Rant's [sic]

Pedant that I am, I sometimes react more strongly to apostrophe errors than to snark, stupidity, and lies.

The poor little punctuation mark is so misused that sometimes I think he should be put out to pasture.

It's easy, folks.

Rule 1. When the word is a contraction ("do not"==>"don't" "it is"==>"it's") you replace the letters that aren't pronounced with the apostrophe.

Rule 2. When there's a possessive "s" added to a noun, the apostrophe goes before the "s" when the noun is singular ("John's hat," "the cat's meow).

Rule 3. When there's a pluralizing "s" added to a noun that is also possessive, the apostrophe goes after the "s" ("the horses' tails," "the Smiths' dinner party").

Three simple rules, folks, that's all.

"It's" and "its" sometimes cause trouble, but they follow the rule.

"It's," meaning "it is" takes the apostrophe internally, because it's a contraction.

"Its" as a possessive doesn't take an apostrophe any more than "his" does--pronouns don't take a possessive apostrophe.

So: "It's a boy!" meaning "It is a boy!" but "Its eggs are green" because "its" is neither a contraction nor a possessive noun.

So endeth the rant. Amen.

(For extra credit: "apostrophe" is also one of the many devices of classical rhetoric:

A digression in the form of an address to someone not present, or to a personified object or idea, as “O Death, where is thy sting?”

Go and sin no more.

(Cross-posted from As the Top of the World Turns).

Ticket time for Mike Nifong?

The North Carolina Bar has upped the ante by amending the charges against Mike Nifong, the prosecutory in the Duke lacross team rape case. Now they're accusing him of withholding evidence and lying to the court, not just improper pretrial publicity.

This is what lawyers call "ticket time"--where you risk losing your license to practice.

The Anniversary of Roe v. Wade

Apparently today is the anniversary of the Supreme Court's decision in Roe v. Wade.

Although in the past I have taken the view that it is imprudent for the state to ban abortion, I have long believed that the Roe decision was poorly reasoned and politically disastrous. I began a series of posts on Roe, but sad to say haven't brought the analysis up to the Roe ruling itself and the equally important Webster case.

In my view, issues of this kind should be resolved through the constitutional political system, by the legislative process (or in some states, the initiative, which is fraught with other difficulties). When unelected, or even nominally elected judges, use legal reasoning that's impenetrable to the mind of the average citizen, to impose their views on highly charged subjects such as abortion, the political process is thwarted, the losers feel cheated and put upon, and the legitimacy of the system suffers.

Before Roe, the country was drifting in the direction of a less restrictive approach to abortion, and if Roe is overruled, the political process will resume. In some states, such as California, which has placed a "right of privacy" in its Constitution, a permissive approach to the issue will prevail; in others, more conservative, some degree of restriction is likely to be enacted. Even supposedly conservative South Dakota refused, this last election, to enact an absolute abortion ban with no exception for rape or incest.

I've also grown increasingly uncomfortable with the cultural consequences of a relaxed approach to abortion. I remember the sorrow when my wife miscarried, before our first child was born healthy. As potential viability becomes possible earlier in a pregnancy, late-term abortion becomes more and more akin to infanticide. Looking at the results of sex-selection abortions in Asia (millions of men who will be unable to marry, because the babies who would have grown up to be their wives were aborted, among other things), the creepily casual way in which technology is used and misused in reproductive matters, and other changes, few of them good, in the culture, I am increasingly troubled. In addition, rather than overpopulation, the developed world appears to be facing rapid population decline, as well as a decline in family life.

It appears to me more and more that we, and I in particular, have gone astray in these matters and the easy acceptance of abortion looks to be one of the reasons. There is much to answer for.

White Shoe Law Firms vs. the Neocon-Christer Mafia

Boy Genius Eugene Volokh

The Volokh Conspiracy is my favorite law blog. Eugene Volokh, leader of the pack, is a law professor and former child prodigy at my alma mater, UCLA Law School, and writes on free speech and slippery slopes, among other things.

On this page, posts are gathered together about the remarks of deputy assistant secretary of defense of detainee affairs Cully Stimson, who questioned the number of major corporate law firms who had signed up to represent detainees at Guantánamo Naval Base, who are, of course, suspected or accused of terrorist activity and affiliations. Stimson suggested that corporate clients pressure these Establishment firms to eschew these representations. Critics, including the Volokh conspirators, piled on the heretic. After a barrage of press and blogosphere discussion, Stimson recanted. However, as Galileo is supposed to have said, the moon still moves.

