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Miles/Sunstein Response to Critics:

University of Chicago law professors Thomas Miles and Cass Sunstein further explain their analysis of judicial "activism" on the Supreme Court, and respond to criticisms, at the University of Chicago Faculty Blog.

The critics contend, rightly, that we do not look at the high-profile constitutional cases. But the number of such cases is small, and it isn't easy to test competing hypotheses about partisanship and restraint. Whelan argues that we fail to examine whether the agency ruling is correct. We agree that an ideal measure of judicial activism would identify the situations in which judges pursue their own ideological goals at the expense of the "correct" legal outcome. Many studies have demonstrated that ideology influences judicial decision-making in a vast range of legal contexts. But these studies generally provide no measure of the correctness of the judges' decisions. The absence of a "correctness metric" shows that it is most difficult to measure correctness in a way that can produce empirical studies of competing hypotheses.

We chose to investigate the justices' votes in challenges to administrative agencies' interpretations of law because this context provides an excellent way of testing for both partisanship and activism. The Court's own decision in the Chevron case strongly suggests that a justice's willingness to uphold an agency's interpretation of should not depend on whether the agency's decision was liberal or conservative. We think that our approach is an innovation over the existing academic literature, and we know that it is a vast improvement over unsubstantiated, anecdote-driven claims about judicial behavior.

The critics allege that the design of our study is flawed because the distinctive context of agency decisions makes it more likely that conservative judges will appear activist. If the data sets include mostly liberal decisions, then of course a liberal justice will show a higher validation rate than a conservative justice. But this objection is misconceived. In addition to measuring overall rates of agency validation for the justices, we also examined whether each justice was more likely to favor an agency when the agency decision was liberal rather than conservative. We coded the political orientation of each agency decision according to an objective method used by several prior academic studies. Agency decisions challenged by industry were deemed liberal, and those challenged by public interest groups were coded conservative. If the distribution of agency decisions were skewed in a liberal direction, as some critics allege, we should have observed few or even no challenges from public interest groups. Instead, we observed a fair number of such challenges. Moreover, our study period included many decisions from both the Clinton and the Bush administration, and it would be a big surprise if decisions by the latter were mostly "liberal."

When we looked at the data, we observed two key facts. (1) Certain justices' rates of validation -- but not others — varied widely with their own political leanings. (2) Certain justices' rates of validation -- but not others — rose when the agency interpretation agreed with their political leanings and fell when it disagreed. These two patterns suggest that certain justices are, according to this imprecise metric, reaching decisions that were likely not correct. Moreover, the patterns strongly suggest that partisanship or ideology influenced certain decisions. (Justice Thomas is the prize-winner for partisanship, but Justice Stevens is a close second.) Judicial ideology appeared to influence some justices' votes in the very context in which courts ought to defer to agencies. By our measure, these patterns smack of judicial activism.

PatHMV (mail) (www):
That doesn't appear to address their worst offense, appropriating the word "activist" and redefining it according to their own arbitrary criteria.
11.1.2007 1:52pm
PatHMV (mail) (www):
I notice th at in the next-to-last sentence of the quote, they use the word "ought," revealing their own biases which they brought to play. I think it's fairly obvious that a study conducted as they did, and defining the term "activist" as they did, would produce these results. They crafted a study which they knew, ahead of time, would reinforce their own hypothesis. A different definition of "activist" with a different study methodology, would produce an entirely different result. The study adds absolutely nothing to the argument, it just dresses up their philosophical opposition in "objective" clothes.
11.1.2007 1:55pm
r78:
PatHM - could you tell me where I can look to find the deed for the word "activist", since you apparently believe that someone owns that word
11.1.2007 2:13pm
David M. Nieporent (www):
If the distribution of agency decisions were skewed in a liberal direction, as some critics allege, we should have observed few or even no challenges from public interest groups.
This statement is offensive in its silliness.
11.1.2007 2:19pm
Ralph Phelan (mail):
"Agency decisions challenged by industry were deemed liberal, and those challenged by public interest groups were coded conservative. If the distribution of agency decisions were skewed in a liberal direction, as some critics allege, we should have observed few or even no challenges from public interest groups. "

There's a lot of assumptions built into the above. Assumptions about where the dividing line between "liberal" and "conservative" is, and whether it can be assumed to be the same for different actors. Assumptions about the motivations and decision making processes of nongovernmental organizations. The assumption that such groups act in the public interest.

