Exploring Employment Discrimination in America
Last updated on June 5th, 2018 at 11:47 am
Exploring Employment Discrimination in America
On November 19, 1863, the 16th President of the United States delivered a speech that would be embedded in the hearts of generations to come. The Gettysburg Address began with the words, “Four score and seven years ago our fathers brought forth on this continent, a new nation, conceived in Liberty, and dedicated to the proposition that all men are created equal (Library of Congress, 2000)” The words in the Gettysburg Address challenge American citizens with the principle of equality. More than a century later, the nation still struggles with discrimination against those who may be different than another person or group.
In the employment arena, laws have been enacted by congress to eliminate discriminatory acts by employers or associate employees. Occasionally these laws are put to test in the Court of Law by companies that have been accused of being in violation. An examination of three such court decisions will be presented including a brief explanation of each law that is allegedly violated.
Fleming v. The Boeing Company
Company Overview and History
The Boeing Company is currently the world’s largest aerospace company. Additionally, they claim the title of the world’s eminent defense contractor. The Chicago based Boeing Company employs roughly 164 thousand people in over 70 countries worldwide. In 2002, the company had revenues of 54.1 billion dollars. Presently, Boeing has established itself as the largest United States exporter (Boeing Company, 2003).
Boeing is widely known for its production of commercial jetliners, military aircraft, satellites and missiles. The list of current jetliners includes the 717, 737, 747, 757, 767 and 777 series aircrafts. There are more than 14,000 of these aircraft in service worldwide, which consist of 75% of the world’s commercial fleet. Boeing also provides global financial services, aviation training services and other diversified services and products (Boeing Company, 2003).
The Boeing Company was founded in 1916 as the Pacific Aero Products Company by William Boeing. Boeing was a prosperous lumberman from Detroit, Michigan who was fascinated with flying with the newly invented airplane (Spurge, 1997). He learned to fly and soon was eager to sell and manufacturer his own aircraft designs. During World War I, the new company received its first production orders of 50 Model C seaplanes from the US Navy. Shortly after this, the company was renamed to The Boeing Airplane Company. The company was the principle producer of military aircraft during the 1920s and became one of the largest aircraft manufacturers in the nation (Boeing Company, 2003).
In 1943, the company was forced to break up into three separate companies. These companies became United Airlines, United Technologies, and the Boeing Airplane Company. Boeing continued to prosper during World War II in which it supplied the allies with numerous aircraft. Most notable of these aircraft was the B-17 and B-29 bombers (Boeing Company, 2003).
After the war, Boeing survived by shifting production efforts to commercial airliners using the newly developed jet turbines. With the Cold War at hand, the military contracted Boeing to erect jet powered bombers and Intercontinental Ballistic Missile (ICBM) systems. The company was propelled into the space race in the 1960s by becoming the primary manufacturer for NASA (Boeing Company, 2003).
Boeing continues to have a dominant role in commercial and military aircraft, missile systems and space technologies. Major acquisitions and mergers have included Hughes Electronics Corporation, Jeppesen Sanderson Inc, Hawker del Havilland, and Rockwell International. Boeing continued to expand by merging with McDonnell Douglas in 1997. (Boeing Company, 2003).
In August 1997, the United States District Court for the Northern District of Alabama was presented a Title VII case against Boeing Company. The case was dual in nature in that two plaintiffs joined complaints against the company. These two cases were joined because they both involved alleged sexual harassment claims against Bobby Philyaw, an Engineer at the company (Fleming v. Boeing Company, 1997).
The first plaintiff was Toni Fleming who was employed at Boeing as a full-time secretary. Fleming worked at the company since 1985 and was transferred in July 1992 where Philyaw was located. Fleming, who is an African American woman, claimed that shortly after arriving, she was alerted by other secretaries that Philyaw had a strong sexual preference for African American women (Fleming v. Boeing Company, 1997).
Fleming stated that Philyaw was constantly touching and gazing at her during the months of September and October. Eventually she asked him not to touch her anymore. Fleming then reported the incidences to Philyaw’s supervisor, Chuck Homan. Homan told Fleming that he would discuss the complaints with Philyaw and that if Philyaw did not cease in these unwanted harassments that she was to notify himself and the companies Equal Employment Opportunity (EEO) Officer. Fleming did not make any contact with the EEO Officer or Homan with any further complaints (Fleming v. Boeing Company, 1997).
