In (Attempted) Defense of Banning Iranian-American Immigration Judges

by Jason Dzubow

If you follow the news from the Executive Office for Immigration Review or EOIR–the office that oversees the Immigration Courts–you are aware of the recent lawsuit filed by Judge Afsaneh Ashley Tabaddor. Judge Tabaddor is an IJ in Los Angeles. She was appointed in 2005 and has been serving ever since. Judge Tabaddor also happens to be Iranian-American.

Judge Tabaddor has been mistreated by the executive branch. We hope she doesn't leave, and we are root-ing for her.
Judge Tabaddor has been mistreated by the executive Branch. We hope she doesn’t Leave. We are Root-ing for her.

According to Judge Tabaddor’s complaint against EOIR, trouble began for her in the summer of 2012 when the White House–considered by some a radical Muslim organization–invited her to attend a “Round Table with Iranian-American Community Leaders.” After some hemming and hawing over the nature of the event, EOIR granted the Judge leave to attend. But afterward, EOIR banned Judge Tabaddor from adjudicating cases involving nationals from Iran. So in other words, an Iranian American Judge who is active in her community is not permitted to hear cases where the alien is from Iran.

On it’s face, EOIR’s decision seems completely ridiculous and indefensible. It would be like forcing members of the National Association of Women Judges to recuse themselves in cases involving women, or stopping members of a Jewish judges association from hearing cases involving Jews, etc., etc. But can EOIR’s decision somehow be justified? Does it make sense to ban an Iranian-American who is involved in her community from hearing cases form Iran? Permit me to try to make that argument (as an asylum lawyer, tilting at windmills is my specialty).

Perhaps EOIR is concerned about the Judge because Iran is considered our enemy (or–on a good day–our rival). Allowing Judge Tabaddor to hear Iranian cases would be like allowing an American originally from the Eastern Block to serve in the White House during the Cold War (Zbigniew Brzezinski) or like allowing a German-American to lead the fight against Germany in WWI (John J. “Black Jack” Pershing) or against the Nazis in WWII (Major General Carl Spaatz). Hmm, maybe that argument doesn’t work so well after all. Let me put it another way. If you are at war with Japan, you’d better imprison all Japanese-Americans. Wait. Maybe that is not such a good argument either. Let’s try this a little differently. 

It could be that EOIR is worried about the appearance of bias. Appearance is very important for judges. If an IJ is perceived as biased, it reduces our confidence in her decisions. It would be as if five Republican-appointed judges voted to end an election recount, giving the victory to the Republican presidential candidate. Oy. Let me give you a better example. Maybe it would be like allowing a Russian figure skating judge who is married to the director of the Russian Figure Skating Association to serve as a judge at the Sochi Olympics. And then the Russian skater miraculously wins. Harrumph. I guess that one doesn’t work too well either. Maybe we should look at the problem another way.

What if we assume that Judge Tabaddor is, in fact, biased in favor (or against) Iranian respondents. If that is the case, why should the recusal order be limited to cases from Iran? Iran and Iraq fought a war recently, so probably the IJ is biased against Iraq and should not hear cases from that country either. Iran also fought a war with Greece back in the day, and if I were Iranian, I’d still be bitter about the Battle of Thermopylae. So the Judge should also be banned from hearing cases involving Greeks, or at least Spartans. Iran has endured invasions by Mongols and Arabs, so Judge Tabaddor obviously should not hear Mongolian or Arab cases, and since Mongolians were mixed in pretty good with the Chinese, we’d better also ban her from Chinese cases–just to be safe. And of course, Iran doesn’t much like Christians, Baha’is or Jews, so the Judge should probably be kept away from cases involving those faiths. In addition, Iran has disputes with Russia, Azerbaijan, Turkmenistan, and Saudi Arabia. The Judge would have to be banned from hearing cases involving those nationals as well. And don’t even get me started about cases involving Israelis. So basically, if Judge Tabaddor is biased, as EOIR seems to assume, the only cases she should decide involve people from Guyana or New Zealand. And maybe São Tomé, but I’m not even sure that’s a country.

