The Constitution (Melissa's Version)

You're not alone if it feels like groundhog day every morning when you read the news or even listen to what we're talking about here on Strix Hirtney.

“And while it's overwhelming to see the trajectory our country is on, we all show up every day, trying to find ways to make it better, to educate our neighbors, and to continue fighting for democracy.”

And our friends at Americans United have been doing the very same thing, day in and day out for almost 80 years. This year alone, they filed three separate lawsuits against Trump's anti-Christian bias task force, which spoiler alert is anything but unbiased. AU has been tracking every mention of Christian nationalist rhetoric from this administration and partnering with many allied organizations to sue and protect our constitutional right of church and state separation. The right that protects all of our abilities to be who we are and live as we choose, so long as we don't harm others.

It's easy to get apathetic as we're all seeing and hearing these attacks in our freedoms every single day and watching a religion be weaponized for a power grub. But now isn't the time to give up. It's the time to fight back against the growing authoritarianism in our country. Consider joining Americans United for separation of church and state. You can learn more by visiting AU.org/cricket because church state separation protects us all.

Let's see if we got this place forward. It's no joke, but when I argue, man argues against you beautiful ladies like this, there's going to have a last word. She's small, not elegantly, but with unmistakable clarity. She said, "I ask no favor for my sex." All I ask of our brethren is that they take their feet or far next.

(Music)

“Hello, and welcome back to Strixfordme, your podcast about the Supreme Court and the legal culture that surrounds it.”

Where you're hosts, I'm Melissa Murray. I'm Leah Litman. And I'm Kate Shaw. And we have a very special episode in store for you today.

The highs are high, the lows are low, first the highs.

To mark the release of Melissa's book, the U.S. Constitution, a comprehensive and annotated guide for the modern user in your eyes, right now. This is not a book you can see. Wait, it is. No, it's a high, it's a manual. For the modern reader, a user guide.

We like you don't read it. But the title as a poster or a reader, or a user. You might have told you about yourself. Okay. When the RF8, as we call her, not above it, wow.

Thank you. I think RF8. If it's the Constitution, I guess I'll proudly snort it. Anyway, sorry, I just- Those will be the highest, as you would say.

We are way off the rails, and it's like 60 seconds in.

“But that, I think, dear reader, slash listener, slash uter.”

I do need to say uter, Kate. Uter. I don't know if we're just pressing on. Anyway, we have a wonderful discussion of Melissa's book that we recorded earlier in a sober or moment on deck.

So stay tuned for that. And then we'll get to the lows. And that means illegal news, including an unfortunately long segment on voting wrongs, where we'll talk about the Virginia Supreme Court decision, invalidating the legislative map that was selected by Virginia voters.

We'll also talk about how the Supreme Court, the United States Supreme Court, made its anti-voting rights and anti-voting rights act decision in Louisiana versus Kelly, somehow even worse. These guys are making it super easy for us to continue our recently launched recurring segment the Colleague catastrophe. And then we'll talk with the president of the Center for Reproductive Rights, Nancy Northup, about what's

going on with Mr. Preston.

But first up, Melissa explains the Constitution.

We get to have a little fun and turn the tables on our very own Melissa Murray. As you all know, she's usually on this side of the mic, asking the questions with us. But today, we're putting her in the hot seat to talk about her new book, the US Constitution, a comprehensive and annotated guide for the modern reader, which was out Tuesday, May 5th. Melissa, thanks for letting us do this to you.

Congratulations on the book and welcome to your own podcast. Thanks for having me. I mean, you can say you're going to do anything to me. So this is a little alarming. Well, we're just getting started. I mean, I feel like I'm at the Supreme Court.

People are doing things to me. This is going to be much more fun, don't worry. I'm sorry. I don't have a physical book. Elsa, I would hold it on my shoulder for this.

I know. But I'm going to just sit from my Constitutional AF mug. And I do have actually by the time the episode drops my multiple copies, I've ordered

And if you listeners haven't yet ordered your own copy.

“And Sam Alito, if you are so far in that may or may not be from me.”

Yeah, at least one. It's not unconstitutional to give gifts. Exactly. To your very favorite Supreme Court. And you know, since you wrote the book.

All right. So good segue. Two Melissa's book. And let's start at the very beginning of the book. And you open it with a various student observation, which is that

Americans frequently invoke the language of the Constitution. Frays is like, it's in the Constitution. Or that's a violation of my Constitutional rights. And you remind us that this abiding faith in the Constitution. I'm quoting here.

And Constitutionalism was not inevitable. It was built over time through institutions and through norms. And here at editorializing, whether you think that relationship with the Constitution, this kind of abiding faith and constitutionalism as our sort of shared civic religion is good or problematic or some combination of both.

So it seems un-controversial to observe that the institutions and norms that have created this relationship with the Constitution are under increasing threat. Okay. So without line-up. When and why did you realize you wanted to write this annotated constitution

with your co-author, James Madison?

“And at what point did it stop feeling like a kind of a traditional book project/collab?”

I'm in start feeling like different and also like something. You know, maybe more urgent. So it's a really good question.

I also say the first thing the book starts off with is a dedication.

And I dedicate it to my parents who were Jamaican immigrants and to my children who are the descendants of those Jamaican immigrants as well as individuals whose own grandparents were enslaved people. And I thought that was actually important to note because we are just living in an moment when this country feels sort of driven by anti-immigrant

forver. There are real questions about whether minorities have a place in the society. And I felt it was really important to make a claim for my parents, for myself, for my kids that this land is ours too. And so I just let me start there.

Where did the project come from? Honestly, it was born in these Twitter streets. So as you know, there's a period prior to January 2025 when everyone is in the Twitter streets. And I was too.

And I was on Twitter and Ellie Mistahall, I mean texted me and said,

you've got to see what Luke Campbell is posting. And if you don't know, if you're not from Florida and you didn't grow up in the 1990s, Luke Campbell is the lead rapper for two live crew, Uncle Luke, Luther Campbell. And he's pretty storied rapper. But he was in these Twitter streets being wild about what Joe Biden should do

and what Joe Biden shouldn't do, what Joe Biden needed to do. And I was reading all of his prescriptions for Joe Biden. And it occurred to me that the president couldn't do any of the things that Uncle Luke wanted him to do. And I was like, wow, Uncle Luke, no surprisingly little about executive power.

Maybe he's a Republican. And if someone like Uncle Luke doesn't know, imagine who else doesn't know what the scope of executive power is. And then Simone Sanders tells him, and I did that special for MSNow, where we talked to millennials about all of the things they were concerned about

with the 2024 election. And when I talked to a lot of those younger people, it occurred to me that they were of the generation post, no child left behind where public school curricula were really devastated. Lots of things aren't music, but most crucially, civics education.

And they, you know, through no fault of their own, had a really thin understanding of how the American government works. And so I thought maybe there's something to this. Like, you know, maybe we should be engaging with the constitution. It was written to be read by the people.

And more importantly, maybe someone should try and explain why we have the provisions we have, why we have the constitution.

“We have, and what's the point of this whole thing in the first place?”

But yes, it all started with two live crews Luke Campbell. And his very lengthy list of things Joe Biden should do. I really hope he has read the book because he's running for Congress right now. And I at least want him to know what article one says. If you're a publisher has not sent him a copy,

they need to get on that. You really need to get on this. I had no idea the story straight back. Started through and the old Twitter. I feel like it doesn't everything.

Yeah, I love really. I guess maybe many great stories. Okay, so one follow up and then I'll give Lea the mic, which is to take us out of the Joe Biden moment and into the present moment. And near the end of the preface, you write, quote,

as we face the prospect of military presence in our cities, questions about the debt ceiling, birthright citizenship, and in positions on freedom of speech and freedom of the press. It is more important than ever to understand the document that has scaffolded our government and indirectly our lives.

What's more, you're such a good writer. So those are all highly salient and alarming ways that the Constitution is being pressur tested right here and right now.

who the modern reader referenced in the book's title really is in your imagination. Like somebody who already follows the stuff and knows a little bit of constitutional law, enough to be dangerous. Someone who is just now realizing they need to set a foundation, like talk about your modern reader.

“I think the modern reader is meant to be aspirational.”

It's sort of anybody right now who is looking around going, like, can they do that? Is that okay? And I think there are a lot of people right now who are looking around asking, can they do that?

And is that okay? And you know, this book is for you. I did not write this for law professors. I did not write it necessarily for law students. I wanted this to be a book that could be accessible to people without law degrees.

People who are in high school just kind of wondering, again, like the absence of civics education, I think is really pernicious. And this is one way, maybe, to fill that gap. Could also be for people who think they know something about the constitution.

I bet they don't know what they think they know. And I bet their knowledge is probably incomplete in some ways. I know mine was. And it was really a learning experience to do this. I mean, like there are so many parts of the constitution that, yes,

we engage with as law professors, but so many parts that we don't. And they're all kind of interesting.

And there are all of these really amazing stories around the various parts of the constitution.

And how they came into being. And so, you know, part of it was just kind of this really fun treasure hunt. Trying to figure out, like, how do we get this? What does it do and what is it for? Just with respect to the people who are asking,

can they do this or can this happen? You know, making this book available. Now, reminded me of an episode we did earlier this year with Kim Shepelie, who talked about protesting authoritarianism and autocracy and hungry. And people did so just by quoting laws and their constitution.

And so making this information accessible to people is a way of empowering them. And also to enable what, you know, academics call popular constitutionism where people can make claims about the constitution. And in so doing influence what the constitution means, like shape it's meaning.