In January 1993, Fleming was contacted by the EEO Officer because a sexual harassment complaint was filed against Philyaw involving a different secretary. Upon asking Fleming if any sexual harassments had occurred after the warning was issued to Philyaw, she indicated that he was continuing to harass her. This information led to the demotion and loss of pay to Philyaw. He also received a written letter of discipline in his employee records. Fleming was assigned a new supervisor. She stated that after these actions were taken, Philyaw was no longer harassing her (Fleming v. Boeing Company, 1997).
Fleming’s case against Boeing was that the company did not act quickly enough to resolve the sexual harassment problems delivered by Philyaw. She maintained that during the time she made the initial complaint in October and when disciplinary action was enforced in January that she was forced to work in a hostile work environment. She was seeking compensatory and punitive damages during this time period (Fleming v. Boeing Company, 1997).
The second plaintiff, Sherrye Alexander was also an African American woman. Alexander was employed by a temporary agency and was placed at Boeing from 1989 to 1991 as a secretary. Similar to Fleming’s case, she was placed in the same group as Philyaw (Fleming v. Boeing Company, 1997).
Alexander claimed that Philyaw persistently sexually harassed her in the form of verbal comments and unwanted physical contact in June to August of 1991. Alexander stated that she informed Philyaw in July that she did not welcome the treatment that he forwarded to her. Philyaw then apologized and agreed to cease with these actions. Alexander also contacted her supervisor at the temp agency about the situation. Her supervisor then contacted an employment manager at Boeing and relayed the complaint. The manager then contacted Alexander and asked her if she would be willing to come to the manager’s office to discuss Philyaw’s behavior. She declined and cited that the situation was improved since she confronted Philyaw (Fleming v. Boeing Company, 1997).
During the month of August, Philyaw tickled and touched her despite the warnings from the prior month. Alexander then reported this action to MacCrone, Philyaw’s supervisor. MacCrone investigated her complaints and then set up a meeting where Philyaw delivered a second apology. Philyaw was issued a verbal warning and Alexander was reassigned so that she was not working for Philyaw (Fleming v. Boeing Company, 1997).
Shortly afterwards, Alexander applied for a permanent secretarial position at Boeing. She was informed that she was denied employment due to the fact that she did not pass a state certification test. She left the company in November of that year and took a job with the United States Army (Fleming v. Boeing Company, 1997).
Alexander claimed that she was denied permanent employment because she complained about Philyaw‘s harassments. She was seeking a court order to force Boeing to hire her as a permanent secretary. Additionally she wanted the company to be required to pay her compensatory and punitive damages based within the scope of Title VII (Fleming v. Boeing Company, 1997).
Title VII and Sexual Harassment Laws
The Title VII of the Civil Rights Act of 1964 forbids employers to discriminate based on race, color, religion, sex, or national origin (EEOC, 1997). Title VII has been successfully used in court cases where sexual harassment claims have been filed (Spurge, 1997). This is because sexual harassment is considered to be a form of sexual discrimination (Fleming v. Boeing Company, 1997).
Sexual harassment is defined as unwelcome advances or other activities of a sexual nature (Spurge, 1997). There are two types of sexual harassment that are defined by title VII (Fleming v. Boeing Company, 1997, p. 509). They are as follows:
- Quid Pro Quo: When sexual conduct is a condition of employment or used as a basis for favorable treatment (Spurge, 1997, p. 509).
- Hostile Environment: Where sexual talk, actions or objects create a hostile atmosphere or interfere with an individuals ability to work (Spurge, 1997, p 509). The victim does not have to be the person harassed but it can also be someone affected by the conduct (EEOC, 1997).
Employers may be held directly or indirectly responsible for one of their employees sexually harassing another individual. Directly liability occurs when an employer knew or should have known that sexual harassment was taking place and they failed to take immediate and suitable corrective action. An employer is indirectly liable when they have explicitly or implicitly authorized this conduct (Fleming v. Boeing Company, 1997).
The Equal Employment Opportunity Commission (EEOC) is the federal entity that enforces Title VII and other discriminatory protection laws. EEOC regulations states that all Title VII charges, including sexual harassment must be filed within 180 days of the alleged violation. All charges must be filed with the EEOC before any private lawsuits can be filed in court (EEOC, 1997).