One of the question laymen often ask lawyers is why they represent people who are obviously guilty of heinous crimes. The stock answer is that to insure we have a fair system, everyone is entitled to representation, and if the goal of representation for everyone is to be achieved. In the abstract, I agree with the statement, although of course many who represent unsavory defendants have other motivations, such as money, fame, making political points, and sympathy for the accused or their plight. None of these motivations is necessary to be condemned, either, but one need not acknowledge the nobility of the actions of lawyers like Lynne Stewart, who was convicted of providing non-legal assistance to the convicted terrorist Omar Abdel Rahman, known as the "Blind Sheikh," or the communist lawyers whose representation of unpopular defendants is said bys ome to have been designed to propagandize about the unfairness of the system, as opposed to achieving the best results for their clients.

Because of the importance of providing representation to all, it's considered unethical to try to dissuade a lawyer from representing a particular defendant. The criticisms that Stimson drew are understandable from this perspective.

And yet, it's worthy of comment that these white shoe firms have flocked to work on this particular issue. The younger lawyers in these firms are perhaps influenced by legitimate concerns for the innocence of some of the detainees (many apparently got swept up in post 9/11 operations more or less at random) and the procedural confusion attendant upon their incarceration, and the professionally interesting constitutional issues raised by the clients' situation. Are they also salivating in response to the conditioning they received at the major law schools, with their heavily left-wing culture, and their location in the blue-state word-worker élite that regards Bush & Co. as a bunch of Bible-thumping fascist rubes, and the Guantánamo cases as a blow against some neocon-Christer Mafia?

The white shoe firms' choice of pro bono clients is not a legitimate target of government pressure, but why these folks choose to do what they do is a proper subject of public discussion.

Unfettered Discretion in BoBo Land

My office is right across from our City Hall. Last night, a client and his architect came in, disconsolate and angry. My client's deck leaks, and I'm suing the general contractor and a passel of other people. In the course of repairing it, my client wants to expand the area of the deck a bit. The expansion is consistent with the zoning.

Not so fast. In our town, you can't move a stick without going through a prolonged and expensive hearing process, called "Design Review." You have to notify your neighbors, put up stakes to show what's going where, and appear before five busybodies (the Design Review Board) to get permission.

My client's desolation and rage came about because the DRB denied his application, not because the deck would interfere with his neighbor's privacy, but because the DRB doesn't like "incrementalism," also known as "salami tactics"--a slice now, a slice tomorrow, and pretty soon I've got the whole salami. Now he can appeal to the City Council, and if they deny the project, sue. In the alternative, he can give up, or spend more money and try again.

All of this is done in the name of conservation and preserving the "village character" of our BoBo town.

In fact, what is being conserved is the high price of property; it's drawbridge politics. Aside from the property rights question as to whether these things should be regulated at all, other than by the law of nuisance, the vice of the process is that in spite of all pretensions, it's essentially standardless. If a neighbor complains, the powers-that-be don't like you, or one of the board members gets a wild hair, you're cooked.

The courts are reluctant to take on these issues. One could say this stance is due to respect for the democratic process, except that the courts don't respect the process when leftist doctrine, developed in the law schools, says that new rights are at stake. Perhaps it's mostly fear that there is so much arbitrariness in local government that if they interfered with this kind of abuse except in the most extreme cases (here's one involving private arbitration, and even there, the remedy was limited), they'd be swamped.

There has been so much frustration that the City Council appointed another committee (of course!) to review the process. Their solution: up the fees and appoint more staff. My solution: abolish the DRB and let property owners build what they want, so long as it complies with the written zoning rules. Clear guidelines and predictability. What a concept!

Until that millenial dispensation arrives, it will continue to suck.

UPDATE: Corrected link to "Drawbridge Politics."

Couch Potato Justice

When the Ninth Circuit Court of Appeals (the federal appeals court for the West and the Pacific) met to consider Kevin Cooper's death penalty appeal, the courtroom was full, but none of the justices was present in person. All three were at remote locations, and one was present only by audio, because the video link was down.

The trend toward remote court hearings is growing, and Mary Schroeder, the chief judge of the Ninth Circuit is concerned:

In an interview late last week, Schroeder, who is based in Phoenix, said she was troubled by the development, and may propose curbs on judicial videoconferencing.

