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A law professor worries Israel could become the next Hungary
(JTA) — Israel’s new governing coalition has been called the “most right-wing” in the nation’s history. That’s heartening to supporters who want the country to get tough on crime and secure Jewish rights to live in the West Bank, and dismaying to critics who see a government bent on denying rights to Israel’s minorities and undermining any hope for a peaceful solution to the Israeli-Palestinian conflict.
While the far-right politics of new government ministers Bezalel Smotrich and Itamar Ben Gvir have drawn much of the world’s attention, a series of proposed changes to Israel’s judicial system has also been raising hopes and alarms. On Wednesday, new Justice Minister Yariv Levin announced an overhaul that would limit the authority of the High Court of Justice, Israel’s Supreme Court. It would put more politicians on the selection committee that picks judges, restrict the High Court’s ability to strike down laws and government decisions and enact an “override clause” enabling the Knesset to rewrite court decisions with a simple majority.
Levin and his supporters on the right justify these changes as a way to restore balance to a system that he says puts too much control in the hands of (lately) left-leaning judges: “We go to the polls, vote, elect, and time after time, people we didn’t elect choose for us. Many sectors of the public look to the judicial system and do not find their voices heard,” he asserted. “That is not democracy.”
Critics of the changes call them a power grab, one that will hand more leverage to the haredi Orthodox parties, remove checks on the settlement movement and limit civil society groups’ ability to litigate on behalf of Israeli minorities.
To help me make sense of the claims on both sides, I turned to Tom Ginsburg of the University of Chicago, where he is the Leo Spitz Distinguished Service Professor of International Law and co-directs the Comparative Constitutions Project, which gathers and analyzes the constitutions of all independent nation-states. He’s also a Jew who has transformed a former synagogue on the South Side of Chicago into a cutting-edge arts space, and says what’s happening with Israel’s new governing coalition “raises my complicated relationship with the country.”
We spoke on Friday. Our conversation has been edited for length and clarity.
Jewish Telegraphic Agency: You have written about law in Israel, which lacks a constitution but relies on a series of “basic laws” to define its fundamental institutions. You’ve written that the Israeli judiciary had become “extremely powerful” — maybe too powerful — in imbuing the basic laws with a constitutional character, but worry that the current reforms will politicize the court in ways that will undermine Israeli democracy.
Tom Ginsburg: The proposed reforms were a campaign promise of certain elements of this coalition who have had longstanding grievances against the Israeli judiciary. The Israeli judiciary over the last decades has indeed become extremely powerful and important in writing or rewriting a constitution for Israel, promoting human rights and serving as a check and balance in a unicameral parliamentary system where the legislature can do anything it wants as a formal matter. A lot of people have had problems with that at the level of theory and practice. So there have been some reforms, and the court has, in my view, cut back on its activism in recent decades and in some sense has been more responsive to the center of the country. But there’s longstanding grievances from the political right, and that’s the context of these proposals.
A lot of the concerns about the new government in Israel are coming from the American Jewish left. But in an American context, the American Jewish left also has a big problem with the United States Supreme Court, because they see it as being too activist on the right. So in some ways isn’t the new Israeli government looking to do what American Jewish liberals dream of doing in this country?
Isn’t that funny? But the context is really different. The basic point is that judicial independence is a really good thing. Judicial accountability is a really good thing. And if you study high courts around the world, as I do, you see that there’s kind of a calibration, a balancing of institutional factors which lead towards more independence or more accountability and sometimes things switch around over time.
Israeli Justice Minister Yariv Levin holds a press conference at the Knesset, the Israeli parliament in Jerusalem, Jan. 4, 2023. (Olivier Fitoussi/Flash90)
You mean “accountability” in the sense that courts should be accountable to the public.
Right. The Israeli promoters of these plans are pointing to the United States, in particular, for the proposals for more political involvement in the appointment process. On the other hand, in the United States once you’re appointed politically, you’re serving for life. There’s literally no check on your power. And so maybe some people think we have too much independence. If these proposals go through in Israel, there will be a front-end politicization of the court [in terms of the selection commission], but also back-end checks on the court [with the override clause that would allow a simple majority to reinstate laws struck down by the Supreme Court]. So in some sense, it moves the pendulum very far away from independence and very much towards accountability to the point of possible politicization.
And accountability in that case is too much of a good thing.
