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Daya: Article 3 Section 3 The Treason Clause

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The treason clause is the only crime explicitly defined in the Constitution. It was not included to insure loyalty of citizens, but rather was included as a precautionary measure to prevent against the government’s misuse of treason prosecutions to stifle legitimate political opposition. By specifying the terms necessary for one to be convicted of treason, trials were focused on the narrowly defined terms of treason and prevented the punishment of cases without sufficient evidence.

The Treason Clause states that treason can only be prosecuted under two circumstances: levying war against the United States or providing enemies with aid and support. In order for an individual to be convicted, there must be testimony from two witnesses of the overt offense or a confession in open court. Additionally, the clause states that Congress is responsible for determining the punishment for treason while also saying that the punishment cannot extend beyond the convicted person’s life. This means that there can be no forfeiture of wealth and property.

In 1807 a case called Ex parte Bollman & Swarthout emerged. The case focused around an alleged plot by former Vice President Aaron Burr and two associates to overthrow the government in New Orleans. However, due to the strict definition of treason, they were not convicted. The Supreme Court decided that conspiring to levy war, such as drawing plans, recruiting troops, and finding maps, was different than having a group of people ready to commit the treasonous act. 

In another treason case, Cramer v the United States in 1954, the defendant, Cramer, was prosecuted for allegedly helping a Nazi soldier who had snuck into America during World War II. The court decided that in the case, there was both concrete action and intent to betray the nation, and therefore Cramer was convicted. This set the bar very high for other treason cases because it required both evident action and intent to betray the nation. In this case, the government attempted to argue that the Treason Clause should be interpreted leniently for wartime use. The court held true to the Framers’ beliefs and dismissed the idea of leniency during wartime, saying that treason cannot be the primary legal weapon to protect national security. While Cramer was convicted for treason, the court told the government that they could pursue other charges such as the  violation of the Espionage act, or the Trading with the Enemy Act without having to go through the specific Treason Clause. This ruling made it much harder to convict someone for treason in the future as there had to be evidence of support for the enemy and intention to betray the nation.

This begs the question, is the Treason Clause still relevant. Firstly, someone can still commit treason, which was the case for Adam Gadahn who was indicted for treason in 2006. Secondly, the Treason Clause represents the original values of the Framers. The strict procedure to convict someone is a reminder that the Framers did not want the government to suppress political opposition with threats of treason and wanted to safeguard individual rights. In America, the rise of the public sphere meant that different political ideas were freely circulating. In addition, today, with the widespread usage of social media, many political ideologies are discussed frequently. In both of these cases, the Framers’ original intentions prevent these discussions from having any repercussions.

Josie Hsieh – Free Speech in the First Amendment

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Ratified on December 15, 1791, the Freedom of Speech Clause was imposed as part of the Bill of Rights, the first ten Amendments to the Constitution. The clause, which was written alongside laws disclosing matters of establishing and exercising religion and the right to petition the government, is most basically understood to state that that the government cannot convict people or organizations on the basis of what they say or write. However, the First Amendment only protects citizens against government officials and agencies, not private corporations or individuals. Free speech is not a limitless right, but the Constitution never clearly defines its boundaries.

The ambiguity in the use of the terms “speech” and “press” have made the amendment susceptible to controversy, as the vast scope of interpretation of these regulations have resulted in political backlash as to what should be deemed acceptable or not. “Speech” also applies to circumstances of the Internet and most forms of expression. Symbolic speech is also protected, as seen in West Virginia State Board of Education v. Barnette (1943) which determined that forcing students to recite the pledge of allegiance violated their first amendment rights, and Texas v. John (1989) that determined that flag burning was not prohibited in the Constitution, and could not be punished.

In most circumstances, decisions on free speech are made based on past court cases and the history of governmental regulation. Political and symbolic speech are regularly safeguarded under the Constitution, as is hate speech. However, over time, specific categories were classified as “low-value”, establishing them as unprotected by the First Amendment. These categories have been deemed non-essential to expression of ideas, but what is within these categories is still subject to debate. Schenck v. The United States (1919) was the first Supreme court case to establish a “low value” category under the conditions of speech that created “clear and present danger”, after Schenck persuaded people to not join the war. 