In the end, I really don’t know whether Judge Tabaddor’s lawsuit will succeed. IJs exist to implement the authority of the Attorney General. If the AG chooses to prevent certain IJs from reviewing cases from certain countries, that may be within his discretion. While the law may not be clear (at least to me), I have no doubt about which side is right. If an IJ behaves in an inappropriately biased manner, she should be removed from her job. But where–as here–there seems to be no question as to the Judge’s integrity, her docket should not be restricted in this insulting and discriminatory way.

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Immigration Judge Apocalypse 2014

by Jason Dzubow

Nearly half of the nation’s Immigration Judges are eligible to retire this year.

Last week, I attended the retirement luncheon for one of them: Judge Wayne Iskra. For the past 10 years, I practiced before Judge Iskra at the Arlington, Virginia Immigration Court. I also clerked for him back in 1998-99. He is a wonderful person who was a great inspiration to me and many others. He was also a great judge–he was devoted to ensuring that justice was done, and he had little patience for attorneys (private attorneys or DHS attorneys) who failed to fulfill their duties.

Immigration Judges today...
Immigration Judges today…

The MC at the lunch, Judge Thomas Snow, noted that before his retirement, the Chief Judge repeatedly described Judge Iskra as “irreplaceable.” Finally, Judge Snow realized that when the Chief said that Judge Iskra was irreplaceable, it meant that he would not be replaced.

So the Arlington Immigration Court, which is already very busy and where cases are currently being scheduled into late 2016, will now go from five judges to four. The same thing happened in Baltimore last summer, when another excellent and long-serving IJ, Judge John Gossart, retired.

Although I have not heard news of any mass retirement, the Associated Press reports that almost 50% of the nation’s Immigration Judges are eligible for retirement this year. While I suppose this is good news for people selling condos in Ft. Lauderdale, it is bad news for the Immigration Court system.

...and in 2015.
…and in 2015.

And yes, as the immigration restrictionists love to remind us, certain immigrants prefer delay, so they can buy more time in the United States. But at least in my experience, this is a minority. Granted, my cases may not be typical. Most of my clients have good cases, and so the sooner they get to the merits hearing, the better. Also, many of my asylum clients have family members who they hope to bring to the U.S. if their cases are granted. The longer the delay, the longer they are separated from (and worried about) their family members. So for me, the increased delays are definitely a bad thing.

Also, I am quite certain that the remaining IJs won’t be happy about their depleted ranks. Immigration Judges are already overworked and overburdened. The title of a 2010 Mother Jones article sums it up well–Judges on the Verge of a Nervous Breakdown. From the article:

Caught in the middle [of the Obama Administration’s efforts to increase deportations] are the judges, for whom mind-numbing bureaucracy collides with thorny moral issues. Most of the time, they work without even basic staff like bailiffs and stenographers. Increased immigration enforcement means that their workload is the highest it has ever been—three to four times larger than caseloads in other federal courts.

And of course, mistakes can have dire consequences. As one IJ noted, “It makes me feel ill to grant asylum to someone who I believe is probably lying, but it also makes me sick to think that I have denied protection to someone who really needs it.”

The obvious solution is to hire more (lots more) judges and court staff. But given EOIR’s budget (or lack thereof), this seems unlikely. So here are a few other thoughts:

– Create an easy, secure on-line system to allow EOIR-registered attorneys to do their Master Calendar Hearings by email. Attorneys could enter their appearances, admit or deny allegations, plead to charges, and set dates for Merits Hearings. For complicated cases (and pro se cases), IJs would still require Master Calendar Hearings, but an on-line system would be a great time saver for everyone.

– Hire more DHS attorneys and staff, and encourage them to communicate with attorneys for immigrants. Many issues can be resolved before trial, which saves time. However, because DHS is also short staffed, they do not have the resources to review cases prior to trial and speak with opposing counsel. If they did, it would shorten hearings and make life easier for the IJs.

– Stop deporting so many people. It seems that President Obama is intent on setting deportation records year after year. As a result, hundreds of thousands of people are being placed into removal proceedings. If ICE were more selective about who it tried to deport, DHS attorneys and IJs could focus more on those cases. We don’t ticket everyone who drives over the speed limit. We don’t prosecute everyone who is caught with a joint. We don’t arrest everyone who illegally downloads music. Why? Because we don’t have the resources to do those things, and to do so would require intolerable levels of intrusion into our lives. In the same way, it seems to me, we could relax a bit concerning deportations. Resources–including judges’ time–is limited. We should use that limited resource more efficiently.