“No, I think that's exactly right. And you know, it's not just like reading the text.”

I mean, you could get one of those free constitutions and read the text. But I think what this does in providing sort of a clause by clause annotation and also history around how some of these various provisions came into being.

It reminds us that we're not the first to make claims on the constitution.

Like this isn't an unprecedented enterprise. Lots of members of the public have made claims on the constitution before and have shaped constitutional meaning. I mean, we talk, I think the founding is very over-determined in constitutional law and theory. The reconstruction amendments, you know, less over-determined.

But we rarely talk about the amendments from the gilded age. So this is the 16th, 17th, 18th, and 19th amendments. And they're literally born in this fervor of populist unrest. You know, people are mad at the turn of the century about the fact that, you know, oligarchs are running a muck and there's this huge consolidation of wealth.

And the American government is raising revenue by imposing tariffs. And the working class hates it because it's regressive. And they bear the burden of it disproportionately. They want an income tax to make the wealthy pay their fair share. They can't because article one prohibits it.

So they start agitating and there's a Supreme Court decision that makes it impossible to have an income tax and they start agitating against that.

And ultimately, they get the 16th amendment, which changes article one in order to allow

for Congress to levy an income tax and to do progressive taxation. And that is born by the people. The 17th amendment is the popular election of senators. They get screwed up a little with the 18th amendment and prohibition. But then they come back with the 19th amendment where they literally double the size of

the electorate by enfranchising women. And that's all through popular agitation and activism. And just on that 17th amendment in particular, you know, you mentioned this as a kind of underappreciated space of constitutional change and empowering people. You know, imagine if people knew more about the 17th amendment and the history behind it

because the 17th amendment said state legislatures aren't going to pick senators. People are.

“I think that understanding that history and what it was getting at provides yet another angle.”

For children during what? Yeah. To understand why Kale is so problematic, right, because the idea that, okay, state legislatures can't pick senators, but they get to pick effectively your housing. But extreme jerrymandering, right?

Like you are allowing people to see connections and understand and to create like our story as a people. And that's just super important. It's exactly like I said jerrymandering because I view Kale as sort of the confluence of this interest and partisan jerrymandering, this new entitlement to partisan jerrymandering with

the longstanding effort to disenfranchise minority voters.

no, we want to do it. And it actually starts at the state level. Like they actually get what is effectively popular election of senators and many states before there's this formal amendment. And you know, and that's a lesson too.

Like this happens at the 19th amendment where they enfranchise at the state level. Women even before there's national enfranchisement. These things can happen incrementally. Some changes better than none. Yeah, and this is that's literally exactly what I was going to say that the set the story, the state level sort of origin story about the 17th and the 19th amendments.

“I think it just like is kind of an important reminder right now.”

Big national change often. And maybe more often than not starts with small local and state level change. And to a point you made on our last episode, Melissa quoting Sheryl and I fall. Like this is a very long game we are playing right now. Making small incremental change against state and local change to our electoral system

and sort of otherwise. Those are the building blocks of federal change and constitutional change. And that's where we have to be working right now. Yeah, I think I said something like, you know, our children and grandchildren will rest under the shade of trees.

They did not plant entering from wells. They did not dig. Like I have no illusions about whether or not we are going to see this kind of change in our life times, but I'm perfectly happy to be committed to doing the work now because this book shows. Like there were people who didn't live to see the fruits of their labor.

But we are living with the fruits of those laborers now. And you know, that's okay too. Yeah. Yeah. Okay.

So here's to scrutiny as you may know.

We've always been up front that we're not coming at the law from a place of neutrality.

It was really, you know, one of the founding premises of the podcast. And we think it's important to have honest, a reverent sometimes bleak. Hopefully still engaging in fun. Conversations about the Supreme Court and the Constitution. And the book seems to be doing something similar, but in a very different format and register.

So how did you find it balancing historical narration with your own commentary in an

“annotated guy like this and how did that tension shape the way you structured the book?”

So I actually, I did another podcast interview about the book. And the person is like, this isn't like strict scrutiny in a lot of ways. Like, you know, it's, there are no cuss words here. And it's like, that's true. True.

That's very fair. I did think I tried to be a little more straight down the middle. Like, you know, here's one person says. There's one other person says it in part because while I would love for more modern readers to be of our view, I just actually like more modern readers to recognize that we are really going

off the rails in terms of how we think about constitutional culture and just like actually get engaged. And so however you choose to enter this space. Like, I'm just happy to be the conduit. But there were some things that I think I couldn't be neutral about.

And, you know, one of them was that I was very forthright about the way in which slavery

is never explicitly mentioned in the original constitution.

But it is literally all over the page. It's, it's almost like a poem set.

“And the compromises they make, I mean, we talk about this in constitutional law to some”

degree. But I don't even think we even scratched the surface of how durable the compromises over slavery really are. And how will like transform it? I mean, the whole idea that they're like making this bargain.

Like, you get 20 years to keep importing slaves. Are you good with that, Southerners? Like, is that going to be enough? And then we're going to have Congress pass a law in 1808. And we're going to make it so no one can come and amend the constitution before 1808

to keep you from enslaving people. We're going to do that for you. And then we're going to stop the enslaving, right? And they're like, no, we're just going to shift from importing this slaves to make them ourselves.

And I mean, just like the perniciousness with which this institution survives. And the compromises, they strike to appease the various enslavers in their myths. And how we kind of live with that in our national DNA, without ever talking about it, and how it carries over into the rest of the constitution in lots of different ways. And we can't shake the residue of that.

We should just be honest about it. Yeah. [MUSIC PLAYING] Stricts here at News brought to you by Zbiotics Pre-Alcohol. This year, I'm focusing on a small shift that makes a huge difference.

Effortless presence. I know it sounds counterintuitive, but for me, it means planning ahead so I can truly live in the moment, especially when I'm enjoying a few cocktails with friends. My simple trick for staying balanced and in the moment is taking Zbiotics pre-Alcohol before my night out.

Zbiotics pre-Alcohol probiotic drink is the world's first genetically engineered probiotic.

It was invented by PhD scientists to tackle rough mornings after a night of drinking. Here's how it works. When you drink, alcohol gets converted into a toxic by product in your gut.

That's to blame for your rough day after drinking. Pre-Alcohol produces an enzyme to break down that by product.

So, if you just remember to take pre-Alcohol and make it your first drink of the night,

drink responsibly, you'll feel your best the next day. Every time I have pre-Alcohol before drinks, I notice a difference the next day. Even after a night out, I can effortlessly get back to my real job doing this podcast, writing, taking care of my kids, all the things without worry. From the first outdoor branch of the year to the start of wedding season,

to celebrating your new favorite read, my book. May social calendar is officially nonstop. So, don't let one long night keep you from enjoying the rest of your weekend. Drink pre-Alcohol to stay on your game and make the most of every sunny Saturday. Remember to head to zbiotics.com/strict and use the code "strict" at checkout

for 15% off. Stricts your knees brought to you by Wilda Laskan Company. I love eating well, and I love when I can take the guess work out of eating well by buying things that have healthy, easily accessible ingredients that are easy and filling and genuinely enjoyable in a way that makes it easy to stay consistent with your clean eating plans.

“While the Laskan Company offers me the best way to get wild caught high quality seafood”

delivered right to my door on my schedule. Each while the Laskan box comes with individually portion fillets that are vacuum sealed, easy to prep, and great for any meal, no matter how quick or how elevated. All of the fish is quick frozen fresh from the Laskan waters, which helps lock in its freshness, texture, flavor, and key nutrients like omega-3s.

This is fish you can trust, with no GMOs, antibiotics, or other additives. And every order supports sustainable harvesting practices in a Laskan fishermen whose history is tied to the region and the practice of fishing. My favorite fish from Wilda Laskan Company is the Pacific cod, which I like to do with a little soy sauce, miso glaze, kind of kind of do a little high end New York restaurant kind of thing.

If you know, you know, and it's absolutely delicious. And I'm saying this is someone who's not the best cook, even I can't mess this up. Wilda Laskan Company is so confident that their fish is the best that they offer a 100% satisfaction and money back guarantee.

So you can try your first box risk free.

Just head over to WildaLaskan.com/strict for $35 off your first order of premium wild caught seafood. That's WildaLaskan.com/strict for $35 off your first order. Many thanks to WildaLaskan Company for sponsoring this episode. So in terms of, that's the original constitution. And obviously there are, you know, there's both the incredibly important reconstruction amendments,

which we'll maybe talk about again in a couple of minutes, but just kind of a lot of attention in the book. Rightly paid to change in the constitution and both constitutional amendment and constitutional change through other routes. And you sort of talk about kind of the book's working theory of constitutional change as running through, you know, three kind of distinct channels. So you have the court, congress, and then what we've already alluded to, just ordinary people working at the grassroots level who can read and interpret the constitution.

And here I'm quoting you as importantly, find it wanting and agitate for change.

“So I think it's fair to say that most constitutional law books focus on the first two.”

And really, on the first one, it's mostly the courts.

There's a bit of congress, and there's not that much about kind of the people working to change the constitution. So what changes for a reader of the book, who has been kind of handed, this sort of like equal weight or stature, in terms of being an active participant in constitutional change, and sort of where in the book would you say you most focus this kind of like popular constitutionalist vision? I think there are lots of different discussions of various amendments and articles where you do see that kind of popular influence and the promise of popular engagement.