Imagine the following scenario:
A government agency makes a decision that a random sample of American voters describes as "liberal."
An NGO whose directors think the decision didn't go far enough file suit, asking for a decision that a random sample of American voters would say isn't merely "liberal" but is downright "radical."
Professional Supreme Court lawyers, or indeed anyone from outside the group's ideological echo chamber, look at the suit and say "gimme a break."
After much searching they find someone to take their case. Somehow they get it through the lower and appeals court levels. But at the Supreme Court level their radical proposal, quite deservedly, either fails to get cert. or gets cert. and loses.
This loss, properly spun as the result of a conservative conspiracy, fires up their base and increases their donations. The NGO buys new Lexus SUVs with hybrid power trains for all their officers.
You count it as an example of a "conservative" decision.

I can't say how often such things happen, but I can say that if it does happen, your methodology, by counting it as a "conservative" decision, will be tacitly accepting the NGO's definition of where "conservative" starts - which is probably way to the left of where most other people would put it.
11.1.2007 2:31pm
Ralph Phelan (mail):
Moreover, our study period included many decisions from both the Clinton and the Bush administration, and it would be a big surprise if decisions by the latter were mostly "liberal."


There's a lot of folks on the right would disagree with that assumption too. I've found Bush to be disappointingly slow at reversing preexisting liberal biases in the Federal bureaucracy.
11.1.2007 2:33pm
frankcross (mail):
I really don't get the criticisms. I don't think they are claiming this is the ultimate or only test of activism, just one piece of more informing evidence.

David may have a more substantive point, though I'm not sure given the lack of explanation. Suppose NRDC challenges an EPA regulation. It does not follow that this regulation was itself conservative. However, it is true that the NRDC bringing the action thinks it has a plausible case that the Court will find the regulation contrary to law (in a direction that is too conservative). Now, given that the overall makeup of the Court is pretty conservative, the empirical test is a pretty good one, I think. I.e., I wouldn't expect the NRDC to waste money challenging a liberal regulation, on the theory that the current Supreme Court would demand a more liberal regulation.
11.1.2007 2:36pm
PatHMV (mail) (www):
r78... the term "activist judge" originated as a conservative epithet towards "liberal" judges who enshrine their own policy preferences as constitutional requirements. Folks like Cass and Sunstein have fought back by saying that conservative judges are really the activist ones. But in doing so, they use an entirely different definition of "activist," which merely adds confusion to the entire issue. As I pointed out in an earlier thread on this topic, it inflames the issue by adding confusion rather than clarity to the analysis. Both sides can honestly say "your judges are more activist!" Without, at a minimum, resolving the definition, then both sides are speaking accurately.

But conservatives definitely started the "activist" label. If you're aware of some alternate history in which this is not the case, please enlighten me. Thus, using the term "activist" to describe a different phenomenon makes it appear as those the report refutes conservative claims about who is more "activist," when in fact it doesn't.

As I said earlier, it is to the credit of Cass and Sunstein that they explicitly set forth their definition. However, only about 1 person in 1,000 will pay any attention to that.
11.1.2007 2:50pm
PatHMV (mail) (www):
frankcross, it's not a matter of "testing" for activism, it's a matter of agreeing on a definition. No test or study of judicial opinions is going to settle the question of what is the definition of the term. And until there is agreement on the definition, studies are useless.
11.1.2007 2:51pm
PLR:
Here's a question for the peanut gallery:

If you consider the Cass/Sunstein findings on the seven current justices on the Supreme Court covered by the study, do the Cass/Sunstein findings paint a demonstrably inaccurate or misleading picture of his or her judicial record?

I'm thinking not.




















the jsutice's
11.1.2007 3:05pm
Ralph Phelan (mail):
I really don't get the criticisms. I don't think they are claiming this is the ultimate or only test of activism

I don't think it's a useful measure of "activism" in any way at all.

By equating "ruling against the executive" with "activism" they assume that unlimited federal power is the default state. I would disagree, and say that allowing an unprecedented federal power grab would be "activist" while ruling against it would be "maintaining the status quo."

