IN THE SUPREME COURT OF THE STATE OF NEW MEXICO
Opinion Number: 2009-NMSC-003
Filing Date: February 9, 2009
Docket No. 31,386
STATE OF NEW MEXICO ex rel.
LEAGUE OF WOMEN VOTERS
OF NEW MEXICO,
Petitioner,
v.
THE HONORABLE MARY HERRERA,
in her official capacity as SECRETARY OF
STATE OF NEW MEXICO,
Respondent.
ORIGINAL PROCEEDINGS ON MANDAMUS
Edward Ricco, Esq.
Jocelyn Drennan, Esq.
Rodey, Dickason, Sloan, Akin
& Robb, P.A.
Albuquerque, NM
for Petitioner
Gary K. King, Attorney General
Scott Fuqua, Assistant Attorney General
New Mexico Attorney General’s Office
Santa Fe, NM
for Respondent
OPINION
BOSSON, Justice.
{1} In this case, we confront a fundamental question about the basic unit of our
representative democracy, the individual vote: What constitutes a valid expression of voter
1
intent? The Legislature has already answered this question, at least in part, by providing that
a hand-tallied vote shall be counted if “the presiding judge and election judges for the
precinct unanimously agree that the voter’s intent is clearly discernable [sic].” NMSA 1978,
§ 1-9-4.2(B) (2003, as amended through 2007).
{2} We hold that this provision of the Election Code, as supported by certain guidelines
and instructions promulgated by the New Mexico Secretary of State (“the Secretary”), is
consistent with the U.S. Supreme Court’s equal protection analysis in Bush v. Gore, 531 U.S.
98 (2000) (per curiam), to the limited extent that that opinion has bearing here, as well as the
federal Help America Vote Act (“HAVA”) of 2002 , 42 U.S.C. §§ 15301-15545 (2005). We
therefore have granted the League of Women Voters of New Mexico’s (“the League”)
emergency petition for writ of mandamus, and have ordered the Secretary to carry out the
intent of our Legislature by fully conforming to and enforcing Section 1-9-4.2(B). We
granted the writ prior to issuing this opinion, which elaborates on that initial order.
BACKGROUND
{3} On October 23, 2008, eleven days before the November 4 general election, the
League filed with this Court an emergency petition for writ of mandamus. The petition
urged us to issue the writ to Secretary of State Mary Herrera, ordering her to enforce Section
1-9-4.2(B), which defines what types of votes on hand-tallied paper ballots shall be counted.
The statute provides that four general categories of marks on a ballot shall be counted as
valid votes:
For paper ballots that are hand-tallied, a vote
shall be counted if:
(1) the ballot is marked in accordance with the
instructions for that ballot type;
(2) the preferred candidates’ name or answer to a
ballot question is circled;
(3) there is a cross or check within the voting response
areas for the preferred candidate or answer to the ballot
question; or
(4) the presiding judge and election judges for the
precinct unanimously agree that the voter’s intent is clearly
discernable [sic].
Section 1-9-4.2(B).
{4} At issue in this case is the “voter’s intent” language of Subsection (B)(4). The
League claims that by ignoring and refusing to enforce Subsection (B)(4), the Secretary
threatened widespread disenfranchisement of New Mexico voters. Without Subsection
(B)(4), the statute would allow for only three types of voter marks to be counted as a valid
vote, aside from marks made in accordance with ballot instructions: a check, a cross or a
circle. Subsection (B)(4) appears to be a catch-all provision which allows other types of
marks to be counted, so long as the presiding judge and election judges “unanimously agree”
2
that the voter’s intent is “clearly discernable [sic].” Section 1-9-4.2(B).
