5 pos 2041

6-1 Race and Civil Rights

1. Commemoration of Civil Rights Movement

  • In August 2023, a large gathering at the Lincoln Memorial marked the 60th anniversary of Dr. Martin Luther King, Jr.'s "I Have a Dream" speech.

  • Approximately 250,000 attendees were present during the original 1963 march.

  • The rally in 2023 was characterized as a continuation of King's vision.

  • Featured criticisms of contemporary civil rights abuses:

    • Voting rights restrictions

    • Increased instances of hate crimes

    • Issues surrounding gun violence.

2. Historical Context of Civil Rights Organizations

  • The National Urban League (NUL) is highlighted as a historic organization alongside the NAACP.

  • The theme of the NUL's 2013 conference was "Redeem the Dream."

  • The 2013 State of Black America report noted progress due to civil rights laws but also highlighted ongoing racial disparities in:

    • Housing

    • Education

    • Health care

    • Employment

    • Economic opportunity.

3. Key Provisions of Major Civil Rights Laws (Table 6.1)

  • 1957 Voting Rights Law:

    • Federal crime to prevent someone from voting in federal elections.

    • Established the Civil Rights Commission.

  • 1960 Voting Rights Law:

    • Authorized the Attorney General to appoint federal referees for evidence gathering regarding voting rights violations.

    • Made it illegal to use interstate commerce to threaten or carry out bombings against voters.

  • 1964 Civil Rights Act:

    • Voter Registration: Made it harder to bar Black voters using literacy tests.

    • Public Accommodations: Banned discrimination in various public spaces based on race, color, religion, or national origin.

    • Schools: Allowed the Attorney General to enforce desegregation of public schools.

    • Employment: Outlawed hiring, firing, or pay discrimination based on race, color, sex, or religion.

    • Federal Funds: Prohibited discrimination in federally funded programs.

  • 1965 Voting Rights Act:

    • Enabled federal oversight in voter registration in areas with discrimination.

    • Suspended literacy tests.

  • 1968 Housing Law:

    • Banned discriminatory practices in housing sales and rentals.

    • Turned local riots and organizing actions into federal crimes.

  • 1972 Education Amendments:

    • Prohibited sex discrimination in education receiving federal aid.

  • 1991 Employment Discrimination Law:

    • Made it easier to sue for job discrimination; prohibited norms for test scores based on race.

4. Civil Rights and the Fourteenth Amendment

  • Addresses the amendment's objective of ensuring equal protection under the law.

  • Measurement of progress and challenges in civil rights law enforcement.

5. Historical Segregation and Oppression

  • Conditions for Black Americans up until the mid-20th century included:

    • Voting disenfranchisement

    • Educational segregation.

  • Systemic oppression was particularly acute in the Deep South where local White populations dominated key societal resources.

  • Legislative barriers and political obstacles impacted Black political engagement.

6. Violence and Resistance

  • Documented instances of racist violence:

    • Lynching statistics indicate significant violence against Black Americans from 1882 to 1946 (4,715 lynchings).

    • Examples of racial violence included the murder of Emmett Till in 1955 and the brutal response to civil rights protests in the 1960s.

    • The Emmett Till Antilynching Act (2022) made lynching a federal hate crime.

7. The Role of Civil Rights Leaders

  • Civil rights advancement necessitated both a broad public support and focused legal strategies.

  • The NAACP's legal focus led to major landmark cases that reshaped civil rights jurisprudence.

  • Common strategies included:

    • Publicizing systemic discrimination.

    • Legal actions addressing racial barriers and inequalities.

8. Landmark Supreme Court Decisions

  • Plessy v. Ferguson (1896): Established separate but equal doctrine.

  • Brown v. Board of Education (1954): Overturned separate but equal in public education.

    • Supreme Court ruled racially segregated schools inherently unequal.

  • Swann v. Charlotte-Mecklenburg Board of Education (1971): Approved busing as a means for integrating schools.

  • Parents Involved v. Seattle School District (2007): Struck down voluntary desegregation efforts without evidence of past discrimination.

9. Changing Dynamics in Congressional Action

  • Historical shifts reflected improvements in public sentiment toward civil rights, leading to legislative change.

  • Major civil rights legislation in the mid-20th century (1957-1968):

    • Civil Rights Act of 1964: Most significant, impacting various domains including public accommodations and employment.