Certainly, those amendments that are passed during the guilty age, so the 16th through 19th. Also, some of the more the later amendments, you know, the 25th amendment, which deals with the whole question of presidential session and presidential incapacity, is literally born of the national trauma of the Kennedy assassination. And you know, that's a moment that obviously is led by Congress, but it gets buying because everyone is like, "Oh my God, what happens if the president isn't a coma?" Like, that could have happened, and I think people are really thinking about all of those possibilities.

“There's also, I think, you know, the kind of hilarious story behind the 27th amendment,”

it was initially proposed as part of the 12 prospective amendments that we're going into the Bill of Rights, but two of them ultimately don't get past and they sort of linger and, you know, back in the gilded age, Ohio becomes a vote for what will be the 27th amendment.

And he writes about this compensation amendment and he gets a C on the paper, the professor is like, "Do better." And he's like, "Okay, I can do better."

“And he starts trying to get this amendment ratified.”

So he starts calling state legislatures and, you know, then circumstances happen. Congress has this big scandal involving checkkiting and the house bank. And suddenly there's all of this interest in passing this amendment that limits Congress from giving itself a pay raise.

And this kid, Gregory Watson of the University of Texas at Austin, winds up getting the last amendment into the constitution over 200 years after it's first proposed.

And happily for him, the University of Texas at Austin thought this was a herculean task and they changed his grade from a C to an A. Students at this doesn't inspire you. I'm not sure what way. You don't like that grade, right? You change the constitution and Melissa has provided you the building blocks to do so.

I mean, if you can change the constitution, I might rethink your grade. Sure.

So the book is often aspirational.

Sometimes even Kate Shawish optimistic. I know. I know. About what? This is like wicked.

I've changed for the better because of you. Well, on the other hand, on the other hand. On the other hand. I know. I know.

You also don't pull any punches when it comes to its flaws.

You know, as you were kind of alluding to previously, you're very clear about the rules that slavery, sexism, elitism and other forces played in shaping the document and it's legacy.

“You know, do you think those influences are still understated and how we talk about the constitution and how did you approach incorporating that into the book?”

One, we don't talk about the slavery in the original constitution at all. It's perfect. That's fantastic. James Madison, you're doing great, sweetie. I think we should grapple with the fact that they are making compromises in order to keep people enslaved and full stuff that it's all over the original document.

And we should talk about and talk about where and how and why. And it's beyond just simply representation in the house of representatives. We should talk about their deep-seated fear of people, like non-wealthy, non-slave-owning, non-property-olding men, like they're deeply concerned. I mean, the constitution, as originally written, is a document that is a lot about minority rule, like the electoral college, the way the Senate is initially elected, like all of that is about a fear of the people.

“And we are constantly, I think, working toward dismantling the kind of elitism and racism that undergird the document.”

And that's the point of Congress and getting the authority from the reconstruction amendments to pass legislation like the voting rights act. I mean, it's why I think so many people are alarmed by the decision in Louisiana versus KLA because we specifically authorize Congress to be able to do certain things to, like, work within the confines of the constitution. To create a more perfect union. And now we have six people on the Supreme Court rolling that back in a way that's inconsistent with the idea of democratic rule and taking cues not just from the president, but also from Congress.

So next question, we started off by talking about kind of popular invocation of the constitution, and I think those kinds of invications are largely kind of about the rights provisions in the constitution, like my fourth amendment rights, my first amendment rights. So I think that those are the part of the constitution or at least the principles in the constitution that people are the most familiar with or sort of reach for the most easily. But I think that we are these days, American sort of seem to be getting a weekly refresher on the more structural provision of the constitution, right, like you mentioned on colloquian article one, right, the Congress creating article the constitution article one two three.

You know, kind of as we are all faced with the latest developments from the executive branch, the relative in action in Congress, and obviously the Supreme Court. So I guess how should a better understanding of those articles of the constitution change the way we think and talk about the separation of powers and sort of how do you hope it changes the way kind of public discourse and public understanding sort of looks in terms of what is happening right now. I think one major point of the book is that the question of structure is not divorced from the issue of rights and certainly not among those who framed the constitution, like you know, they created the original document without many explicit protections for individual rights.

And they did so because they really did believe that if you divided governmental power, you would be protecting rights, like they believe that the states would protect the rights of citizens, they believe that if you did not allow power to be consolidated in any particular branch, you would be protecting the rights of the people.

They had the whole colonial period where they have the British parliament passing these laws that make their lives unbearable intolerable. They have the mad king who's doing all of this stuff. So, you know, they really fear the prospect of a two powerful federal government. So when they sit down. But they also recognize that you have to have a relatively powerful federal government because they have the trauma of trying to fight this revolutionary war with this articles of confederation that's basically like a friendship bracelet between 13 states.

And so they want something that will bind them together that will enable them to have a government that works, but they don't want anything that will allow power to be consolidated in a way that can be used against the people. So they see structure and rights going hand and hand.

“Maybe not as perfectly as some people would have like them to, but they get that and, you know, they're journaling through it in this constitution. And I think that is something we should understand in real time.”

Separation of powers, questions like whether the president has the power to do X or Y. It's not just about the president's relationship to a coordinate branch of government.

It's about the broader relationship around the idea of limited government as a means of preserving the rights of the people. So, have writing the book changed. How you think about teaching a comma or how you think a comma should be taught. And not just writing the book. I mean, I think the work that Kate and I did earlier this year in that Supreme Court review piece on skirmati really focused me and thinking, you know, maybe I should do more with executive constitutionalism in my conla class. I taught a pretty traditional conla class, which focused a lot on the court.

I think that's a mistake right now. And you know, I'm happy to admit that my course will be updated to reflect the changes in our landscape and I will be talking more about how the administration is advancing a particular vision of sex equality using these executive orders. I think the work that the three of us did in what we are calling the juridical presidency, which is forthcoming in northwestern maybe it'll have a new title, but this whole idea of presidential settlements being a work around and being a separate kind of separation of powers problem is something that I'll talk about in structure.

So, you know, just the work that we've done together, I think, has really illuminated for me how I might change the course, but you know, one of the things I always do in my course is the first assignment is to read the constitution and, you know, I don't ever assign my own work. I don't think I'll ask students to buy or read this book, although I'm sure my publisher is like, what?

“I think I might just assign the preface just as a reminder to them that it's not academic like what we're doing like it is academic obviously you're in law school, but this is a bigger enterprise than just getting to the end of the semester.”

Okay, one more question in the book, which is you could obviously have written an entire book and people have about any one article or one amendment and I'm curious, you know, you had to make choices about what to include and what to cut, where there are any particular annotations or, you know, stories or characters or anything else that you ended up kind of like leaving on the cutting room floor or just like ideas or debates that you wish you had had more time or space to explore. The 19th Amendment, I wanted to talk more about some of the women who are involved there, not just, you know, the Crystal Eastmins and Anaz Moholins and Elizabeth Katie Stanton and all of those people, but, you know, people like Mary Church Terrells, like some of the black women who are involved in the black women's club movement that did a lot of this work around the 19th Amendment and weren't really included by the traditional suffragist crowd.

I think we had to take out some of that. There was a lot of effort, I think, to deal with some of the more technical parts of the constitution and make it more digestible and reader friendly.

I mean, it's like some of it is just like, you know, the the capitation parts of article one. I was like, I spent a lot of time just trying to make that user friendly. But there are a lot, there are just a lot of really good stories. I mean, I think we forget like they're just really amazing and inspiring stories. Like I love the story about how the 19th Amendment finally gets passed because this Tennessee legislator.

“His, he was prepared to vote against the amendment and then his mother writes him and is like, I think the fuck not you will you will vote for this and he does it because he's a good boy.”

He worked at boys. And that that that scene is dramatized in the stuff the musical self very very well. Good boy. Okay. So quick lightning round. We are going to put you on the spot with four questions. Maybe we will chime in as well.

First, what's one constitutional provision you jettison? Electrical college.

Oh, I was going to say the same. Okay. Okay. If I can't do that one, I would use that amount of motion. Second one. Okay. Yeah. Okay. Okay. All right. That's a good new constitution. I like it better already.

That's a good one. Maybe a right to education.

I always think just making it easier to amend like it.

That's true. It's kind of the kind of cheating like if you had a genie and you wish for like a thousand wishes. I mean, like maybe that's a cop. But it just does feel like an elemental problem is that article five makes it so hard to amend the damn thing. So it's hard to choose one thing, but one thing you could choose that would facilitate a lot of other things would be making it easier to amend it. Well, you know, an amendment that addressed hardest and cherry mandarin or any kind of cherry mandarin would help.

Yeah, I'm going to say like man for sure. Yeah. Yeah. You could do personal representation or amendment that that told states they had to set up independent redistricting commission. Exactly.

Could you do that?

“Um, that's, I think, those are all deep DC statehood, like just, I mean, you don't need to in the constitution. You can do it by legislation.”

But if you, but you make DC in the constitution, why not make it a state in there too or give it, you know, actual meaningful representation in Congress? The amendments dealing with DC are so fascinating because it's so clear how much it's about race. Like, it's just, I mean, and Puerto Rico doesn't make it in because there's no amendment dealing with Puerto Rico, but you could imagine it's like the same reason. Totally wrong. Okay. What is a provision you leave exactly is written and just tell people to actually read it or interpret it differently?

Um, the privileges or immunities clause of the 14th amendment, which could be doing so much more work. And no Justice Thomas, I'm not looking at you as a means of the corporation. Like, it could have done more. Um, it could go further Justice Thomas if you, you know, if you know, you know, I'll just, it's the week after color. I just feels like 15th is is right there and we're not actually interpreting or enforcing it properly.