{5} The Secretary appears to have decided not to enforce Subsection (B)(4) because of
an advisory letter from the Attorney General, which concluded that Subsection (B)(4) is
unconstitutional. That letter issued on May 16, 2008. In a belated response to the letter, the
Secretary on September 30, 2008 promulgated an emergency amendment to1.10.12.15(C)
NMAC, a rule which provides guidance to absentee precinct boards about how to read ballot
markings. The new rule advised that ballots not marked in accordance with instructions
would be counted “only if the voter has marked a cross (X) or a check (/) within the voting
response area, circled the name of the candidate or both.” 1.10.12.15(C) NMAC
(9/30/2008). By excluding any additional consideration of voter intent, this rule effectively
eliminated Subsection (B)(4) from Section 1-9-4.2. It also contradicted the Secretary’s
earlier guidelines, Instruction 2008-10, which provided specific rules as to when votes
should be counted.1
{6} The Attorney General’s letter on which the Secretary relied concluded that
Subsection (B)(4) is “inconsistent with HAVA and vulnerable to challenge on constitutional
equal protection grounds.” The letter asserted that the standard established by Subsection
(B)(4) for determining voter intent “is virtually indistinguishable” from the Florida standard
famously criticized in Bush v. Gore. The Florida Supreme Court had initially ordered the
counties undertaking manual vote recounts in the 2000 presidential election to consider the
“intent of the voter.” Bush v. Gore, 531 U.S. at 102. The U.S. Supreme Court reversed the
Florida Supreme Court and rejected the “intent of the voter” standard as arbitrary and
violative of equal protection principles. Id. at 103. Accordingly, the Secretary asserted to
this Court that she had a constitutional duty not to apply Subsection (B)(4).
{7} On October 28, immediately following expedited oral argument, we issued the writ
requested by the League. We ordered the Secretary to comply with Subsection (B)(4). This
opinion follows.
DISCUSSION
{8} We begin by reiterating the longstanding and fundamental principle that the right to
vote is of paramount importance. See Calkins v. Stearley, 2006-NMCA-153, ¶ 30, 140
N.M. 802, 149 P.3d 118; State ex rel. Read v. Crist, 25 N.M. 175, 199, 179 P. 629, 637
(1919). The courts of New Mexico have long held that in service of this important right,
courts should guard against voter disenfranchisement whenever possible and interpret
statutes broadly to favor the right to vote. See, e.g., Darr v. Vill. of Tularosa, 1998-NMCA-
104, ¶ 18, 125 N.M. 394, 962 P.2d 640; State ex rel. Walker v. Bridges, 27 N.M. 169, 174,
199 P. 370, 372 (1921). New Mexico courts have also held that the right to vote can be
1
Our use of the word “guidelines” in this opinion refers to the Secretary’s Instruction
2008-10, and not the emergency rule amendment 1.10.12(C) NMAC.
3
subject to reasonable constraints consistent with the statutes governing voting. See Calkins,
2006-NMCA-153, ¶ 30. This Court may not interpret statutes unreasonably in order to
facilitate voting. Id.
{9} We therefore confront two interests which may at times be opposed to one another.
On one hand is the interest in effectuating a voter’s intent. This is a very powerful interest
indeed, for if a government fails to accurately identify and record a voter’s choice, it has
failed to carry out the fundamental transaction which sustains our representative democracy.
On the other hand is the interest in ensuring that marks on a ballot are interpreted
consistently for every voter. This too is a powerful interest. If officials read marks on a
ballot one way in one part of the state and another way in another part of the state, the
government has treated voters unequally for an arbitrary reason, namely geography. That
would be unacceptable under equal protection principles.
{10} Both HAVA and Bush v. Gore aimed to focus more sharply the discretion of election
officials in divining voter intent, or at least to standardize the methods by which officials
may determine that intent. The question before us is whether Subsection (B)(4), in concert
with regulations promulgated by the Secretary, hews to the principles set forth by Bush v.
Gore and HAVA. Before addressing that question, we detour briefly to consider the
propriety, under New Mexico law, of mandamus in this case.
MANDAMUS
{11} We first consider the League’s standing to bring an action in mandamus, and whether
mandamus is an appropriate remedy. This Court in its discretion may grant private parties
standing to vindicate the public interest in cases presenting “issues of great public
importance.” State ex rel. Sego v. Kirkpatrick, 86 N.M. 359, 363, 524 P.2d 975, 979 (1974).
Determining the validity of individual votes is of unquestionable importance. Establishing
clear rules, prior to election day, as to how such validity is to be established is of equal, if
not greater, importance. Therefore, there can be little doubt that construing the statute
governing the counting of hand-tallied ballots qualifies under the “great public importance”
standard of the Sego line of cases.