By equating "ruling against an NGO" with "conservatism" they're allowing the directors and members of some generally liberal and often far-left groups to define what constitutes "conservative." A finding based on this methodology that the Supreme Court leans conservative is about as informative as a survey that finds that the majority of Ivy League describe themselves as "politically moderate" - by which they mean they're to the right of Trotsky.

Miles &Sunastein have measured the relative success rates of businesses and NGOs in challenging the EPA.

All their claims as to what their data means seem to reduce to them implicitly assuming their own conclusions by the way they define their terms.
11.1.2007 3:09pm
Ralph Phelan (mail):
"NRDC bringing the action thinks it has a plausible case that the Court will find the regulation contrary to law"

If so, it may be the only reason they consider it plausible is that they live in an ideological echo chamber.

But I'm not willing to accept your assumption that they believe they have a chance of winning in court. They may believe that a loss in the Supreme Court could be a victory in the court of public opinion, or even more importantly in the court of fundraising.
11.1.2007 3:15pm
Ralph Phelan (mail):
"As I said earlier, it is to the credit of Cass and Sunstein that they explicitly set forth their definition. However, only about 1 person in 1,000 will pay any attention to that."

Which is too bad, because that carefully crafted definition is what guaranteed they'd get the results they wanted.
11.1.2007 3:18pm
andy (mail) (www):
It's hard to believe that Sunstein approached the data neutrally -- he did, after all, write a book called "Radicals in Robes" (referring to conservative judges). I'd like to see the same study done by someone who hasn't already made his disgust for conservative jurisprudence clear.

"appropriating the word "activist" and redefining it according to their own arbitrary criteria."

Yeah, just how originalism was conveniently re-named "religious fundamentalism" in sunstein's book. If the goal is to be neutral, why characterize a particular approach using a politically incendiary label?

He may as well say, "In this essay, I will be referring to conservative justices as sh!t-for-brains. However, that has nothing to do with whether they are right or wrong."
11.1.2007 3:24pm
andy (mail) (www):
It's hard to believe that Sunstein approached the data neutrally -- he did, after all, write a book called "Radicals in Robes" (referring to conservative judges). I'd like to see the same study done by someone who hasn't already made his disgust for conservative jurisprudence clear.

"appropriating the word "activist" and redefining it according to their own arbitrary criteria."

Yeah, just how originalism was conveniently re-named "religious fundamentalism" in sunstein's book. If the goal is to be neutral, why characterize a particular approach using a politically incendiary label?

He may as well say, "In this essay, I will be referring to conservative justices as sh!t-for-brains. However, that has nothing to do with whether they are right or wrong."
11.1.2007 3:25pm
andy (mail) (www):
It's hard to believe that Sunstein approached the data neutrally -- he did, after all, write a book called "Radicals in Robes" (referring to conservative judges). I'd like to see the same study done by someone who hasn't already made his disgust for conservative jurisprudence clear.

"appropriating the word "activist" and redefining it according to their own arbitrary criteria."

Yeah, just how originalism was conveniently re-named "religious fundamentalism" in sunstein's book. If the goal is to be neutral, why characterize a particular approach using a politically incendiary label?

He may as well say, "In this essay, I will be referring to conservative justices as sh!te-for-brains. However, that has nothing to do with whether they are right or wrong."
11.1.2007 3:26pm
andy (mail) (www):
It's hard to believe that Sunstein approached the data neutrally -- he did, after all, write a book called "Radicals in Robes" (referring to conservative judges). I'd like to see the same study done by someone who hasn't already made his disgust for conservative jurisprudence clear.

"appropriating the word "activist" and redefining it according to their own arbitrary criteria."

Yeah, just how originalism was conveniently re-named "religious fundamentalism" in sunstein's book. If the goal is to be neutral, why characterize a particular approach using a politically incendiary label?

He may as well say, "In this essay, I will be referring to conservative justices as %!%!#-for-brains. However, that has nothing to do with whether they are right or wrong."
11.1.2007 3:27pm
Waldensian (mail):
Andy, could you repeat that?
11.1.2007 3:35pm
andy (mail) (www):
APOLOGIES!

Computer was screwing up. Mr. Adler, please delete extraneous posts.
11.1.2007 3:52pm
Ralph Phelan (mail):
It is a favorite tactic in politicized "social science" to let your definitions do the heavy equivocation work for you.