So I would say section five or section two, the enforcement clauses at the reconstruction. Yes. Yeah. Yeah. Those are those are.

Yeah. You know, you, you had this, um, section two of the 19th amendment. Lee, I think we don't do enough about a new and recassin wrote a terrific piece in the Georgetown Logic and all about this, which I cited here. Enforcement clauses for the win.

Mm-hmm. All right. Wait, last question. Better coauthors slash collaborator Andrew Weissman or James Madison. What if I say, okay, this is no shade to Andrew, I love Andrew.

I don't know James Madison. So obviously, I would say Andrew Weissman. But if I had to pick the best coauthors and collaborators who'd be you guys. No hands down. Oh.

So yeah, um, Andrew was great. James Madison, you know, we worked fairly well. Did. Yeah. I did go to Australia.

I did go to Iowa. I did go to his house once. Had me over. Took the tour. That was great.

Great. Oh, well, this is a probably perfect place to end. Okay, let's go. We got to end on a much happier note. I was going to make it happy.

Okay. I was going to say some happy things. See it, but it gets to follow because she's even happier.

“So what did they take our intern Jordan Thomas for helping us with this episode?”

And also just to think, you Melissa, you know, you said Kate and I were your favorite collaborators. Like, I cannot believe we have been doing this podcast for seven years.

I count myself as lucky every single day to get to work with you and just getting to cheer you on and see all that you're doing is incredible.

I know this is a perfect thing to each other at one first street. I know just as so. Oh, Sam, you are my favorite. You're amazing. Wow.

I love that. Yes. I will at the risk of being saccharine. Yes, the same way. We're coming up on seven years in June.

We're going to have a seven year anniversary. We have to throw a party. Yes. But I will say no. It is also fun.

We are everywhere. Yes. Oh, that's true. We kind of are. We just need like a doctor party.

But it is, I mean, it's a total privilege to get to collaborate. Extremely closely with both of you. And then it is also kind of fun to sort of step back and then see like if you're doing a solo project like this. Well, so it's like incredibly impressive. Really important contribution.

Love treating it. Love getting to talk to you about it and have both ordered multiple copies and we'll tell everyone. And I love pitching it for a non. We spend a lot of time with lawyers and law students. And they could use this book too.

But like that is really not who you are targeting. Many, many, many, many more people are not in those two categories. And need to know and understand more about the constitution and they should all buy and read this book. I agree with that. Oh, heartedly.

“I think definitely by and read this book.”

The U.S. Constitution. If you're looking for a great gift bundle for anyone graduating from high school. I would say the U.S. Constitution plus lawless. Like that's a true one.

Hey, hey, hey, hey, hey, hey. First application coming out in June.

You're a true fake and then some snark. Like, yeah, why not? And then we either then we light it up right you get the neutral take rate.

It's a diss track roll it up.

“So this play ladies. Well, well, so thanks for joining us on your own podcast.”

Thank you for having me on my podcast. Great. It's great. Anytime. Any time.

Publish yours. Please come back. People with their own publicity outlets. Great authors. Really great.

I mean, we really do work very hard in this podcast.

We do. Okay, to use the platform to plug the books that we also. Poor people get in tears into. But people don't get that. We sort of a lot of time doing this.

Yes, a lot of time. Again, it's cathartic. It's gratifying. We think we put something valuable on the real. But it's a lot of work. And so damn, if we're not going to also use it to tell you all about this. Exactly.

There we go. The US Constitution, a comprehensive and annotated guide for the modern reader.

“Stricts here at News, brought to you by bookshop.org, would you be surprised to learn that we are living in the resurgence of Renaissance, some might say of independent bookstores?”

More than 1000 new bookstores have opened in the last five years. And I love this because independent bookstores do more than just sell books. They take care of and pour back into their communities. They create safe spaces that foster culture, curiosity, and a love of reading. And when you purchase from bookshop.org, you're supporting more than 3000 local independent bookstores.

So they can continue their essential work in their communities.

And if you go to bookshop.org right now, you can get one of my favorite reads. The US Constitution, a comprehensive and annotated guide for the modern reader by yours truly, Melissa Murray. This is such a fabulous gift for Mother's Day, Father's Day, graduation gifts. Everyone in your life who wants to support democracy and be more up to speed on the constitution than even those on our highest court. And you can do it by shopping at bookshop.org, supporting democracy and supporting independent bookstores all at the same time.

What's not to love? Head over to bookshop.org and use our code, Strict26 to get 10% off your next order at bookshop.org. That's 10% off at bookshop.org with code Strict26. Stricts New Year's brought to you by fast growing trees.

“Did you know that fast growing trees is America's largest and most trusted online nursery with thousands of trees and plants in over 2 million happy customers?”

They have all the plants, your yard or home needs, including fruit trees, privacy trees, flowering trees, shrubs and houseplants. All of these plants are grown with care and they're guaranteed to arrive healthy because that's the fast growing trees guarantee. Whatever you're looking for, fast growing trees helps you find options that actually work for your climate space and lifestyle. Just click, order, grow and get healthy, thriving plants delivered directly to your door. They're alive and thrive guarantee promises that your plants arrive happy and healthy.

Plus, you get ongoing support from trained plant experts who can help you plan your landscape, choose the right plants, and learn how to care for them every step of the way. Spring is here and that means it's planting season, so what am I doing? I'm trying to get my fiddle fig situation in good order. I want more fiddle figs in my life and so I'm going to fast growing trees so I can get more for not just my office, but my hallway, my living room. All the places where I want to live and things up with some nice greenery.

It's so reassuring to order plants knowing that they're guaranteed to arrive exactly as I would like them, and that I'm later going to be supported by experts who are available 70s a week by email chat or phone to help me keep these plants alive and thriving. Right now, fast growing trees has great deals on spring planting essentials up to half off on select plants. And strict surrounding listeners get 20% off their first purchase when using the code strict at checkout. That's an additional 20% off better plants and better growing at fast growing trees.com using the code strict at checkout fast growing trees dot com code strict.

Now's the perfect time to get to planting. Let's grow something together. You strict to save today offers valid for limited time terms and conditions may apply. That was a fun conversation about an awesome book on constitutional rights and now on to voting wrongs on Friday the Virginia Supreme Court in a 4 to 3 decision ruled that the legislative maps that Virginia voters approved in the recent election cannot go into effect for the upcoming midterms. Virginia voters had approved a set of maps that would counter act Republican gerrymanders in Texas, Tennessee Louisiana and elsewhere.

The decision rests on something of a debatable and I'd say dubious technicality. Virginia voters had previously banned partisan gerrymandering in their state constitution.

Now the Virginia constitution has a complex process for amendment amendments have to first be proposed by the legislature then there has to be a general election and then the amendment can be submitted to the voters to be approved. That process requires there to be an intervening general election so in between the legislatures proposal of an amendment and the voters approving the amendment. In this case Virginia said it complied with that requirement for amending the constitution because the legislature proposed the amendment for days before election day.

However, in a 423 decision, the Virginia Supreme Court said that that process didn't count because by the time the legislature proposed the amendment voting had already started in the Commonwealth.

Therefore, the amendment didn't go through the constitutionally required process according to the court. There wasn't an entire election between the proposal and the adoption of the proposal and therefore the amendment couldn't go into effect. This wipes away the for possible additional seats in Congress that the new map might have given Democrats and again would have given Democrats a shot of winning back the house. In case you're wondering, a majority of the justices on the Virginia Supreme Court were effectively chosen by the Republican party justices in Virginia are selected by the state legislature and a majority of justices on the Virginia Supreme Court were selected when the state legislature was controlled by the Republican party.

“And Republicans controlled at least one of those legislatures because of their extreme partisan gerrymandor. So do you see how it all works together?”

It's like think about that meme of the guy smoking cigarettes furiously while planning at a board filled with like strings tied together. That's the conspiracy theory here it is in action.

Well, I mean reading this opinion, I felt like the picture of Ben Affleck smoking the cigarette outside the Duncan donets because it's super rich reading the justices in the majority. Complaining about partisan gerrymandering when their decision effectively locks in Republican partisan gerrymandering the decision is obviously hugely disappointing and it's a voting wrong because it nullifies an election after the fact. And that's a pretty scary development. If you remember in the 2020 presidential election and the litigation after that election, the stop the steel movement and the efforts to undo the election via litigation and courts were met with firm opposition precisely because courts aren't supposed to invalidate elections after the fact.

And no court in the 2020 presidential election was willing to actually throw out votes that had been cast.

And this Virginia decision is a scary step in that direction. I know it's not a decision about a candidate. And yes, it's about the process for submitting an amendment, but still the Virginia Supreme Court refused to rule on this issue before the vote. I understand the legislature was arguing that they couldn't, but the court still had the option to. Then there's the fact that other Republican controlled states are being allowed to do exactly what the Virginia legislature and Virginia people attempted to do change election rules after an election got started in Louisiana Louisiana is attempting to suspend the election in which more than 40,000 Louisianaans already voted.

And I will wait for a court ideally, let's say the United States Supreme Court to tell them that they can't do that. We may be waiting a while. Oh wait, this Supreme Court just encouraged Louisiana to do it.

“Yeah, this after the fact point is so important. So remember we talked a lot on this podcast about unsuccessful North Carolina Supreme Court candidate Jefferson Griffith who tried.”

And came kind of close to succeeding to throw out the results of an election that he had lost asking courts to change the rules surrounding voting months after the election had, you know, not broken in his favor. It was not successful there, but this does feel like a kind of seal breaking moment in the invalidation of an election. Like you said, we had not a candidate election, but still a really important one that has been invalidated on the narrowest of margins after the fact. And as you said, it's especially rich in sort of contrast to other states that in the wake of Kale are scrambling to change their legislative districts after voting has already begun.

