SCOTUS Overturns Juvenile Life Sentences


In another very important decision, the Supreme Court, by a 5-4 margin with Justice Kennedy joining the four more liberal justices, ruled that mandatory life sentences for juvenile offenders violates the 8th Amendment prohibition on cruel and unusual punishment. You can read the full ruling here.

By requiring that all children convicted of homicide receive lifetime incarceration without possibility of parole, regardless of their age and age-related characteristics and the nature of their crimes, the mandatory sentencing schemes before us violate this principle of proportionality, and so the Eighth Amendment’s ban on cruel and unusual punishment.

Unsurprisingly, Scalia, Thomas, Alito and Roberts were all fine with it.

Comments

  1. says

    On the one hand, I’m a proponent of not holding things people did as teenagers (and to a lesser extent, college students) against them for the rest of their life. On the other hand, I question just how well the rest of your life will turn out when this:

    In No. 10−9646, petitioner Miller, along with a friend, beat Miller’s neighbor and set fire to his trailer after an evening of drinking and drug use. The neighbor died.

    is how you’re spending your 8th-9th grade years. Beating and/or burning another human being to death. Not for nothing, but when I was a high school freshman…I knew pretty clearly not to do that. I’m sure that, constitutionally, the Supremes made the right choice here but Klebold & Harris were minors too and they damn well wouldn’t have deserved anything less than life without parole, had they not killed themselves.

  2. David C Brayton says

    The commentors have missed a key aspect of this case–mandatory life terms w/o parole were ruled unconstitutional. The case did not hold that under all circumstances, life w/o parole is unconstitutional.

    Depending on the individual state law, and the circumstances of the case, life w/o parole for a juveniles is a possibility.

    Klebold & Harris would have been in jail for a mighty long time.

  3. sheila says

    @chriswalker It says the decision prohibits mandatory life sentences. Presumably there’s nothing to stop discretionary life sentences.

  4. says

    @Katherine Lorraine – Not everyone can be rehabilitated, nor does everyone want to be. I don’t think you can take, say, Charles Manson and turn him into a friendly team member at the local Target. Well, you can, but he’ll probably be leading a murderous cult again in his off time.

    @Everyone else – Yes, I appear to have misread the operative word. I was reading it as “life”, when it is actually “mandatory”.

  5. Dennis N says

    Not everyone can be rehabilitated, nor does everyone want to be.

    Yes, but there is no way to judge this about a future 59 year old at the sentencing for a present 16 year old. That is why we have parole boards, to make these judgements periodically. Being eligible for parole does not mean we let dangerous individuals free.

  6. baal says

    It’s a mark against the SCOTUS (and the rest of us for that matter) that it was 5:4 decision. The 4 show many signs of needing remedial classes in ethics and what counts as functioning country.

    I suppose I can dream we’ll take the private industry (who lobby for ever more crimes and longer sentences) part out of the equation. They haven’t been shown to be cheaper in the long runs and prison locations are being used for partisan political reasons.

  7. sailor1031 says

    “The 4 show many signs of needing remedial classes in ethics…”

    A few remedial classes in Constitutional Law are also needed as these Bozos demonstrate yet again their complete unfamiliarity with the constitution.

    There is a simple reason why the rules are supposed to be different for juveniles – young, plastic brains are not fully formed and such qualities as wisdom and good judgment are generally somewhat lacking, as anybody can appreciate if they take a little time to ponder all the stupid stuff they did themselves when young. Unfortunately “tough on crime” trumps logic, reason, knowledge and civilization every time!

  8. oranje says

    @Chris Walker – Now I have the image of Charles Manson working as a greeter at Target in my head. The red polo shirt would be excellent.

    This cuts once again to one of those very core ethical/practical dilemmas we face. Punishment v. Rehabilitation. I prefer rehabilitation as a goal, but that does not address the issues surrounding sociopaths or those who will never be able to live in conventional society. How do we handle them?

    No, seriously, how? Do we continue with the types of prisons we have now? Do we attempt to establish some kind of heavily regimented and monitored colony that can actually produce goods (probably wouldn’t be popular for services)?

  9. says

    Not everyone can be rehabilitated, nor does everyone want to be. I don’t think you can take, say, Charles Manson and turn him into a friendly team member at the local Target. Well, you can, but he’ll probably be leading a murderous cult again in his off time.