    • Voting Rights Act of 1965: Enabled federal enforcement of voting rights.

    • Housing Act of 1968: Addressed discrimination in housing.

10. Post-Civil Rights Developments

  • Increase in the number of Black elected officials from 1970 to 2010.

  • Developments in voter registration and electoral participation among Black Americans.

  • Reauthorization of Voting Rights Act provisions in 2006 and subsequent challenges including Shelby County v. Holder (2013), which struck down essential preclearance requirements.

  • Recent legislative efforts at state levels to enhance or restrict voting rights.

11. Concluding Reflections on Racial Integration

  • The complexity of achieving true integration beyond simply desegregating schools by law.

  • Outcomes of court decisions and public policy towards long-standing structural inequalities in education and housing.

6.2

Women and Equal Rights

The political and legal efforts to secure civil rights for Black citizens were accompanied by efforts to expand rights for women. There was an important difference between the two movements, however: whereas Black Americans were protesting legal restrictions designed to violate their rights, women had to argue against a tradition that claimed to be protecting them.

Legal Context and Early Legal Cases

  • The Supreme Court's ruling in 1908 upheld an Oregon law limiting female laundry workers to a ten-hour workday.

    • Argument: It was justified by claiming women differ from men in physical capacities, justifying legislation to compensate for women's unique burdens.

    • Quoted justification: "The two sexes differ in structure of body, in the functions to be performed by each, in the amount of physical strength, in the capacity for long-continued labor, particularly when done standing … the self-reliance which enables one to assert full rights, and in the capacity to maintain the struggle for subsistence."

Key Historical Events

Seneca Falls Convention

  • Date: July 19–20, 1848.

  • Location: Seneca Falls, New York.

  • Organizer: Elizabeth Cady Stanton.

    • Drafted the Declaration of Sentiments, modeled after the Declaration of Independence.

    • Identified injustices against women, including prohibitions on voting and property rights.

    • Called for social, civil, and religious rights for women, especially the right to vote.

  • Voting rights for women emerged slowly from various states, particularly in the West.

  • Nineteenth Amendment was ratified in 1920, establishing that no state may deny the right to vote based on sex.

    • Notably, many Black and Native American women still faced voting barriers until the civil rights laws of the 1960s.

World War II Impact

  • The war increased the labor demand, leading to the employment of millions of women, famously represented by "Rosie the Riveter."

  • Increased visibility for the feminist movement in the 1960s, marked by Betty Friedan's The Feminine Mystique (1963).

Legislative Changes

  • Equal Pay and anti-discrimination laws responded to feminism:

    • Equal pay for equal work.

    • Prohibition of discrimination based on sex in employment and educational institutions receiving federal funding.

    • Ban on discrimination against pregnant women in the workplace.

  • The Supreme Court began altering constitutional interpretations, especially regarding the Fourteenth Amendment, which prohibits state-level discrimination.

    • Amendments shifted from protective paternalism to evaluating whether distinctions based on sex are justified.

Standards of Judicial Review in Discrimination Cases

The Supreme Court employs three standards to judge discrimination cases:

  1. Rational Basis:

    • Policy must use reasonable means to achieve a legitimate government goal.

    • Example: Age restrictions for drinking.

  2. Intermediate Scrutiny:

    • Must serve an important government interest and be substantially related to that interest.

  3. Strict Scrutiny:

    • Applicable when discrimination is based on race or sex; must serve a compelling government interest, be narrowly tailored to achieve that interest, and use the least restrictive means.

Key Discrimination Cases

  • Reed v. Reed (1971): Gender discrimination violates the equal protection clause.

  • Craig v. Boren (1976): Gender discrimination justified only by an important government objective and a substantial relation to that objective.

  • Rostker v. Goldberg (1981): Congress's discretion in drafting men without drafting women.

  • United States v. Virginia (1996): Invalidated male-only military school funding.

Legislation Addressing Sex Discrimination

  • Civil Rights Act of 1964: Prohibits sex discrimination in employment.

  • Title IX (1972): Prohibits sex discrimination in federally funded educational programs.

  • Lilly Ledbetter Fair Pay Act (2009): Extends timeframe for filing pay discrimination lawsuits.

  • Discussion of Title IX regarding transgender protections.

    • The Obama administration aligned Title IX protections based on gender identity.