{12} The New Mexico Constitution gives this Court the power to issue writs of mandamus
“against all state officers.” N.M. Const. art. VI, § 3. Mandamus is appropriate to compel
state officers to perform a statutory duty. State ex rel. Clark v. Johnson, 120 N.M. 562, 569,
904 P.2d 11, 18 (1995). Here, the Secretary is clearly a “state officer” within the meaning
of the Constitution, and it is clear that the Secretary must follow the Election Code, and does
not have the power to change its mandatory provisions. Weldon v. Sanders, 99 N.M. 160,
164-65, 655 P.2d 1004, 1008-09 (1982).
{13} This dispute is before us because the Secretary claims she has a duty not to enforce
Subsection (B)(4) because of a perceived conflict with federal law. For reasons that follow,
we disagree. We conclude that the Secretary has a clear mandatory duty to enforce
Subsection (B)(4) as written and as amplified by the Secretary’s own guidelines.
4
Accordingly, mandamus is an appropriate remedy.
SUBSECTION (B)(4)
{14} The Secretary argues that Bush v. Gore “directly addressed” the issue in the present
case, and that a “straightforward application” of the language of HAVA “compels the same
conclusion as that compelled by Bush – [Subsection (B)(4)] lacks sufficient uniformity to
comply with HAVA.”
{15} We are not persuaded that Bush v. Gore compels the Secretary to ignore New Mexico
statutory law. Already limited by its own terms to the facts before that Court, Bush v. Gore
is of even more limited relevance here. Furthermore, Subsection (B)(4), when combined
with the specific guidelines the Secretary had originally implemented, provides sufficient
statewide uniformity to comply with both Bush v. Gore and the plain language of HAVA.
{16} The Supreme Court in Bush v. Gore concluded that the recount process ordered by
the Florida Supreme Court in the 2000 presidential election lacked sufficiently uniform rules
for determining how a vote was to be counted. 531 U.S. at 105-06. It held that the Florida
Supreme Court’s order that local election officials were to discern the “intent of the voter,”
without anything more specific, violated equal protection principles. Id. The Court noted
that the “problem inheres in the absence of specific standards to ensure . . . equal
application” of the “intent” standard throughout the state. Id. at 106. The Court further
observed that its consideration was “limited to the present circumstances, for the problem
of equal protection in election processes generally presents many complexities.” Id. at 109.
{17} In part because of the opinion’s unusual self-limiting phrase, the precedential weight
of Bush v. Gore is ambiguous, but the case nevertheless appears to have continuing life. See,
e.g., Chad Flanders, Comment, Bush v. Gore and the Uses of “Limiting,” 116 Yale L.J.
1159, 1167 (2007) (asserting that the Bush v. Gore Court’s limiting language is “historically
unique,” and observing that the “practical issue of whether lower courts must follow Bush
v. Gore . . . seems unlikely to disappear any time soon”); Richard L. Hasen, The Untimely
Death of Bush v. Gore, 60 Stan. L. Rev 1, 3 (2007) (noting that no U.S. Supreme Court
opinion, concurrence, or dissent has ever cited to the case, and declaring that “Bush v. Gore
is dead”); Adam Liptak, Bush v. Gore Set to Outlast its Beneficiary, N.Y. Times, Dec. 23,
2008, at A1 (asserting that the opinion is “turning out to have lasting value after all”). Our
research shows that some courts have found the decision applicable to challenges of voting
systems, see, e.g., League of Women Voters v. Brunner, 548 F.3d 463, 477 (6th Cir. 2008);
Black v. McGuffage, 209 F. Supp. 2d 889, 898 (N.D. Ill. 2002); Common Cause S. Christian
Leadership Conference of Greater L.A. v. Jones, 213 F. Supp. 2d 1106, 1108 (C.D. Cal.
2001). Courts have also applied the decision to challenges of recount procedures and
standards for determining voter intent. See, e.g., Big Spring v. Jore, 109 P.3d 219 (Mont.
2005). It seems, then, that some courts have treated Bush v. Gore as having some
precedential weight, despite the opinion’s warning that it applied only to the facts before that
Court.
