viable false imprisonment claim and the beauty of a false imprisonment claim is that it is an intentional tort, so immunity laws would not protect and teachers could be personally liable as well. It wouldn't take many of these cases to shock administrators and teachers into changing their behavior. There may even be a criminal charge that could be applicable (I would have to do more research on that to be sure).
Next, there is a lot of due process issues entangled in this - and my feeling is that schools are not getting them right. Really, this is a suspension, plan and simple. Since it is a suspension, all the due process that accompanies suspensions should accompany this ... but my feeling is that it is not. From the number of incidents I saw yesterday, the principal would be spending all her time filling out paperwork for these things if it was being done properly. Students and parents need to be aware that their rights are probably being violated in a ton of these cases, and again, a few highly publicized lawsuits would help.
Bottom-line: This needs to stop. The padded room concept has gone way past its original intentions and there is simply no way to justify the expansive use of these rooms today. How did we even allow this to happen in the first place?
I have always been against the "safe room" concept that is becoming more and more popular in schools ... because this is where that concept inevitably leads:
This post was written by Abigail Mack, a Master's student in one of my classes here at UK. When I do my YouTube Assignment, I try to find ways to reward the best work and I thought this post warranted publishing. Enjoy.
Allergybullying occurs when one individual intimidates a person, usually a schoolmate, by threatening to expose that person to food that they are allergic to.[1]This phenomenon is dangerous and possibly deadly form of bullying for children with food allergies.Many parents were already concerned about peanut products in their children’s school lunches, but many schools have taken steps to protect students with peanut allergies.Some schools have a “peanut free” lunch table, while other schools have adopted various measures including making peanut butter sandwiches offsite or providing very young students with a 504 Plan for their allergy.[2] Despite these precautions, parents now have to be concerned that a bully will force their child to encounter a peanut product.Incidents of allergy bullying have doubled in the last five years, forcing some schools to ban peanut products on school grounds.[3]
Incidents
New York –During the spring of 2007 in Mastic, NY a group of girls harassed fourteen year-old Sarah VanEssendelft with peanut butter sandwiches when they decided they no longer wanted VanEssendelft sitting at their lunch table.One day they all brought the sandwiches to lunch so that VanEssendelft could not sit with them.A few days later, a boy in one of VanEssendelft’s class brought a peanut butter cup and ate it in class, which sent her to the hospital for four days.Since the incident VanEssendelft’s mother has applied for a 504 plan, the school banned eating in all classrooms, and the school will consider future allergy bullying as discrimination against a disability.[4]
Kentucky- Officials arrested an eighth grade girl after she put peanut butter cookie crumbs in a classmate’s lunch box.The bullying victim did not eat the crumbs and she did not have an allergic reaction from exposure.However, the bully is now facing felony charges in juvenile court for wanton endangerment.[5]
Legal Issues
Allergy bullying falls under the terms of most state’s anti-bullying policies.As of April 2008 thirty states had adopted an anti-bullying policy aimed at defining, preventing, and outlining the consequences associated with bullying in school.Most of these policies encourage an early reporting system aimed at preventing initial incidents from continuing and escalating.State anti-bullying policies do differ.Some states do not define bullying categorically, meaning that their policies do not define harassment based on gender, sexual orientation, and other categories of discrimination.
For More Information on Bullying and Allergy Bullying see:
[2] Karen Plumley, “Life Threatening Food Allergies in School: What Schools are Doing for Kids who are Allergic to Peanuts.” Retrieved March 29, 2009 from http://specialneedseducation.suite101.com/article.cfm/food_allergies_in_school
[3] Lauren Cox,“Peanut Butter and Deadly Taunts.” Retrieved March 29, 2009 from http://abcnews.go.com/Health/AllergiesNews/story?id=4659705
Justin Bathonon Wednesday, January 14, 2009 at 1:09PM
Alright, this is absolutely one of my least favorite topics to write about, but since it has been grabbing a lot of headlines lately, I figure we might as well get it over with. This is sort of like plane crashes. It happens only infrequently, but when it does it is guaranteed to grab national headlines. There is far more fear out there of sex-crazed teachers than there needs to be (this affects (reported cases) less than .01 percent of teachers per year). It also doesn't help that there is this national infatuation with this issue (for various nasty reasons I am not going to mention). But, let's deal with it anyway:
First, legally, there are a few different issues here and let's address each one briefly.