    That’s true, but there must be a reason why the American justice system is so shocking bad at it, and a good part of it may be that too few prisoners are given the chance of rehabilitation, or even a reason to want rehabilitation in a system that focuses almost solely on the punitive. If countries like Norway can rehabilitate 80% of their convicted felons, then there is absolutely no reason why America languishes at around a 33% success rate.

    I suspect the strong welfare system in place in Norway helps a lot, but that doesn’t mean the American judicial system can’t do a much better job than their doing now without a big boost to the welfare system, if the political will was there.

  10. says

    You know, I was thinking about this and I came up with a hypothetical.

    What if Manson got rehabilitated?

    I mean yes, he was a monster, but what if he went to prison and got rehabilitated to society. He accepted his issues, he apologized to everyone, he made amends, he accepted a court-mandated weekly therapy session or something of that nature.

    Would we want to keep him in jail anyway, or would we let him out back to society?

  11. eric says

    Not everyone can be rehabilitated, nor does everyone want to be.

    True, but in the U.S. we seem to have a justice system that forgot the first rule of holes. By that I mean: we put our criminals in a place where they are likely to become more criminal, not less so, making the original problem worse.

    I agree with Katherine @4 – this is more about punishment and revenge. If our justice system was focused on reducing future crime, we would try and increase the humanity of current criminals instead of purposefully stripping it from them.

  12. d cwilson says

    Manson is never going to get parole. He knows it. He didn’t even show up for his last parole hearing.

  13. Ben P says

    Life without parole is about punishment. It’s about revenge. It’s not about what prison should be – rehabilitation and reintroduction into society.

    Not true at all.

    Most experts identify four potential motives for judicial punishment: (1) Retribution/Revenge (i.e. you did something bad so we’re punishing you); (2) Deterrence (i.e. we’re making an example of you so others don’t do something that stupid); (3) protection (we’re putting you in jail so you can’t hurt anyone else); and (4) rehabilitation.

    The latter three are determined at least to some extent by social science factors, probability of continuing offenders, recidivism, conduct in prison and other things.

    Retribution on the other hand is entirely an emotional factor. Even behind that emotional factor there may be some logic. Many people quite naturally seek retribution and or revenge for wrongs done to them, no matter how much people try to work it out, such things are deeply embedded in concepts of right and wrong and fairness. If people believe that their government is not *fair* or “justice” the government soon develops a credibility problem and people will seek justice outside of the government.

    Life without parole can easily serve any of the first three rationales. Social science backing deterrence is there but the effect is admittedly very fuzzy as to particular penalties. For people who are truly dangerous protection is also an entirely valid rationale. It may be the case that a particular person simply cannot be rehabilitated, so the best option is to separate them from the population.

    A lot of more liberal people have opinions that seem to involve the assumption that no one is beyond rehabilitation. My (admittedly short) experience as a prosecutor has convinced me differently. Whether it’s from social factors, or psychological factors or something completely unknown there are people out there who have almost no compunction about breaking laws or the harm they cause when they do it. They beat someone because he offended them, they rob a store because it seemed like an easy way to get money, they shoot the clerk because they suddenly got afraid of getting caught. If let out of prison there’s a near certainty they end up re-offending. Rehabilitation is a noble goal but society is simply better off with some people behind bars.

  14. says

    tacitus “If countries like Norway can rehabilitate 80% of their convicted felons, then there is absolutely no reason why America languishes at around a 33% success rate.”
    Clearly you’re forgeting about American Exceptionalism®.

    d cwilson “Manson is never going to get parole. He knows it. He didn’t even show up for his last parole hearing.”
    Well, they’re never going to let him out if shows such a lackadaisical attitude.

  15. yoav says

    I was watching the Rachel Maddow report on the decision a few days ago and snorted coffee all over my TV when I heard about the reason one of the conservatives (I can’t remember which) gave for his objection, apparently it can’t be considered cruel and unusual punishment since we do that all the time.

  16. says

    I prefer rehabilitation as a goal, but that does not address the issues surrounding sociopaths or those who will never be able to live in conventional society. How do we handle them?

    You keep them locked up and medicated, for life, if necessary. I believe we need to be doing way more in terms of the rehabilitation of prisoners — not only would it slash the costs of incarceration, it would prevent thousands, perhaps even millions, of Americans from becoming future victims of crime — but only a fool would argue that every single person can be rehabilitated.