Two experiences:

I read of a study that found "hunger" in American was most prevalent in rural areas. Further digging discovered that they were measuring "fraction of the population eligible for food stamps but not getting them" as their definition of "hunger." Could it be the "hungry" folks in the rural areas were growing their own food? Anyway, whatever they measured it wasn't actually hunger, and they were lying when they claimed they did.

In an education magazine there was a rating of various school systems for "Friendliness of atmosphere" or something of the sort. I looked up two systems I had experience with, and found the ratings the reverse of what I expected. On further digging, I found that what they were really reporting was "fraction of staff with Masters degrees" and then assuming the conclusion that people with masters degrees improve the school's atmosphere.

That's how you do social "science" - measure something that does exist objectively, make an extremely dodgy assumption about what it signifies, and claim to be measuring that instead. If possible, hide the dodgy assumption in a footnote.

"Overturning an EPA power grab" = "Conservative actism" - same trick.
11.1.2007 4:10pm
cvd (mail):
I agree with this
11.1.2007 4:31pm
frankcross (mail):
It's as if people don't understand social science. This is just information. If you don't like the definition of judicial activism, you can reject it as a measure. Others may find it informative. If you don't like the liberal vs conservative analysis, you can reject it (though I think that just reflects your own political biases). E.g., asserting a regulation is an EPA power grab, without even knowing anything whatsoever about what the particular regulation said. However, if you say he is biasing the study to reach preordained conclusions, you need evidence for that, and assertions to that effect are shabby.

This is just information to add to the debate. Without this sort of information you get . . . ideologically biased hackery, sometimes approaching paranoia, shouting "liberals are activists" or "conservatives are activists" with no real basis besides personal prejudice This sort of research is actual evidence, which is inconvenient to the ideologues.

I've done a very similar study over a slightly different time period and found that Rehnquist was the most restaintist. I included some earlier years, and Brennan and Marshall joined Thomas as more activists. But the results were roughly similar. I'd be happy to talk about methodologies.
11.1.2007 4:38pm
PatHMV (mail) (www):
Frankcross, you're missing the point. The results of this study are ENTIRELY and easily predictable ahead of time, once you decide to use that particular definition of judicial activism. But the study purports to inform us regarding some real issue. The issue, however, arose using an ENTIRELY DIFFERENT definition of the word "activism," and thus it is misleading, in the general cultural context, to present this study as if it refutes, in any way, the general conservative criticism of "judicial activism."

I mean, why did they do this study? Did the left wake up one day and start complaining about judicial activism? No, that's predominantly a conservative battle-cry. Cass and Sunstein wouldn't be writing about it or studying it at all, except to try to say to conservatives: "no, YOUR judges are the activists, not OURS." The crucial part of that debate is what the word "activism" means.

Cass and Sunstein clearly adopted a definition which would lead to the conclusion they wanted when measured with the methodology they selected. There's no objective reason to choose their definition over many others, including the definition that conservatives generally use. Their paper should say right up front: "We're NOT measuring the kind of 'activism' which originalists/textualists/conservatives complain about, so our study doesn't actually address that issue. Since both sides are using different definitions of 'activism,' it's entirely possible for both sides to be correct when they claim the other side's judges are the 'activist' ones."
11.1.2007 4:46pm
frankcross (mail):
No, actually, they are not at all predictable. They did not clearly adopt a definition that would lead to the conclusion they wanted. Their definition makes liberals look like the activists in other time periods.

Your final sentence is correct, there are different definitions of activism. But this is a reasonable one that does not contain a predictable bias and can be empirically operationalized. And they're clear on the nature of their measure, so readers who disagree can reject it on those grounds. Give me a neutral way to study "the kind of activism that originalists/textualists/conservatives complain about" and I'll try to do a study measuring that.
11.1.2007 4:55pm
govols:
Ralph: They don't "hide the definition in a dodgy footnote"--it's right there at the top of the post (and in the paper). If you're going to accuse someone of bad faith, at least make a stab at using evidence relevant to this study, rather than citing something unrelated you've glanced at in the last ten years.

Pat: we're never going to agree on such a definition, particularly in its application. I guess that means no one should write about it, or try to think of other ways in which we might measure activism?