5
{18} In the case before this Court, however, Bush v. Gore’s relevance is limited. In
addition to the self-limiting nature of the case, it is not applicable here because the Court
addressed a situation far from analogous to our own. The Florida Supreme Court had
ordered that local officials find the “intent of the voter,” but provided no guidelines for doing
so, Bush v. Gore, 531 U.S. at 106, while the Secretary’s guidelines in New Mexico provide
clear context and guidance for local election officials. The Bush v. Gore court noted that
there was no requirement in Florida that the election judges come to a unanimous agreement
as to what constituted voter intent, while New Mexico law specifically requires unanimity
among election judges in determining voter intent. Section 1-9-4.2(B)(4). The Supreme
Court noted that counties in Florida were using different standards for determining “intent
of the voter,” and at least one county even changed standards in the middle of the recount
process. Bush v. Gore, 531 U.S. at 106-07. Here, all counties in New Mexico are subject
to one uniform standard.
{19} It is true, as the Attorney General observed in his letter to the Secretary and as the
Secretary argued to this Court, that under Subsection (B)(4) and the Secretary’s guidelines,
a theoretical possibility remains that election officials in different parts of the state could
interpret the same ballot marking differently. However, we presume that the Secretary will
obey the law in implementing the statute and the regulations, and that she will make a
forceful effort to achieve uniformity in interpreting ballots. Furthermore, as we discuss
below, there must be some room for discretion by local officials in order to guard against
disenfranchisement. The hypothetical possibility that future violations may occur is an
insufficient basis for striking down Subsection (B)(4) now. That statute achieves an
appropriate balance between ensuring against disenfranchisement and promoting uniformity
in the interpretation of hand-written ballots. Of course, we remain open to persuasion in any
future case that might present concrete examples of arbitrary and discriminatory application
of Subsection(B)(4) and the Secretary’s guidelines.
{20} The Secretary’s guidelines, styled Instruction 2008-10, were attached to the
Secretary’s August 22, 2008 memo to county clerks, titled “Absentee and Provisional
Ballots, What Constitutes a Vote?” Instruction 2008-10 lays out detailed guidelines for
determining what kinds of ballot marks should, and should not, constitute a legal vote, along
with 30 graphical examples of ballots with unconventional markings, accompanied by rules
about how to interpret such marks. For example, the instructions specify that a ballot on
which the voter filled in the optical-scan ovals for more than one candidate for a single office
shall not be counted. The graphical display shows three candidates, George Washington,
Abraham Lincoln, and John Adams, with ovals to the left of their names. Two of the ovals,
those for Lincoln and Adams, are filled in. The third remains empty. Beneath this graphical
demonstration are the clear words, in boldface type: “Invalid vote.” In another example
ballot, the voter has darkened the oval next to John Adams’ name, and has left the Lincoln
and Washington ovals blank. However, the voter has handwritten “Yes” over Washington’s
name. Beneath this sample is the instruction: “Valid Vote for Adams.” There are numerous
such examples, all with clear instructions as to whether election judges should count such
marks.
6
{21} Of course, it would be impossible for the Secretary’s guidelines to account for every
imaginable expression of voter intent. Human beings are unpredictable; sometimes it takes
another human, rather than a machine or mechanically applied guidelines, to interpret human
markings. An overly mechanical or formulaic approach might lead to unnecessary
disenfranchisement of voters who mark their ballot in ways not accounted for in official
guidelines, but which nonetheless, to the human eye, would appear as clear expressions of
voter intent.
{22} At the same time, the discretion given to election judges must have clear
limits—such is the mandate of HAVA and Bush v. Gore. Subsection (B)(4), along with the
Secretary’s guidelines as articulated in Instruction 2008-10, strike an appropriate balance.
In concert, the two allow for some discretion by local election judges, but limit that
discretion with clear and uniform guidelines. The August 22 memo and Instruction 2008-10,
with its detailed rules and examples, are the kind of uniform standards that the U.S. Supreme
Court found lacking in Bush v. Gore.
THE HELP AMERICA VOTE ACT OF 2002
{23} HAVA supports our conclusion. Congress passed the legislation in the wake of Bush
v. Gore. The portion of the statute that applies here requires that states adopt “uniform and
nondiscriminatory standards that define what constitutes a vote and what will be counted as
a vote.” 42 U.S.C. § 15481(a)(6).
{24} We are unable to find case law, state or federal, specifically interpreting the portion
of HAVA at issue in this case, and the parties in this case cited none. Dolan v. Powers, 260
S.W.3d 376, 380 (Mo. Ct. App. 2008), comes the closest to interpreting the HAVA provision
at issue here, but that court does not go so far as to actually construe the statute, but rather
merely mentions the law as background in interpreting a Missouri statute, quite similar to
our own Section 1-9-4.2(B), regarding the proper determination of voter intent.