    • Controversies and legal challenges arose concerning state laws affecting transgender students' rights.

Proposed Constitutional Amendments

  • Equal Rights Amendment (ERA): Proposed in 1972, affirming equal rights under the law regardless of sex.

  • Received ratification from 35 states, failing to reach the necessary threshold by the 1982 deadline.

  • Recently debated as additional states (Nevada, Illinois, Virginia) ratified; issues of potential new deadlines raised.

Landmark Supreme Court Cases Regarding Women's Rights

  • Case Examples of Illegal Sexual Discrimination:

    • Different legal ages for men and women to become adults or purchase beer are unconstitutional.

    • Mandatory pregnancy leaves and arbitrary health standards for women in employment are prohibited.

    • Equal pay for women in high school coaching roles.

  • Permissible Sexual Distinctions:

    • Laws that punish men but not women for statutory rape are acceptable; men and women are deemed not “similarly situated.”

    • All-male and all-female schools are allowed under certain conditions.

Sexual Harassment

  • Two forms defined by the Supreme Court:

    1. Quid Pro Quo: Illegal to request sexual favors for employment or promotion; employers are strictly liable.

    2. Hostile Work Environment: Must be reported for liability; employers are liable only if they failed to address the situation.

  • The Supreme Court's rulings in 1998: Varied outcomes based on environments and reporting, establishing definitions of liability.

Privacy and Sex

  • Regulation of sexual matters traditionally managed by states, asserting police power over morals and safety.

  • Supreme Court decisions shifted towards recognizing a right to privacy over time, notably through the case of Griswold v. Connecticut (1965), where contraceptive sales were protected under this inferred right.

Roe v. Wade and Subsequent Cases

  • Roe v. Wade (1973): Established a constitutional right to abortion under the right to privacy.

    • Defined trimesters for abortion legality:

      • First trimester: unfettered rights.

      • Second trimester: state regulation permitted for the mother’s health.

      • Third trimester: states may ban abortions.

  • Over time, laws and restrictions developed, including the Hyde Amendment, limiting federal funding for abortions.

  • Following several rulings supporting and upholding Roe, the Court changed course with the Dobbs v. Jackson Women’s Health Organization (2022) ruling, overturning Roe and allowing states to prohibit abortion.

    • Justice Alito's majority opinion emphasized the lack of constitutional reference to abortion.

    • Dissent expressed concerns about the ruling's impact on women's rights.

Summary of Legal Developments in Abortion

  • Significant variations in state laws regarding abortion access post-Dobbs decision.

  • States either moved to expand rights or impose strict bans with varying exceptions (life of mother, rape, incest).

  • Recent rulings have addressed also religious exemptions to contraceptive mandates in employment.

Conclusion

Ongoing debates, developments, and legal battles indicate the complex landscape of women's rights, emphasizing the importance of understanding historical context and the evolving nature of legislation and court interpretations.

6.3

6-3 Affirmative Action

Overview

  • Central theme: The ongoing debate between equality of results and equality of opportunity in the context of civil rights and affirmative action.

    • Equality of Results: Advocated by many civil rights organizations, suggests that all racial groups must be compensated to achieve similar outcomes.

    • Equality of Opportunity: Argues against preferential treatment, asserting that discrimination should not occur in reverse.

Affirmative Action

  • Definition: Laws or regulations requiring organizations to take active steps in increasing the representation of racial minorities and women.

  • Emphasis on not just opportunity but also necessary resources, such as family leave, to ensure equitable compensation.

  • Recent arguments supporting affirmative action highlight diversity, equity, and inclusion, suggesting institutions should reflect cultural and ethnic diversity.

Rights of the Disabled

  • Americans with Disabilities Act (ADA): Enacted in 1990, this law extended protections to individuals with disabilities, similar to those granted to women and racial minorities.

    • Definition of Disabled Person: Includes individuals with physical or mental impairments that significantly limit major life activities, those with a history of such impairments, and those perceived as having such impairments.

    • Rights of Disabled Persons:

    • Employment: Protection against denial of employment or promotion; reasonable accommodation provisions unless undue hardship can be demonstrated.

    • Government Programs: Access to government programs and benefits cannot be denied.

    • Transportation: New transportation must be accessible to disabled individuals.