This really isn't difficult, folks. No one can measure the view of "activism" many of you promote because we don't agree on the correct interpretation of the Constitution. Hence, we can't sort out, generally, when judges are acting correctly and when they are following their preferences. (It's little disturbing to see some of the commentators implicitly suggest that every conservative Supreme Court decision follows the plain/original meaning of the Constitutional text, while liberals just make it up as they go along). Their use of the term "activist," while not without its problems, is coherent and reliably measured, if not perfectly valid.

As Professor Cross says, you can reasonably disagree with their measure, or the usefulness of a definition of activism that rests mainly on the Court's propensity to overturn decisions of the elected branches. But why such hostility?
11.1.2007 5:03pm
PatHMV (mail) (www):
Their use of the term "activist," while not without its problems, is coherent and reliably measured, if not perfectly valid.


Yes, it is all those things. But the only reason there's a debate over "judicial activism" at all is because of conservative complaints about liberals. It was not a charge originally leveled by the left against the right. This study does nothing to confirm, refute, or even address the original claim by conservatives against "liberal judges." It's just got nothing to do with it. But it confuses people by using the same word to mean something entirely different.
11.1.2007 5:30pm
frankcross (mail):
Actually, while the term itself wasn't used, the concept of judicial activism began as an attack by liberals against conservatives striking down New Deal legislation. Then it was assumed as a neutral standard briefly (coined by Arthur Schlesinger with no ideological valence), before it became used by the right to criticize the Warren Court. Within the past decade, though, it has been extensively used by the left to criticize the Rehnquist/Roberts courts.

Ideologies do not have ownership of concepts. They fluctuate over time.
11.1.2007 5:44pm
Ralph Phelan (mail):
It's as if people don't understand social science.

See my 3:10. I understand it all too well.

If you don't like the definition of judicial activism, you can reject it as a measure.


We recently published an oped in the Los Angeles Times, in which we gave "awards" to Supreme Court justices, based on a statistical study of their votes. The Judicial Neutrality Award went to Justice Anthony Kennedy. The Judicial Restraint award went to Justice Stephen Breyer. The less coveted Partisan Voting Award went to Justice Clarence Thomas. Justice Antonin Scalia received the Judicial Activism Award.


How many LAT readers went to the source and discovered that the "statistical analysis" was based on extremely questionable assumptions?

Equating "overturning the executive" with "judicial activism" isn't just incorrect, in context it's deliberately dishonest.

asserting a regulation is an EPA power grab, without even knowing anything whatsoever about what the particular regulation said.

You misunderstood me. I wasn't claiming any particular case was an "EPA power grab." I was using a hypothetical case of overturning an EPA power grab as a gedankenexperiment to see if the coding system would classify it correctly. It failed.

But this is a reasonable one [definition of activism]
I disagree. See above.
that does not contain a predictable bias
If you know the data well enough you can guess what measures will come out the way you want. And if you don't, you can try different ones until you get the result you want.
and can be empirically operationalized.
Just because you can measure it does not mean it actually means anything, much less what the authors claim it means.
Their definition makes liberals look like the activists in other time periods.
In High School chem class I learned that when fudging data, it's best not to make it look too good. In the real world, the same applies to selecting real data, and to which hypotheses you report the tests of. Certainly if they came up with an "activism" measure that the Warren Court didn't peg, the fact they're peddling BS would so obvious even the LAT would balk.

It's little disturbing to see some of the commentators implicitly suggest that every conservative Supreme Court decision follows the plain/original meaning of the Constitutional text, while liberals just make it up as they go along.

"Living Document"
"Penumbra"
"Evolving Standards"

I'm not implicitly suggesting it, I'm explicitly stating that I believe it a valid criticism. This attempt to "objectively" disprove that criticism is partisan politics pretending to be scholarship.
11.1.2007 5:52pm
PatHMV (mail) (www):
Look at it this way. Suppose I say the sky is blue, and you say the sky is red. I go out and use a colorimeter to measure the color of the sky at noon every day except when it's raining. You go out and use a colorimeter to measure the color of the sky at sunset every day. We each average our individual results, and I say, truthfully: "Yep, my measurements prove that the sky is blue!" You take your results and say, truthfully, "Yep, my measurements prove that the sky is red!"

We're both perfectly correct, but we also haven't helped further the debate about the color of the sky in any way.
11.1.2007 5:57pm
frankcross (mail):
Exactly. And we know why, because of timing, which is disclosed in the methodology. Give me a methodology to test judicial activism according to your definition. Anything, so long as it is falsifiable.

