Jan. 5, 2007

A Freewheeling Academic Freedom Debate

Elena Kagan, dean of Harvard Law School, lowered her spectacles and, as if addressing a group of students, presented her audience with a case study.

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Panelists were quick to disagree with Kagan, who has been mentioned in the search for the Harvard presidency. Stanley Fish, a professor of humanities and law at Florida International University, took particular issue with the dean’s comments about “institutions’ core values” and with her admission that, in the Minnesota case, she would instruct staff members to select faculty candidates who wouldn’t provoke student protests.

“Schools shouldn’t have values, except in a very narrow sense,” Fish said. [When asked later in the session to explain what type of values a law school should adopt, Kagan responded that there wasn’t enough time to respond.]

Fish said law schools should avoid taking a political stance at all cost. He brought up Rumsfeld v. Forum for Academic and Institutional Rights, in which the Supreme Court upheld the Constitutionality of a law that allows the government to withhold federal funds from institutions that limit military recruiters’ access to campuses. The decision allows institutions to protest the recruiters’ presence, but doing so would be inappropriate and “an exercise no different than coming out against the Iraq War,” Fish said.

Geoffrey Stone, a professor at the University of Chicago Law School, added that the only valid protest from law schools is on the grounds that recruiters are “coming into their house, not as a proxy for giving a university’s views on sexual orientation [implicit in the “Don’t Ask, Don’t Tell” policy.]

Another of Kagan’s case studies involved an undergraduate English department that had invited and then uninvited a speaker after learning of a comment made that some perceived as anti-Semitic. Kagan said she understood the reaction, but Fish argued that once the invitation is made, the deal is done.

Stone introduced another scenario: that of an university making a blanket policy to hire or reject candidates based on a political affiliation. He said while universities should, in theory, strive to be ideologically blind in hiring, law school faculties are so dominated by supporters of the Democratic party that some type of affirmative action for right-leaning instructors might be needed.

Still, Stone called David Horowitz’s tack of approaching state legislators in an effort to regulate public institution hiring practices “abhorrent,” adding that colleges must take up the matter internally.

At the start of the panel, William W. Van Alstyne, a First Amendment scholar and law professor at the College of William and Mary, argued that academic freedom is under greater attack now than in decades past.

He pointed to a series of recent First Amendment cases that he called “discouraging,” including Garcetti v. Ceballos, in which the Supreme Court ruled that a public employee’s job-related speech, expressed in reference to official duties of employment, should not be given First Amendment protection. Even though the court largely avoided mentioning academe, Van Alstyne said it would probably have a cooling effect in the classroom and hurt academic freedom.

But is academic freedom worth protecting? Only when one applies a limited definition, Fish argued. Worthy of protection: a professor’s ability to introduce material and equip students with analytical skills.

“That’s it,” he said. “There’s nothing else. The moment a professor tries to do something else [such as inject a political opinion], he is performing an action for which there should be no academic freedom.”

Fish added that a professor who comes clean about her political view at the start of class still shouldn’t be protected. “Ask this question,” he said. “Is it an account or an advocacy of an agenda?

— Elia Powers

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Comments

Uniform is the Issue

The rejection of a former government lawyer because of one prior position paper on a case by case basis may be acceptable. To allow all decision makers to reach the same decision because it is politically correct is a problem. The discussion of how to educate lawyers is much deeper than this review of specifics. See the jefound presentation to the Department of Education National Advisory Committee on Institutional Quality and Integrity made on December 4, 2006, posted to our website at http://jefound.org

William Sumner Scott, J.D.

wss@jefound.org

William Sumner Scott, J.D., at 8:35 am EST on January 5, 2007

So...how about the writing instructor who doesn’t state her political position but talks about her church and then leads her class in online research, directing them to the Drudge Report as a primary source?

kgotthardt, at 10:20 am EST on January 5, 2007

missing points

There are a couple of points missing from the discussion. When most people in government write a memo, it doesn’t serve the same role as academic discussion or even a law school exercise. Its function is akin to a complaint or brief or opinion from a judge: it instructs others on what one’s actor’s view of the law is, and if that actor is in a position to determine “the law” The memo takes a position on the issue, and others can look to it as a directive or guidance.