In respect to Toni Fleming’s case, the plaintiff did not file claiming any quid pro quo sexual harassment issues. This limited Fleming’s case to be limited to hostile environment claims. The Court had to decide if Boeing was indirectly or directly responsible for hosting a hostile environment in respect to Fleming (Fleming v. Boeing Company, 1997).
The court did not find any evidence that Boeing was directly or indirectly responsible for Philyaw’s actions. The court found that Boeing took suitable and immediate action against Philyaw when Fleming first confronted him and his supervisor. Fleming also failed to contact the EEO Officer as instructed if Philyaw continued to harass her. When the EEO officer contacted Fleming and was given information that Philyaw did indeed to continue these actions, Boeing immediately took action. Philyaw was demoted and his pay was decreased in response to his conduct. The court found that this fulfilled the immediate and appropriate correction obligations of the company. Furthermore, the court dismissed any accusations that Boeing was indirectly liable by any means of endorsing Philyaw’s behavior (Fleming v. Boeing Company, 1997).
Sherrye Alexander, the second plaintiff also was not successful in retrieving any damages from Boeing. First and foremost, Alexander failed to file her complaint with the EEOC within the prescribed 180 days of the alleged sexual harassment. If Alexander did file in a timely manner, it was also established that she did not have a prima facie case against Boeing. A prima facie case would be the argument that she was rejected for the position despite her qualifications. Boeing calls for that all applicants for permanent secretarial positions must pass an Alabama state typing test before being considered. Alexander did not pass the test nor could she provide any evidence that Boeing has ever hired an applicant who has failed the test. These facts were sufficient to prove that Alexander’s rejection for the job was not based on her complaints against Philyaw (Fleming v. Boeing Company, 1997).
Additionally Boeing was found to have provided immediate and appropriate action against Philyaw in regards to his harassments against her. This is a fulfillment of obligation demanded by Title VII. Another factor was that Alexander erred in declining to meet with the manager to discuss Philyaw’s conduct in July 1991 (Fleming v. Boeing Company, 1997).
Leisek v. Bright Wood Corporation
Company Overview and History
Bright Wood Corporation was founded in 1960 in Madras, a city in Central Oregon, where it is still currently located. The company specializes in the remanufacturing of secondary lumber. Bright Wood began its first year operating out of a planer shed, now has grown to utilizing 14 plants in Madras with a number of plants on the west coast (Bright Wood Corporation, 2002).
The company claims to produce 1,300 truckloads of lumber and logs each year. This ranks the company with the title of being the world’s largest secondary lumber remanufacture. The company also reports to maintain a growth rate of about 20 percent (Bright Wood Corporation, 2002).
John Leisek, a former employee of the Bright Wood Corporation and also a member of the Oregon National Guard charged that his former employer violated the Uniform Services Employment and Reemployment Rights Act of 1994 (USERRA) by terminating his employment unlawfully. The case was previously tried in the United States District Court for the District of Oregon. The court ruled in favor of the employer and had been appealed to the Ninth Circuit of the United States Court of Appeals (Leisek v. Brightwood Corporation, 2002).
Leisek’s full-time employment with Bright Wood began in December 1991. He began his career with the company as a production worker and was promoted to the position of a quality assurance inspector when he was terminated in July of 1996. Leisek was also a member of the National Guard before he became employed with Bright Wood and remained in the National Guard during his entire stay at the company (Leisek v. Brightwood Corporation, 2002).
Leisek also owned and operated his own hot-air balloon that he decided to affix the National Guard insignia on it. This balloon was soon valued by the National Guard as a valuable promotional tool Leisek created the Hot Air Balloon Interaction Team (H.A.B.I.T) to travel around the country in search of new recruits. In 1995, he was granted a leave of absence by Bright Wood to engage with this campaign (Leisek v. Brightwood Corporation, 2002).
In 1996, Leisek was promoted to a more specialized job title as a quality assurance inspector. The National Guard issued several written orders to perform temporary active duty to lead the H.A.B.I.T program once again during various dates from May 1996 to September 1996. He presented the list of events during this time period to Bright Wood, although he did not have written orders for every event at that time. Due to the fact that there were a number of events during the summer, he again asked if he could take a leave of absence during this entire period.