    • Public Accommodations: Ensure “full and equal” access to public facilities.

    • Telecommunications: Regulations for devices assisting the hearing or speech impaired must be efficient and available as much as possible.

    • Comparison with Civil Rights: The ADA does not enforce rights for disabled individuals in the same strict manner as the Civil Rights Act does for race and gender.

Equality of Results vs. Equality of Opportunity

  • Equality of Results Advocates: Argue that overcoming racism and sexism necessitates race and sex considerations in remedies.

    • Examples include integrated schools and affirmative action in hiring.

  • Equality of Opportunity Advocates: Argue against preferential treatment based on race or gender, emphasizing color-blind and sex-neutral legislation.

    • Advocates for school choice and against mandatory busing for racial integration.

Courts and Affirmative Action

  • Legal Landscape: Supreme Court decisions on affirmative action between 1978 and 1990 show a split in rulings.

    • Affirmative action can either mean actively seeking diverse candidates or imposing quotas.

  • Key Supreme Court Decisions:

    • Bakke (1978): The University of California couldn't use explicit quotas but could consider race.

    • Federal vs. State Rules: Federal laws might allow certain quotas more readily than state laws.

    • Strict Scrutiny Standards: All race-based decisions must go through strict scrutiny for constitutional compliance.

Compensatory Action vs. Preferential Treatment

  • Definitions:

    • Compensatory Action: Providing aid to help disadvantaged groups catch up (supported by many).

    • Preferential Treatment: Offering advantages in hiring and admissions (widely opposed).

  • Example of Compensatory Action: A 1970s study defined it as giving disadvantaged groups extra education or training.

Case Study: Adarand Constructors v. Peña (1995)

  • Context: A construction company challenged a federal program that favored minority-owned businesses.

  • Court's Decision: Affirmative action must be tightly scrutinized; racial preferences need a compelling governmental interest; Colorado did not show a pattern of past discrimination.

California Initiative (1996)

  • Voter-approved measure to prevent state employers from considering race, sex, or ethnicity for preferential treatment.

  • Subsequent legal battles regarding affirmative action policies - with mixed outcomes across states regarding higher education admissions.

Landmark Cases Summary

  • Bakke (1978): Ruled that quotas are unconstitutional but acknowledged diversity as a legitimate goal.

  • United Steelworkers v. Weber (1979): Allowed for race considerations in employment agreements.

  • Richmond v. Croson (1989): Established strict scrutiny for affirmative action plans.

  • Grutter v. Bollinger (2003): Allowed race as a plus factor but not as a numerical advantage in admissions.

  • Fisher v. University of Texas (2016): Upheld the use of race as a factor in admissions decisions for diversity.

  • Students for Fair Admissions v. Harvard and UNC (2023): The Supreme Court ruled that considering race in admissions violates the equal protection clause; this overturned decades of affirmative action precedent.

Conclusion

  • Current legislative and judicial landscape around affirmative action remains complex due to varying state laws and court interpretations.

  • The balance between addressing historical discrimination and individual merit continues to be a contentious issue in American society and politics.

6.4

6-4 Sexual Orientation and Civil Rights

Supreme Court Decisions in the 1980s

  • State Control over Sexual Laws

    • In the 1980s, the Supreme Court was inclined to permit states to regulate private sexual conduct.

    • Example: Georgia enacted a law banning sodomy.

  • Bowers v. Hardwick (1986)

    • Supreme Court ruled (5–4 majority) that the Constitution does not prevent states from having laws regarding private sexual conduct.

    • The ruling emphasized that the right to privacy was intended to protect family, marriage, or procreation rather than sexual preference.

Evolving Court Perspective in the 1990s

  • Colorado Constitutional Amendment

    • Voters in Colorado adopted a state constitutional amendment prohibiting laws that protect individuals based on sexual orientation (homosexual, lesbian, or bisexual).

    • The law did not penalize LGBTQ+ individuals but prevented specific legal protections awarded to underrepresented racial or ethnic groups.

    • Some Colorado cities had already established ordinances for LGBTQ+ protections.

  • Supreme Court Ruling

    • The Supreme Court struck down the Colorado amendment, stating it violated the equal protection clause of the federal Constitution.

Right to Privacy and Sexual Orientation

  • Lawrence v. Texas (2003)

    • The Court overturned a Texas law that banned same-sex sexual conduct (5–4 decision).