Following that, Chaplinsky v. New Hampshire (1942) deemed “fighting words,” face-to-face personal insults which are expected to instigate immediate fights, unprotected, although it is unclear whether Chaplinsky’s insults could actually incite a fight today. Defamation was instated as unprotected in 1964, after the New York Times was charged for containing minor inaccuracies in an ad about a public figure in New York Times v. Sullivan. Obscenity was initially established as unconstitutional under the First Amendment in Roth v. The United States (1957), claiming that Roth’s mailing of obscene content was “without redeeming social importance.”

Deciding these cases depends on whether one wants to uphold individual liberty or social order. Opinions on what should or is constituted as “low value” speech are still debated in the twenty-first century as the rise of new technology gives people the opportunity to say anything anonymously or with little consequence. 

 

Article IV: The Guarantee Clause

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The Guarantee Clause (Article IV) responds to and prevents oppressive types of governments like monarchies. The Guarantee Clause reflects the framers’ aim to ensure democratic principles in the United States and maintain a representative government in each state. The Guarantee Clause states that every state must have a republican form of government. This ensures that no state inflicts a monarchy, dictatorship, aristocracy, or stratocracy. The clause does not detail the conditions of the republican government (specifically regarding voting requirements), but it does guarantee federal protection to all states from foreign invasions and domestic violence. 

Some scholars interpret this clause as a finite check on the federal government’s interference with the states’ autonomy and, specifically, enabled each state to set appropriate requirements for state and local elections. Others interpret this provision to explain that the federal government can interfere with states’ voting requirements if the conditions disenfranchise part of their population. Scholars argue that post Reconstruction Era, specifically in places where African American’s made up at least 40% of the population, the Guarantee Clause was not upheld, disenfranchising African Americans.    

Texas v. White (1891) provides some context for this interpretation, as the ruling dictated that the newly freed African Americans would become part of the people; thus, they were included in the republic and entitled to vote. Subsequently, Chin utilizes Ratliff v. Beale, which explained how and why Mississippi disenfranchised African Americans.

They declared that the newly enfranchised race (who were greater in numbers) lacked the intelligence and governmental instinct to complete these public services. This acknowledges Mississippi’s “problem” because African Americans comprised most of the population. Furthermore, the elected government personnel would not reflect who the white people desired to hold power in the state. By claiming that Black people did not have sufficient intelligence, the Mississippi Constitutional Convention addressed this problem by creating literacy tests and poll taxes to prevent African Americans from voting.

With these two cases in mind, African Americans, who made up the majority of the population, did not vote; thus, allowing Mississippi and other former Confederate states to run on the minority vote. Finally, in United States v. Mississippi (1965), the United States acknowledges the systematic disenfranchisement of African Americans and, ergo, states running on the minority vote.

The Supreme Court case Oregon v. Mitchell (1970) ruled that Congress could change the age requirement only for federal elections, not state or local ones, as it was beyond Congress’s authority. This ruling supports interpretations regarding states’ autonomy as it prevented the federal government from impeding Oregon’s rights.

Although the 24th Amendment (1964) abolished literacy tests and polling taxes, Chin’s claim extrapolates to current forms of disenfranchisement like gerrymandering. It provokes readers to question if the federal government’s allowance of states’ gerrymandering violates the Guarantee Clause. The Guarantee Clause reflects Lockean ideas of popular sovereignty in that each state runs on a republican form of government where the people have control through elections. Similarly, the provision incorporates Rousseau’s idea of the general will, as the clause guarantees that states govern according to the majority vote.

The Treason Clause – Lauren Nam

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The Constitution’s framers’ intention by writing the treason clause was not to enforce strict loyalty to America onto the citizens but to prevent the abuse of treason prosecution. Recognizing the historic misuse of accusations of treason to stamp out political oppositions, in order to avoid forming a repressive government, this clause attempts to expressly define the act of treason and enforce restrictions for prosecution. 

Article III, Section 3, Clause 1 constitutes treason against the United States only as two types of actions. The first act considered treason is declaring war. The second act is assisting and abetting an enemy of the United States. The second half of this clause establishes safeguards against prosecution of treason. To be convicted of treason, this clause requires at least two witnesses to testify to have seen the same explicitly treasonous act or the defendant to confess in open court.

Although these two umbrellas of actions may seem vague, the Court has interpreted this clause very narrowly, in line with the Framers’ original intentions, and has only indicted one person of treason since 1954. By writing this clause, the Framers limited Congress’ ability to define treason and instated difficult parameters to proving the crime.