"I was at the courthouse in San Francisco on Tuesday, and I was very surprised and concerned when I learned all three judges were on video," Schroeder said. "That was a first. Several other judges are concerned as well, and we are going to have a full discussion as soon as we can.

"I don't think this is going to happen again."

The practice grew up innocently enough--lawyers from Guam asked for the privilege because the trip for a brief oral argument was long and expensive. In many routine appeals, argument is brief and unlikely to change the result.

In a death penalty case, the problem is more serious. Is something lost because the judges and the lawyers can't see one another in three dimensions, and look one another in the eye?

I've had some experience, not with video, but with telephone appearances in the trial courts. I don't like them, because the visual clues are entirely missing, but with traffic in the Los Angeles-Orange County area being as bad as it is, you can't always justify charging a client for a four-hour round trip to a court, for a three-minute appearance where nothing is done but setting a date. In such instances, teleconferencing through CourtCall, the company that has the contract, saves time and client expense.

Indeed, some judges now post tentative rulings on motions on the Internet, encouraging lawyers to "submit" on them, that is, accept the ruling. If the ruling, for example, says a complaint is defective but may be amended, it's often not worthwhile to appear.

All of this, of course, is a loss. Law students participate in "moot court" (mock oral argument) to hone their advocacy skills, and the Socratic method of question, answer and debate still rules in the law schools. In trial courts nowadays, it's rare that such skills are needed. The motions are studied by staff attorneys or law clerks, and minds tend to be made up in advance. A few old-line judges used to enjoy discussing the case law in open court, and the intellectual challenge was stimulating. It doesn't happen much. Short of trial, the premium is on written advocacy, which, fortunately, I'm good at.

In appellate courts, even with video appearances and judges who've already studied the record and often made up their minds in advance of argument, video may have it's place, but one loses something. The give and take is a bit artificial and an air of unreality descends over the proceedings.

It's like the difference between live theater in a small house and TV drama. Live theater has something special. Of course, most of us are couch potatoes more than theatergoers these days. It's too bad. And it's too bad that the immediacy of contact with appellate judges, whom one sees only in oral argument, is in jeopardy.

The Camel's Nose Is In the Tent, and He's Got a Spliff In His Mouth

LA's police chief William Bratton Views With Alarm the rapidly increasing numbers of so-called medical marijuana clinics.

So he's proposing legislation to regulate them, including a ban within 1,000 feet of schools.

Concerned by a 2,350% increase in the number of medical marijuana dispensaries in Los Angeles in a one-year period, Police Chief William J. Bratton is calling for a moratorium on new facilities until strict rules can be adopted governing them.

In a report to the Police Commission, Bratton said he wants to ban existing dispensaries within 1,000 feet of schools, churches, parks and places designated exclusively for the care of children. He also advocates limiting their hours to 10 a.m. to 6 p.m.

The establishments are allowed under a 1996 state ballot measure and a more recent state law making marijuana available to patients by prescription to relieve pain or nausea.

Bratton said the number of dispensaries increased from four in November 2005 to 98 a year later.

"This has fostered an increase in … crime problems and caused quality-of-life issues for families and communities, as evidenced by the 110 complaints received from neighbors, business owners and concerned citizens concerning these dispensaries," Bratton's report states.

* * * *

"One clinic blatantly resorted to placing fliers on the windshields of vehicles parked in and around Grant High School in an obvious effort to entice children," Bratton said.

The chief did not identify the clinic, but said its flier stated that it is legal to own, grow and smoke medical marijuana and that "qualification is simple and our experienced physicians are more than happy to help you," adding that the visit is free if the applicant does not qualify.

Bratton is right about one thing. These places are not all simply supplying weed to people on chemotherapy. The medical marijuana thing is a way of relaxing controls on the foul weed. Even if the excuse is plausible, like sacramental wine during Prohibition, the exception's being used, as the Chief says (horror of horrors!) for "profit and recreational drug use".

I don't care for the stuff, but if you started out analyzing the deleterious effects of pot and booze, you'd probably legalize pot and ban booze. Pot makes people passive and silly, not combative (although remember the word "assassin" comes from hashishin, the youths the Old Man of the Mountain plied with hashish to give them visions of heaven before he sent them on their missions).