1. State Anti-Teacher Sex Laws: These state laws are becoming more and more popular and most states have adopted such a law or in some stage of the process of trying to get such a law. Obviously they vary in their provisions, but the general point is to prevent or prosecute teacher sexual abuse of students. Like the one in Washington they contain criminal penalties for teachers found guilty. As more and more states adopt these laws, local prosecutors will have another weapon with which to attack teachers that engage in sexual conduct with their students. --- As far as the Washington case, that is a clear example of the limits of these types of criminal laws. The law was written to protect "minors" - which does not include 18 years olds. Thus, that law cannot be used to prosecute that teacher. However, the teacher will lose his job, lose his license, and could be subject to civil actions (see below). And, since this case got so much attention, I would assume many states will either move that age up or just say students generally.
2. Statutory Rape Laws: These laws vary greatly across states, but generally criminalize sexual relationships with children in their teens, up to about age 16-18 (depending on the state). The recent trend has been to increase this age. While there are various loopholes and this is a complicated area of law, as a general rule teacher sexual abuse of students (other than perhaps seniors in high school as was the case in the news story above) will probably also amount to statutory rape, which has a lengthy prison sentence, among other punishments (including inclusion on the sex-offender list).
3. State Child Abuse Laws:Because we are talking minors and we are talking abuse, these laws kick in as well. Sexual abuse is a standard type of abuse defined in these statutes, so all the possible criminal ramifications contained under these laws can be brought to bear on the teacher. Here is a good national resource on Child Abuse, but check your state laws.
4. Teacher Dismissal Laws: Outside of state law violations for criminal conduct (above), there are also legal implications for a teacher keeping their job. Immorality is a teacher dismissal criteria in most states. With no exceptions, teachers can be fired for having sex with a student under these immorality state law provisions. A teacher that has sex with any student, even a student over 18, should immediately be fired, pending due process. The teacher should be placed on paid leave while the due process moves forward and as quickly as possible the Board of Education should issue a ruling firing the teacher.
5. State Teacher Certification Laws: A fifth legal issue related to teacher sex with students is state certification laws. Not only will teachers be fired 100% of the time for having sex with a student, but more often than not they will also lose their teaching license as well. An October 2008 report found that between 2001 and 2005, 2,570 teachers lost teaching credentials for sexual misconduct. Again this process involves due process and the teacher has a right to defend themselves to the state teacher certification board, but with adequate evidence teachers will almost always have their licenses revoked.
6. Various Tort Actions: All of the above address government punishment of teachers, but individual students can also sue teachers under various theories for assault, intentional infliction of emotional distress and others and recover substantial monetary damages against the teacher.
7. Child Abuse and Harassment Actions Against School or Other Employees: When teachers sexually abuse students, there is frequently more than just the offending teacher involved legally. Abused students have a private right of action to bring suits against schools if there were aware of the harassment and did nothing to stop it. Also, because this may amount to child abuse, the mandatory reporter laws kick in and other teachers that failed to report could face fines or prison time (and possible revocation of their teaching license as well).
Those are the big legal issues at play and, depending on the case, there might be others as well. But, you can see these are pretty complicated legal cases, but they always end with the teacher losing their job, probably losing their license, and probably going to jail for a while under various laws.
Second, ethically this is a no-brainer, obviously. Teachers, don't have sex with students. Don't even think about having sex with students. Don't even have flirtatious relationships with students. I feel like I don't even need to say that. Also, obviously, administrators and other teachers need to report this when they even have a hint that it is going on. Just like any other child abuse reporting, that is both their duty under the law and their moral obligation to protect students that may not be able to protect themselves.
But, with that out of the way, there are a lot of other less obvious ethical issues here. What is the ethics in pre-service teacher preparation not making future teachers aware of these legal ramifications of their actions? What's the ethical responsibility of state legislators, regulators, district personnel, school leaders and others? As part of their law, South Carolina instituted a sex-abuse prevention training program. Maybe that's worth looking into? And all those ethical questions need to be couched by remembering we are talking about an extremely small fraction of the teaching population that ever has problems on this issue.
Anyway, knowing the legal issues surrounding teacher sexual-abuse is a good place to start, if nothing else.
Schools are canceling class more because of safety concerns on voting day. I am okay with that. Sends a good message to students that voting is pretty important.
In honor of the world series ... The United Countries of Baseball - I love pictures like this. Nice to see the team with one of the smallest nations in the Series. I am a national league guy (a Cardinals fan for life), but you can't root against the Rays here.
So, the big story today is the video out of Missouri showing a cop dragging down a student as he attempted to stop a fight in school (here is the backstory). The national cable networks picked up the story this morning. The cop is under investigation and I am not going to comment on the incident. Its a judgment call and maybe he went over the line slightly, although it is certainly not outrageous.