Again, you don’t want courts that can just make up rules. They should be responsive to society. On the other hand, you don’t want judges who are so responsive to society that there’s no protection for the basic rights of unpopular minorities.
What makes Israel either unique or different from some of the other countries you study, and certainly the United States? Part of it, I would guess, is the fact that it does not have a constitution. Is that a useful distinction?
They couldn’t agree on a single written constitution at the outset of the country, but they have built one through what you might call a “common law method”: norms and practices over time as well as the system of “basic laws,” which are passed by an absolute majority of the Knesset, where a majority of 61 votes can change any of those. But while they’re not formally entrenched, they have a kind of political status because of that term: basic law.
By the way, the Germans are in the same boat. The German constitution is called the Basic Law. And it was always meant to be a provisional constitution until they got together and reunified.
If you don’t have a written constitution, what’s the source of the legitimacy of judicial power? What is to prevent a Knesset from just passing literally any law, including ones that violate all kinds of rights, or installing a dictator? It has been political norms. And because Israel has relied on political norms, that means that this current conflict is going to have extremely high stakes for Israeli governance for many decades to come.
Can you give me a couple of examples? What are the high stakes in terms of democratic governance?
First of all, let me just say in principle that I don’t oppose reforms to make the judiciary more independent or accountable in any particular country. But then you obviously have to look at the local context. What’s a little worrying about this particular example is that several members of this coalition are themselves about to be subject to judicial proceedings.
Including the prime minister, Benjamin Netanyahu.
Right. And for example, they need to change the rules so that [Shas Party chairman] Aryeh Deri can sit in the cabinet despite his prior convictions. That indicates to me that maybe this isn’t a good-faith argument about the proper structure of the Israeli, uncodified constitution, but instead a mechanism of expediency.
Any one of these reforms might look okay, and you can find other countries that have done them. The combination, however, renders the judiciary extremely weak. Right now, it’s a multi-stakeholder commission that nominates and appoints judges in Israel, and the new coalition wants to propose that the commission be made up of a majority of politicians. We know that when you change the appointments mechanism to put more politicians on those committees, the more politicized they become.
Think about the United States process of appointing our Supreme Court judges: It’s highly politicized, and obviously the legitimacy of the court has taken a big hit in recent years. In Israel, you’d have politicized appointments under these reforms, but then you also have the ability of the Knesset to override any particular ruling that it wanted. Again, you can find countries which have that. It’s called the “new commonwealth model” of constitutionalism, in which courts don’t have the final say on constitutional matters, and the legislature can overrule them on particular rulings. But I think the combination is very dangerous because you could have a situation where the Knesset — which currently has a role in protecting human rights — can pick out and override specific cases, which really to me goes against the idea of the rule of law.
You mentioned other countries. Are there other countries where these kinds of changes were enacted and we saw how the experiment turned out?
The two most prominent recently are Hungary and Poland, which are not necessarily countries that you want to compare yourself to.
Certainly not if you are Israel.
Right. There’s so much irony here. When the new Polish government came in in 2015, they immediately manipulated the appointment system for the Constitutional Court and appointed their own majority, which then allowed them to pass legislation which probably would have been ruled unconstitutional. They basically set up a system where they were going to replace lower judges and so they were going to grow themselves into a majority of the court. And that’s led to controversy and rulings outside the mainstream that have led to protests, while the European Union is withholding funds and such from Poland because of this manipulation of the court.
In Hungary, Victor Orban was a really radical leader, and when he had a bare majority to change the constitution he wiped out all the previous jurisprudence of the Constitutional Court. I don’t think the Israeli government would do that. But still there is this kind of worrying sense that they’re able to manipulate interpretation of law for their own particular political interest.
Another thing I want to raise is the potential for a constitutional crisis now. Suppose they pass these laws and the Israeli Supreme Court says, “Well, wait a minute, that interferes with our common law rules that we are bound by, going back to the British Mandate.” It conflicts with the basic law and they invoke what legal scholars call the “doctrine of unconstitutional constitutional amendments,” which is basically saying that an amendment goes against the core of our democratic system and violates, for example, Israel’s character as a Jewish and democratic society. Israel has never done this, but it is a kind of tool that one sees deployed around the world in these crises. And if that happened, then I think you would have a full constitutional crisis on your hands in Israel.