The Court’s interpretation of the definitions of treason over the years have remained specific, with the Court, in many cases, reaffirming the distinction between conspiring to and actually levying war. In the case of Ex parte Bollman & Swarthout (1807), which pertained to the covert plot of Aaron Burr to overthrow the New Orleans government and tried two of his associates, both defendants were dismissed of their charges.

The necessity of concrete action and not just sentiment or expression against the United States in order to convict a person of treason, is a protection of the first Amendment and the rights of citizens. Under the treason clause, the Court found that the actions of Bollman and Swarthout were insufficiently carried out to be considered treasonous acts, establishing that intent alone cannot incriminate someone. However, as illustrated in subsequent cases, intent is pivotal in meeting the strict parameters that the Treason Clause requires to meet.

Article III, Section 3, Clause 2 grants Congress the power to decide the punishment of treason, however, protects the right of the family members to inherit property of those convicted of treason after such person has died. The clause specifically mentions, “Corruption of Blood”, a reference to English Common Law. In order to diverge from English Common law, in which Corruption of Blood was the automatic punishment of attainder for treason, the Framers prevent the consequences of treason beyond the convict’s life. 

While the Framers were trying to prevent the abuse of the treason clause, the French were on the brink of revolution. The French Revolution, specifically the reign of terror, unfolded in events that the Constitution was actively fighting against. The paranoia and fear of counter revolution which characterized the period led to mass executions and public unrest. The bloody events of the reign of terror is a testament to the necessity of the treason clause.

Jared Davis – The Ninth and Tenth Amendments

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The Ninth Amendment, written and framed by James Madison, is one of the most debated and ambiguous amendments to the Constitution. It states that certain rights in the Constitution do not mean that other rights do not exist. The main point of conflict revolves around identifying these additional rights. One shared interpretation is that these rights refer to the natural rights inherent from birth, as the Constitution only specifies some rights in great detail. This interpretation aligns with the context in which the amendment was crafted. During the debates between antifederalists and federalists on including a bill of rights, James Madison argued that listing specific rights would leave the government to argue that only the enumerated rights are protected. Therefore, the Ninth Amendment seeks to balance and protect both enumerated and retained rights, subject to interpretation. While the amendment has not been frequently used in cases, it has found use in both Roe v. Wade and Griswold v. Connecticut (1965). In these cases, the court used the ninth to recognize privacy rights not explicitly mentioned in the Constitution but considered pre-existing rights deserving protection. These examples help reinforce the amendment’s significance in countering the criticism of vague language, although the lack of explicit mention of these rights leaves room for further interpretation. The Ninth Amendment remains the most complex amendment within the Constitution, prompting us to question what new rights today may exist that should have been included in the original document.

 

The Tenth Amendment of the United States Constitution is historically and interpretively significant. It addresses concerns over individual rights, state sovereignty, and the balance of power between the federal and state governments. Its inclusion aimed to prevent an excessive concentration of power in the federal government and respond to the demands of the states and their citizens. Commonly understood, the Tenth Amendment guarantees states’ rights and authority, ensuring a balanced power distribution between the federal government and the states. However, interpretations have diverged over time. Some argue it grants states broad powers to resist federal encroachment, while others believe it has limitations and does not grant absolute state sovereignty. The Supreme Court case of New York v. United States (1992) illustrates the debate over the Tenth Amendment. The ruling favored New York, reaffirming state sovereignty and reviving the amendment’s significance. It emphasized the amendment’s role in maintaining a balanced power distribution and protecting states from excessive federal intrusion. The Tenth Amendment connects to federalism, balancing individual rights, government authority, and shared power. Its preservation of state sovereignty and protection of rights make it significant. The interpretation that grants states broad powers is more persuasive. It aligns with federalism and the amendment’s intent, preserving state autonomy and authority. Given its historical context and ongoing relevance, I would not advocate amending the Tenth Amendment. It safeguards state sovereignty and individual rights, and altering it could disrupt the balance of power between the federal government and the states, undermining the principles of federalism.