    But how many is that, out of the general population? It can’t be more than a small percentage. If America got serious about reforming the judicial system from top to bottom, they would slash the size of the prison population. Remember, there are seven times more Americans in jail (per capita) than in many major European nations. Imagine how much better off we would be if we could get that down to typical European levels?

    In other words, we have a whopping 80%+ of the general prison population to rehab before we even have think about tackling the toughest cases in the system. Perhaps there will come a day when treatment of sociopaths is possible, but in the meantime, we would probably be doing them a favor by rehabbing the other 80% that is rehabable (assuming American criminals aren’t intrinsically more intransigent than their European brethren) since there would be more time to work on them if there were far fewer inmates to deal with over all.

  17. David C Brayton says

    @yoav–Well, the Constitution does only prohibit “cruel and unusual” punishments. So, why you spit your coffee is a bit of a mystery.

    Ending someone’s life as punishment was rather common back in the day. And that is a rather cruel thing to do.

    Prohibiting simply cruel punishments would have changed the status quo quite a bit.

    It seems obvious (but maybe it isn’t) that a lot of socially acceptable punishment is also cruel. So, it had to be modified with another word and that word became unusual.

  18. says

    Retribution on the other hand is entirely an emotional factor. Even behind that emotional factor there may be some logic. Many people quite naturally seek retribution and or revenge for wrongs done to them, no matter how much people try to work it out, such things are deeply embedded in concepts of right and wrong and fairness. If people believe that their government is not *fair* or “justice” the government soon develops a credibility problem and people will seek justice outside of the government.

    Granted, but you have to balance the desire for retribution with the future safety of citizens who will one day be living in the vicinity of those who are eventually released. It serves no one if the focus on retribution and punishment and little else, which is clearly what has happened in the USA. The massive criminal underclass that has been created causes large amounts of unseen collateral damage in terms of the effects it has on the broken families and children of those spending years in jail.

    A lot of more liberal people have opinions that seem to involve the assumption that no one is beyond rehabilitation. My (admittedly short) experience as a prosecutor has convinced me differently. Whether it’s from social factors, or psychological factors or something completely unknown there are people out there who have almost no compunction about breaking laws or the harm they cause when they do it. They beat someone because he offended them, they rob a store because it seemed like an easy way to get money, they shoot the clerk because they suddenly got afraid of getting caught. If let out of prison there’s a near certainty they end up re-offending. Rehabilitation is a noble goal but society is simply better off with some people behind bars.

    I agree that not everyone is redeemable, but the problem in the US that the system has given up on far too many seemingly irredeemable cases. It takes money, time, and a serious commitment of people in many walks of life, from the social workers working with the kids from impoverished broken homes, through a criminal lack of defense lawyers, to a barely functioning parole system. Reform *should* be top of the list when it comes to the judicial system. Other countries do it, and have succeeded in making their societies much better places to live, and not just for the wealthiest either.

    The problem isn’t that too many liberals think that rehabbing everyone is possible — I’m not even sure any liberal really believes that — it’s that far too many conservatives believe that the *only* solution that ever works with criminals is to lock them up and throw away the key.

  19. harold says

    It’s a mark against the SCOTUS (and the rest of us for that matter) that it was 5:4 decision.

    I was going to say that. The four Tea Party justices are sociopaths.

    However, while being extremely glad for this decision, and while being in favor of legalizing marijuana and sex work between consenting, competent adults, against executions, and in favor of treatment, not punishment, for substance abuse, and rehabilitation for most things, I am a somewhat “tough on violent crime” progressive.

    Katherine Lorraine Chaton de la Mort said –

    You know, I was thinking about this and I came up with a hypothetical.

    What if Manson got rehabilitated?

    I mean yes, he was a monster, but what if he went to prison and got rehabilitated to society. He accepted his issues, he apologized to everyone, he made amends, he accepted a court-mandated weekly therapy session or something of that nature.

    Would we want to keep him in jail anyway, or would we let him out back to society?

    I don’t think Manson, or Breivik for that matter, should ever be released from custody.

    The reason I don’t think so is that I think we lack the ability to confirm that someone like that has been rehabilitated. “He accepted his issues, he apologized to everyone, he made amends, he accepted a court-mandated weekly therapy session or something of that nature” – none of that would reassure me in the slightest.