And Ralph Phelan's attack on the honesty of the authors, unsupported by any evidence, is dubious. They are not the only ones to use this measure. Accusing them of "fudging" seems pretty defamatory.
11.1.2007 6:41pm
PatHMV (mail) (www):
Frank, are you seriously contending that Cass and Sunstein had no idea that their arbitrarily chose definition, combined with their arbitrarily chosen methodology, would not show the results that it did?
11.1.2007 6:46pm
frankcross (mail):
Yep. Because their definition was not arbitrarily chosen (its transparent and reasonable though limited in scope)nor was their methodology (which seems pretty common). Now, their methodology isn't entirely clear, it was just an editorial but it was set forth reasonably.

I have used a similar methodology (to be published in Constitutional Commentary), I think, and found similar results, though my time period was longer and included some Warren Court holdovers and they appeared the most activist.

BTW, I suspect Miles was the primary methodologist here, and I don't consider him noticeably liberal.
11.1.2007 9:58pm
Gildas (mail):
So just to be clear about the methodology here...

Recently OSHA tried to have small arms ammo defined as 'explosives' under Federal Regulations (which would have effectively shut down every gun shop in the land). No one is quite sure whether this was some bureaucratic SNAFU or something more sinister - in any case OSHA got stomped on once the word got out and actually agreed that the rules would not be written that way *before* the comment period closed.

However, here's a hypothetical: say OSHA didn't listen and promulgated those rules anyway. The NRA and the NSSF (National Shooting Sports Federation) sue and eventually win the case. Now, is that a conservative activist decision because NSSF is an industry lobby group? Or is it a liberal activist decision because NRA is an NGO? Or is it simply plain good law because someone at OSHA was smoking crack when they came up with the idea?

This whole methodology is bunk: garbage in, garbage out.
11.2.2007 12:30am
Ralph Phelan (mail):
And Ralph Phelan's attack on the honesty of the authors, unsupported by any evidence, is dubious. They are not the only ones to use this measure.

You mean the academy contains more liberal political activists claiming to be scholars than just them? Gosh, what a surprise. (Anyone remember the paper out of Berkely "proving" that liberals are smarter?)

Once again you conveniently misunderstand. That was an "analogy". I'm not accusing them of making up any data - just of cherry-picking their data and model to get the result they want, inaccurately labeling what they measured, and then claiming in the popular press to have proven something that a close reading of their work doesn't support.

In other words, I accuse them of nothing that isn't (sadly) standard practice in the social "sciences."
Accusing them of "fudging" seems pretty defamatory."
11.2.2007 9:23am
Ralph Phelan (mail):
Oh yeah - frankcross hasn't yet responded to my most substantive criticism: That by coding any defeat of the NRDC by the EPA as a "conservative" result this method implicitly uses the leadership of the NRDC as its benchmark for "center," while I contend it is in fact far to the left of the center of the American electorate.
11.2.2007 9:30am
Ralph Phelan (mail):
Whoops! Formatting error. Should have been:

And Ralph Phelan's attack on the honesty of the authors, unsupported by any evidence, is dubious. They are not the only ones to use this measure.

You mean the academy contains more liberal political activists claiming to be scholars than just them? Gosh, what a surprise. (Anyone remember the paper out of Berkely "proving" that liberals are smarter?)

Accusing them of "fudging" seems pretty defamatory."

Once again you conveniently misunderstand. That was an "analogy". I'm not accusing them of making up any data* - just of cherry-picking their data and model to get the result they want, inaccurately labeling what they measured, and then claiming in the popular press to have proven something that a close reading of their work doesn't support.

In other words, I accuse them of nothing that isn't (sadly) standard practice in the social "sciences."


* Unlike Michael Bellesiles they're smart enough to understand that fabricating data is both risky and unnecessary - a good social scientist/polemicist should be able to select, frame and spin genuine existing data to get the result he wants.
11.2.2007 9:36am
Brian K (mail):
I contend it is in fact far to the left of the center of the American electorate.

hahaha...you're complaining because they didn't find an objective measure to code for your subjective biases?
11.2.2007 9:48am
Ralph Phelan (mail):
"you're complaining because they didn't find an objective measure to code for your subjective biases?"

I'm comp;aining because they implicitly claimed in the LAT that their subjective biases are objective truth.
11.2.2007 10:06am