Bright Wood denied his request of leave on the basis that his absence during the summer would be a hardship for the company now that he retained a job specialty. The company advised him to abstain from participating in these balloon events for the National Guard. The list of events submitted to the company that were significant to the case was as follows (Leisek v. Brightwood Corporation, 2002).
- June 23 to June 30, Boise Idaho, written orders.
- July 3 to July 7, Monroe Wisconsin, written orders.
- July 8 to July 14, Montrose, Colorado, no written or verbal orders.
Bright Wood honored the dates which contained written orders; however, the company denied him any time off for the Colorado event. Leisek left the company to participate in the Idaho and Wisconsin events. Leisek contacted his manager, David Duncan at Bright Wood to inform him that he was going to continue on to the Colorado events. Duncan reiterated the fact that since Leisek did not have any written orders that he was expected to return to work since he failed to produce any written orders concerning the Colorado events. Duncan warned that if he did not return to work, he would be considered to voluntarily abandon his job and would therefore be terminated. Leisek then commented to Duncan that he would peruse his other options. Leisek went on to the Colorado event and several events thereafter without contacting Bright Wood (Leisek v. Brightwood Corporation, 2002).
On September 25, Leisek returned to the company seeking reemployment. He was denied reemployment in the event that his employment was officially terminated. The company welcomed Leisek to resubmit another application for employment consideration. Leisek refused to do so and was not offered employment (Leisek v. Brightwood Corporation, 2002).
Leisek filed action against Bright Wood for violation of the USERAA for unlawful termination. The District Court granted judgment in favor of Bright Wood, citing that Leisek failed to institute a prima facie under the law. The Court of Appeals has been asked to reverse this decision. The Appeals Court must decide on three issues (Leisek v. Brightwood Corporation, 2002). They are:
- If Leisek’s military obligations was a motivating factor in the employer’s decision to terminate him against USERRA regulations.
- The question if Leisek would have been terminated from Bright Wood despite being in the National Guard concerning the USERRA claims.
- If Leisek’s absence without Guard orders prohibited his reemployment rights under USERRA.
The Uniform Services Employment and Reemployment Rights Act
The Uniformed Services Employment and Reemployment Rights Act of 1994 (USERRA) was enacted into law on October 13, 1994. The USERRA was intended to supercede the previously written Veterans’ Reemployment Rights (VRR) Statute. The USERRA spells out and reinforces the VRR Statute. This act is administered by the United States Department of Labor via the Veterans Employment and Training Service (VETS) and can be officially found in United States Code at Chapter 43, Part III, Title 38. There are three main principles defined in the act (Department of Labor, 2003). They are as follows:
- To encourage non-career service in the uniformed services by eliminating or minimizing the disadvantages to civilian careers and employment which can result from such service.
- To minimize the disruption to the lives of persons performing service in the uniformed services as well as to their employers, their fellow employees, and their communities, by providing for the prompt re-employment of such persons upon their completion of such service.
- To prohibit discrimination against persons because of their service in the uniformed services.
The USERRA states that if an employee’s military obligation causes the employee to be absence from their civilian employment then they are entitled to reemployment by the employer (Department of Labor, 2003). The following conditions must apply:
- Advance written notice is provided to the employer of the absence.
- The cumulative length of these absences does not exceed five years.
- The person submits an appropriate application for reemployment no later than 90 days after the conclusion of their term of service.
- Employees are disqualified from reemployment rights if they receive a dishonorable or equivalent discharge from the military.
When the employee completes his term in the military, the employee is permitted to be reemployed in one of two ways (Department of Labor, 2003):
- Returned to the position in which they would have been if he had remained continuously employed or a position of like seniority, status and pay.
- If the employee is not qualified to perform a position described above, their former position of employment or a position of like seniority, status and pay, which they are qualified to perform.
USERRA also protects the employee from prohibiting discrimination because of their military status and obligations. A company can be held in violation of USERRA if the employee can prove that their military status was a substantial or motivating factor in an unfavorable employment action. The employer must prove that the employer would have taken the same action regardless of the employee’s military status (Leisek v. Brightwood Corporation, 2002).
Leisek did not have any written orders for the Colorado event nevertheless he attended the event regardless. His failure to report to work generated unexcused absences. It is Bright Woods company policy that any employee may be terminated in the event of such absences. The Appeals Court found that this unauthorized absence was deemed to be outside the protection of USERRA (Leisek v. Brightwood Corporation, 2002). However, the law states that Leisek only needed to produce evidence that his military obligations were a motivating factor in his termination (Department of Labor, 2003).