    I do not trust someone who has ever exhibited such a level of sadistic, brutal violence. Brutal violence with sadistic overtones is highly predictive of more brutal violence. Brutal sadistic violence against animals is highly predictive of brutal, sadistic violence against humans. Our understanding of people like this is extremely poor. I strongly suspect that one would have to apply methods that would be far more inhumane than life in prison to change a brain that thrills to causing horrific suffering in others into a brain that is safely able to function in society.

    I would like to add that in addition to being one of the most harmful types of criminals, those who attack the vulnerable out of sadism are also the hardest to catch. If someone kills someone else for having an affair with his wife, or stealing all his money, or selling drugs in the wrong territory, that’s usually easy to piece together. When unconnected strangers are targeted, that creates a very puzzling situation for law enforcement. That’s why serial killers get to become serial killers. Because they keep getting away with it.

    So, given that mass murderers/serial killers are incredibly poorly understood, attack the most helpless for reasons that are not understandable economic or emotional motivations, are often exceptionally gifted at manipulation, and then add the fact that if they did become recidivists, it might take multiple victims to tell…no, sorry, sadism-motivated mass murderers and serial killers can stay locked up. By the way, a Norwegian sentence of 21 years is roughly equivalent to first parole hearing after 21 years in the US. It does not mean he will be released at a comparatively young age.

    My main question is whether it would be more humane to have the likes of Manson in a forensic mental institution.

    However, by all accounts, he’s very adapted to prison.

    A more trivial question is whether he should be released if he becomes so elderly and/or demented that he poses only a low physical threat. I still slant against even that.

  20. harold says

    To fully clarify –

    I couldn’t care less about punishing Charles Manson, but for the pragmatic reason that cunning, manipulative killers who kill total strangers out of sadism cannot be reliably shown to be rehabilitated, at least not with today’s science, I think they should be stay locked up. And I think that if someone did actually want to rehabilitate that kind of brain, they’d have to go way beyond A Clockwork Orange to do it. I oppose the death penalty, but those types, confinement is the way to go.

  21. harold says

    One final, less ranting comment.

    Rehabilitation rather than pure punishment (along with maximum possible compensation to victims), for most crimes, is a core progressive value.

    However, if we go too far and claim to be able to rehabilitate brutal sadists, we risk two very undesirable outcomes –

    1) I am always annoyed by the use of the euphemism “closure” for revenge, but letting sadistic killers out on the basis of unconvincing rehabilitation is disrespectful to the crime victims. Crime victims as a group are mainly just as oppressed and down trodden as those who commit crimes.

    2) If you let Charles Manson out and he goes on a killing spree, then there will be an understandable backlash. In fact, some of the current brutality in our system is partly due to backlash against the premature release of violent criminals during the 1970’s and 80’s, and subsequent horrible crimes. If there is a backlash, then those who would benefit from rehabilitation will be denied it.

    The reason I am ranting a bit is that I feel a major, common mistake that decent hearted progressives make is to model ALL criminals as potentially salvageable victims of circumstances. Most probably are, but some aren’t.

  22. birgerjohansson says

    There are psychopats who probably have some faulty wiring in the frontal lobe of the brain. Some of them can at least be improved by therapy, but they can probably never become “normal.
    And many are not motivated to even try.
    Fortunately the truly irredeemable are few.

  23. David C Brayton says

    Wow, the vitriol against these conservative justices is rather intense. These guys aren’t psychopaths, Harold.

    The justices in dissent value a certain mode of Constitutional interpretation. They are very concerned that the Court might be seen as deciding cases based on what five of nine people think makes sense instead of deciding cases based on the text and original meaning of the Constitution.

    And they have a right to be concerned here. Years ago, the Court decided that “cruel and unusual” should be evaluated based on the “evolving standards” of our society. What’s C&U today may not be tomorrow.

    Well, if that isn’t a standard that invites judicial activism* I can’t imagine what would be. (*As much as I detest that word and its routine abuse, it is appropriate here.)

    If I were a state governor, I would have commuted the mandatory sentence of most minor offenders. Kids are stupid and they sometimes do horrific things that, after they grow up, they would never even consider.

    But does the Constitution give the Court the power to invalidate punishments that were approved by legislatures? Yes, as long as the punishment is C&U.