So, the various torture memos are not simply one lawyer musing about just what the constitution, USC, and Geneva convention allows, but rather one step in a process by which the law, as it applies to executive branch officials is made. Before the memo was written, someone else asked for “guidance” as to what “the law” was. But this “guidance” (or a similar term) wasn’t an academic question, it was a request for a legal justification for a likely pre-ordained conclusion. The people at OLC followed suit. On the other hand, “memos” may later be overturned by other executive branch actions, or the results of the memo (but not the memo itself) may be held to be unconstitutional by a court.

The result is that a professor that, at a past job, put his name on a morally questionable decision should likely be viewed not as being incompetent, but rather as part of a legal process. And, quite frankly, there are many lawyers (often those who become professors) that participated in less celebrated cases that might have yielded results that are unpalatable to some. By the same token, there are many, in this country – perhaps a majority – who think that it is immoral to represent accused terrorists, or people that are accused of a crime. It is far more likely to see institutions engage in viewpoint (or “experience”) discrimination against them.

Unfortunately, many of the speakers at this events seem to be speaking to a non-legal audience. For example, in Garcetti v. Ceballos, the court was careful to note that the question of the freedom of a government lawyer to publically question his superiors is usually resolved under state law and other constitutional provisions. Unfortunately, most scholars of constitutional law, when talking to non-legal audiences don’t want to go into this nuance, because it tends to confuse non-lawyers. (If you do, read, part IV of the opinion, on p. 16 of http://www.supremecourtus.gov/opinions/05pdf/04-473.pdf.)

Mr. Scott, Wow. It takes guts to cite your own work as proof.

Larry, at 10:20 am EST on January 5, 2007

To me, a real commitment to academic freedom does not mean that an institution abandon its values. We do not expect that a women’s college should hire faculty who believe women incapable of learning, or that an historically black institution would hire faculty who propose that there is no racial inequality in the contemporary world, because these things would be contrary to the missions of those schools.

However, and this is the important thing, once a faculty member is hired, then academic freedom should be protected—whether that faculty member is an adjunct, a non-tenure-track instructor, or is on the tenure track. That means once hired, if your research begins to lead in a direction contrary to the school’s mission, so be it.

The point is that there is a difference between the politics of hiring and the protection of academic freedom for those who have already been hired.

ML, at 10:30 am EST on January 5, 2007

Lawyers agree speech is free when it apes their own.

“Unfortunately, most scholars of constitutional law, when talking to non-legal audiences don’t want to go into this nuance, because it tends to confuse non-lawyers,” saith Larry. In my experience, most lawyers, including those self-described as “constitutional law experts,” are committed to obfuscation and confusion whenever that advances the client they are hired to promote. Less than two years ago, a locally prominent professor of law was retained by my college to “investigate” a complaint and subsequent charges against me. He then, after finding me “guilty,” was brought in as an expert to testify that he, as a professor, would never have employed an anecdote I had used (an anecdote deemed “offensive” by one complainant); that, in his judgment, the anecdote was not “germane” to the composition class I was conducting. The magistrate ruling on the issue found this testimony suasive. “Academic freedom,” therefore, at my college, means whatever speech any retained lawyer says is fit for public presentation, whatever speech will not corrupt the youth of Athens. And this “standard” is applicable to all professors, whether tenured, nontenured, or tenure-tracked. The college suppressed publication of the magistrate’s opinion, maintaining that it is thus protecting the “privacy rights” of the complainant/informant. This maneuver, of course, was at the direction of hired counsel.

John C. Bonnell, Professor of English at Macomb Comm. College, at 1:45 pm EST on January 5, 2007

Fish’s Freedom

Fish says, “The moment a professor tries to do something else [such as inject a political opinion], he is performing an action for which there should be no academic freedom.” There are two problems with this view: who do we trust with the absolute power to distinguish between a scholarly opinion and a political opinion? And why are political opinions deemed to be so horrible? What exactly is so dangerous about having political discussions in the classroom? Why does Fish think that the purpose of a university is to educate students about scholarly matters and nothing else?

John K. Wilson, at 1:50 pm EST on January 5, 2007

Professor Fired

ML, To me, your comment is well put.

I know of a professor summarily fired at a for-profit university for criticizing her institution (mildly, according to her) on her blog. What about blogging and a corporation’s right not to have its business reputation besmirched in such a public sphere? (On the other hand, why must corporations in gerneral be so paranoid about PR? Why the very existence of the Public Relations industry?) Her institution states that it upholds academic freedom but chooses not to discuss her case (more to it than she lets on? Was she whistleblowing?)