The Second Amendment

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The second amendment to the Constitution grants citizens of the United States of America the right to bear arms. The reason behind the passing of the second amendment was to prevent the need for the United States to maintain a standing army. Many U.S citizens feared that if there were a standing army, the government would use soldiers to oppress citizens. This fear was generated because of the British troops occupying several parts of America at the time. The Quartering Act obliges U.S citizens to allow wandering troops to remain on their properties, causing unnecessary complications in the lives of many U.S colonists. These troops were viewed as a burden and citizens feared that members of a standing U.S army would abuse their liberties just as so. In order to prevent soldiers from causing harm to U.S citizens, the Framers decided that the government should only be allowed to raise full-time, paid army troops when needed to fight foreign opposition. For other needs such as protection from invasions, the government would rely on a citizen led militia. This militia would be made up of men supplying their own weapons in order to protect the nation. 

The original purpose of the second amendment was to allow citizens to bear their own weapons when serving in the military forces in the United States. However, the most common interpretation is that the amendment grants all citizens the right to keep and bear arms. This amendment can be easily misunderstood because of lack of clarity. Legal scholars often argue that, because of the lack of clarity, the amendment is able to be interpreted in multiple ways. If I were to explain the second amendment to someone in conversation, I would explain that it grants all U.S citizens the right to bear arms. While I do not believe that this was the original purpose of the amendment, I do believe that this is how it reads. If I were to offer a slight change in the second amendment, I would suggest more specific wording in order to directly relay the purpose. However, because of recent events and increase in gun violence, I do not believe that average citizens should be offered the right to bear arms at all, and I would limit the amendment to those serving in governmental organizations such as the military or the police force.   

 

Zohar Lindemann- The Tenth Amendment

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Once the American colonists won the revolutionary war and gained their independence, the nation struggled to find a balance between the practical demands of running a large country and the ideals of freedom and individualism that they had so recently fought for. Many of the Constitution’s framers were afraid of creating yet another absolutist rule, feeling that offering too much power to a central government would leave the wants and needs of the common people forgotten. Other framers felt that the lack of a strong central government would result in political chaos. Many elements of the Constitution, which is largely considered a federalist document, are written with precaution to the fear that a central government would have the ability to completely overrule other political powers. For this reason, the framers deemed unnecessary the inclusion of a Bill of Rights, although numerous state constitutions had them at the time. To those drafting the Constitution, simply entertaining the idea that the federal government would have the ability to overrule the natural rights of the people was considered dangerous. The 10th Amendment ensures that there are thorough limitations on the federal government’s power and that the rights of the State and of the individual are properly protected, with federal power extending only as far as the Constitution dictates it is able to. 

After the 1933 installment of the New Deal, a federal effort to stabilize the economy, the 10th Amendment became somewhat obsolete. However, in 1992, it regained its relevance as a consequence of the “New Federalism” movement. Rober Schapiro asserts that for the benefit of the U.S. “politically, socially, and morally,” the 10th amendment should have remained neglected. In various instances, but most prominently throughout the Civil Rights Movement, the amendment has given states the ability to enforce racial inequality laws that contradict directly the rights outlined in other sections of the Constitution. Schapiro argues that in today’s world, federal and state powers are so intertwined that the amendment’s only purpose is to provide legal loopholes for states whose intentions dispute the core values outlined in the Constitution, providing a necessary “backstop” for everything not mentioned. 

The debate around the interpretation of this text is illustrated in the Garcia v. San Antonio Metropolitan Transit Authority (SAMTA) case. Within the case, SAMTA claims that being an institution controlled by a state government, they are exempt from federal labor controls such as minimum wage and overtime requirements. Ultimately, the court ruled in favor of Garica, arguing that the “traditional” function of a state government was subjective and that the structure of the federal system itself provided sovereign protection enough. Under the commerce clause, SAMTA was deemed subject to congressional legislation. This case serves as a demonstration of the ongoing debate over the role of a central government within the U.S.

Both the French and American revolutions can be considered as a test of the function that Enlightenment values serve within practical governments. With the French government often considered a failure, and the clear difficulties that the 10th amendment illustrates between federal and state power, the 10th amendment raises questions about the ability of radical Enlightenment ideas, such as Montesquieu’s strong belief in the separation of powers, to function smoothly.