Supreme Court President Aharon Barak speaks with Prime Minister Benjamin Netanyahu during a ceremony in the Supreme Court marking 50 years of law, Sept. 15, 1998. (Avi Ohayon)
What does a constitutional crisis look like?
Suppose you have sitting justices in Israel who say, “You know, this Knesset law violates the basic law and therefore it’s invalid.” And then, would the Knesset try to impeach those judges? Would they cut the budget of the judiciary? Would they back down?
When you compare Israel’s judicial system to other countries’ over the years, how does it stack up? Is it up there among the very strong systems or is it known for flaws that might have maybe hobbled its effectiveness?
It’s always been seen around the world as a very strong judiciary. Under the leadership of Aharon Barak [president of Israel’s Supreme Court from 1995 to 2006] it became extremely activist. And this provoked backlash in Israeli politics. That led to a kind of recalibration of the court where it is still doing its traditional role of defending fundamental rights and ensuring the integrity of the political process, but it’s not making up norms left and right, in the way that it used to. This is my perception. But it’s certainly seen as one of the leading courts around the world, its decisions are cited by others, and because of the quality of the judges and the complex issues that Israel faces it’s seen as a strong court and an effective court and to me a balanced court.
But, you know, I’m not in Israel, and ultimately, they’re going to figure out the question how balanced it is or where it’s going to go. I do worry that an unchecked majoritarian system, especially with a pure proportional representation model like Israel, has the potential for the capture of government by some minorities to wield power against other minorities. And that’s a problem for democracies — to some degree, that’s a problem we face in the United States.
How correctable are these reforms? I am thinking of someone who says, “These are democratically elected representatives who now want to change a system. If you want to change the system, elect your own majority.” Is the ship of state like this really hard to turn around once you go in a certain direction?
This is an area in which I think Israel and the United States have a lot of similarities. For several decades now, the judiciary has been a major issue for those on the political right. They thought the Warren Court was too left-leaning and they started the Federalist Society to create a whole cadre of people to staff the courts. They’ve done that and now the federal courts are certainly much more conservative than the country probably. But the left didn’t really have a theory of judicial power in the United States. And I think that’s kind of true in Israel: It’s a big issue for the political right, but the political left, besides just being not very cohesive at the moment, isn’t able to articulate what’s good about having an independent judiciary. It is correctable in theory, but that would require the rule of law to become a politically salient issue, which it generally isn’t in that many countries.
How do you relate to what is happening in Israel as a Jew, and not just a legal scholar?
That’s a great question, because it really raises my complicated relationship with the country. You know, I find it to be a very interesting democracy. I like going to Israel because it’s a society in which there’s a lot of argument, a lot of good court cases and a lot of good legal scholars. On one level, I connect with my colleagues and friends there who seem very demoralized about this current moment. And I honestly worry about whether this society will remain a Jewish and democratic one with the current coalition.
The rule of law is a part of democracy. You need the rule of law in order to have democracy function. And I know others would respond and say, “Oh, you’re just being hysterical.” And, “This isn’t Sweden, it’s the Middle East.” But the ethno-nationalist direction of the country bothers me as a Jew, and I hope that the court remains there to prevent it from deepening further.
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Number of UK Schools Marking Holocaust Has Dropped by Nearly 60% Since Oct. 7 Massacre
Tens of thousands joined the National March Against Antisemitism in London, Nov. 26, 2023. Photo: Tayfun Salci/ZUMA Press Wire via Reuters Connect
The number of British schools commemorating the Holocaust has plummeted by nearly 60 percent following the Palestinian terrorist group Hamas’s Oct. 7, 2023, invasion of southern Israel.
Since Hamas-led Palestinian terrorists perpetrated the largest single-day massacre of Jews since World War II, the number of secondary schools across the UK signed up for events commemorating Holocaust Remembrance Day, which takes place annually on Jan. 27, dropped to fewer than 1,200 in 2024 and 854 in 2025, according to data from the Holocaust Memorial Day Trust.
The figure had been rising each year since 2019, reaching more than 2,000 secondary schools in 2023.
There are about 4,200 secondary schools in the UK.
Sir Ephraim Mirvis, chief rabbi of the UK, commented on the figures in an essay published in The Sunday Times, expressing alarm about an increasingly hostile environment for the British Jewish community.