    According to the Court’s other precedents, the meaning of cruel and unusual evolves and changes. What was C&U in the 1920s may be A-OK today and C&U in 2112. The justices in dissent think this is a terrible way to interpret the Constitution.

    And they have a good point. Stare decisis should mean that once a case has been settled, it’s done. The Court’s precedents regarding the 8th Amendment let things evolve and change. What was settled today, may be different two decades from today.

    Do any of those Justices think that mandatory life for juveniles is a good idea? I don’t know but I doubt it. The important point, however, is that those Justices are willing to let the Legislature make that decision because the the original meaning of “cruel & unusual” would have permitted mandatory life terms.

  24. flatlander100 says

    KL@4:

    Re: prisons should not be for punishment but for rehabilitation of the inmates.

    Been hearing that mantra for many many years now. Still haven’t heard a convincing reason why rehabilitation should be the primary purpose of a prison, rather than a secondary or tertiary purpose. I see no particular reason why the primary goal of a prison sentence shouldn’t be punishment for the crime,or why the secondary purpose should’t be protection of society by separating a criminal from that society for a period of time [keyed to the severity of the offense], and why rehabilitation should not be the tertiary purpose of prisons, to be achieved once the primary and secondary purposes have first been secured.

  25. dingojack says

    Here are less than amusing facts on American prisions.

    The money quote (pardon the pun):

    STEVEN FRY: Well one of the things I should have said, when talking about contraband, is that you’re not allowed to bring into America anything made by forced labour or prisoners, but in America you can almost say, if you were so minded, that they have re-invented the slave trade.
    They [prisoners] produce, for example, 100% of all military helmets, ammunition belts, bullet-proof vests, ID tags and other items of uniform*, 93% of domestically produced paints, 36% of home appliances, 21% of office furniture, which allows the United States to compete with factories in Mexico, because, of course, obviously, the workers can’t refuse to work for 25 cents an hour –
    JIMMY CARR: I, I very much would like to say something hilarious – but something must be done!’

    I’m with Jimmy Carr.

    Dingo
    —–
    *I bet all those soldiers in Afghanistan feel safer knowing that Charlie Manson made the kit they’re relying on, for $0.25/hr because there was no other option but solitary.
    (Also, if they make ID, why don’t they make fake ID’s and walk out the front gate? Seems a little weird to me).

  26. dingojack says

    yoav (#19) – The “cruel and unusual” excuse came from the dissent.
    So ‘hang, draw and quartering’, or ‘death by a thousand cuts’, or ‘flaying alive’, or ‘breaking on the wheel’, or ‘crucifixion’, or ‘Auto-da-fé’ or …
    all perfectly OK.
    Cruel yes, but practiced widely, so not unusual.

    @@

    Dingo

  27. says

    “Wow, the vitriol against these conservative justices is rather intense. These guys aren’t psychopaths, Harold.”

    While I don’t think that they’re psycopaths (sociopaths, more likely), I DO think that they’re assholes who rant about Constitutional “originalism” when it suits their politics and ignores it otherwise.

    If it walks, bullies and spends time hunting with people who have business before the court–during that time when the business is ongoing–like a Tony Ducks, well…

    Dingojack:

    I like Mr. Fry, but I think a citation is needed for those %ages he talks about. Oswego Industries, a “sheltered workshop” not too far from where I live, produces items for the military as do hundreds, if not thousands of other companies. Both DoD and GSA have a preference for using the services of veteran owned (especially if the owner is disabled) companies. There ARE a shitload of things made by prisoners at many prisons, I’m just not sure that he’s got his numbers right.

    I’m not pro-capital punishment. Having said that, I think keeping someone caged like a zoo specimen for decades is far more cruel and unusual than simply executing them. I am not talking about “normal” criminals, here, but the Manson sort of homicidally inclined individuals. I’m not suggesting that we take them out and shoot them, I’m just not sure that locking them away serves any real purpose–other than garnering votes for the Law’n’order crowd.

  28. slc1 says

    In discussing Charles Manson, it should be pointed out that he was originally sentenced to capital punishment. However, after he was sentenced, the Supreme Court ruled that capital punishment was cruel and unusual punishment and, until that decision was subsequently overturned by a later Supreme Court decision, all death penalties were converted to life in prison. Thus, Manson escaped the gas chamber, as the original death penalties were not re-instituted after the overturning of the decision.