The burden of evidence of discrimination was found to be fulfilled in Leisek complaints. When Leisek’s initial notice of duty was presented to the company, Bright Wood complained to Leisek that his absence would create a strain for the company during the summer. The company was reluctant to allow him time off for his written orders. Furthermore, the plant manager explicitly informed Leisek that the company would not accept any future absences even when they were presented with written orders in association with the H.A.B.I.T. activities. The court cited that the burden of proof of compliance to USERRA was shifted to Bright Wood. Bright Wood was unable to produce evidence that his Guard status was not a factor in his termination. The Appeals Court reversed the judgment by the District Court in favor of Leisek (Leisek v. Brightwood Corporation, 2002).
The second issue at hand was for the Appeals Court to rule in the matter of Bright Woods refusal to reemploy Leisek. Because Leisek attended the Colorado event without orders, his unexcused absences were outside the protection of USERAA. Leisek then refused to reapply for a position when he was offered to by the employer. Therefore, he did not submit an application to Bright Wood within 90 days as mandated by the law (Department of Labor, 2003). The court upheld the decision by the District Court, ruling in favor of Bright Wood in the issue of Leisek’s reemployment rights (Leisek v. Brightwood Corporation, 2002).
Davey v. Lockheed Martin Corporation
Company Overview and History
The Lockheed Martin Corporation is an advanced technology company based in Bethesda, Maryland that was established in 1995 when Lockheed Corporation and Martin Marietta merged. Although the company has been newly formed, it is comprised of 17 heritage companies that date back to 1909. These 17 companies include Lockheed Corporation, Martin Corporation, American Marietta, Goodyear Aerospace, General Dynamics, Sperry, IBM Federal Systems, Ford Aerospace, Sanders, Gould, Xerox Electro-Optical Systems, Loral Corporation, UNISYS, and Vought (Lockheed Martin, 2002).
Lockheed Martin currently employs 125 thousand employees worldwide and in 2002, generated 26.6 billion dollars in sales. The company offers research and development services as well as a manufacturer of advanced technology systems and aerospace aircraft and equipment. Eighty percent of the company’s business is with the United States Department of Defense (Lockheed Martin, 2002).
The company is best known for its jet powered aircraft. Most notably are the C-130 transport cargo, F-16 Fighting Falcon, SR-71, F-117A Stealth Fighter, F/A-22 Raptor, and the U-2S spy plane. Lockheed Martin is also responsible for the manufacturer of NEXTRAD Doppler RADAR, the GPS System, the Hubble Space Telescope, Magellan spacecraft, Pershing II missile systems, and the Titan IV missile systems. Additionally the company has set milestones that have shaped the aerospace industry (Lockheed Martin, 2002). Some of the prevalent achievements of the company are as follows:
- In 1962, John Glenn is the first American to orbit the Earth using General Dynamics Atlas Rocket (Lockheed Martin, 2002).
- During 1963, Jacqueline Cochran pilots a Lockheed F-104 Starfighter, setting the woman’s speed record at 1,429 mph (Lockheed Martin, 2002).
- Lockheed’s SR-71, the world’s fastest aircraft sets the worlds fastest speed record by traveling America’s coast to coast in 64 minutes and 2 seconds at an average speed of 2,144.8 mph in 1990 (Lockheed Martin, 2002).
- Lockheed Martin develops a tracking infrastructure system for the U.S. Postal Service. This system enabled the Post Office to track and confirm packages, greatly maximizing delivery time and accuracy and reducing the likelihood of lost packages (Lockheed Martin, 2002).
Lockheed Martin continues to expand their services beyond the limitations of aerospace. The company generated $3.1 billion in 2002 in these diversified services. These services include energy programs, government and commercial IT services, and other federal services (Lockheed Martin, 2002).
Lockheed Martin employed Susan Davey in November 1987. In 1989, she held the title of a test engineer in which she was responsible for writing and revising procedures on highly classified payload systems. During 1991, Davey’s supervisor, Richard Turner issued her a low score on her review. Davey learned that her low ranking was given for layoff reasons. She filed an ethics complaint stating that her second-level supervisor, Ronald Bills was involved in discriminatory favoritisms in favor of male employees. Her complaint was that male employees were more likely to be promoted and were given unfair overtime preferences. This complaint resulted in the demotion of Bills and the demotion of Turner (Davey v. Lockheed Martin Corporation, 2002).