The other noteworthy thing in the Chief's screed is his call for a ban within 1,000 feet of a school. This hypocritical ploy is now used all the time as part of an emotional plea to, so they say, protect children. 1,000 feet is a fifth of a mile, or four blocks. This kind of proposal, blessed by the Supreme Court in the case of so-called adult venues, i.e. pornography, is just an excuse to ban or at least harass an unpopular kind of business. It has nothing to do with protecting children in the real world; it's just a cynical exploitation of fears for children.

And who appointed the cops as moral arbiters? They're supposed to enforce criminal laws, not come up with new ones. Instead the do things like visit schools and tell kids not to use drugs, a program demonstrated to be ineffective.

Legalize it. Strike a blow against the Nanny State.

Mt. Soledad Cross

The Ninth Circuit (the federal Court of Appeals that covers California) has told the District Court to vacate (withdraw) its order requiring removal of the large cross on Mt. Soledad in La Jolla.

On May 3, 2006, Judge Gordon Thompson, Jr., moved to enforce an order he initially made in 1991, telling the city that the cross violated the state constitution's ban on government aid and preference for religion, and to remove it or face a fine of $5,000 per day. In August, Congress passed a bill allowing the federal government to take control of the land. That rendered Judge Thompson's order moot, since the land no longer fell under the authority of the California constitution, triggering the 9th Circuit's decision.

Two more lawsuits, of course, are in the wings, challenging the federal government's allowing the cross to remain on federal land.

That we spend so much time on issues like this confirms my view that our freedom-of-religion jurisprudence is wacky. It's a majority (and historically) Christian country. You don't have to like it, but it is. Get over it.

The Somali Cabbies of MPLS

Somali cabbies in Minneapolis, who apparently make up a significant proportion of the cabbies who serve the airport, are demanding the right to refuse service to anyone transporting alcohol, or dogs. Alcohol is forbidden under Islamic law, and according to some interpretations, dog saliva is ritually unclean.

In fact, the unilateral refusal of service is inconveniencing others, including the "First Mate," the wife of Minneapolis blogger Captain Ed:

It also goes beyond the airport cabs, as the First Mate discovered on more than one occasion where she used taxis for normal travel when she still used Cory as her guide dog. She had to threaten one cabdriver with a complaint to get him to allow the dog, and on other occasions had to explain the open access laws for service dogs in America.

Now, compare and contrast the issues raised by Christian pharmacists who claim the right to refuse to sell the "morning after" pill on the ground that it's a forbidden abortifacient. Feminists and lefties are outraged, arguing that a pharmacy is a kind of public utility that should not be able to pick and choose what services within its authorized area of business it will provide.

The Muslim cabbies and the Christian pharmacists are claiming a religion-based exemption from a rule of general application.

There is a long history in this country of enacting generally applicable laws that have a religious basis, notably Sunday closing, or "blue" laws. These have been upheld in many cases, but on the somewhat strained basis that they have a secular purpose, such as limiting the hours of work or preventing traffic congestion.

The constitutional case law in this area is quite confused. But from a policy perspective, requiring a licensed public conveyance to carry anyone carrying a lawful substance or a licensed guide dog hardly seems like an imposition, and the demand for an exemption by a religion whose beliefs demand the enactment of its own system of law to govern society as a whole, seems ominous.

Nifong Bows Out

Michael Nifong, the rogue prosecutor in the Duke lacrosse team case, has finally come to his senses enough to ask the state Attorney General to appoint a special prosecutor in the case. Grounds: the State Bar investigation creates a conflict of interest.

I can't imagine the case lasting 48 hours once this happens.

No Forced Mediation In California

In the last several years, much of my practice has been in the area of construction defects, sometimes also known as "the dream house that becomes a nightmare."

In California, these cases explode. The owner sues the builder, and owner or builder or both sue every subcontractor they can think of, in hopes of compelling additional insurance companies to contribute to settling the case. Although I've tried them, these cases rarely go to trial, because the defects are usually evident and the cost prohibitive.

Instead, these cases go to mediation. Mediation is a process conducted before a third party, often a lawyer or retired judge. Unlike an arbitrator, a mediator has no power to make a ruling on the merits of a case.

Many hold themselves out as mediators, but relatively few are really good at it. And although it may seem that a mediator has the easy job of sitting around and playing "Let's Make a Deal," effective mediation is quite difficult, requiring legal knowledge, psychological insight, and patience, among other things. Perhaps that's why private mediation can be quite costly, especially in a complex case where several sessions may be needed to achieve a settlement.