    • The Court reiterated that the right to privacy encompasses the individual’s right to be free from governmental intrusion into sexual matters.

    • Defined privacy rights as the ability to define one’s own concept of existence, meaning, universe, and the mystery of human life.

    • This decision explicitly overruled the precedent set by Bowers v. Hardwick.

Marriage and Same-Sex Relationships

  • Massachusetts Supreme Judicial Court Ruling (2003)

    • The court decided that LGBTQ+ individuals must be allowed to marry.

    • The legislature attempted to pass an amendment banning same-sex marriage, but it was voted down in 2007.

Developments in Other States

  • While Massachusetts legalized same-sex marriage, thirteen other states amended their constitutions to restrict it.

  • California's Same-Sex Marriage Licensing (2004)

    • San Francisco's mayor began issuing marriage licenses to same-sex couples.

    • The California Supreme Court reversed the mayor’s decision.

    • The legislature voted to legalize same-sex marriage, which was vetoed by Governor Arnold Schwarzenegger.

    • In 2008, Proposition 8 was approved by voters, banning same-sex marriage.

    • A federal district judge later ruled Proposition 8 unconstitutional in 2010.

Supreme Court Cases on Same-Sex Marriage

  • Hollingsworth v. Perry (2013)

    • Challenged the constitutionality of Proposition 8.

    • The Court decided that the parties lacked standing to defend the law after California officials declined to do so.

    • Resulted in the overturning of Proposition 8 without affecting other states’ laws.

  • United States v. Windsor (2013)

    • Addressed the Defense of Marriage Act (DOMA); a 1996 federal law that denied federal recognition of same-sex marriages.

    • The Court ruled that DOMA was unconstitutional for depriving legally married LGBTQ+ couples of federal benefits enjoyed by heterosexual couples.

    • Did not declare same-sex marriage a fundamental right that all states must respect.

Further Challenges and Legal Changes

  • Following the DOMA ruling, legal challenges to state laws against same-sex marriage arose in several states.

  • Obergefell v. Hodges (2015)

    • The Supreme Court ruled (5–4) that same-sex marriage is constitutional, significantly expanding marriage rights for LGBTQ+ individuals.

  • Respect for Marriage Act (2022)

    • Officially repealed DOMA and mandated that all states and territories recognize same-sex and interracial marriages, ensuring religious freedom for religious schools and nonprofits.

Supreme Court and Private Group Exclusions

  • In early rulings, the Court differentiated between cases involving private organizations and government actions.

  • Boy Scouts of America v. Dale (2000)

    • The Court ruled (5–4) allowing the Boy Scouts to exclude LGBTQ+ individuals from its membership based on their right to decide membership criteria.

  • Changes in Policy

    • In 2013, after public discussion and controversy, the Boy Scouts announced that openly LGBTQ+ boys could join, but LGBTQ+ men would still be excluded from leadership.

    • By 2015, the organization lifted all restrictions on LGBTQ+ individuals.

Landmark Cases Summary

  • Boy Scouts of America v. Dale (2000): Allowed exclusion of LGBTQ+ from private organizations.

  • Lawrence v. Texas (2003): Invalidated state bans on same-sex sexual conduct.

  • United States v. Windsor (2013): Required federal recognition of same-sex marriage benefits.

  • Obergefell v. Hodges (2015): Established constitutional right for same-sex marriage.

  • Masterpiece Cakeshop v. Colorado Civil Rights Commission (2018): Allowed baker to refuse service for same-sex wedding on religious grounds.

  • Bostock v. Clayton County, Georgia (2020): Affirmed employment discrimination protection based on sexual orientation under Title VII of the Civil Rights Act of 1964.

  • 303 Creative LLC v. Elenis (2023): Concluded that anti-discrimination law may not impose requirements violating free speech of designers for same-sex events.

Evolving Understanding of Sexual Orientation in Society

  • Recent decades have shown a shift in social norms regarding sexual orientation and acceptance of LGBTQ+ individuals.

  • Contrasts with past classifications:

    • The American Psychological Association deemed homosexuality a mental disorder until 1973.

    • Increase in societal acceptance of diverse sexual orientations, including support for the right to marry among the U.S. public.

  • The Supreme Court often reflects these societal changes in its rulings, evidenced by its decision about employment discrimination protections for LGBTQ+ individuals in 2020.