During 1992, her new supervisor, John Shupe, gave notice to Davey that she was slated to be laid off. Her position was eliminated on April 12, 1993 and resulted in her termination of employment. Her previous job responsibilities were divided among those who where not laid off. Davey proceeded to file a complaint with the EEOC on the basis of sex discrimination and retaliation. The EEOC issued Davey a right to sue notice where she filed action in September 1996 (Davey v. Lockheed Martin Corporation, 2002).
During 1997, Davey was made aware of job openings in the test engineering department where she previously worked. She contacted the technical staffing manager and met with him to express her interests. The manager stated that Shupe had modified the organizational chart that did not include any test engineering openings and referred her to apply for a test conductor position. However upon inquiry, she was informed that she would not obtain a job offer in that position (Davey v. Lockheed Martin Corporation, 2002).
Davey filed discrimination charges against Lockheed Martin in Circuit Court citing that the company discriminated her on the basis of gender in 1992 and retaliation against her in 1993 when she was dismissed. She later modified her lawsuit to include a second retaliation demand when she was refused employment in 1997. A jury found Lockheed Martin not accountable for the 1992 discrimination charge or for the 1993 retaliation charges. However, the jury awarded compensatory damages of $50,000, punitive damages of $200,000 and an additional $363,210 in other awards as the jury ruled in favor of Davey in the 1997 claims (Davey v. Lockheed Martin Corporation, 2002).
Lockheed Martin appealed the verdict in respect to the verdict concerning the 1997 retaliation claim. The company claims that the court mistakenly denied the company the right to present a material aspect of the case which led to an unjust punitive damages award. The company maintained that they were in good faith compliance with Title VII. The company also contends that the court failed to inform the jury that an invidious motive must be a motivating factor in an employment decision. Lockheed Martin sought after the dismissal of all punitive and attorney fees (Davey v. Lockheed Martin Corporation, 2002).
Title VII Case Law
Title VII of the Civil Rights Act of 1964 protects employees from being discriminated upon the basis of race, color, religion, sex and national origin (EEOC, 1997). A 1999 case, Kolstad v. American Dental Association 527 U.S. 526, sets the model for a framework for awarding punitive damages in discrimination cases. This case provides employers with a protection against punitive damages (Davey v. Lockheed Martin Corporation, 2002).
The Kolstad case stated that the employee must prove that the employer carried out these discriminatory acts knowing that it was violating federal law. If this can be accomplished, then the next step would be to establish that the supervisor who committed the violation was within the scope of employment. The Court added that even if this criterion was established, punitive damages would not be granted if the employer had displayed that they are engaged in good faith efforts to comply with Title VII. The bare minimum that an employer needs to fulfill this obligation is to adopt anti-discrimination policies and make efforts to educate employees about Title VII (Davey v. Lockheed Martin Corporation, 2002).
The Appeals Court for the District of Colorado found that the Lower Courts erred in its decision to disallow Lockheed Martin to include the Kolstad decision to their defense. The Appeals Court found no evidence that Lockheed Martin acted in bad faith or intentions to comply with Title VII regulations. The Appeals Court cited that when Kolstad is properly applied that Lockheed Martin is not liable for punitive damages on the 1997 claim. The Court voided all punitive damages and attorney fees that were awarded to Davey. Additionally, the Court ordered a new trial that was limited to the matter of punitive damages (Davey v. Lockheed Martin Corporation, 2002).
In many cases, the Court may rule in favor of the employee and the worker receives their proper restitution. There is desire that the company in violation learns from their faults and corrects their policies in anticipation that they will not be repeated. Those companies that do not take advantage of lessons learned may continue to make the same oversights and frequently encounter law suits. Regardless of if the company wins a case, the mere knowledge that a company has been found to be engaging in discriminatory activities, erodes the reputation of the company. Companies must continuously educate their leaders of the laws and that discriminatory acts will not be tolerated in the 21st century. A company that fails to take such measures will cease to remain competitive in the years to come.
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©2018 Michael A. Hartmann
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