– Don’t allow any more IJs to retire. OK, maybe it is not technically legal to force IJs to keep working, but an immigration lawyer can dare to dream. Besides, I want Judges Iskra and Gossart back.

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The Seven Habits of Highly Annoying Immigration Judges

by Jason Dzubow

Well, I’ve dissed immigration lawyers, asylum-seeker clients, and the BIA, so I might as well offer my criticism of Immigration Judges. Of course, this comes with the usual disclaimer: None of the IJs that I appear before have any of these annoying habits. But I have heard speak of such problems from other lawyers (terrible, terrible people), so please blame them for this list. If you need names and addresses, email me offline. With the shifting-of-the-blame thing out of the way, here is the list:

7 – Changing Court Dates: I suspect that most immigration attorneys have a schedule best explained by Chaos Theory – Make a small change to the delicate balance in our calendars and things fall apart. Obviously, IJs sometimes need to postpone (or advance) hearings. The problem comes when hearing dates are changed without checking with the attorney first. This potentially creates scheduling conflicts for the lawyer, who must then file a motion to change the court date. This can be stressful and time consuming (and it might add to the client’s expenses). The better approach is for the clerk to contact the attorney prior to changing the court date. In my experience, when this happens (rarely), it is done by phone. Perhaps it would be easier for the clerk to contact the attorney using a new technology called email. This would be more efficient for all involved, as attorneys could avoid motions to re-schedule and IJs would not have to deal with such motions. 

Mocking litigants is generally considered an annoying habit (even if they deserve it).
Mocking litigants is generally considered an annoying habit (even if they deserve it).

6 – Double Booking: This issue is less of a problem these days, at least in my home courts. But there was a time when my Individual Hearings were commonly double booked. This meant that we prepared for the hearing, went to court, waited (sometimes for hours), and were then told to go home. Given client stress and attorney time wasted, I am glad that double bookings have become more rare.

5 – Denying Cases: OK, I really shouldn’t complain about this, as it is part of an IJ’s job. But it is kind of annoying.

4 – Failing to Rule on Motions: I understand that IJs are busy people. But if IJs could rule on motions in a timely manner, it might increase overall efficiency. Pleadings can be done by motion, thus reducing crowds at Master Calendar Hearings. Issues for trial can be narrowed, making trials less time consuming. Some cases can be resolved completely by motion. You get the idea. The problem, however, is that since IJs cannot be relied upon to rule on motions in advance of the hearing, it is not really worth the attorney’s time to write the motion (and then spend more time repeatedly calling the court to ask whether the motion has been granted). If IJs consistently responded to motions in a more timely way, lawyers would file more motions, and cases might be resolved in a more efficient manner.

3 – Stopping the Asylum Clock: As I have written previously, the rules governing the Asylum Clock are–to put it diplomatically–ridiculous. Different IJs interpret the rules differently. Some IJs interpret the rules restrictively and some even appear to make an effort to prevent the respondent from obtaining a work permit. Given the long waiting periods for these cases, aliens suffer great hardship when they do not receive a work permit. Unless the alien is engaged in egregious and purposeful delay, IJs should err on the side of keeping the Clock moving and of allowing asylum seekers to obtain their work permits.

2 – “Egalitarian” Master Calendar Hearings: Most IJs give priority to aliens who appear with an attorney at the Master Calendar Hearing. Of course, I am an attorney, and a somewhat impatient one at that, and so I do not like waiting around during a MCH. But there are more legitimate reasons for prioritizing represented respondents. First, respondents who are represented usually take less time during the MCH than unrepresented respondents. So more people will get done more quickly if represented aliens go first. Second, while most immigration lawyers do not charge by the hour, some do. Therefore, it is more expensive for some respondents to have their attorneys wait around for their turn at the MCH. Third, even those lawyers (like me) who do not charge by the hour might charge an extra fee for MCHs before IJs who are known to be slow (I have not done this, but I have considered it). If lawyers are more expensive, it is more difficult for aliens to retain us. Thus, when IJs do not have efficient MCHs, it potentially creates an access to justice issue for aliens.