“I fear for what will happen this year,” Mirvis wrote. “For if we cannot teach our children to remember the past with integrity and resolve, then we must ask ourselves what kind of future they will inherit.”
Mirvis urged readers to put themselves in the shoes of a UK teacher preparing a Holocaust memorial event. “Now imagine that as you begin to organize such an event, you learn that some parents of pupils at your school are unhappy about it,” he added. “One of the claims that Holocaust education is a form of “propaganda”; another insists that the event must not go ahead unless it also highlights the awful suffering of Palestinians in Gaza.”
Karen Pollock, chief executive of the Holocaust Educational Trust, described to The Times how some students “arrive in the classroom with views shaped by social media trends rather than evidence.”
The European Jewish Congress (EJC) released a statement on Monday reflecting on the drop in UK schools recognizing the Holocaust.
“Holocaust Memorial Day is not about politics. It is about memory, responsibility, and education. It exists to honor the 6 million Jews murdered in the Holocaust and to remind future generations of the consequences of hatred, indifference, and extremism,” the EJC stated. “Avoiding commemoration out of fear of controversy undermines the very purpose of education. When remembrance becomes optional, memory itself becomes fragile.”
The EJC continued, “Now is precisely the moment when Holocaust education matters most: when misinformation spreads easily, when antisemitism is openly visible, and when fewer survivors remain to bear witness. Schools play a vital role in preserving this memory, not only for Jewish communities, but for society as a whole.”
Dwindling commemoration of the Holocaust comes amid a steep surge in antisemitism across the UK.
The Community Security Trust (CST) — a nonprofit charity that advises Britain’s Jewish community on security matters — recorded 1,521 antisemitic incidents from January to June this year. This was the second-highest number of antisemitic crimes ever recorded by CST in the first six months of any year, following 2,019 incidents in the first half of 2024.
In total last year, CST recorded 3,528 anti-Jewish hate crimes — the country’s second worst year for antisemitism, despite an 18 percent drop from 2023’s record of 4,296.
“When a trigger event such as the Oct. 7 attack occurs, antisemitic incidents initially spike to a record peak; then gradually recede until they plateau at a higher level than before the original trigger event occurred,” CST stated.
These figures juxtapose with 1,662 antisemitic incidents in 2022, 2,261 in 2021, and 1,684 in 2020.
The struggles of the UK’s educational establishment to counter the rising antisemitism problem mirror the ongoing challenges confronted by its medical institutions.
In November, UK Health Secretary Wes Streeting called it “chilling” that some members of the Jewish community fear discrimination within the NHS, amid reports of widespread antisemitism in Britain’s health-care system.
The comments came weeks after British Prime Minister Keir Starmer unveiled a new plan to address what he described as “just too many examples, clear examples, of antisemitism that have not been dealt with adequately or effectively” in the country’s National Health Service (NHS).
One notable case drawing attention involved Dr. Rahmeh Aladwan, a trainee trauma and orthopedic surgeon, who police arrested on Oct. 21, charging her with four offenses related to malicious communications and inciting racial hatred. In November, she was suspended from practicing medicine in the UK over social media posts denigrating Jews and celebrating Hamas’s terrorism.
Other incidents in the UK included a Jewish family fearing their London doctor’s antisemitism influenced their disabled son’s treatment. The North London hospital suspended the physician who was under investigation for publicly claiming that all Jews have “feelings of supremacy” and downplaying antisemitism.
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US-Based Anti-Zionist Groups Spread Terrorist Propaganda on Social Media, New Report Shows
A student puts on their anti-Israel graduation cap reading “From the river to the sea” at the People’s Graduation, hosted for Mahmoud Khalil and other students from New York University. Photo: Angelina Katsanis via Reuters Connect
Anti-Zionist groups operating in the US are using social media to spread anti-Israel propaganda confected by foreign terrorist organizations based in Gaza and elsewhere across the Middle East, according to a new report by the Anti-Defamation League (ADL).
“Protesters and activists are not merely praising the activity of terror groups; they are actively sharing their official propaganda, disseminating communiqués, videos, and other materials directly into mainstream platforms,” says the report, titled “Digital Couriers.”
“This propaganda spread functions to normalize the eliminationist goals and terrorist tactics espoused by groups like Hamas and the [Popular Front for the Liberation of Palestine] within certain activist circles in the US,” the report continues. “It blurs the line between legitimate protest and explicit endorsement of terrorism and antisemitic violence.”