“And you know, that's not the only double standard that is being applied in the gerrymandering wars. The Virginia Supreme Court, remember said this provision was procedurally invalid and it ran a fall of the state's ban on partisan gerrymandering.”

So ladies, guess what other state also has a state constitution that banned. Yes, partisan gerrymandering. Yes. Is it, say, with the sunshine state? Is it my state? If it's bored of me. Melissa is ding ding ding. She has its number. Yes, the Republican controlled and Republican stacked Florida Supreme Court has already chosen not to enforce that state's ban on partisan gerrymandering against Florida's gerrymandering, you know, different kind of gerrymandering, Republican favoring rather than democratic favoring.

So clearly that's the principal basis on which to distinguish Virginia from Florida. I'll just say I've had Florida's number since 1983 and did as well.

Although there is more that they might do to impact the 2028 elections and thereafter Republicans seem to be targeting around two to four congressional seats in Alabama and Louisiana and perhaps additional seats in Mississippi and South Carolina as well, which is all to say that this entire landscape seems entirely anti-democratic and extremely, extremely effed up. And let's just put blame where blame is due. This kind of anti-democratic asymmetry is only possible because of the United States Supreme Court.

“Let's go to the Kale catastrophe, the ongoing impact of Louisiana versus Kale. Let's get started.”

Right. So last episode, we floated the idea of a recurring segment about Louisiana versus Kale and it's followed just to keep kind of everyone up to speed on how momentously awful this decision was and is.

Kale took out what remained of the Voting Rights Act, allowing white Republicans to gerrymander and lock themselves into power by locking out of power voters of color and voters of different parties.

Last week, the court decided that its decision in Kale was so awesome, more on how awesome it is in a moment, but so awesome that the decision had to go into effect immediately. Typically, after the court issues and opinion by its rules, it usually waits 32 days to issue what is called the judgment or the mandate and what exactly is the judgment or the mandate. You can think about it as the court making its decision official, like for real for real. There's something that has the force of law and that lower courts have to abide by. So certifying the judgment returns the case to the lower federal court and issues a directive to the parties to take action in the case.

So here, the court had already released its opinion saying that Louisiana need not and could not create a second black opportunity district as a way of complying with the Voting Rights Act.

The judgment in the case effectively tells Louisiana you would be in violation of this if you had a second black opportunity district. So do something to change that releasing the judgment in Kale is a way of accelerating Louisiana's already heard efforts to draw new districts that erase political opportunities for black voters. It effectively eliminates the lower court injunctions that had required them to do so. Exactly what the court did rather than wait the usual 32 days to certify the judgment and issue directive to lower federal courts and to the parties the court certified the judgment in Kale in a matter of days. So less than one week after the case was decided.

“But why? Why so speedy fellas? What's going on here?”

Is there like I don't know an election looming or something could it be that in some places including Louisiana there is an election that is already underway. So if you really want to stick it to black voters you better get to step in to immediately ensure that the election is conducted under a set of maps where black voters are basically locked out of political opportunity could that be what it is. No, I'm sure it's neutral principles passive virtue exactly, but just as Jackson was not going to let this go as she shouldn't and we shouldn't and you all shouldn't.

So she descended from the court releasing or certifying the judgment and noted that the court has granted an application to issue a judgment over a losing parties objection twice in the last 25 years. And that doing so here gives the appearance of partiality as she writes quote the court's decision to buck our usual practice is tantamount to an approval of Louisiana's rush to pause the ongoing election in order to pass a new map the court on shackles itself from both constraints today and dies into the fray and just like that those principles give way to power and quote.

So Samolito, the whiny little bit from New Jersey could not handle someone accurately describing what he had done saying the truth out loud is as ever the meanest thing you can possibly do to Samolito.

And here's what Justice Alito had to say in response to this stinging review from Justice Jackson.

“First of all he called it baseless and insulting and I imagine Justice Jackson sat at her deaths and thought yes exactly that's what I was trying to I'm glad you picked up on it.”

But here's what he really had to say quote the descent would require that the 2026 congressional elections in Louisiana be held under a map that has been held to be unconstitutional. This is me staring in Alan vs. Milligan where the Supreme Court allowed the 2022 midterm elections the elections where Democrats lost the house to be conducted under a map that a court would later invalidate.

So out of Texas way back in the olden days of checks notes December 2025 in those cases lower courts found that the state's election rules were likely unconstitutional.

“And in each case the Supreme Court said the courts decision had come to close to the election to do anything about the possible illegality, but I guess now we're going to fix all of that.”

And we're going to move quickly, namely, actually to make these elections happen under really good maps. So just to cap it all off, Alida also tone police justice Jackson closing out his statement by saying quote the descent's rhetoric lacks restraint.

His statement was joined by justices Thomas and Gorsuch.

So in addition to the developments in Louisiana other states are also hopped to trot on a racing black electoral power, the Tennessee legislature as expected and as encouraged by Marsha Blackburn and Sam Alito.

“Adopted the map that breaks up the only minority opportunity district in that state by breaking up the city of Memphis into multiple districts.”

And Memphis as friend of the show Ari Burman has pointed out in the past week has been a single legislative district since 1923. So for over a century the city of Memphis has been a single legislative district as makes perfect sense this new map erases that it also effectively prevents Memphis from sending the incomparable Justin Pearson to Congress, which I am quite sure was not an accident in the mind of these state legislators. Justin Pearson was one of the state legislators who was kicked out one of the three state legislators who is kicked out of the Tennessee chamber at in response to his protest over gun rights.

So I guess he's too much of a rabble browser to go to Congress in any event. Also making moves is Alabama. Alabama has requested to lift the injunction from Merrill versus Milligan. Again, Merrill versus Milligan was the case in which the Supreme Court said that the voting rights act required Alabama to create to minority opportunity districts. Merrill versus Milligan is also known as Allen versus Milligan is also the case that's pretty much identical to Louisiana versus Kelly that the court decided in to know totally different John Roberts tells us because yes John Roberts was for Merrill versus Milligan and he's against it in Louisiana versus Kelly.

But they're effectively the same cases it's just that it happens that Merrill versus Milligan had to be decided in 2023 a year after jobs in 10 years after Shelby County and that seemed just maybe a little too on the nose even for this court. In any event in Merrill versus Milligan, Alabama tried to create only a single minority opportunity district and now it's request to lift that injunction is kind of awkward given that in Kelly. Justice Alito said that the Milligan case was totally different. Right. Again, all these guys just keep telling on themselves. It's not totally different. It's the same thing. This is awkward as hell. Super anti democratic and super anti black voter.

Yeah, we're fascism maxing now. And if you're wondering, could anyone have guessed that Alabama would be foaming at the mouth to erase minority opportunity districts. We give you this exchange from the oral argument in Merrill versus Milligan between Justice Kagan and the solicitor general of Alabama.

“General some of your arguments. I think not all of them, but some of your arguments would strongly indicate that Alabama could enact a plan with no majority minority districts. Do you think Alabama could do that?”

Under the current guidelines, I don't think we would be able to because court attention. What do you mean under the current guidelines? I'm interested in whether you think, as a matter of federal law, as a matter of the voting rights act, you are prohibited from enacting the plan that has zero majority minority districts. I think it would depend on sort of the guidelines that are being proposed there in the motivation. So you think that there are circumstances. I mean, this is important to me because some of your arguments sweep extremely widely, maybe most of them.

There are circumstances in which a population that is 27% of the state's population could essentially be foreclosed from electing a candidate of their choice anywhere.

There's always going to be that intensely local appraisal to see what was going on there.

So it all depends on low, you know, just it all depends. You will note that in that exchange, Alabama refused to rule out the possibility of drawing zero political opportunity districts in a state where one third of the population is black and more than one third of the state votes democratic.

In addition to all of the boy law of Calay, the Guardian found there was even more boy math in the decision than we thought. So last episode, Kate noted that Alito had said, "Hey, there's no racial turnout gap in Louisiana anymore. Look at the numbers for these elections, which just so happened to be elections when Barack Obama was at the top of the ticket and voting rights act preclearance was still an effect." Well, in addition to those boy maths, the Guardian found that Alito measured the turnout gap on the basis of what it called an unusual methodology.

One that measured voter turnout with reference to the total population when the widely accepted approach is to consider voter turnout as a proportion of citizen voting age population or voter eligible population,

which would exclude non-citizens and people who can't vote, only time Sam Alito wants to count citizens, because the problem is, had Alito used the acceptable or accepted method,

then black voter turnout wouldn't have exceeded white voter turnout in the 2016 presidential election, whereas it did under Alito's boy methodology.

“But under his methodology, what's he basically counting fetuses?”

Be honest. You know, why not? Why not? Anyway, two other notes on Calay, democracy jacket reported that the lead plaintiff in Calay, one Bert Calay, was at the stop the steal rally at the US Capitol on January 6, 2021, because that's where all the freedom fighters who want safe and fair elections were. What's the voting right, shocking, revelations? It's almost like all of this wasn't a tack on the VRA, the stop the steal movement, all of this is a war on democracy. Who said that? I think we said it many, many moves ago anyway.

But did they listen? I recall something similar.