{25} Applying plain-language definitions to the operative HAVA terms, “uniform and
nondiscriminatory,” and reading these words in concert with HAVA and Bush v. Gore, it is
clear that HAVA requires some basic level of consistency in the way election officials
interpret whether a particular type of ballot marking is a valid expression of voter intent.2
In HAVA’s preamble, the legislation’s purpose is set forth as establishing “minimum
election administration standards for States and units of local government with responsibility
for the administration of Federal elections.” HAVA, Pub. L. No. 107-252, 116 Stat. 1666,
2
Black’s Law Dictionary defines “uniform” as “characterized by a lack of variation;
identical or consistent.” Black’s Law Dictionary 1564 (8th ed. 2004). Black’s second
definition for “discrimination” is most fitting here: “a failure to treat all persons equally
when no reasonable distinction can be found between those favored and those not favored.”
Id. at 500.
7
1666 (2002) (emphasis added). Section 15484 restates this notion, noting that HAVA’s
requirements are “minimum requirements and nothing in [42 U.S.C. §§ 15301-15545] shall
be construed to prevent a State from establishing election technology and administration
requirements that are more strict than the requirements established under [42 U.S.C. §§
15301-15545] so long as such State requirements are not inconsistent with the Federal
requirements under [42 U.S.C. §§ 15301-15545].” 42 U.S.C. § 15484. Making this idea
even more explicit, and applying it generally to the entire statute is the following Section:
“The specific choices on the methods of complying with the requirements of [42 U.S.C. §§
15301-15545] shall be left to the discretion of the State.” 42 U.S.C. § 15485. HAVA, then,
is a floor beneath which the states are not permitted to go. Further, the statute’s plain
language is clear that states retain wide latitude, above that floor, in carrying out the statute’s
basic requirements.
{26} HAVA’s legislative history further supports the notion that Congress did not intend
to strip states of their traditional role in supervising and carrying out elections. Rather, the
statute’s main supporters, Democrats and Republicans alike, made explicit that state officials
were to retain considerable discretion in carrying out HAVA’s basic requirements. Senator
Chris Dodd, a Democrat and the principal author in the Senate of the conference report,
asserted in floor debate for the conference report that: “nothing in this bill establishes a
Federal definition of when a voter is registered or how a vote is counted.” 148 Cong. Rec.
S10488, S10488 (statement of Sen. Dodd) (emphasis added). Senator Dodd reiterated this
idea multiple times, elsewhere asserting that “what constitutes a valid vote is left up to the
States. We don’t federalize registration and we don’t federalize how votes get counted. We
have left that to the States . . . States ought to have the flexibility of deciding what system
works best for them.” 148 Cong. Rec. S10412, S10421. Across the aisle and in the House
of Representatives, Rep. Bob Ney, a chief House sponsor of HAVA, similarly asserted in
floor debate for the conference report that “[t]his legislation will pose certain basic
requirements that all jurisdictions will have to meet, but they will retain the flexibility to
meet the requirements in the most effective manner.” 148 Cong. Rec. H7836, H7838.
{27} Given HAVA’s lack of any definition of what constitutes a vote within the meaning
of 42 U.S.C. § 15481(a)(6), along with the clear intent of Congress to leave considerable
discretion to the states to define for themselves what constitutes a legal vote, it appears that
the most HAVA requires is uniform statewide standards as to what a legal vote shall be. In
other words, states are required to have certain minimum standards that are consistent
geographically, as well as in terms of traditional bases for discrimination: race, gender, and
the like. For reasons already discussed, Subsection (B)(4), in concert with the guidelines
originally promulgated by the Secretary, provides sufficient assurances that county clerks
in various parts of the state will interpret “voter’s intent” in a uniform and nondiscriminatory
fashion. It is a clear, statewide standard, and therefore meets the requirements of HAVA.
{28} We draw support from the statutes of our sister states, many of which are similar to
our own. A plurality of states appears to use a “voter intent” standard, and many of them
apply such a standard with language strikingly similar, though not identical, to our own.