1 – Showing the Proper Level of Respect: Notice, I did not say, “Showing Respect.” Sometimes IJs are not respectful enough to immigration lawyers; other times, they are too respectful to us lawyers. While I certainly believe that IJs should err on the side of being respectful to everyone in the courtroom, they do sometimes allow lawyers to get away with a bit too much. Oft times, alien respondents are not aware that their lawyers are unprepared or incompetent. When such behavior is egregious, IJs should point out the problem to the alien (and potentially to the bar association). Further, unprepared attorneys waste time at Master Calendar Hearings and cause delay for everyone else. There is no need for IJs to respect such behavior. On the other hand, some IJs run their courtrooms by bullying and demeaning attorneys (DHS attorneys and respondents’ attorneys). Obviously, this is inappropriate and, for the most part, ineffective. Good attorneys are sometimes unprepared, and sometimes make mistakes. It is harder for lawyers to do our best work when we face disrespectful comments at the slightest misstep. That said, while disrespectful IJ behavior can be a problem, it seems to me that such behavior is (fortunately) pretty rare.

Well, there you have it. While some IJs have bad habits (or so those nasty lawyers tell me), most IJs that I have encountered are hardworking, diligent, and fair. As we (hopefully) prepare for a major immigration reform, it is important to appreciate the positives about our immigration system and the legal protections we offer non-citizens. It is also important to appreciate the Judges and others who make that system work.

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There Is No Such Thing as a Tough Immigration Judge

by Jason Dzubow

A recent article in the Sun Sentinel (Broward County, Florida) got me thinking about what it means to be a “tough” Immigration Judge.

Judge Ford, pictured here at his Senior Prom.
Judge Ford, pictured here at his Senior Prom.

The article discusses Judge Rex. J. Ford, who will be celebrating (if that is the right word) 20 years on the bench this April. According to the Sun Sentinel, “In 96 percent of the 2,057 proceedings Ford completed in fiscal 2011, he ordered the person removed from the country.” Judge Ford told the paper: “I follow the book and I don’t get reversed.” The article also notes that Judge Ford is a registered Republican who “garnered attention in 2008 with the release of a U.S. Justice Department report that named him as playing a role in recommending the appointment of immigration judges based on their political leanings.” Judge Ford denied that he considered party affiliation in advocating for specific job candidates.

First, I suppose the Sun Sentinel mentions that Judge Ford is a Republican because Republicans are considered “tougher” on immigration than Democrats (this, despite the fact that President Obama has deported record numbers of illegal immigrants during each year of his Administration). I can’t help but think that this is an unfortunate stereotype–at least to some extent. Maybe I will write a post about that subject in the future, but for now, I will just note that Judge Ford was appointed during the Clinton Administration. In this post, I am more interested in how we decide which IJs are “tough.”

The most objective measure of an IJ’s “toughness” is his asylum denial rate, which can be found at TRAC Immigration, a website affiliated with Syracuse University. The toughest Judges are the ones with the highest denial rates. By this measure, Judge Ford is pretty tough. Of the 256 IJs examined by TRAC, only three deported people at a higher rate than Judge Ford. Does this mean that he is tough? Or does it mean that he doesn’t know what he is doing? Or something else?

Whenever a judge’s denial rate deviates significantly from the mean, it raises a red flag. In Judge Ford’s case, his denial rate of 93.3% is much higher than the national average of 53.2%. But I think it is more important to compare his denial rate with the local average. Why? Because local factors significantly impact denial rates. In Judge Ford’s case, the aliens he sees are all detained. Denial rates for detained asylum seekers are much higher than rates for non-detained aliens. In part because such aliens are less likely to be represented by attorneys and have a more difficult time gathering evidence, but mostly (I think) because such aliens often have no valid defense to removal, and so they tend to file weak (or frivolous) asylum claims as a last-ditch attempt to remain in the United States. Also, many detained aliens are ineligible for asylum due to criminal convictions or the one-year asylum bar. Comparing Judge Ford to his local colleagues, his denial rate does not seem particularly unusual. The denial rate for other IJs at Miami’s Krome Detention Facility (where Judge Ford is listed on the TRAC website) is 89.8%. So while Judge Ford is probably not an “easy” judge, if he were relocated to a different court, with a non-detained docket, I bet that he would grant a lot more cases.