The groups employ a number of social media platforms to further the mission, including “Resistance News Network” (RNN) on Telegram, a “radical, antisemitic, anti-Zionist” channel which “plays a key role in getting translated terrorist content into the hands of American activists, while also creating and packaging its own content and glorifying terror attacks and other violence.”
Instagram is another online service which pro-Hamas activists use as a news wire. It is especially popular with Students for Justice in Palestine (SJP), an organization that has been central to the campus antisemitism crisis that has seen Jewish students harassed, excluded, and assaulted at colleges across the US.
SJP, the ADL says, has shared messages by Hamas spokesmen, commemorated the Oct. 7, 2023, massacre across southern Israel as a day of celebration for the anti-Zionist movement, and shared footage from that day in which a Hamas fighter was “inside the home of an Israeli family.”
The ADL argues social media platforms should aim for “disrupting the pipeline,” enforcing their “existing policies” which already proscribe sharing content of foreign terrorist groups. College and universities, it continues, are responsible for ensuring that students do not do so and break federal law in the process.
“More broadly, it is incumbent upon the general public to engage in due diligence when consuming and sharing content online and associating with activist groups and individuals,” the report concludes.
Anti-Zionist groups have been flagged before for functioning as arms of Hamas while promoting Islamism as well as the geopolitical aims of countries such as Iran.
In October, SJP’s national office (NSJP) appeared to call for executing Muslim “collaborators” working with Israel in retaliation for the death of Palestinian influencer Saleh Al-Jafarawi during a brewing conflict between the Hamas terrorist group and a rival clan, Doghmush, in Gaza City.
“Saleh’s martyrdom is a testament to the fact that the fight against Zionism in all its manifestations — from the [Israel Defense Forces] to its collaborators — must continue,” the group said in a statement posted on social media. “In the face of hundreds of thousands of martyred Palestinians these past two years alone, collaborators and informants maintain their spineless disposition as objects of Zionist influence against their own people.”
The statement launched a series of unfounded charges alleging that anti-Hamas forces are “exploiting Gaza’s youth for money” and pilfering “desperately needed aid to the killing of their own people in service of Zionism.” NSJP added, “Death to the occupation. Death to Zionism. Death to all collaborators.”
Additionally, NSJP has publicly discussed its strategy of using the anti-Zionist student movement as a weapon for destroying the US, saying in 2024 that “divestment [from Israel] is not an incrementalist goal” but enacted with the later goal of setting off “the total collapse of the university structure and American empire itself.” On the same day the group issued that statement, Columbia University’s most strident pro-Hamas organization was reported to be distributing literature calling on students to join the Palestinian terrorist group’s movement to destroy Israel during the school’s convocation ceremony.
“This booklet is part of a coordinated and intentional effort to uphold the principles of the thawabit and the Palestinian resistance movement overall by transmitting the words of the resistance directly,” said a pamphlet distributed by Columbia University Apartheid Divest (CUAD), an SJP spinoff, to incoming freshmen. “This material aims to build popular support for the Palestinian war of national liberation, a war which is waged through armed struggle.”
Other sections of the pamphlet were explicitly Islamist, invoking the name of “Allah, the most gracious” and referring to Hamas as the “Islamic Resistance Movement.” Proclaiming, “Glory to Gaza that gave hope to the oppressed, that humiliated the ‘invincible’ Zionist army,” it said its purpose is to build an army of Muslims worldwide.
“We call upon the masses of our Arab and Islamic nations, its scholars, men, institutions, and active forces to come out in roaring crowds tomorrow,” it added, referring to an event which took place the previous December. “We also renew our invitation to the free people and those with living consciences around the world to continue and escalate their global public movement, rejecting the occupation’s crimes, in solidarity with our people and their just cause and legitimate struggle.”
Middle East experts have long suspected that foreign agents are conspiring with SJP chapters.
In July 2024, then-US National Intelligence Director Avril Haines issued a statement outlining how Iran has encouraged and provided financial support to the anti-Israel campus protest movement and explaining that it is part of a larger plan to “undermine confidence in our democratic institutions.” Haines also confirmed that US intelligence agencies have “observed actors tied to Iran’s government posing as activists online, seeking to encourage protests, and even providing financial support to protesters.”