The 3rd and 4th Amendments of the Bill of Rights

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The motivation for the Third Amendment being included in the Bill of Rights came from the Quartering Act. The Quartering Act was a law that allowed British soldiers to be sheltered in the private homes of colonists.(1) The amendment makes it unconstitutional for the government to house soldiers in the private residences of citizens of the United States without the owners’ express permission in times of peace, but during war the process of quartering soldiers must be prescribed for by law. Some scholars interpret the Third Amendment as applying to increasingly militarized police forces in addition to the military. However, this understanding of the amendment was defeated in the 2015 case Mitchell v. City of Henderson where the plaintiffs were forced out of their home by police in preparation for a nearby operation. Mitchell sued the city on the grounds that his Third Amendment rights had been violated, but a Federal Court decided that the police are not soldiers so the amendment did not apply.(2) The Third Amendment, like checks and balances on power in other parts of the constitution, is a roadblock to government overreach. The policing interpretation of the Third amendment is persuasive to me because it controls the interactions between citizens and the police. In my opinion the amendment should be altered to protect against quartering from both military and law enforcement personnel. 

General warrants in Britain and writs of association in the colonies were some of the major pressures that led to the inclusion of the Fourth Amendment in the Bill of Rights. General warrants and writs of association allowed law enforcement to search a person’s property without any suspicion of a crime. The Fourth Amendment protects people from unreasonable searches and seizures. It requires that a warrant only be issued with a reasonable level of suspicion for a crime, and with specific objectives. What constitutes probable cause or a search in the Fourth Amendment has been debated by many legal scholars. A Supreme Court decision in 1985 over the case Dow Chemical Company vs. The United States partially answered the question of what constitutes a search. Dow Chemicals sued the US on the basis that its Fourth amendment rights had been violated after the EPA observed their factory grounds without a warrant. The Court decided in the favor of the United States, because the factory’s grounds were an open area and the Fourth amendment only deals with “the invasion of areas where intimate activities occur.” The Fourth amendment is another amendment like the Third that deals with the specter of an authoritarian government overpowering the people. I agree with the interpretation that mass government surveillance is unconstitutional because it searches the personal data of people unsuspected of a crime. I also agree with the interpretation that security checks are constitutional, because people are making a decision to agree to the security check when they enter the area. I would not advocate any changes to the Fourth amendment because it protects the people from unreasonable law enforcement activity.

 

1 – American Battlefield Trust, “The Quartering Act,” American Battlefield Trust, accessed June 1, 2023, https://www.battlefields.org/learn/articles/quartering-act#:~:text=The%20last%20act%20passed%20was,quarter%20or%20house%20British%20soldiers.

2 – Leonard Niehoff, “What Is the Third Amendment, and Will the Supreme Court Ever Examine It Again?,” interview by Andrew Cohen, Brennan Center for Justice, last modified August 3, 2022, https://www.brennancenter.org/our-work/analysis-opinion/what-third-amendment-and-will-supreme-court-ever-examine-it-again#:~:text=Into%20this%20category%20goes%20the,up%20to%20the%20Revolutionary%20War.

 

Peytin Metz – The Impeachment Clause

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The United States Constitution was highly informed by the experiences they had under British rule, both negative and positive. The Framers of the Constitution drew inspiration from the British Impeachment tradition, which was a system put in place in order to hold high-ranking officials accountable for any serious offenses that had been committed. They wanted to ensure that the U.S. President would not be able to abuse their power, as they observed in the British monarchy. To prevent an unbalanced concentration of power in the Executive branch, they created an intricate system of checks and balances, including the impeachment process. Historically, there have been three Presidential impeachments. Andrew Johnson in 1968, Bill Clinton in 1998, and Donald J. Trump in 2019 and 2021. The process of Impeachment begins with an impeachment inquiry conducted by the House of Representatives. It is then put to trial in the Senate, where a vote is conducted to determine if the individual is to be convicted or acquitted.

The Impeachment Clause is located in Article II of the Constitution, which lists the enumerated powers of the Executive branch. This clause states, that in a trial of impeachment, the President may risk being removed from office if convicted of “treason, bribery, or other high crimes and misdemeanors.” This clause served as another check against the President, giving Congress and the House of Representatives the power to remove the President and Vice President from office if necessary. The interpretation of the phrase “high crimes and misdemeanors” is widely debated, because it only appears in the context of the Impeachment Clause. It means that the President or Vice President can only be impeached on the basis of violating the rules of public office, and impeachment cannot be inflicted as a punishment for basic incompetency. This makes the distinction between lack of ability and impeachment-worthy actions challenging to find. 