Speaking more generally, where an IJ with a non-detained docket denies asylum cases at a significantly higher level than his local colleagues, I don’t see that as a sign of “toughness.” I see it as a failure to properly apply the law. The INA, the CFR, and various precedent decision from the BIA and the federal courts provide guidance to IJs about how to make decisions. They set forth how to determine if an alien is credible (consistent testimony and submission of reasonably available evidence). They define “persecution,” nexus, and the different protected grounds. In reaching a decision, an IJ is obliged to follow these laws; he is not permitted to “go with his gut.” In my experience, most IJs do their best to follow the law. Therefore, if one IJ stands out in terms of her denial rate (whether it is too high or too low), something is wrong.

In deciding an asylum case, it is not the IJ’s job to be tough or easy; it is her job to analyze the facts in the context of the law. Where an IJ’s denial rate differs significantly from the local average, it may be a sign that the IJ is not following the law. In such a case, the IJ’s supervisors should determine what is happening and whether additional training or some other corrective action is necessary.

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The Problem With Immigration Lawyers and How to Fix It, Part 1: Immigration Judges

by Jason Dzubow

The poor quality of the immigration bar is a much discussed topic in certain circles (I wrote about it here).  A recent study in the Cardozo Law Review that was featured last month in the New York Times provides an opportunity to discuss the situation, and give my two cents about how to improve representation for immigrants.  According to the Times, “The study was conducted by a group of lawyers and researchers under the auspices of Robert A. Katzmann, a federal appellate judge in New York City.”  “Judge Katzmann blames predatory lawyers who are not familiar with immigration law for much of the poor representation.”

Judges to Immigration Lawyers: You stink!

The Times reports that Immigration Judges in the New York City area were surveyed, and they were less than pleased with the quality of the attorneys practicing in their courts.  The judges said that 33% of immigrants have “inadequate counsel” and 14% have “grossly inadequate” counsel.  The judges “gave private lawyers the lowest grades, while generally awarding higher marks to pro bono counsel and those from nonprofit organizations and law school clinics.”

I believe that Immigration Judges bear some blame for the lawyers’ poor performance.  Aside from the fact that I’m a vindictive so-and-so who doesn’t like judges dissing attorneys, why would I blame judges for attorney behavior?  Let me explain.

Immigration Judges are bound by certain ethical rules, which are set forth in the Ethics and Professionalism Guide.  The Guide states that Immigration Judges–like all DOJ attorneys–have a duty to report allegations of misconduct by other Justice Department attorneys and “a duty to report allegations of misconduct by non-Department attorneys.” See United States Attorneys’ Manual (“USAM”), Chapters 1-4.100 & 1-4.150 (“Allegations of misconduct by non-DOJ attorneys or judges shall be reported to OPR [Office of Professional Responsibility] for a determination of whether to report the allegation to appropriate disciplinary officials.” (emphasis added)).  Thus, it is mandatory for IJs to report misconduct.

According to IJs in New York, 14% of attorneys are “grossly inadequate,” meaning:

They are often poorly prepared or make incoherent arguments in court.  Some fail to present key evidence or witnesses.  Others simply do not show up.

Under the rules of the Guide and the USAM, it seems pretty clear that Immigration Judges are duty-bound to report attorneys who engage in at least some of these bad practices.  To the extent that IJs do not report such behavior, they are encouraging and enabling incompetent and/or dishonest attorneys to continue preying upon naive aliens.

Based on my experience working at an Immigration Court and as a practitioner, everyone–including the IJs–knows who the bad actors are.  I am not talking about attorneys of good will who periodically screw up.  We all make mistakes.  I am talking about attorneys who routinely fail to provide minimally competent work and who regularly destroy their clients’ chances to remain in the U.S.  Given many foreigners’ inexperience with our system and their fear of the authorities, it is critical that Immigration Judges report incompetent and dishonest lawyers to the appropriate disciplinary committees.  When they fail to fulfill this duty, they allow the harmful conduct to continue.

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Are Well-Fed Judges More Likely to Grant Asylum?

by Jason Dzubow

A recent study of parole judges in Israel demonstrates that the judges tend to issue more favorable decisions on a full stomach.  The study, by Shai Danzuger of Ben Gurion University, examines 1,112 parole board hearings in Israeli prisons.  In the chart below, the vertical axis represents the proportion of cases where the judges granted parole.  The horizontal axis shows the order that cases were heard throughout the day.  The dotted lines represent the points where the judges went away for a morning snack and a lunch break.