So, um, other note about Calay, uh, friend of the pod, Sherlin, I felt made an appearance on the daily show, where she spoke with John Stewart about the Supreme Court, New King, the Virgin Rights Act in Louisiana versus Calay, and during that conversation, John came up with a way of describing Sam Alito's take on racism and racial discrimination that needs to happen, like everyone needs to make this happen, so here it is. Is the idea now that to try and address that isn't itself racist, that it's, it's literally he who smelt it, dealt it, racism? Is that, is that really what?

“I hate, that that's what it is, but that is what it is.”

Yes, it is the whoever smelt it, dealt it, theory, the race, I like it. Yes, it's great, the far theory of racism.

Yes, yeah, link it to Sam Alito forever. Yeah, these supremacist court.

Correct, Captain, I was like, what's the deal with it? What's the deal with it? What's the deal with it? I was like, I know how to play this game. I mean, sure does. We call these Alito districts now. Yeah, that's good, that's good. All right. Um, so the same week that the court decided to make an exception to the usual rule. We were talking about earlier about when a judgment issues in a case where the exception just so happened to facilitate Republican redistricting racial minorities and Democrats totally out of power.

The Chief Justice gave a speech at a judicial conference where he said, quote,

“I think the view is as truly political actors, which he don't think is an accurate understanding of what we do.”

He also had this to say, quote, we're not simply part of the political process, and there's a reason for that, and I'm not sure people really grasp that. So they view us as political actors as the guy who repeatedly behaves like a political actor and not simply part of the political process as the guy who literally remaking the political process. Also, sir, have the courage to make these remarks on camera so that we can do a YouTube rapid reaction video to your remarks. We can still do it. I'm happy.

Yeah. I mean, we should make like a little, you know, blow up face of John Roberts that you can hold in front of yourself. Well, you recite it to simulated as best we can. I also have to say, it takes real cheek to say something like this. Maybe two weeks after Jody Cantor and Adam Lipteck put your ass on blast where you literally were being a political actor.

Taking statements that weren't even in the court record because there was no record in the clean power plan, but you're watching Fox News and you're really pissed about what EPA administrators are saying, they will not play in your face, sir. And so you then put John Roberts in the court. And then you literally depart from decades of precedent governing the shadow docket and then you want to say that you're not a political actor.

John Roberts, it's not for real.

“No, can I just come back to something we said earlier in episode? We were quoting Justice Jackson's descent from the mandate issuance order.”

Principles give way to power. Like I just think that actually is as good a summation of like what we were seeing on display and they don't like being called out on that. And this is the temper tantrum that we see when they are. The chief also had this to say, quote, one of the things we have to do is issue decisions that are impopular. I don't know that I would call it unpopular to completely a viscerate a statute that had broad bipartisan support and had been reauthorized multiple times by a democratically elected Congress.

Like maybe our understanding of popular and the vox popular are just completely different, but I would not call that just unpopular.

I'm sure it was so hard for you, John, to nullify the voting rights act. It's not like you haven't wanted to do that for like four decades. I mean, I was working on it for so long when I was in the White House, but then I stopped. I mean, I did try and do it when I was in the DOJ, but I mean, it's like no one thought it would really happen, so I'm just kind of like, wow, look at me. The brave truth teller, John Roberts. Okay, so speaking of DOJ where a young John Roberts cut his teeth, like learned the skills that we are now all living under.

There is good news from the Department of Justice, which is that if you are looking for a job, the civil division of the DOJ once one of the most prestigious places a young lawyer could work is apparently so desperate to hire people.

It is now handing out signing bonuses of up to $25,000 to hire lawyers who can work out of non DC offices, including New York San Francisco, Dallas and Raleigh.

Make DOJ great again, I guess. It actually turns out that the federal government is offering all sorts of job perks these days, so let's open up the liquor cabinet and see what these guys have in store for us this episode. Okay, so more reporting from the Atlantic, which has reported since we last recorded that quote, FBI Director Cash Patel, and that's cash with like a dollar sign set of an S, has given out bottles of his personalized whiskey to FBI staff as well as civilians he encounters in his duties.

The Atlantic describes the bottles as being engraved with the words quote, cash Patel FBI Director, and a rendering of an FBI shield surrounding the shield is a band of text featuring Patel's director title and his favorite spelling of his name as I said cash with a dollar sign. An eagle holds the shield in its talons along with a number nine presumably a reference to Patel's place in the history of FBI directors.

“I think her answer would be so impressed. It's Jay Edgar Bozer. Yeah, I heard the guys on positive that term, I don't know the coin did, but I read it.”

I'll cut at them for it, but in any case, and that might be the most significant thing that Cash Patel has ever done, like make you look fondly on Jay Edgar Hoover. I know his, I don't have a drinking problem line of personal bourbon answering questions raised by his, I don't have a drinking problem line of personal bourbon. This report from the Atlantic came from the same reporters. Sarah Fitzpatrick, who reported the story about Cash Patel allegedly being hung over and inebriated while on the job. This is the same reporter that Cash Patel has sued.

This time, according to Fitzpatrick's reporting quote, the FBI did not dispute that Patel gives out bottles of whiskey and scribe with his name. But a spokesperson portrayed the gifts as routine within the FBI and the broader government side known constitutional to give gifts. I would say the government, according to Robin Crowe, in my day, Cash is going to have to pay him up. It's just personal bottles of bourbon, like where's your private censor anyway. He's a humble FBI director, he's all he got. We finished finished reading this quote, though, because he doesn't read the FBI jet as his personal jet.

So there's that. Why not vote? Okay, so back to the story. The story continues quote, when I reached a former longtime senior FBI official to ask whether he'd ever seen personally branded liquor bottles distributed by a previous FBI director, he burst out laughing. And that was the right reaction because no one has ever been out.

“You don't think Jim Colmy was doing this. Can you imagine?”

I mean, the whole episode is horrifying and also somewhat amusing. The dollar side. I'm just like, sorry. What? I mean, it's a gift. It's getting wag culture. It's giving loser in cell culture.

It's just embarrassing. Yeah. So it's all those things.

“Embarrassing, pathetic, horrifying kind of funny.”

But I mean, really not at all funny is reporting from last week, also involving the reporter. We were just talking about Sarah Fitzpatrick at the Atlantic who has broken now these two stories about Patel. And she is being targeted by the FBI with a criminal leak probe according to reporting from last week. So I guess, again, it's not surprising that that is the kind of misuse of power that these guys are engaging in targeting critics. It feels like a very alarming escalation.

It gets worse. MS now has reporting from Carol Lennig and Ken Delaney in saying that. Cash, but tell us ordered polygraphs of people close to him in the FBI to try and determine the leaker. And I'm just saying, John Roberts is right there. If you want to find a leaker.

A lot of John, a way. Wrong guy, never mind. You go to the, you go to the Marshall. That's right.

“And you have the Marshall just ask people, are you the leaker?”

Are you the leaker? There's a way to get an odorized. No, but can't you get them to notorize a document? Oh, right. With the right stamp.

And then you know for sure. Yeah. Okay. So quick lightning round with a few more pieces of news.

First, we have to talk briefly about the fact that the EEOC has filed a quote like huge

scare quotes civil rights lawsuit against the New York Times on the theory that the Times discriminated against a white man by not giving him a promotion because that's who gets to file civil rights lawsuits and Donald Trump's America, Melissa, you had a great threat about this lawsuit. Do you want to repurpose any of it on the pod? I'm just going to say straight up.

One, there's also reporting from New York Magazine and the cut. I think that may actually identify who this person is.

“So if you want to know, I guess go there.”

I will say I don't think the point of this lawsuit is to prevail in court as I note in the thread. There has been no legal determination that efforts to remedy rampant under representation and certain employment sectors is impermecible, whether under the Constitution or under statutes. So that's not what the EEOC is after here.

I think what is really happening is that this is an effort to cow newsrooms into basically thinking twice

when they might hire a woman or a person of color and to cement the under representation of those groups that has long persisted in newspapers and other legacy media for generations. And to the extent this shapes coverage of certain issues and shapes the way people understand the issues and how it relates to a democracy. I think all of that is the point. Indeed, this is this administration's M.O. like intimidation, deterrence, basically stopping people from doing things that they can do, like basically making them obey and advance.

One thing they couldn't do is keep E.G. and Carol from spending Donald Trump's money. So the DOJ has now stepped in into the appeal of E.G. and Carol in the verdict against Donald Trump. And they basically said the president wants a freeze of the payments being made to her. So we will see where that goes. But I'm pretty sure E.G. and Carol was just going to tear it up with that money.

I wonder if he just doesn't have it. They've also asked for the federal government to basically stand in for Donald Trump, rather than having the litigation against him. We have talked about this before in our paper forthcoming in northwestern about personal litigation that takes on a very public import and persona and profile. And this is the kind of like most literal expression of that. Seeking to have the government step in in this lawsuit to say Trump was somehow acting in his official capacity.

At least in terms of some of the remarks he made against about E.G. and Carol that were what led to the 80 plus million dollar verdict that she obtained against him.

We will see all that effort to substitute fairs. Another decision not the court of international trade ruled on Thursday last Thursday that the president's new theory about tariffs is also wrongheaded and fucked up. The president apparently does not have the authority to impose tariffs under section 122 of the trade act of 1974. That's the latest statute that he's invoked to underwrite these tariffs. Those tariffs that he imposed in the wake of the court's tariff decisions impose 10% tariffs on various imports.

Notably the court of international trades ruling not only invalidated those tariffs under section 122. They also ordered the administration to refund the money collected something that the Supreme Court's decision did not do. And a district court ruled for the American Historical Association. Another group that had challenged the grant terminations by the national endowment for the humanities.