The thing is, it is exactly the kind of conduct thatwe expect from cops, isn't it? The way he took that girl down and handcuffed her was textbook and had it been in any other setting rather than a school, he would be getting high fives from everyone. Cops are trained to fight violence with violence. To react quickly and harshly. To control the situation at all costs, including, if necessary, the ultimate violent act (the cop in that video was carrying a gun). In schools, cops are violence contributors - they are there to do what the teacher's cannot. Now, maybe they deter more violence in the end and that is a kind of lesser evil choice we need to make. But, we have to continue to ask ourselves whether we want that kind of reactionary mentality in our schools. And that is a really hard question.
I have been working on the site a lot lately and failing to post a lot of good ed. law stories that folks have been sending me. So, I wanted to get these two up concerning dress codes, both of which Scott McLeod sent over.
(1) A school district is forcing students who break the dress code to wear a prison-style jumpsuit as punishment. Um, how many days until the entire school breaks the dress code on the same day to make a "this school is a prison" type statement? First, second day of school? If you are wondering, the jumpsuits look sort of like the one O.J. is modeling for us.
(2) On the other hand ... a school in California is being sued because they did not have enough regulation of the dress code. A student who was allowed to wear makeup and feminine clothing was shot and killed at the school and now the family is suing because the school allowed the boy to dress so differently which may have contributed to the violent act against him.
Seems like there is an acceptable middle ground, but maybe it is just me?
UPDATE: Well, I didn't even get to bed and I found one more. A student in Missouri who dyed her hair pink in honor of her father that died of cancer is suspended until she changes it. This is a closer call, but if you watch the video below, its not that pink. Anyway, must be the season for dress code issues.
“Students
can’t learn and teachers can’t teach in classrooms where kids are
disruptive. Some teachers are afraid to restore order when needed
because they fear legal harassment. It’s unacceptable that a teacher
would have that hesitation,” Daniels said. "Ultimately, we need parents
to recognize that firm school discipline is in every child’s interest,
and support teachers in doing whatever is necessary to maintain it. But
for now, we need action to see that no student’s education is damaged
by the bad behavior of anyone around him."
Although the campagin would never say "we want to protect teachers who hit kids" ... that seems to be the clear intention given the history in Indiana. As a former teacher of teachers in Indiana, this law seems wildly out of touch. The teachers, the vast majority of them anyway, don't want to hit the kids in the name of discipline. Frankly, good teachers don't need to resort to that.
I am all for clarifying the laws surrounding teacher discipline ... I would agree there is a moderate level of confusion about what is acceptable. But, here is a wild idea, how about we actually teach the teachers what is acceptable? You know, like actually tell them what they can and can't do? I know that sounds mildly insane compared to a more reasonable measure like a paddling protection act, but in these trying times ...
C'mon. Days like this make me glad I left Indiana.
Here is an article
out today on an off-campus student conversation about Prom and a
"spoiled" girl in their school. The conversation was taped and a
student posted it to YouTube. The school administrators, concerned over
cyberbullying, suspended the student who uploaded the video for two
days, but not the other students recorded in the video that were
actually making fun of the "spoiled girl." Now, the student that was
suspended has sued claiming her free speech rights were violated.
It is not that often that I get to post articles where I think the
administrator did the right thing, but this is one of those cases.
First, I think the school should have no authority over the off-campus
conversation. Now, many will argue there was a nexus, but kids will
gossip and complain about other kids and the school does not need to be
involved in much of that. So the decision not to punish the other
students was probably right. Second, I think there is a good reason to
suspend the student that uploaded the video. The conversation itself is
not harmful, but the publication of that conversation was. The
publication on YouTube probably had bad intent behind it and could
potentially be classified as cyberbullying. Lastly, there was probably
no free speech concerns here. In order to be protected under the First
Amendment, expression has to rise to the level of protected speech
meaning that it must be intended to communicate an idea. I don't really
see how posting a YouTube of other students gossiping is intended to
convey an idea. Even if it is intended to convey an idea, the school
could argue it was inflammatory and/or disruptive to the educational
process.
Mark W. has Gay-Straight Alliance allowed in Florida. And, I think, a smart decision out of Washington State on opening the files of teachers accused of sexual misconduct.
Scott McLeod beat me to a hard hitting post on a school administrator not allowing a student to have long hair. The student is Native American and has never cut his hair in his life.