The business of private "ADR" ("alternative dispute resolution") has exploded over the last two decades. Firms such as JAMS and Judicate West, as well as the old-line American Arbitration Association, are quite lucrative. Many experienced judges can't fight the temptation to make real money as mediators and arbitrators.

Judges on the bench have also gotten into the habit, especially in complex matters such as construction defect cases, of ordering the parties to mediate a case and to pay for the privilege.

No more, at least in California.

A new case, Jeld-Wen, Inc. v. Superior Court (2007) 2007 DJDAR 233, No. D048782, puts a stop to the practice of forced participation in mediation. Jeld-Wen, apparently a window company, was an uninsured cross-defendant in a construction defect case. This means that another party, probably a defendant builder or general contractor, had brought Jeld-Wen into the case, claiming it was partly responsible and had to contribute to resolving the case.

The trial judge ordered everyone into mediation, and ordered them to share the costs. Jeld-Wen, lacking insurance and claiming it didn't install the subject products, refused to participate or to pay. The court slapped Jeld-Wen with "sanctions" (basically a fine).

Jeld-Wen then "ran a writ," that is, asked the Court of Appeals to order the trial court to stop. Normally Courts of Appeal won't even hear such writs, preferring to wait until a case is completely over. Every now and then the Courts of Appeals do decide to hear an issue, especially if it's an important and new issue of law.

In Jeld-Wen's case, the Court of Appeals in San Diego told the trial court to back off. No statute or court rule, it said, empowered a trial judge to order a party to pay for private mediation over its objection.

This ruling is a good one. One of the basic functions of government is to administer justice, and one of our system's advantages is that in business matters our system of justice is reasonably predictable. Our courts are busy, and understandably are tempted to move cases to resolution however they can, including by using private mediation. Private mediation of construction cases will undoubtedly continue to be popular, because the parties will conclude it's in their best interest. However, it's unfair to require a party that may or may not have the resources, to pay a private mediator against its will. The principle that the courts are open to all is important, and this rule--no one can be forced into mediation--reaffirms that principle. It will also avoid the suspicion that there is a conflict of interests, that judges are ordering parties to hire their former colleagues or future employers. And it will force mediators to be a bit more competitive, in quality if not in price.

Circumstantial Evidence

The long-delayed murder trial of Michael Goodwin is finally over. Goodwin was charged with the murder of a former business associate, Mickey Thompson, and his wife.

The Thompsons lived in the small, wealthy foothill community of Bradbury. Two black men rode up on bicycles and shot the couple. Goodwin fled the country, and supposedly lived on a sailboat in the Caribbean for years, but ultimately returned. He was arrested, tried and convicted.

No one saw him do it, and there was no physical evidence such as DNA, fabric, or ballistics connecting him to the crime. The actual killers have never been found and for all we know may have been killed themselves. The evidence consisted, among other things, in Goodwin's threats to kill Thompson, his flight, and reports by witnesses who said they remembered, years later, that they had seen Goodwin in the neighborhood shortly before.

I'm not going to rehash the trial. The papers have done that, and no doubt there will be a book out before long.

The point here is about the law of evidence. Many non-lawyers think that "circumstantial evidence" is legally inferior to direct evidence, as when a witness says he saw the event in question. Not so. Circumstantial evidence has the same standing as direct evidence, and a jury can convict a defendant even of murder based entirely on circumstantial evidence. (In the Goodwin case, there was some direct evidence--descriptions of the crime scene, autopsy results, and so on).

Here we have motive and opportunity, flight as reflecting consciousness of guilt, and the evidence of Goodwin's presence at the scene before the killings. All of this is circumstantial evidence, and it's undoubtedly legally sufficient to convict. On appeal, the fact that the evidence may seem thin won't be enough for a reversal; if a reversal comes it will be due to legal error, not insufficiency of the evidence. An appellate court doesn't need to find guilt beyond reasonable doubt. It just has to find sufficient evidence to make out a case on which a jury could convict.

So, surprise and delight (or annoy) your friends. Next time they say, "It's only circumstantial evidence," set them straight.

From Organ Enlargement to "Christian" Loans

I'm the recipient of scads of spam.

Used to be, a goodly portion of the messages offered me the opportunity to enlarge my virile member, and drugs to stiffen it. Another tranche of missives invited me to participate in myriad variants of the Nigerian "419" scheme--to transfer millions illegally in exchange for a cut of the loot, including Suha Arafat's clandestine estate.