It's a remarkable opinion that details just the stunning carelessness and hubris of Doge.

I would say that's a good to know. And that is the news, but stay tuned now for our conversation with Nancy Northup and then for our favorite things. Strixe Newtonies brought to you by smart credit. Here's something most people aren't told about their credit score. It's not just whether you pay your credit cards.

It's when you pay your credit cards. Yes, most people don't realize the timing is everything.

But smart credit state experts understand how credit bureaus operate.

So they've created something called the best pay down date, which is built around how credit reporting actually works. So instead of guessing you get a personalized strategy that shows you what to do and when to do it all to help you maximize your credit score. And that matters because better credit can mean lower payments and more money in your pocket. And this is where it gets really interesting. You can see your full credit picture in one place, your score, what's affecting it and if something needs your attention, you can take care of it right there.

So before you apply for anything, a car loan and apartment refinancing your mortgage, it makes sense to start with smart credit. Go to smartcredit.com/strict and try it for just $1. You may be surprised to see how many points smart credits estimates you can gain on your credit score. That's smartcredit.com/strict results me very cancel any time. And now to help us break down, what the fuck is going on with Mifra Pristone is Nancy Northup.

Nancy is the president and CEO of the Center for reproductive rights. The organization that represented the clinics and dobs versus Jackson Women's Health Organization. The decision which our listeners of course will know is what overruled Rovers' way. The Center for reproductive rights also represents the many women in several different states who are seeking decisions clarifying the scope of medical exemptions under state abortion bands, including cases in Texas and Tennessee. Welcome to the show, Nancy. We are so appreciative of you taking the time.

“It's going to be here. Let's just sort of get right to it. Why are anti-abortion forces targeting Mifra Pristone the way they are right now and why is that such a big deal?”

Well, they're targeting Mifra Pristone because abortion pills have been a lifeline in post-ro America. Currently in the United States, two thirds of people getting abortions are doing so via abortion pills. Specifically, since the FDA has allowed telehealth to be used that you can have a visit on your computer with your provider and then receive the pills by mail or pick them up in a local pharmacy. Now one in four people are having their abortions that way. So it's a big deal. They don't like the fact that people want to get abortion care and they are getting abortion care in a way that is safe and effective.

According to the US Food and Drug Administration, and can you talk a little more, Nancy, just sort of before we go deeper? So you talked about just how common and kind of widespread this particular use of Mifra Pristone is.

“And you said, safe and effective at the end. Can you just talk a little bit more about kind of what we know about the safety and efficacy of abortion pills, which include Mifra Pristone?”

Certainly, I mean, going back over 25 years, the FDA approved a medication abortion, a regime that involves two different pills. Mifra Pristone and Misa Prostone as safe and effective for being on the US market.

It had been approved years before in France, but the US finally caught up 25 plus years ago.

And so it's been on the market. There were initially restrictions that the FDA put on it unnecessary restrictions from a health perspective, but there were restrictions put on it for years. And one of those restrictions was that you had to go in person. But the FDA, first during COVID, and then afterwards approved it also by telehealth. But there have been hundreds of studies that have shown it to be safe and effective. There have been millions of women in the United States, and even more millions around the world who have ended their pregnancy safely and effectively with this two drug regime.

“So Nancy, our listeners will remember that in the FDA versus Alliance for Hypocratic Medicine, which the Supreme Court dealt with a few terms ago,”

there was another attack on Mifra Pristone. That challenge was that it's actually filed in Emerilitexus in the courtroom of one Matthew Kesmerick. I'm he's a judge, but he's also America's leading scientist on this issue that is a joke as well.

including guidance about what point in a pregnancy that Mifra Pristone can be prescribed and whether Mifra Pristone could be prescribed via telehealth.

The Supreme Court unanimously reversed that decision, saying that the plaintiffs in the case, this was a group of anti-bortion doctors and dentists, didn't have standing because they hadn't established that the availability of Mifra Pristone or the FDA's guidance on Mifra Pristone had harm them or was likely to harm them going forward,

“and that was because their theory of the case depended on a set of absolutely implausible events that were incredibly attenuated.”

But as we've noted before on this podcast, by reversing the decision on standing, the Supreme Court didn't address whether the fifth circuit was correct that the FDA was wrong to allow Mifra Pristone to be prescribed via telemedicine. So now the fifth circuit has picked up the mantle in this new case that's been filed by a different plaintiff here at Louisiana. But Louisiana's theory of standing seems pretty attenuated too. So can you explain how the jurisdictional questions in this case are different from the case that the court throughout in 2024?

Well, they're not. Louisiana doesn't have standing. I mean, the analytical reasoning, very hard in the fifth circuit, it turns out.

They try to establish it in two different ways. The first is super, you know, attenuated the claim that because they say two women who had complications from allegedly having an abortion with medication abortion appeared in hospital emergencies,

“and we're treated at some expense to the state. I think $92,000 was their claim. It tells you a little bit about how expensive health care is.”

But that is a very attenuated claim. We don't, we don't know where they got medication abortion. We don't have any idea whether they got medication abortion to telehealth and why that even matters.

And so that's very attenuated. That Louisiana comes in and says, you know what? Actually, here's the real rub.

We can't effectively enforce our criminal ban on abortion because people are accessing medication abortion through telehealth visits and receiving pills through the mail. You know, the fact that Louisiana can't enforce its criminal statute is not a reason for standing to stop the entire nation from getting abortion pills safely and effectively. I mean, I was a prosecutor in the U.S. Attorney's Office and the Southern District of New York. I couldn't go to court and say, you know, I'm having problems, you know, enforcing this law and bringing this criminal prosecution.

I'd like you to knock down a few things in other states to make that little bit easier for me. So, you know, it's, it's an absurd position that they've taken and a very dangerous one. I mean, we have a lot of states in this country that support access to reproductive health care access to abortion care. Our voters have, you know, put it on the ballot and said, hell, yes, this is what we want. And in states where people would be surprised, like, you know, Missouri and Arizona and, you know, Michigan and Montana.

And the voters in those states should not have their desires to have their state constitutional right to abortion overridden by Louisiana's problem with enforcing its abortion crime. This also under the impression that federal law, not state law was supreme, such that if federal law was making it more difficult to enforce state law, not exactly a constitutional injury, even though the reverse might be true. But again, just a humble constitutional law professor here.

“So, what Nancy did the Fifth Circuit do in this Louisiana case and what effect would their ruling have if it's allowed to go into effect, what if I did it have when it was in effect for that weekend?”

So, the Fifth Circuit issued the District Court said, no, we're not going to block the telehealth provision that the FDA has approved. And the Fifth Circuit, you know, made this ruling that not only said, we disagree with the way the District Court judged who would be harmed if an injunction was put in place. And we think that Louisiana should prevail here. We're putting in an injunction. We're doing it right now, immediately. And came out five o'clock on Friday night. And that meant, you know, across, we represent, you know, clients across the nation, those that do telehealth had to scramble and figure out what they were going to do, they had to have, you know, patients come in if they were scheduled for that weekend.

So, it created absolute chaos and upending.

“Well, and not just I want to point out, and I was talking to a friend of mine in California over the weekend, and she said, well, this doesn't apply like in California.”

I'm like, this applies in California. Okay, you cannot get a telehealth visit for medication abortion and pick it up at the pharmacy or have it mail to you in California. Did not understand that was a consequence of it. So, if this is not a wake-up call to people across the nation, that it does not matter if your state protects abortion rights in your constitution, if you're legislator protects it.

If you have a shield law in your state that protects your doctors, doesn't matter if this kind of, you know, ill-founded ruling is allowed to go forward.

Yeah, so I guess just want to specifically follow up on this because although the ruling was unsubstantiated, had no basis in law or fact, and, you know, is hugely consequential. Miffopristone is still going to be accessible, you know, with this ruling, if it's allowed to go into effect as is medication abortion, even by telemedicine, even if it's not, you know, the currently approved protocol. So, could you just talk a little bit about how this would affect the accessibility and availability of Miffopristone and medication abortion?

Well, I mean, to begin with, as I've been saying, it requires that you have to go to your provider in person to get the medication. And as we know, abortion clinics have closed. In recent years, I think about a state like me and, again, protects the right to abortion, but main family planning, which used to have 18 clinics throughout the state providing abortion. So, they had to close some of their clinics because of the defund plan parenthood provision that Congress passed. So, if you have to drive along distance and take time off of work and be able to get into that scheduled, you know, appointment, it's going to make it harder to get care.

“That's why it's a big deal. That's why it's important. And again, it's nationwide nationwide. So, Nancy, I know that you know that our friend of the pod Samuel Alito really issued a win for abortion rights last week.”

And he issued an administrative stay that provided a week for briefing and whatnot for the court to get its ducks in a row about this, but it also allowed Miffopristone to be distributed via telehealth for this period of one week while the court decided what it's going to do going forward.

This means he's pro choice, right?

Well, professor, I know you know that. And so many people have asked me, like, what should we make of this Sam Alito doing this? That must he must know how wrong this is. Can you help us work through this? Help us teach the kids. Yeah, it's an administrative stay. It's just a procedural move to say, you know what? We will let parties file their briefs. We will, at a very short schedule, but we will let the parties file the briefs. We will read and think about the briefs. And, you know, Monday night at 5 p.m. The stay will be in effect too. It's just a procedural move. It's what one would expect a court to do when considering something as upending as a nationwide.

Invalidation of an agency determination about a drug's health and safety. And as our friend of the pod, a real friend of the pod this time, Steve Velada has reminded us that just as Alito has as the circuit justice for the EFFF circuit issued administrative stays before when emergency petitions have come before him.