Conclusion

  • The evolving legal landscape regarding LGBTQ+ rights demonstrates significant judicial and societal changes over time.

  • Variety of state-level responses to marriage equality showcase complicated political and legal battles, illustrating the ongoing conversation about civil rights and sexual orientation in the United States.

6.5

Civil Rights Movement and Political Participation

  • Mid-20th Century Context

    • The civil rights movement significantly transformed political participation in America, particularly for Black voters in the South.

    • The goal was to ensure that Black voices were heard and included within the political system.

  • Influence of Northern Opinion

    • Northern perception viewed civil rights as a remedy for an unfair struggle between White and Black Southerners.

    • This perception was crucial in rallying Northern support for civil rights initiatives.

  • Legal and Political System Changes

    • Legal precedents and legislative actions began applying civil rights to both Northern and Southern states, eliciting Northern opposition to court-ordered busing and affirmative action.

    • The political landscape evolved to make it challenging to limit civil rights laws to the South or modify federal court decisions through legislation.

  • Judicial Effectiveness

    • Courts might struggle without political allies; early school desegregation faced strong public resistance.

    • However, courts can be effective with organized support, even against public dissent.

Women’s Rights Movement

  • Comparison with Black Civil Rights Movement

    • The women’s rights movement mirrored many organizational methods and tactics of the Black civil rights movement, albeit with different goals.

  • Conflict Between Protection and Liberation

    • Women aimed to repeal laws that purportedly protected them but often served to limit their rights.

    • This tension contributed to the failure to ratify the Equal Rights Amendment in the 1970s.

    • In 2020, the amendment achieved the required state threshold for ratification. However, courts ruled it invalid due to exceeding the original 1982 deadline.

Supreme Court Decisions on Reproductive Rights and Affirmative Action

  • Abortion Rights

    • From 1973 to 1989, the Supreme Court upheld constitutional protections for abortions in the first trimester.

    • Post-1989, the Court approved various state restrictions on abortion accessibility.

    • In 2022, the Supreme Court reversed the landmark 1973 Roe v. Wade ruling, removing federal protections for abortion rights.

  • Affirmative Action

    • From the late 1970s into the 21st century, the Court mandated that affirmative action programs undergo strict scrutiny, ensuring they addressed established discrimination.

    • The burden of proof rested on those alleging discrimination, with regulations primarily focused on hiring rather than layoffs.

    • In 2023, the Court declared affirmative action policies in higher education unconstitutional.

LGBTQ+ Rights Developments

  • Ongoing Analysis

    • Continuous studies examine whether LGBTQ+ rights will experience similar progress as Black civil rights and other marginalized groups.

    • Significant decisions have indicated evolving policy dynamics affecting same-sex marriage.

  • Key Figures and Firsts

    • U.S. Senator Tammy Baldwin (D-Wisconsin) became the first openly LGBTQ+ member of Congress, serving in the House (1999-2013) and as a Senator (2012, 2018, 2024).

    • Thirteen openly LGBTQ+ individuals served in the 118th Congress.

  • Public Opinion Shift

    • 1996: Support for same-sex marriage was at 27%.

    • 2021: This figure rose to 70%, reflecting a significant societal change.

    • Younger voters exhibit higher support for LGBTQ+ rights, although older Americans' perspectives have also shifted positively.

  • Changing Political Landscape

    • President Clinton, upon entering office, attempted to lift the military's ban on openly LGBTQ+ individuals but faced significant backlash, leading to the implementation of the "Don’t Ask, Don’t Tell" (DADT) policy and the Defense of Marriage Act (DOMA) in 1996.

    • President Obama supported DADT and DOMA initially but later reversed course, allowing open service in the military (2013) and endorsing the repeal of DOMA.

    • The Supreme Court declared DOMA unconstitutional in June 2013 and legalized same-sex marriage in June 2015. Congress codified this decision in 2022.

  • Current Policy Debates

    • Recent discussions have centered around transgender rights, particularly concerning sports participation and gender-affirming healthcare.

    • These issues are framed as either a “culture war” or potential future majoritarian policies alongside Social Security and Medicare.

  • Future Considerations

    • The evolving public opinion, media influence, and the role of policy entrepreneurs will shape future debates surrounding LGBTQ+ rights issues.