Mitchell Rubinstein, with a link to the 11th Circuit upholding a Pledge opt-out statute, thinks the Supremes are going to eventually hold that students can be required to recite the pledge. - I might disagree. For one, for the same reason conservatives are especially fond of the Second Amendment and deregulation, there is something distasteful about the government forcing individuals to praise it. Secondly, the "under God" religion issue really complicates it and makes the outcome of such a case much less predictable.
In the case that has probably generated more posts on this site than any other (that's what happens when the plaintiff leaves a comment), Savana Redding has finally won her case against the school that strip searched her over missing Ibuprofen. The 9th Circuit, sitting En Banc, ruled 6-5 that the strip search was not reasonable under the 4th Amendment. (ABA Journal).
Common sense informs us that directing a thirteen-year-old girl to remove her clothes, partially revealing her breasts and pelvic area, for allegedly possessing ibuprofen, an infraction that poses an imminent danger to no one, and which could be handled by keeping her in the principal’s office until a parent arrived or simply sending her home, was excessively intrusive.
Clearly, correct.
I have made my feelings known on this case before, and obviously I feel the Court reached the right outcome here, even if it did take an En Banc review. Now, barring review by the Supreme Court (see below), Savana can rest easily and feel that justice was finally served.
As to the effect on educational law, I do think this case will have an impact although it broke no new constitutional ground. The reasonableness standard and its two prongs (justified at its inception and reasonable in scope) continued to be the analysis used by the Court, but what this case does is find that the reasonableness standard is not a protection for school officials, as the dissent argues. School officials can (and do) violate this standard and when they do they are putting their schools at risk and should be appropriately punished. It is up to the judges to determine reasonableness under the Constitution; it is not something that should be left wholly at the administrator's discretion.
Second, I know many ed. law professors that try to draw fine lines between strip searches and searches that are not strip searches but involve the removal of some, but not all, clothing. That should stop after this case. I would advise administrators to no longer engage in the removal of student clothing. The administrators in this case attempted to not go so far as a strip in this case by not fully removing her underwear, but the removal of the outer layers of clothing was enough to constitute a strip search. Unless in dire and/or highly justifiable circumstances, the removal of clothing should probably not be considered an option.
We may not have heard the last of this case, however. Because of the publicity, the Circuit, the outcome, and the period of time since T.L.O. was decided, I do give this case a 15-20% chance or so of being heard by the Supreme Court. But, either way, this case will continue to be referred to for years to come when discussing reasonable suspicion in schools.
The lead content in artificial turf fields (present at some schools) may be too high.
Pennsylvania has become ground zero in the fight over evolution. The latest salvo: Philadelphia academic institutions are now holding a Year of Evolution to celebrate Charles Darwin's 200th birthday.
The Arizona Republic, perhaps trying to do Mr. McCain a favor (since he doesn't really have an education policy at all), does a bit of a Q and A on what each candidate would mean for education.
Around the blogosphere:
Mark Walsh has the Supreme's decision to limit the death penalty in child rape cases and how it tangentially relates to schools.
And for your Friday Fun: Virgin Galactic. In a couple years, they are going to be making regular trips to space. For only $200,000 you can book your flight now. Assuming that none of you will be booking your flight, you can at least enjoy the photos as construction seems to be progressing nicely.
Mark Walsh, who does an excellent job tracking these things, has 3 education cases being denied cert. by the Supreme Court. I was sort of hoping they would grant cert. in the corporal punishment case, but they didn't (and perhaps for the better, considering how conservative this court is, the last thing we need is a Supreme Court opinion validating physical punishments of kids by school authorities).
The LA Teacher's walkout plan referenced a couple posts back, will be going forward as a judge denied an injunction trying to stop it.
The Scopes Monkey Trial will not be reenacted in full this year in the Dayton, TN courtroom where the first drama played out. (If anyone around Dayton wants to get that on tape and send it to me, I would love to feature it in a post).
NY Times article on Evolution Opponents new strategy. Don't you just love how this debate "evolves" - and every single story or article has to use that metaphor in the first paragraph. Must be some policy on that I am not aware of. (Also: Rubinstein)
As a person that hates the dentist, mandatory dental exams for children to enter schools is something that just doesn't sit right for me. (ZzzzzZZZZzzzzZZZzzzZZZZZZzzz ... god I have an irrational fear of dentists - see below).
And around the Ed. Law Blogosphere (any of my new ed. tech. readers are encouraged to visit other members of our little school law social network that I am working to build):
Mark Walsh at the School Law Blog has a rare school elections oriented post (don't see a lot of those, in fact in my three years of blogging, that might be the first).
Justin Bathon on 
Compared to mine, Jim keeps a pretty clean desk. 