Legal scholars often debate the vagueness of this phrase, wanting it to either be read more narrowly or broadly. Scholars argue that if impeachable offenses were more narrowly read, it would leave the government unprepared for any unanticipated misdemeanors. If the offenses were read too broadly, the clause would risk forming legislative partisanship that would obstruct the independence of other government officials. Many people refer to the words of Chief Justice John Marshall to defend the ambiguity of the Impeachment clause. He stated that the “constitution [is] intended to endure for ages to come and, consequently, to be adapted to the various crises of human affairs.” He believed that the Constitution cannot and should not be expected to explicitly list the proper grounds for impeachment. It should be malleable and open to interpretation, to ensure that an unfit member of the Executive Branch can be punished accordingly. Many fear that narrowly defining the grounds of impeachment would allow the person who risks such punishment to avoid it on a specific technicality of the phrase.

Isabella Graham Torres — The Sixth Amendment

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The common interpretation of the Sixth Amendment is that it purports that everyone has the right to a fair trial. This trial must be speedy, public, and contain a jury consisting of unbiased people from the state where the alleged crime was committed, and witnesses for and against the defendant. Lastly, the amendment also states that the accused has the right to a lawyer for said trial. Before the Sixth Amendment, our court system was very disorganized.

Neither side of a trial had a lawyer, trials were glorified, minute-to-hour-long shouting matches, and the jury consisted of 12 men who knew the defendant and/or the victim and were therefore very biased. The incentive to include the Sixth Amendment in our constitution was to help organize the legal system and make criminal trials fairer for defendants. Originally, the main contention with the Sixth Amendment was whether or not the amendment’s right to counsel in criminal cases applies to felony defendants in state cases as well as capital ones.

The main Supreme Court ruling dealing with the importance of the Sixth Amendment is Gideon v. Wainwright (1963). In this case, Gideon was accused of Breaking and Entering. When he requested a lawyer, he was denied one and sent to jail. He then filed a habeas corpus petition claiming that, under the Sixth Amendment, he was deserving of a lawyer and shouldn’t have gone to jail. At the end of the appeals process, the Supreme Court ruled in his favor, stating that almost every aspect of the Sixth Amendment is valid to federal and state prosecutions, meaning that Gideon in fact did deserve a lawyer. I agree with the interpretation supported by the Supreme Court: the Sixth Amendment is meant to be taken at face value and applied to all aspects of our legal system.

In order to truly present ourselves as a fair country with an unbiased legal system, we need to support all of our citizens. If I could change one aspect of the Sixth Amendment, I would advocate for amending the part of the amendment added by the Supreme Court after Gideon x Wainwright, in which it is required that public defenders give adequate representation to their clients. I believe that instead of controlling the effectiveness of public defenders, which is already a near impossible task, the legislation should instead provide better funding for public defenders. More than 80% of defendants charged with felonies are indigent, meaning that more than 80% of defendants in felony cases rely on public defenders. Despite public defenders representing a massive portion of defendants in our country, they are severely underfunded. In 2009 in Florida, the annual caseload of felonies per public defender 2,225 misdemeanors and over 500 felonies.

This disregard for public defender’s time has disadvantaged both them and their clients, seeing as they no longer have the time to fully investigate each case. Also, due to how many cases each public defender has, they get severely backed up, meaning that approximately 500,000 defendants waiting for their trial wait in jail for at least a year before it happens. These conditions are horrific and not sustainable. If the government increases funding for public defenders and places more equitable limits on how many cases public defenders can have, the way the US conducts criminal cases will improve exponentially for defendants and lawyers alike.                                                                                                                                                                                                                                                                                                                                  

Bibliography (for written portion): 

Guardian. “Poor People Rely on Public Defenders Who Are Too Overworked to Defend Them.” The Guardian. Last modified June 17, 2015. Accessed June 2, 2023. https://www.theguardian.com/commentisfree/2015/jun/17/poor-rely-public-defenders-too-overworked.

Bibliography (for video): 

Guardian. “Poor People Rely on Public Defenders Who Are Too Overworked to Defend Them.” The Guardian. Last modified June 17, 2015. Accessed June 2, 2023. https://www.theguardian.com/commentisfree/2015/jun/17/poor-rely-public-defenders-too-overworked.