8
Some states use a clear voter-intent standard, while others state it in the negative: ballots
where voter intent cannot be determined do not count. Statutes using the voter-intent
standard, stated either in the positive or the negative, include: Ariz. Rev. Stat. Ann. § 16-
645(A) (2006) (“When canvassing write-in votes the apparent intent of the voter shall be
taken into consideration to the extent possible.”); Conn. Gen. Stat. § 9-150(j) (2007) (“In the
counting of absentee ballots the intent of the voter shall govern, [so long as three conclusive
presumptions apply].”); Idaho Code Ann. § 34-1203 (2008) (“Any ballot or part of a ballot
from which it is impossible to determine the elector's choice, shall be void and shall not be
counted.”); Ind. Code Ann. § 3-12-1-1 (2002) (subject to various exceptions, “the primary
factor to be considered in determining a voter's choice on a ballot is the intent of the voter”);
Me. Rev. Stat. Ann. tit. 21-A, § 696(4) (2004-05) (“If a voter marks the voter's ballot in a
manner that differs from the instructions at the top of the ballot but in such a manner that it
is possible to determine the voter's choice, then the vote for the office or question concerned
must be counted.”); Mo. Rev. Stat. § 115.453(3) (2007) (“The judges shall count votes
marked substantially in accordance with this section and section 115.456 when the intent of
the voter seems clear.”); Mont. Code Ann. § 13-15-206(4)(a)(ii) (2007) (“If a majority of the
counting board members agree that under the rules the voter's intent can be clearly
determined, the vote is valid and must be counted according to the voter's intent”); Utah
Code Ann. 1953 § 20A-4-105(6)(a) (2007) (“In counting the ballots, the counters shall give
full consideration to the intent of the voter.”).
{29} Although the wording of these statutes varies, sometimes greatly, all of them have
in common a key concept: voter intent is the polestar by which officials are to judge the
validity of ballots, and election judges have some discretion in determining what constitutes
a valid expression of voter intent. New Mexico’s statute has the same goals, though its
wording is more spartan than many other statutes. It is evident from the statute’s history that
our Legislature specifically added the voter-intent wording to the legislation in 2007. The
2003 version of the statute held that “only a cross (X) or a check (T) within the voting
response area shall be counted.” Section 1-9-4.2(B) (2003). Our Legislature in 2007
amended the statute to include the words that are at issue in this case. Subsection (B)(4)
provides that a voter’s mark shall be counted if “the presiding judge and election judges for
the precinct unanimously agree that the voter’s intent is clearly discernable [sic].” Section
1-9-4.2(B)(4). It is clear that by adding entirely new voter-intent language to the statute, our
Legislature intended to delegate discretion to the Secretary to implement regulations for
determining what constitutes “voter intent,” and to diminish the chances for voter
disenfranchisement by broadening the universe of valid ballot markings.
{30} We find no suggestion in the case law that any of the statutes of our sister states have
been overturned on equal protection grounds. That said, there appears to be little case law
interpreting these statutes, and none that we are able to find interpreting them in light of
Bush v. Gore and HAVA.
{31} In this absence of interpretive material, the Attorney General appears to have
understood federal law to bar virtually any statute which has as its goal determining “voter
9
intent.”3 For the reasons set forth, we disagree.
CONCLUSION
{32} Section 1-9-4.2, including Subsection (B)(4), as implemented by the Secretary’s
Instruction 2008-10, is constitutional on its face. We therefore have ordered the Secretary
to enforce Subsection (B)(4) as written and as interpreted by the Secretary’s guidelines.
{33} IT IS SO ORDERED.
RICHARD C. BOSSON, Justice
WE CONCUR:
EDWARD L. CHÁVEZ, Chief Justice
PATRICIO M. SERNA, Justice
PETRA JIMENEZ MAES, Justice
CHARLES W. DANIELS, Justice
Topic Index for State ex. rel League of Women Voters v. Herrera, No. 31,386
AE Appeal and Error
AE-MD Mandate
CR Civil Rights
CR-VR Voting Rights
3
The Attorney General’s broad reading of Bush v. Gore, it must be noted, would
likely invalidate all of the above-cited statutes from our sister states, because they all seek
to discern the “intent of the voter,” a standard which the Attorney General appears to have
concluded is per se unconstitutional.
10
CT Constitutional Law
CT-ED Equal Protection
CT-RV Right to Vote
FL Federal Law
FL-FL Federal Laws, General
GV Government
GV-EL Elections
ST Statutes
ST-IP Interpretation
ST-CN Constitutionality
11