There are fashions in spam. Nowadays I get lots of stock tips in graphic form, to evade the spam filters, offers to sell me fake Rolexes, and to download cheap (and probably pirated) Windows software, which, as a Mac cultist, I don't use.

Today's topic, however, is the increasingly common solicitation for "Christian" financial services, such as payday loans. For example, today I received an unsoliced email that contained this image:
I'm intrigued by the "Christian" angle. For much of its life, the Church condemned lending at interest, while tolerating the lending activities of a caste of Jews who lacked the same scruples as to the practice. These days, it tolerates the practice, but it's hard to see what would make a lender's activity "Christian," besides, perhaps, declining to make a profit on the sorrows of the poor.

I'm no sleuth, but Google provides a few tools even for amateurs such as I. It turns out that the address of this particular lender is in Las Vegas, and although its address is given as "848 N. Rainbow Blvd. # 612" in Las Vegas NV, Google Maps's imaging software seems to show only a small building, suggesting that there's no sixth floor, and we're dealing with a mail drop.

If we go to their website, in the small type, there's a disclaimer:

* Christian Faith Financial is a financial matching service - matching prospective borrowers with prospective lenders. Your information may be placed with one of several independhttp://www2.blogger.com/img/gl.link.gifent loan companies. Not all independent loan companies will approve you for a loan or can provide you with up to $1,500 on your first loan. We cannot guarantee final approval of unsecured cash loans. Qualifying for final approval of a cash loan depends on various factors including income and the state in which you reside. Christian Faith Financial is not a financial institution or a lender. The independent loan companies may verify your supplied information with any number of independent verification companies including but not limited to: CLVerify, Teletrack, or Accurint.

In short, the website is just a finding service for a series of payday lenders. The FTC warns against them, and the Nevada Legislature is considering tightening control on them.

Then I checked the domain from which the spam came, streetsworlds.com. This appears to be a bad credit lending site, with nothing particularly Christian about it. A "whois" search of the domain name leads to

Reliant First
Web Master (customer.dept@reliantfirst.com)
952 Troy-Schenectady #310 Road
Latham
NY,12110
US

This website advertises email and web marketing services. In short, if Reliant First is not an illegal spammer, it's something close. Unless it's somehow related to a Canadian mortgage lender, also named "Reliant First."

If I were an investigative reporter, or wished to invest additional time in phone calls and web searches, undoubtely I could find out a good deal more without much difficulty. Certainly, it seems that the "Christian" label and the Bible quote are just window-dressing designed to bring in the marks. According a posting by the Arizona Corporation Commission, this is known as "afffinity fraud," using the mark's ethnic or religious association to attract him to a scam such as this one:

In Arizona, the Baptist Foundation of Arizona is a recent example of an affinity fraud. The Corporation Commission issued an order requiring the Baptist Foundation of Arizona and two related corporations, Arizona Southern Baptist New Church Ventures, Inc., and Christian Financial Partners, Inc., to cease and desist from violating the Arizona Securities Act in offering and selling their investment products. The three nonprofit corporations have sold more than $530 million in investments involving promissory notes, to more than 13,000 investors throughout the United States. An investigation conducted by the Securities Division revealed that the Foundation had misrepresented its financial condition to investors.

The Christian press itself contains many stories about the surge in "Christian" scams, such as this one, which includes the following:

I've been a securities regulator for 20 years, and I've seen more money stolen in the name of God than in any other way," said Deborah Bortner, president of the North American Securities Administrators Association. Securities regulators are warning that religious-based investment seams have risen dramatically, citing three prominent cases that accounted for a total of $1.5 billion in losses.

Bortner, who is also director of securities for the state of Washington, said in a statement August 7 that "when you invest you shouldn't let your guard down merely because someone is appealing to your religion or your faith." In the past three years, securities regulators in 27 states have taken action against hundreds of individuals and companies that used spiritual or religious beliefs to gain the trust of investors.

The association cited the cases of Greater Ministries International Church, the Baptist Foundation of Arizona and the IRM Corporation as key examples of a fraudulent mixture of religion and money. Association officials held a news conference in Washington, D.C., the day after Gerald Payne, founder of the Tampa, Florida-based Greater Ministries International Church, was sentenced to 27 years in prison on fraud and conspiracy charges.

To summarize, this proves Shakespeare right when he wrote, "The devil can cite Scripture for his purpose."

Jim Bakker lives.

Meanwhile, if you feel your virile member is inadequate, have I got an herb for you . . .