My question: Are only faculty officially accorded free speech, i.e. academic freedom? It appears private companies in the “business” of education can toggle, at their convenience, between the term “faculty,” which they can use when accreditation agencies are visiting their campuses, and “employees,” at all other times, especially in states where their inherently non-tenured faculty are subject to Employment at Will. Evidently, Meg Spohn’s company fired her as an employee and not as a professor who thought she had the free speech right of a public intellectual.

I haven’t thought this all the way through yet, but I can see a possible difference between blogging and, say, department-REQUIRED, online faculty meetings. For I know a professor who claims to have been threatened with firing in the latter case, for listing certain weaknesses in for-profit education. Of course, there may be more to that story as well (the prof’s own PR issues? the company’s fear that he was trying to start a union?).

But whatever happened to citizen free speech, in any case? It’s supposed to be true outside the workplace (except for yelling “fire,” etc.) But what about the workplace itself? Libel, no, if by that we mean malicious lying. But what about stating certain facts about one’s company about which one has grave concerns regarding working conditions for faculty and what appears, to the concerned professor, to be the deleterious effects on faculty and students alike?

To Stanley Fish: Suppose one’s political stance (agenda even!) happens to be an excellent—perhaps the best—tool for promoting critical thinking. Otherwise, a professor of a right, left, or other persuasion is forced into an innocuous, unenthusiastic role: presenting what, in a given context, may be a false balance or erroneous middle-of-the-road. Here the old “bogus issue” debate between, say, unfettered cannibalism and some form of regulated cannibalism may serve. Should the professor who stands outside that debate not argue that such an outside view is not only possible but may have great merit? Or should s/he instead default to a moderator’s stance “in the middle"? Middle between what and what? Personally, I have no trouble with students moving among classrooms and discussing issues as framed by any number of professorial perspectives—mainstream, radical, etc.—so long as professors acknowledge that there is no such thing as any single middle of any single road, but here’s how the situation looks to her or him (including all the arguments that animates the teacher!) Inquiry involves finding new unexamined assumptions to examine. It is precisely bias that is able to ask the kinds of questions that seek them out. A professor with an emotional fixation on a political view is actually poised to ask students to consider certain kinds of questions otherwise not asked. The danger, as I think Fish rightly warns, is that a professor’s orientation can just as easily impede students’ asking other questions of their own. Therefore, this principle must be acknowledged. Precious few of my students—to the best of my knowledge—have ever expressed a problem with such a pedagogy. On the contrary, many students on ideological rights, lefts, and off-the-charts positions have celebrated it. I hope it goes without saying that it’s unethical to tie a student’s grade to his or her existing opinions. Heck, I even think it’s unethical to tie students to grades period. But that’s another discussion.

David R., To ML and Stanley Fish, at 1:55 pm EST on January 5, 2007

FREEwheeling discussion?

Stanley Fish? THE Stanley Fish? Seven and a half years ago he opined on the Today Show (May 6, 1999) that of course my college has a right—a duty—to suppress speakers of my ilk. If I am not laboring to turn out citizens who would be fit companions at any cocktail party he might attend, then he could not understand what purpose my institution might possibly serve. On other occasions Mr. Fish has also made it clear what nonsense he thinks “freedom of speech” inherently is, as it does not advance the sort of politics he admires. But at least he is honest—an unusual quality in academic and legal circles.

John C. Bonnell, Professor of English at Macomb Comm. College, at 1:55 pm EST on January 5, 2007

Reply to Mr. Bonnell

Mr. Bonnell,

While one can describe themselves as an “expert” in constitutional law, in legal circles, there are certain minimum qualifications. These usually are: 1) having clerked for a Circuit Court of Appeals judge; 2) holdings an academic position; 3) frequent and successful litigation of constitutional issues; and 4) publication.

While lay people love to accuse lawyers of “obfuscation” and “confusion” the word doesn’t mean too much. Non-lawyers are always confused. On the other hand, lawyers generally DO represent clients, and so they will likely offer you an interpretation of the law (in this case, the constitution) that best suits their clients’ position. Nothing surprising about that.