The study controls for various factors, such as gender, ethnicity, and type of crime, and its conclusion–that the judges’ decisions are strongly influenced by whether they’ve eaten–seems pretty convincing.  My question is: Does this study have any applicability to Immigration Judges or Asylum Officers?

One reason to think that the study is not applicable to IJ’s and Asylum Officers is that the Israeli judges ruled on 14 to 35 parole cases per day.  While IJs in Master Calendar Hearings often rule on more than 35 cases per day, such cases are rarely final decision where the alien is contesting removal.  Most final decisions occur during Individual Hearings, and IJs generally do not adjudicate more than four or five individual hearings per day (especially when those hearings involve asylum applications, which tend to take more time than other types of immigration cases).  Asylum Officers also have a much lower daily caseload than the Israeli judges.  Thus, the challenges faced by the Israeli parole judges are quite different from those faced by Asylum Officers and IJs in the United States.

On the other hand, the study does point to the problem of fatigue as a factor in decision-making, and it makes sense that fatigue would affect IJs and Asylum Officers, all of whom are overworked and under pressure.  How–or whether–that fatigue affects asylum cases is not known.      

Studies of asylum cases have shown that the results can be arbitrary (see, for example, this posting about the article Refugee Roulette) and that “unobservable factors,” such as gender and education, may affect asylum decisions.  However, as far as I know, there has not been a study of how fatigue affects decision-making.  There is, however, significant evidence that IJs (and presumably Asylum Officers) are stressed out by the heavy case load and the difficult types of cases. 

What, then, is the solution?  I suppose the easy answer is to hire more IJs and more Asylum Officers.  EOIR has been expanding the number of judges, but given our current budgetary woes and the vast number of cases, it is doubtful that a handful of new IJs will make a great difference in the overall stress level.  Another solution (which I don’t love) is to simplify the system and eliminate some layers of review (for example, combine the Immigration Courts and the Asylum Offices into one body, which would handle all cases at the trial level).  A final thought is to encourage the BIA to issue more decisions (I have written about this before in the cleverly titled (if I do say so myself) blog post–The Unbearable Lightness of BIA-ing).  This would create more certainty and regularity in the system.  It certainly won’t solve the problem, but it does seem like a reasonably easy way to improve efficiency.

Fatigue, stress, and overwork are all factors that negatively affect decion-makers in the asylum system.  The more we can do to alleviate those problems, the better decisions we can expect.  In the mean time, I recommend that you bring the IJ a nice sandwich before your trial.  It couldn’t hurt.

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How Safe Are Immigration Judges?

by Jason Dzubow


Government Executive reports on a recent event at the National Press Club featuring Judge Randall Frye from the Social Security Administration and president of the Association of Administrative Law Judges, and Judge Dana Leigh Marks, an immigration judge in San Francisco and president of the National Association of Immigration Judges.  The pair described threats to judges involving guns, baseball bats, cut brake lines, and broken legs.

A safe judge is a happy judge.

“Between March 2009 and February 2010, SSA offices that handle disability claims received 49 threats; individual Social Security judges received 20 threats,” reported Government Executive.   “At a Las Vegas federal courthouse in January, a man believed to have been irate over a reduction in his Social Security benefits gunned down a courthouse official and injured a U.S. deputy marshal.”  There are no statistics available from the Department of Justice concerning threats to immigration judges or court personnel, but given the high-stakes nature of proceedings, it would not be surprising if threats have been made. 

The main concern is lack of security at certain immigration and SSA courts.  Many such courts are not housed in government buildings and do not have rigorous screening procedures.  Immigration courts also often lack secure parking lots, elevators, and entryways.  At the Press Club event, Immigration Judge Marks pointed out that “she could ride the elevator with someone whom she decided to deport.”  That is certainly the case in the courts where I litigate. 

Suggestions for improvements included increasing the number of security guards in the reception area, stationing a bailiff in every active courtroom, higher railings in front of judges’ benches, and creating secure entrances, exits, and parking lots for judges.  At the minimum, the Justice Department should make available data on threats to immigration courts.  Then, at least, we could have a sense of the problem.

Of course, improvements to security cost money, which seems to be in short supply.  As the number of cases (and level of frustration) in immigration courts increase, we should not forget to ensure the safety of those who enforce and adjudicate our immigration law.  Let’s hope we don’t have to wait for a tragedy to realize the importance of protecting our public servants.

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