Follow Dion J. Pierre @DionJPierre.
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NYC Schools Chancellor Implored to Enforce Political Neutrality After Anti-Zionist ‘Teach-In’ for Kids
New York City Public Schools Chancellor Kamar Samuels shakes hands with members of the press after 3-K and Pre-K applications opened on Jan. 14, 2026, at a school in Cypress Hills, New York, USA. Photo: Derek French / SOPA Images via Reuters Connect
Teachers who promoted a “Palestine Teach-In” for New York City schoolchildren on Martin Luther King’s birthday violated the city’s policy on political neutrality on school grounds and violated free speech protections afforded to teachers as government employees, according to a new letter sent by nonprofits to Public Schools Chancellor Kamar Samuels.
The event, organized by a group which calls itself “NYC Educators for Palestine,” targeted “kids ages 6-18,” according to social media screenshots included in the groups’ letter. New York City officially prohibits attempts to indoctrinate students with views held by schoolteachers, having adopted a “politically neutral learning environment” policy in June 2009.
That policy must be enforced, said the two nonprofits, StandWithUs and the North American Values Institute (NAVI), who wrote to Samuels.
“NYCPS [New York City Public Schools] teachers’ speech can be considered government speech, as opposed to private speech, depending on the context. The teachers involved in advertising and speaking at the event are proactively sharing their status and training as NYCPS teachers to attract attendance,” the groups said. “Doing so risks misleading families as to whether the event is sponsored or supported by the DOE [Department of Education].”
“NYCPS teachers’ speech — even private speech off of school grounds — can be limited if it would interfere with the ‘effective operation of the school,’” the letter continued. “NYCPS teachers, as city employees, may not use their positions of authority to influence students. Whether or not they are literally in the classroom, students are considered ‘captive audience’ members to their teachers.”
The Algemeiner has asked the United Federation of Teachers (UFT), which represents over 200,000 teachers and other education professionals in collective bargaining negotiations, to respond to the letter and has not heard back. At least one UFT caucus promoted the event.
The UFT has been criticized for violating political neutrality before. According to a report published in September by the Defense of Freedom Institute (DFI), the union has gone from fostering popular support for anti-Zionism among students to seeking cover from government by placing one or more of its fellow travelers in high office. To that end, the UFT endorsed the New York City mayoral candidacy of Zohran Mamdani in July, calling the avowed socialist and Hamas sympathizer a potential “partner.”
“The historical record shows that, whatever their shortcomings, previous generations of teacher-union leaders stood up to antisemitism in K-12 schools on behalf of their Jewish members and promoted strong US support for Israel in the face of existential attacks on that country,” the report stated. “Now, antisemitic activists grossly dishonor that legacy by weaponizing teacher unions to spread antisemitism, intimidate Jewish teachers, and recast the classroom as a battlefield against the West.”
Other states have faced similar challenges, as public school teachers have seemingly assumed that they have academic freedom and free speech rights enjoyed by professors.
In December, a California judge weighed in on this issue while striking down a challenge to the state’s new K-12 antisemitism law, a measure which established a new Office for Civil Rights and other protections for Jewish students.
In the suit, a teacher argued that the K-12 antisemitism law was “hastily written” and “singled out for punishment” anti-Zionist viewpoints. She also criticized the law because she said it “empowers anyone to file a complaint claiming classroom content and instructional materials criticize Israel and Zionism,” preventing teachers “from freely discussing these critical issues.”
In her decision, Judge Noël Wise, appointed by former US President Joe Biden in 2024, said that even if what the teacher and LA Educators for Justice in Palestine argued was true, it failed legally for asserting public teachers’ right to unfettered free speech, which does not exist for government employees while they are at work. Teachers may comment on matters of public interest, she explained, citing past jurisprudence by the US Supreme Court, but they cannot interfere with government’s advancing its “legitimate interests.” When they speak in the classroom or on a public school campus, Wise stressed, they do so not as private citizens but as state officials speaking “with the voice of the government” — a fact which allows government to steer or proscribe what is said on its behalf.
She continued, “As public school education belongs to the government, the government may regulate Teacher Plaintiffs [sic] speech to accord with the government’s education goals. It is of no significance that the curricula and the attendant speech required to teach it may advance a single viewpoint to the exclusion of another.”
Follow Dion J. Pierre @DionJPierre.