However, as to your specific case, the 6th Circuit has ruled against you (though you still could have continued it, but you chose not to), and it is over. You really need to move on, and stop blaming lawyers for your problems.

Also, nobody found you “guilty” of anything, and you had more opportunities to explain yourself then most people ever get. Your explanations were unavailing.

Larry, at 3:50 pm EST on January 5, 2007

Dear Larry:

You are mistaken, Sir Larry, about my choosing not to continue: the “judges” in Censornati granted immunity to the college for the usual baloney reason that the college officials and their host of attorneys could not possibly have known they might be violating my First Amendment rights. That being the (their) case, they deemed it so unlikely that I could succeed “on the merits,” they forced the district judge to dismiss my claim. My subsequent appeal to the Supreme Court was denied.

As for the “guilty” charge, you do not know the circumstances to which I am referring; the numerous instances of being charged, always being found “guilty” as charged, the punishments administered (including Soviet style “reeducation,” aka “sensitivity training"), have never been made public. In point of fact, I have never had a chance to make my case in any judicial forum. Your presumption to the contrary is amazing, if not altogether surprizing. As Orwell said, where the people support freedom of speech, there will be freedom of speech, regardless of what the law says. In a nation where people do not support such freedom—particularly lawyer people—there will be no freedom of speech, regardless what the law says. Among these “lawyers” who are inimical to freedom of speech, I certainly include many “judges,” up to and through the Supreme Court. (Any reader interested in studied buffoonery might start with FCC vs Pacifica, where an abject lesson in a judge’s inability to differentiate between an actual turd and an indicative word is manifest. That, and consider all the nonsense about “community values” that Supremes and other hypocrites resort to—as though the First Amendment itself was not a prima facie rejection of such pious absurdity. Every repressive regime has substantial support from the “community” it dictates to. For example, in the stunning interpretation of the Nazi “final solution” discussed at the Wannsee in 1943, one of the discussion leaders deputized by the Fuhrer asked his twenty-odd confreres, when discussing the legalities of gradual as over against precipitous genocide, how many of them were lawyers or had been extensively trained in the law, all but two hands went up. In short, things so precious as human freedom and dignity are not always best left in the hands of lawyers.)

John C. Bonnell, Professor of English at Macomb Comm. College, at 6:45 pm EST on January 5, 2007

Well, the 6th Circuit’s opinion (reversing the grant of a preliminary injunction, but not ruling on the merits) speaks for itself.

http://pacer.ca6.uscourts.gov/cgi-bin/getopn.pl?OPINION=01a0057p.06

The readers can decide what it means.

Larry, at 8:35 pm EST on January 5, 2007

“In short, things so precious as human freedom and dignity are not always best left in the hands of lawyers”

John, actual lawyers agree with you.

JBM, at 8:25 am EST on January 6, 2007

Non-lawter’s questions for “Larry”

“Non-lawyers are always confused.” Like to debate that unqualified statement?

When did LLBs “transubstantiate” into JDs in the States?

Are there viable alternatives to the adversarial system of “justice"?

In referring to collective nouns, where does St Augustine refer to the collective noun representing lawyers as a “plague"?

Jacques Albert, at 1:50 pm EST on January 6, 2007

Self-entitled & self-indulgent

OK — I’ll be Larry’s punching bag, on this.

IMHO, this MCC thing is a load of self-indulgent hooey. Are there moments that I’d like to use curse words in the classroom? Of course. Do I?

No — it is unprofessional, especially in front of pre-professional students. Do judges tolerate open cursing in courtooms? Supervising MDs in hospitals? Bank presidents in banks?

No. I can’t think of a faster way to be disciplined and/or fired.

Lack of self-control involving required behavior is indicative of more serious problems. As in, whether someone should continue in one’s current position. Perhaps transfer to the weekend prison education program would be more conducive to one’s development.

L.H.H., at 1:50 pm EST on January 6, 2007

Analysis of the Bonnell Case

The case was lost by Prof. Bonnell when he drafted his syllabus. Once the record was complete, he was subject to the musings of unaffected judges.

Had Prof. Bonnell included notice of adult content in his syllabus he could have defended the student complaint with assertion of “waiver” by the student’s election to enroll, provided the course was not required.

If the course was required, he could have defended the bringing of the complaint by assertion of “waiver” when the college administration accepted his syllabus.