  29. reddiaperbaby1942 says

    I’ve never understood the conservative predilection for originalist readings of the Constitution. Sure, Madison et al. were intelligent, educated and enlightened men for their own time, and did a good job under difficult circumstances — they had to reconcile the demands of South and North, of large states like Virginia and small ones like Rhode Island; but the conditions and needs of our contemporary society are quite different from those of the 1780s. Although brilliant (and unique) for its own time, the Constitution is in many ways an awkward instrument for present-day governance. The newer constitutions of many West European countries guarantee their citizens the same civil rights as ours, and are far better adapted to contemporary society. But of course it would be political suicide (by cruel and unusual means)for any American politician or judge to say so in public.

  30. marcus says

    democommie@ 33

    “I’m not pro-capital punishment. Having said that, I think keeping someone caged like a zoo specimen for decades is far more cruel and unusual than simply executing them. I am not talking about “normal” criminals, here, but the Manson sort of homicidally inclined individuals. I’m not suggesting that we take them out and shoot them, I’m just not sure that locking them away serves any real purpose…”

    This is very reasoned and nuanced point. I also am not “pro-capital punishment”. In many cases locking someone away for life for their crimes against humanity is probably more cruel than simply executing them (though obviously not unusual). However, I am not overly concerned about how much someone like Breivek suffers during his, what I hope is, a very long life in prison. (Not that I think that his incarceration should be intentionally inhumane.) I am against capital punishment for all the rational reasons that have been noted on this site and elsewhere concerning certainty of guilt, high cost of necessary appeals ,etc. I am not against it because people like Breivik or Manson deserve to live, I just think that society doesn’t deserve to have to kill them. The day those two stop sucking in air the world will be a better place. Put another way, I am not willing to risk the chance of an innocent person being executed so that the Breiviks and Mansons of the world can have a (relatively) quick way out. Fuck them.

  31. eric says

    David Brayton:

    Years ago, the Court decided that “cruel and unusual” should be evaluated based on the “evolving standards” of our society. What’s C&U today may not be tomorrow.

    Well, if that isn’t a standard that invites judicial activism* I can’t imagine what would be.

    According to the Court’s other precedents, the meaning of cruel and unusual evolves and changes. What was C&U in the 1920s may be A-OK today and C&U in 2112. The justices in dissent think this is a terrible way to interpret the Constitution.

    No, they agree with it, they just don’t agree with this particular use of it. If they really thought ‘evolving community standards’ was a terrible way to interpret the constitution, they would rule that putting people in stocks and whipping them was reasonable punishment for all sorts of things.

    In fact, colonial punishment rarely put people in jail for long periods of time at all; jail was where you were held before you went to court. Once you were found guilty, punishment consisted of something else (like stocks, whipping, a fine, etc…) So if your conservative judges thought ‘evolving community standards’ was a terrible way to interpret the constitution, they should rule against any long prison sentence. Because long prison sentences have come about due to evolving community standards since the 1700s and early 1800s.

    Do any of those Justices think that mandatory life for juveniles is a good idea? I don’t know but I doubt it. The important point, however, is that those Justices are willing to let the Legislature make that decision because the the original meaning of “cruel & unusual” would have permitted mandatory life terms.

    No, as a historical fact, it probably wouldn’t. The harshest legal punishment meted out those considered not old or mature enough to be tried as an adult was a whipping. And a life sentence for anything, even for adults, would’ve been extroadinarily unusual. Anything that was so serious that it couldn’t be addressed by some form of corporal punishment, period of servitude, or fine, probably warranted execution. In all honesty, a 14-year-old convicted of murder (like the SCOTUS case) would’ve been considered an adult and summarily executed after the trial, probably by hanging. But sentenced to spend the rest of his life in a cell? Highly unusual. Probably unheard of, and if you had suggested it, they would’ve thought you were crazy.

  32. Aliasalpha says

    @Katherine Lorraine, Chaton de la Mort

    You know, I was thinking about this and I came up with a hypothetical.

    What if Manson got rehabilitated?

    I’d imagine he’d be murdered within a week, the murderer would get a minimal sentence (since everyone hated manson) and would probably end up as a ‘justice’ commentator on fox

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