“In many of those cases, in circumstances where I think he's inclined to agree with the litigants requesting the stay, he often doesn't put a deadline on the stay.”

But, this particular relaying came with a quite short leash, which we should also remember. So don't worry, Steve. For Sam just yet is what I'm not, that's yes. Yes. That makes me sort of want to get ahead of maybe another round of commentary along the lines that you were just kind of alluding to Melissa. So this stay will expire. We're going to get a decision. So this is again an administrative stay. We're likely to get a decision on an actual stay, you know, within a day or two after this episode airs on Monday morning.

So it's entirely possible that the court will order a longer term stay of the fifth circuit ruling. Nancy, what should we make of the court doing that?

No, we should understand that there is a further procedural completely proper and should be expected.

“I mean, injunctions against federal agency decisions should not be quickly granted.”

And so it just means there's going to be more time for the court to consider it. Or you'll hopefully that this will go back and go through a normal decision process and the court will consider it on the merits. But yeah, no one should read anything and go back to their business as usual. They should read all of this as deeply troubling. So listen to that legacy media, do not give Sam Alito credit for doing the absolute least.

This is literally no cookie for Sam. No cookie for Sam. Okay, so Nancy, another question. So can you maybe talk in general terms about what, you know, so we don't know exactly if another stay will hopefully be granted. If this case gets argued in the fall when the court is is sitting again and, you know, the drug remains available over.

The course of the summer on the existing FDA approved terms, but of course there's a lot of uncertainty both in terms of what the courts will do. But also the FDA itself says it is undertaking this internal review.

“I think there's just like a lot that we don't know sort of about what the next few months will hold.”

So can you talk a little bit about how people can and should support abortion access during this like deeply uncertain time. And maybe I don't think we've really explicitly talked about this. So can you also talk a little bit about if, if a press don't again becomes unavailable, at least in terms of telehealth. How people might be able to get a different protocol for medication abortion because medication abortion is of course possible. Without using methapristone.

So could you talk a little bit about all of that? Yes, and I'm actually going to go in reverse order to say that no matter what happens. If you are a person who is seeking abortion care, call a trusted provider. Don't assume because you heard a podcast and you thought you understood that you just can't even get it. Or there's no way to get it via telemedicine.

Call a trusted provider. Find out what the situation is before making any assumptions. So that's number one. In terms of help, while I will start with that, support your providers. They're very important.

They're on the front lines of providing care under incredible stress. Support local abortion funds.

You know, in this post, they've always been important because so many states don't cover abortion care under their Medicaid programs or people are otherwise low income.

There are abortion funds that help people get the care they need, help them travel in this post-ro America if they need to get that care. And there are usually ones in locales and every place in the country or there's the national network of abortion funds. Talk about the issue. People are so misinformed. You're getting people calling you saying what's happening to Justice Alito seems like he's being great on abortion.

“You know, I'm talking to people who are pretty knowledgeable, but still say, wait, what do you mean it's going to be banned here in California?”

To talk about it, don't let it, you know, it's been very hard to push through in this media environment around this crisis that we still have. We live in a country in which in some states people are free to control their reproductive lives and in other places they are not free to do so. So we got to remind people that every single day, we have the free and the unfree. And in this case, Louisiana versus FDA is the unfree trying to come after the rest of the state. So talk about it, get educated about it.

And you do need to, you know, pick up that phone or send that, you know, text or send that email to your office holders. Whether they support abortion rights or not. If they don't, they need to know there's people out there who do support it.

And if they do, they always say to us, we don't hear enough.

We don't hear enough. We got to, you know, you got to buckle up, you got to let them know we're out there and we want them to keep on going. So all those things are important. But talk, talk, talk, talk, talk about it because you know it's going to happen over the next months. We're going to hear a lot in the media about, you know, no one cares about abortion rights anymore.

We hear it every single cycle. Well, on that note, listeners make sure to make caring about abortion. A thing in the upcoming elections cycle and thereafter. Thank you so much, Nancy, for taking time out of your schedule to educate our listeners and explain what's going on and what we should do about it. Thank you for having me.

Thank you for covering it. Okay. So some favorite things. Two new great albums released in the last week, Casey Musgraves, middle of nowhere. And Moona's dancing on the ball.

Also two New York Times pieces, also related to boating rights act and what the Supreme Court did to it.

John Roberts believes in an America that does not exist. Okay. I will go next. Melissa, you recommended yesterday. I think last week and I read it.

And I devoured it.

“I felt differently at different places about it.”

It's actually not what I thought it. It's not quite about what I thought it was better. Isn't quite what I thought it was. What was it? Well, it just, it's just much darker.

I mean, it's not, it's not anyway. It's more than the premise is very straightforward. Tradwife gets like, you know, like time traveled back in time and like, it's shitty back there. It's just much more complicated than that. Surface description suggests, but it's, I really enjoyed it.

Okay. A couple of the things. New York City mayors are on Mamdaani doing the five burrow bike ride and all the video that emerged from him doing that. And then also skipping the Met Gala to hang out with fashion industry workers.

I loved both of those. Friend of the pod. Roadie occasional earthdwell roadie of the pod Chris Hayes had a wonderful conversation on his podcast with Molly Crap Apple about her book here where we live as our country. I'm really recommend that.

And another podcast to recommend the daily didn't episode. Filled with kids questions for the Artemis to crew.

And the four of them are like the most amazing charming, like,

spiritually elevated people. Like they're so impressive. And I love the questions and I love the conversation. So really recommend that. And then tonight, I'm going.

“So I think it'll be one of my favorite things, but I haven't done it yet.”

To the WNBA team in New York, the liberties home opener. And I'm taking three 12 year old boys who are enormous liberty fans. And I just like more fans of all stripes for the WNBA is like a thing I'm super excited about. And I'm super excited that players have a much better deal this season. We talked a little bit about the bargaining around that.

So psyched for the opener and I will pass them like to you Melissa. Okay, I'm minor going to be super shallow. So I did not attend the Matt Gallaud. Didn't get my invitation just waiting. But I did watch and I did have thoughts on some of the fashion.

The theme this year was basically fashion as art.

And I, I don't know if I loved it or I love to hate it. Probably the latter, but Lauren Sanchez Bezos. Deciding to dress up as the John Singer Sergeant painting Madame X for which she spent a shit ton of money on a scaparelli dress. That honestly made her look like she was going to the 11th grade prom. Like it was just basic.

I mean, I don't even know what else. I also enjoyed the video of her and her friends watching Joshua Henry sing on the steps of the met. And nobody could clap on the beat. I am going to relate this directly to the decimation of the voting rights act. I will also say I was very impressed and I loved loved the artist Amy Sherald.

She was the one who did Michelle Obama's official portrait. She wore a custom look by Tom Brown that was inspired by her painting. Miss everything unsuppressed deliverance and it was everything. Just I love the whole idea. Like I just love the whole fashion as art and people referencing these works of art.

I wish some of them weren't so basic, but Amy Sheralds was absolutely a plus. I will also plus one to Jimmel Boole's John Roberts believes in an America that does not exist in the New York Times. In part because he exhorts the American public to reclaim the Constitution as their own and to start making the same kinds of constitutional claims. That the Supreme Court seems to do without any reference to the document itself, but you can reference the document because I wrote this book. So I like that Jimmel Boole and I are on the same page.

Works for me. All right. Okay.

“So somehow keeping why does it seem like the Supreme Court always saves its worst decisions for June?”

Maybe the first gentle breezes of some are filled in with inexplicable rage.

We cannot say for sure. Of the rulings that may transpire include mail-in ballots, deportation protections, rules governing whether transgender athletes get to participate in sports, birthright citizenship and more. So this June, the three of us at strict scrutiny are headed to New York City to break down all of the cases in question and whatever horrors the Roberts Court has in store for us with judicial expertise and petty jokes at Sam Alito's expense in equal measure. Catch strict scrutiny live at the historic Grammar C Theater on June 20th as part of the bad decisions tour.

Tickets are on sale now. You can grab them at croquet.com/avets. And in the latest episode of Runaway Country, I got to join my friend Alex Wagner to discuss a lot the outrageous selective indictment of Jim Comey, not for his off-brand whiskey production. But for June, Jim Comey. You're not by him?

It seems essentially not by him.

“No matter, he is being charged for it anyway.”

We talked about Trump's insane $10 billion lawsuit against the IRS.

And generally, why it matters when the Department of Justice is weaponized against the perceived political enemies and deployed to help the friends of those already in power. I mean, like, this week feds rate at the office of the black woman who led the Virginia redistricting effort.

“We didn't even get a chance to cover that.”

There is just so much.

So tune in to Runaway Country wherever you get your podcast.

You can hear me this week and you can hear Alex's great other guests other weeks.

“And you can also watch us any time on YouTube.”

[Music] Jacksonia is a cricket media production hosted and executive produced by Leo Lippman, Me, Melissa Murray and Kate Shaw. Our senior producer and editor is Melody Raoul. Michael Goldsmith is our producer. Jordan Thomas is our intern.

We get our music from Eddie Cooper and production support from Katie Long and Adrienne Hill. Matt DeGroot is our head of production and we are really grateful for our digital team. Our production staff is probably unionized with the writer's guild of America East. And if you haven't already, be sure to subscribe to strict scrutiny in your favorite podcast app and on YouTube at strict scrutiny podcast.

So you never miss an episode.

And if you really want to help other people find the show, please rate and review us. It really helps. [BLANK_AUDIO]