The union that was supposed to represent Prof Bonnell failed its duty to him.

The public record does not contain the syllabus or that it was an issue presented at the college administrative hearing. Without the syllabus defenses, the public morals to be presented to students defined by the college administration and enforced by the court will determine the result.

I would never want to be subject to the political correctness imposed by those two groups and also be responsible for lucid thought by college students.

William Sumner Scott, J.D.

Judicial Equality Foundation, Inc.

wss@jefound.org

William Sumner Scott, J.D., at 1:50 pm EST on January 6, 2007

Answer for Mr. Albert

Mr. Albert, American law schools used to issue LLBs. These were three year post-graduate degrees. Unfortunately, this is an abbreviation for “Legium Baccalaureus” So, after 4 years of college, where on earns an Bachelors’s one could embark on an LLB, which had a similar name. At some point, people wiser than me, decided to call the same degree a “JD” or “Juris Doctorate.”

In England and most other common law countries, LL.B. remains the common degree that lawyers hold. So, a non US/Canadian LL.B. roughly translates to “JD.”

In the US, possession of a JD alone generally does not allow one to practice before courts or represent people. One must be admitted to the bar, which usually involves passing a bar exam, which is administered by individual states. Foreign LL.B.s generally cannot take this exam, but in some states, will allow them to take the bar exam after taking a year of courses leading to an LL.M usually in “American law.” Some Americans have LL.Ms. in specific subjects in addition t their J.D. Usually “taxation” but the amount of LL.M. programs grows every year.

Sorry, I don’t know about St. Augustine.

LHH, Nothing to punch you about. I was just posting that decision so people can draw their own conclusions about Mr. Bonnell, who thinks that he is just as important as Mr. Churchill, and we all care about his tales of woe.

I should note for Mr. Scott, that there is no duty not to offend individual people. Indeed, offending people does not constitute sexual harassment, and unless a school decides to enforce a “no sexually harassing the students” policy against a professor (as they chose to do against the unfortunate Mr. Bonnell), students can’t avail themselves of the same remedies that employees do (who essentially argue that they were either “constructive discharged” because of the “hostile environment” or were given some sort of dirty quid pro quo.

JBM, Some lawyer like to tell non-lawyers that they want non-lawyers to make decisions. But this is just a pithy little bone thrown to them. In reality, when non-lawyer start making decisions about law or even policy, all hell breaks loose, and they need to call a lawyer.

Larry, at 5:50 pm EST on January 6, 2007

Politics of hiring?

ML said — “The point is that there is a difference between the politics of hiring and the protection of academic freedom for those who have already been hired.”

How is it that one can discriminate on the basis of a candidate’s politics but NOT on the basis of his/her sex, color, national origin, sexual orientation? How is that legal? And what the hell kind of academic freedom is that when one must pass an ideological litmus test to be hired? What’s next, we can only hire democrats or independents or greens or people whose hair is purple? How Pol Pot is that? Stalin? Mao? Do you hear yourselves? And you are educating those who will staff our legal system? Scary thought!

Conservadad, at 7:00 pm EST on January 6, 2007

Why politics is different

Conservadad, Because the 1st amendment doesn’t apply directly to private entities, and Title VII doesn’t prevent private discrimination on the basis of politics. See 42 U.S.C. 2000e-2(a).

(There are some arguments, not relevant here, regarding the interaction of gender and politics, but I am too tired to get into them.)

Larry, at 10:21 pm EST on January 6, 2007

Dear Larry, Part II

No, Larry, my case is not as important as Ward Churchill’s, and it will remain that way until lawyers get their hands on it and the methods that make suppression of my free speech a general practice. William Sumner Scott is correct when he observes that my “union” betrayed me, its own contract, and the very idea of unionism when it rushed to deliver me to the College’s counselors. It half-heartedly corrected course two years ago when the College began attacking other professors. It learned, perhaps too late, what L.H.H. does not understand, that a government which stoops to banning words will soon be banning ideas. (My principal union “representative” urged me to seriously consider teaching authors and their works that are less controversial, or less disturbing to students, particularly women. “You have to give the College, something, John.”) I am, of course, paraphrasing John Harlan, the Supreme Court Justice who also observed, with regard to language, that one man’s vulgarity is another man’s lyric. The College now reserves the right to modify not only diction but also ideas. It does this by declaring them, words and ideas of which it does not approve, as “not germane.” It goes about it thus: a female student complains about, say, a particularly loud or obnoxious tie the professor wears. She says that, in her view, it is unprofessional or distracting. The College, ever diligent, says all such complaints must be taken seriously, especially because there is a sexual element in it. Sex, you say? Definitely. Ties, like cigars, may have a dual signification. The College stages an “investigation,” brings charges of “sexual harassment,” finds the professor guilty as charged, and announces the next step in graduated discipline. But, sexual harassment?! Indeed. Ties can be instantiations of phallocentric, hegemonic abuse and intimidation. Even if it did not occur to the informing student to make such an association, the College is compelled to do it for her. This compulsion has many beneficial implications. Because the student has been “sexually harassed,” she has a condition of victimization similar to a woman who has been raped. She is entitled to anonymity. The substance of her complaint can be forever sealed. The College has announced that complaints and correlative documents have the same privileges of confidentiality as do the “victims” who filed the complaints. There is nothing in federal or state law to support this extreme characterization of what must be held secret (law makes it clear that without a name or other individuating element the “record” is no valid such thing). Nevertheless, the College knows that the judiciary will look the other way when the College moves to enforce its curious “standard,” just as it did in Bonnell v. Lorenzo. It has threatened me, and probably others, with instant dismissal should I ever discuss in public the details of any student complaint. It thus saves itself from public scrutiny. (An arbitrator’s ruling against my academic freedom in 2004 was, contrary to typical practice, suppressed by the College, to supposedly preserve the “rights” and the sensibilities of the informer. It also spared the College’s clandestine machinations from public review.)

No one besides my students knows what language I use or have used, and why I use it. That is because I have never been granted a public hearing, a public trial. L.H.H.’s imagination and Larry’s naïve belief that the 6th Circuit case he shares with anyone in this readership is somehow representative of reality are most unfortunate. To paraphrase J. Stalin, the suppression of one man may border on the tragic; the suppression of thousands is merely a statistic. I am not as garish as W. Churchill, nor worthy of tabloid copy or O’Reilly’s bloviations. I may simply be among the first of the nameless, faceless masses who went under when America forfeited its freedom

John C. Bonnell, Professor of English at Macomb Comm. College, at 10:21 pm EST on January 6, 2007

“In reality, when non-lawyer start making decisions about law or even policy, all hell breaks loose, and they need to call a lawyer.”

Let actual lawyers issue advice about law.

JBM, at 10:30 am EST on January 7, 2007

Normative pronouncements and observations

JBM, I don’t understand. Who is giving “advice” “about the law”? Moreover, since this is a public message board, I don’t think anyone thinks they are receiving legal advice. Most of us have been practicing for well over a decade (sometimes two), we are pretty confident where the line between observations and normative pronouncements lies.

If you are a lawyer, we will just have to agree to disagree about the proper role of non-lawyers. But, if you trust non-lawyers in your own affairs, you do so at your own risk.

Mr. Bonnell, People can read the 6th Circuit’s opinion and reach their own conclusions. I hope they do. I don’t support or oppose you. I really don’t care.

Larry, at 3:40 pm EST on January 7, 2007

“Most of us have been practicing for well over a decade (sometimes two), we are pretty confident where the line between observations and normative pronouncements lies.”

Yes, we are. You, however, are not. Lawyers understand the concern.

The Internet is fun, but posting opinions on it does not make anyone a lawyer or that person’s opinion legally insightful.

JBM, at 4:45 pm EST on January 7, 2007

WKRP in Cincinnati?

” .. I am not as garish as W. Churchill .. I may simply be among .. the nameless, faceless masses who went under when America forfeited its freedom ..”

Yes. And Dr. Johnny Fever can’t say “booger” on the radio, either. The U.S. is becoming the USSR and Communist China. How sad.

(BTW: if MCC is such an awful place — I’ll bet David Horowitz’s funders would buy any faculty member, a one-way ticket to France. Just ask.)

Bart, at 7:15 am EST on January 8, 2007

JBM, I am trying to see your point. If anyone doubts anything I say, I provide citations. People can read the referenced materials and judge for themselves. You did not provide citations, but instead, you argue that I am wrong because you assert that I, for some reason, am not a lawyer.

Larry, at 8:30 am EST on January 8, 2007

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